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  • 2009 To 12 24 12 0204 Emails To @nvbar - Org 925 Pages Bate Stamped Needs Attachments With 5 14 and 7 31 RX Prescription History

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    NevadaGadfly
    162 views933 pages
    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: THE MATTER OF ZACHARY BARKER COUGHLIN, ESQ. ) ) ) ) ) ) CASE 60975 Notice of Appeal of 8/26/13 Order in CR12-2025 NOTICE OF NON-SERVICE OF COURT’S ORDER OF 4/23/14 Coughlin submits this on his own behalf to apprise this Honorable Court of the fact that he was never served with and or never received a copy of its Order of 4/23/14 referenced in the attachment to an email of 7/9/14 from the State Bar’s Laura Peters, which also attached an Order of 6/30/14 in this same case which Coughlin also was never served with and never received. Coughlin submitted a filing electronically in 60975 (of 6/18/12) and such was filed, however, Coughlin still is unable to view such case in his eFlex account, and a review of the attached printout of the Notifications page in Coughlin’s Eflex account demonstrates that he was not electronically served either of the above orders. Coughlin has made several telephone calls and emails to the SBN since April 18, 2014 and received absolutely nothing in the way of a response other than the filing by the OBC’s Machado of 6/3/14 in 62337. It is unclear if the OBC’s King is still assigned to this case as the letter emailed to Coughlin today is from the OBC’s Pattee. Respondent (the undersigned) would have addressed both this Court’s Order of 4/23/14 and of 6/30/14 by now had he ever been served it or aware of it in any way. It is relevant to note that the bulk of the thrust behind NNDB Chairman Susich’s SCR 117 Petition in 60975 has been put to rest by Respondent’s filing in 62337, and Respondent seeks to incorporate such herein again here now. One, RMC Judge Nash Holmes vacated both of the orders attached as Exhibits 4 and 5 to such SCR 117 Petition herein by way of her attached 4/9/14 Order of Dismissal (which begat this Court’s 5/16/14 Order in 62337 in response to Coughlin’s attaching such Orders of Dismissal to his 4/22/14 filing in 62337) of such case (which Coughlin was never permitted to appeal nor even challenge by Writ of Mandate to whatever extent Pengilly’s proviso applies to a pro se attorney defendant found in contempt, which is/was, apparently, the fate of Coughlins’ attempts to appeal or challenge by writ of mandate RMC Judge Howard’s Order For Summary Punishment of Contempt attached as Exhibit 1 to the SCR 117 Petition (please see debate over Judge Elliott’s 3/15/12 Order in the appeal/petition for writ challenging both the candy bar/cough medication petty larceny conviction (see 60838 as well) in SBN’s filings of 6/3/14 in 62337 and Coughlin’s response thereto). Further, it is interesting to note that, while the SBN’s 8/23/12 SCR 105 Complaint at issue in 62337 included amongst its vague charges both of the filings by Coughlin attached as Exhibits 2 and 3 in the SCR 117 Petition in 60975 of 5/30/12, come time for the disciplinary hearing, the SBN completely abandoned any attempt to paint such as misconduct of any sort (not even within the faux SCR 117 style RPC 1.1 “competence” approach the SBN constantly took during such SCR 105, 102/111(8) formal disciplinary hearing (versus the plural “proceedings”…to reference the distinction between the process set forth in an SCR 111(8) referral and those inherent to SCR 105 Complaints and or SCR 102 Petitions being filed). Clearly, the SBN abandoned any attempt to paint those two filings by Coughlin as misconduct considering what they really revealed was that Coughlin brought to light the fact that the Washoe County Sheriff’s Office currently burglarizes tenants instead of following the dictate of NRS 40.253 requiring a tenant be given 24 hours from “receipt” of a summary removal order prior to the Sheriff effecting a summary lockout. The fact that it is the Washoe County District Attorney’s Office (which employs the same NNDB member DDA Bruch Hahn that sat on Coughlin’s April 2012 Screening Panel) which defends the Washoe County Sheriff’s vi

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    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: THE MATTER OF ZACHARY BARKER COUGHLIN, ESQ. ) ) ) ) ) ) CASE 60975 Notice of Appeal of 8/26/13 Order in CR12-2025 NOTICE OF NON-SERVICE OF COURT’S ORDER OF 4/23/14 Coughlin submits this on his own behalf to apprise this Honorable Court of the fact that he was never served with and or never received a copy of its Order of 4/23/14 referenced in the attachment to an email of 7/9/14 from the State Bar’s Laura Peters, which also attached an Order of 6/30/14 in this same case which Coughlin also was never served with and never received. Coughlin submitted a filing electronically in 60975 (of 6/18/12) and such was filed, however, Coughlin still is unable to view such case in his eFlex account, and a review of the attached printout of the Notifications page in Coughlin’s Eflex account demonstrates that he was not electronically served either of the above orders. Coughlin has made several telephone calls and emails to the SBN since April 18, 2014 and received absolutely nothing in the way of a response other than the filing by the OBC’s Machado of 6/3/14 in 62337. It is unclear if the OBC’s King is still assigned to this case as the letter emailed to Coughlin today is from the OBC’s Pattee. Respondent (the undersigned) would have addressed both this Court’s Order of 4/23/14 and of 6/30/14 by now had he ever been served it or aware of it in any way. It is relevant to note that the bulk of the thrust behind NNDB Chairman Susich’s SCR 117 Petition in 60975 has been put to rest by Respondent’s filing in 62337, and Respondent seeks to incorporate such herein again here now. One, RMC Judge Nash Holmes vacated both of the orders attached as Exhibits 4 and 5 to such SCR 117 Petition herein by way of her attached 4/9/14 Order of Dismissal (which begat this Court’s 5/16/14 Order in 62337 in response to Coughlin’s attaching such Orders of Dismissal to his 4/22/14 filing in 62337) of such case (which Coughlin was never permitted to appeal nor even challenge by Writ of Mandate to whatever extent Pengilly’s proviso applies to a pro se attorney defendant found in contempt, which is/was, apparently, the fate of Coughlins’ attempts to appeal or challenge by writ of mandate RMC Judge Howard’s Order For Summary Punishment of Contempt attached as Exhibit 1 to the SCR 117 Petition (please see debate over Judge Elliott’s 3/15/12 Order in the appeal/petition for writ challenging both the candy bar/cough medication petty larceny conviction (see 60838 as well) in SBN’s filings of 6/3/14 in 62337 and Coughlin’s response thereto). Further, it is interesting to note that, while the SBN’s 8/23/12 SCR 105 Complaint at issue in 62337 included amongst its vague charges both of the filings by Coughlin attached as Exhibits 2 and 3 in the SCR 117 Petition in 60975 of 5/30/12, come time for the disciplinary hearing, the SBN completely abandoned any attempt to paint such as misconduct of any sort (not even within the faux SCR 117 style RPC 1.1 “competence” approach the SBN constantly took during such SCR 105, 102/111(8) formal disciplinary hearing (versus the plural “proceedings”…to reference the distinction between the process set forth in an SCR 111(8) referral and those inherent to SCR 105 Complaints and or SCR 102 Petitions being filed). Clearly, the SBN abandoned any attempt to paint those two filings by Coughlin as misconduct considering what they really revealed was that Coughlin brought to light the fact that the Washoe County Sheriff’s Office currently burglarizes tenants instead of following the dictate of NRS 40.253 requiring a tenant be given 24 hours from “receipt” of a summary removal order prior to the Sheriff effecting a summary lockout. The fact that it is the Washoe County District Attorney’s Office (which employs the same NNDB member DDA Bruch Hahn that sat on Coughlin’s April 2012 Screening Panel) which defends the Washoe County Sheriff’s vi

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    2009 To 12 24 12 0204 Emails To @nvbar - Org 925 Pages Bate Stamped Needs Attachments With 5 14 and 7 31 RX Prescription History

    Uploaded by

    NevadaGadfly
    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: THE MATTER OF ZACHARY BARKER COUGHLIN, ESQ. ) ) ) ) ) ) CASE 60975 Notice of Appeal of 8/26/13 Order in CR12-2025 NOTICE OF NON-SERVICE OF COURT’S ORDER OF 4/23/14 Coughlin submits this on his own behalf to apprise this Honorable Court of the fact that he was never served with and or never received a copy of its Order of 4/23/14 referenced in the attachment to an email of 7/9/14 from the State Bar’s Laura Peters, which also attached an Order of 6/30/14 in this same case which Coughlin also was never served with and never received. Coughlin submitted a filing electronically in 60975 (of 6/18/12) and such was filed, however, Coughlin still is unable to view such case in his eFlex account, and a review of the attached printout of the Notifications page in Coughlin’s Eflex account demonstrates that he was not electronically served either of the above orders. Coughlin has made several telephone calls and emails to the SBN since April 18, 2014 and received absolutely nothing in the way of a response other than the filing by the OBC’s Machado of 6/3/14 in 62337. It is unclear if the OBC’s King is still assigned to this case as the letter emailed to Coughlin today is from the OBC’s Pattee. Respondent (the undersigned) would have addressed both this Court’s Order of 4/23/14 and of 6/30/14 by now had he ever been served it or aware of it in any way. It is relevant to note that the bulk of the thrust behind NNDB Chairman Susich’s SCR 117 Petition in 60975 has been put to rest by Respondent’s filing in 62337, and Respondent seeks to incorporate such herein again here now. One, RMC Judge Nash Holmes vacated both of the orders attached as Exhibits 4 and 5 to such SCR 117 Petition herein by way of her attached 4/9/14 Order of Dismissal (which begat this Court’s 5/16/14 Order in 62337 in response to Coughlin’s attaching such Orders of Dismissal to his 4/22/14 filing in 62337) of such case (which Coughlin was never permitted to appeal nor even challenge by Writ of Mandate to whatever extent Pengilly’s proviso applies to a pro se attorney defendant found in contempt, which is/was, apparently, the fate of Coughlins’ attempts to appeal or challenge by writ of mandate RMC Judge Howard’s Order For Summary Punishment of Contempt attached as Exhibit 1 to the SCR 117 Petition (please see debate over Judge Elliott’s 3/15/12 Order in the appeal/petition for writ challenging both the candy bar/cough medication petty larceny conviction (see 60838 as well) in SBN’s filings of 6/3/14 in 62337 and Coughlin’s response thereto). Further, it is interesting to note that, while the SBN’s 8/23/12 SCR 105 Complaint at issue in 62337 included amongst its vague charges both of the filings by Coughlin attached as Exhibits 2 and 3 in the SCR 117 Petition in 60975 of 5/30/12, come time for the disciplinary hearing, the SBN completely abandoned any attempt to paint such as misconduct of any sort (not even within the faux SCR 117 style RPC 1.1 “competence” approach the SBN constantly took during such SCR 105, 102/111(8) formal disciplinary hearing (versus the plural “proceedings”…to reference the distinction between the process set forth in an SCR 111(8) referral and those inherent to SCR 105 Complaints and or SCR 102 Petitions being filed). Clearly, the SBN abandoned any attempt to paint those two filings by Coughlin as misconduct considering what they really revealed was that Coughlin brought to light the fact that the Washoe County Sheriff’s Office currently burglarizes tenants instead of following the dictate of NRS 40.253 requiring a tenant be given 24 hours from “receipt” of a summary removal order prior to the Sheriff effecting a summary lockout. The fact that it is the Washoe County District Attorney’s Office (which employs the same NNDB member DDA Bruch Hahn that sat on Coughlin’s April 2012 Screening Panel) which defends the Washoe County Sheriff’s vi

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    of 933

    Index of emails from Coughlin's ZachCoughlin@hotmail.com to various @nvbar.

    org email
    addresses responsive to Bar Counsel's requests 020:
    12/24/12 Subject: Challenge for Cause Etc. COURTESY COPY O !"!#$%
    12/21/12 Subject: ! a& 'r(t(ng to re)uest a fee 'a(*er of the +earl+ ,-.. efle/ charge%
    12/2./12 Subject: ( th(n0 ( alrea1+ re2orte1 th(s3 but%
    12/14/12 Subject: court refus(ng to f(le 1ocu&ents an1 e/h(b(ts &(ss(ng% 5TT5C67E#TS
    12/14/12 Subject: R7C cert(f+(ng Secon1 8u1(c(al f(l(ngs to S9# e/h(b(t 1: fro&
    11/14/12 'as ne*er 2ro*(1e1 to coughl(n%
    12/1;/12 Subject: 2rotect(on or1er aga(nst <CP= 8(& "esl(e3 Es).%
    12/14/12 Subject: 8(& "esl(e (s a scra22+ 1u1e RE: Coughl(n%
    12/1-/12 Subject: The Three E>s? 'c21 fa(lure to 2ro*(1e essent(al 411 call c1 1(sco*er+ of ;/1- an1
    ;/1@3 2.12 to Coughl(n (n rcr2.12A.:B:-.% 5TT5C67E#TS
    12/.B/12 Subject: Please ta0e not(ce <: +our e&a(l 'as unrea1able%
    12/.4/12 Subject: &ore of the for&al gr(e*ance aga(nst S0au3 Young3 "esl(e3 an1 =ogan RE: for&al
    'r(tten gr(e*ance aga(nst S0au3 Young3 "esl(e3 =ogan3 etc. <: 411 calls &(ss(ng
    fro& 'hat 'as 2ro1uce1 b+ C(t+ 5ttorne+ S0au%
    12/.4/12 Subject: for&al 'r(tten gr(e*ance aga(nst S0au3 Young3 "esl(e3 =ogan3 etc. <: 411 calls
    &(ss(ng fro& 'hat 'as 2ro1uce1 b+ C(t+ 5ttorne+ S0au %5TT5C67E#TS
    12/.-/12 Subject: State 9ar of #e*a1a refus(ng to f(le sta&2 Res2on1ent>s 2lea1(ngs%
    11/-./12 Subject: P"E5SE =!$!T5""Y TR5#S7!T 7Y E#T!RE !"E TO 7E !77E=!5TE"Y%
    11/2@/12 Subject: <: =(s2osal of Personal Pro2ert+ at R(*er Roc0% 5TT5C67E#TS
    11/2:/12 Subject: 2lease attache1 f(l(ng of 11 2: 12 #ot(ce of 6(ll an1 9a0er>s 7alfeasance%
    5TT5C67E#TS
    11/2:/12 Subject: RE: Su22le&ental to 11 2- 12 corres2on1ence regar1(ng 1(sco*er+ (n 8osh( B4;443
    52r(l 2..4 Or1er sanct(on(ng Coughl(n%
    11/2B/12 Subject: Su22le&ental to 11 2- 12 corres2on1ence regar1(ng 1(sco*er+ (n 8osh( B4;443 52r(l
    2..4 Or1er sanct(on(ng Coughl(n% 5TT5C67E#TS
    11/2-/12 Subject: "!T!$5T!O# 6O"= #OT!CE October 4th3 2.12 cert(f(e1 &a(l(ng of #ot(ce of
    !ntent to ta0e =efault%
    11/2-/12 Subject: 11 2- 12 57E#=E= SUPP"E7E#T5" TO RESPO#=E#T>S E7ER$E#CY
    7OT!O# TO SET 5S!=E3 5"TER OR 57E#= 5"" OR=ERS SO 5R 9Y
    ##=93 S9#3 P5#E"3 OR 9O5R=3 5#= #OT!CE O !RRE$U"5R!T!ES
    O PROCEE=!#$S T6US 5R an1 SUPP"E7E#T TO CER!!E=
    5#S<ER OR RESPO#SE TO <65TECER ED%
    11/2-/12 Subject: Ch(ef 7arshal Ro2er an1 7arshal 6arle+ on sett(ng the recor1 stra(ght (n #$12A
    .4-B%
    11/22/12 Subject: 2lease (n1(cate so&e res2onse to &+ sub2oena an1 1(sco*er+ re)uests%
    5TT5C67E#TS
    11/22/12 Subject: or&al re)uest for na&es of those on &+ Screen(ng PanelE%
    11/22/12 Subject: 8u1ge 6o'ar1 an1 Cassan1ra 8ac0son 'ant to e/2la(n% 5TT5C67E#TS
    11/22/12 Subject: <ashoe "egal Ser*(ces Paul Elcano an1 State 9ar of #e*a1a>s Coe S'obe>s contacts
    '(th &+ fa&(l+% 5TT5C67E#TS
    11/21/12 Subject: RE: 7r Coughl(n%
    11/21/12 Subject: RE: 7r Coughl(n%
    11/2./12 Subject: <: 9ar 51&(ss(on an1 e&2lo+&ent %5TT5C67E#TS
    11/14/12 Subject: gr(e*ance aga(nst Cre(g S0au3 Es).3 Reno C(t+ 5ttorne+>s Off(ce%
    1/:
    0434, 0435 60838












































    11/1;/12 Subject: RE: 1oes R(char1 6(ll ha*e stan1(ng to f(le a gr(e*ance%
    11/14/12 Subject: ne' =(sco*er+ f(nall+ 2ro1uce1 b+ Reno C(t+ attorne+ on 1/12/12 8a+'al0(ng arrest
    (n SCR 1.B Co&2la(nt%
    11/14/12 Subject: C(t+ 5ttorne+ S0au3 u21ate1 1(sco*er+ (n (Phone case3 1(s2atch recor1(ngs3 1on>t
    see& to re*eal bas(s for Fa 2oss(ble f(ghtF assert(ons (n off(ce test(&on+ an1
    2rosecutors>s f(l(ngs an1 argu&ent%
    11/1-/12 Subject: S9# an1 or Panel '(ll be brea0(ng the la' b+ hol1(ng a hear(ng to&orro' (n
    *(olat(on of SCR 1.BG2HGcH 2roof attache1%
    11/12/12 Subject: SCR Rule 1.4G-H Co&2la(nt f(le1 aga(nst 9ar Counsel I(ng an1 Cler0 of Court
    Peters%
    11/12/12 Subject: "!T!$5T!O# 6O"= #OT!CE P"E5SE RET5!# 5"" EC!=E#CE%
    11/11/12 Subject: Tr(bal Pol(ce not allo'e1 to arrest for &(s1e&eanors <: Case #o. RCR2.11A
    .:--41%
    11/11/12 Subject: <: %
    11/11/12 Subject: E&ergenc+ E/ Parte 7ot(on #$12A.2.43 .4-43.4-B%
    11/.;/12 Subject: RE: Case #o. RCR2.11A.:--41%
    11/.:/12 Subject: F(n*est(gatorF Peters 2utt(ng the bl(n1fol1 on herself:%5TT5C67E#TS
    11/.:/12 Subject: G#o SubjectH%
    11/.:/12 Subject: G#o SubjectH%
    11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
    11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
    11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
    11/.B/12 Subject: <: #E: ST5CEY R!SSO#E CS. 8O6# =5C!= $ESS!# G5R9H: Sub2oena
    =uces Tecu&: CC1.A.1-41%5TT5C67E#TS
    11/.4/12 Subject: RE: con*(ct(ng attorne+ of su&&ar+ cr(&(nal conte&2t 1ur(ng 2en1enc+ of Or1er for
    Co&2etenc+ E*aluat(on%
    11/.4/12 Subject: RE: 7r. I(ng>s assert(on (n h(s -/1:/12 letter%
    11/.-/12 Subject: con*(ct(ng attorne+ of su&&ar+ cr(&(nal conte&2t 1ur(ng 2en1enc+ of Or1er for
    Co&2etenc+ E*aluat(on% 5TT5C67E#TS
    11/.-/12 Subject: <: 7r. I(ng>s assert(on (n h(s -/1:/12 letter% 5TT5C67E#TS
    11/.2/12 Subject: RE: S9# st(ll has not 2ro*(1e1 Coughl(n access to the &ater(als he (s ent(tle1 to to
    2re2are for 11/14/12 6ear(ng%
    11/.2/12 Subject: S9# st(ll has not 2ro*(1e1 Coughl(n access to the &ater(als he (s ent(tle1 to to
    2re2are for 11/14/12 6ear(ng% 5TT5C67E#TS
    11/.1/12 Subject: <h+ no Case+ 9a0er3 Es).3 5ll(son Or&aas3 Es).3 <CSO =e2ut+ 7achen3 or R7C
    7arshal 6arle+3 <CP= 9(ra+ =ogan3 ==5 Jach Young%
    11/.1/12 Subject: RE: Recor1s%
    11/.1/12 Subject: RE: Coughl(n: Pet(t larcen+ case%
    11/.1/12 Subject: RE: Coughl(n: Pet(t "arcen+ case AA 6an1AOff Trans&(ttal% 5TT5C67E#TS
    1./2-/12 Subject: &+ ne' a11ress%
    1./22/12 Subject: gr(e*ance aga(nst Ie(th "oo&(s3 Es). an1 Chr(sto2her 6aKlettASte*ens3 Es).3 "e'
    Ta(tel3 Es).3 an1 6enr+ Sotelo3 Es).3 an1 <CP= 9(ra+ =ogan an1 8(& "esl(e%
    1./1;/12 Subject: bar gr(e*ance aga(nst R(char1 6(ll3 Case+ 9a0er3 an1 Ie(th "oo&(s3 Roberto
    Puentes3 "e' Ta(tel%
    1./1@/12 Subject: <: u21ate 2roof of ser*(ce%
    1./1@/12 Subject: "!T!$5T!O# 6O"= #OT!CE re*2.11A..1@.; c*11A.-:2;3 :.--1 :1-;-3 S9# *.
    Coughl(n C5SE #U79ER #$12A.2.43 #$A.4-B3 #$ .4-4 5TT5C67E#TS%
    2/:












































    1./1@/12 Subject: u21ate 2roof of ser*(ce%
    1./1B/12 Subject: "!T!$5T!O# 6O"= #OT!CE re*2.11A..1@.; c*11A.-:2;3 :.--1 :1-;-%
    5TT5C67E#TS
    1./11/12 Subject: RE: Coughl(n: RCR11A.:--41 GPet(t "arcen+H an1 RCR12A.:@4;. GRes(st(ngH an1
    RCR2.12A.:B:-. G&(sue of 411H %5TT5C67E#TS
    1./11/12 Subject: RE: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
    COU$6"!#3 #o. :.;-;%
    1./11/12 Subject: RE: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H
    *ersus SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
    5TT5C67E#TS
    1./1./12 Subject: <: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H
    *ersus SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
    1./1./12 Subject: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H *ersus
    SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
    1./.:/12 Subject: <: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
    COU$6"!#3 #o. :.;-;% 5TT5C67E#TS
    1./.:/12 Subject: <: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
    COU$6"!#3 #o. :.;-;%
    1./.:/12 Subject: <: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
    1./.-/12 Subject: &ore courtes+ co2(es%
    1./.-/12 Subject: &+ 2h+s(cal a11ress%
    1./.-/12 Subject: courtes+ co2(es of 'hat 'as f(le1 to1a+% 5TT5C67E#TS
    1./.2/12 Subject: 2roble& '(th the f(le (n RCR2.11A.:--41%
    1./.1/12 Subject: <: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T% 5TT5C67E#TS
    4/24/12 Subject: c(tat(on to legal author(t+%%
    4/24/12 Subject: Cler0>s l(ab(l(t(es for fa(l(ng to f(le 1ocu&ents sub&(tte1 <: 7ot(on to =(s&(ss
    S9# *. Coughl(n% 5TT5C67E#TS
    4/24/12 Subject: <: 7ot(on to =(s&(ss S9# *. Coughl(n% 5TT5C67E#TS
    4/1;/12 Subject: 7ot(on to =(s&(ss S9# *. Coughl(n% 5TT5C67E#TS
    4/1;/12 Subject: <: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
    4/1@/12 Subject: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
    4/12/12 Subject: =(sc(2l(nar+ 6ear(ng for Coughl(n on Se2te&ber 2Bth3 2.12 at S9# 4 a&%
    5TT5C67E#TS
    4/.;/12 Subject: gr(e*ance' f(le1 (n 52r(l +et to be ac0no'le1ge1 or g(*en a case nu&ber <: Please
    see attache1 5TT5C67E#TS%
    4/.;/12 Subject: gr(e*ance an1 co&2la(nt aga(nst ==5 Young an1 <CP= =ogan3 "esl(e3 an1 9osler%
    5TT5C67E#TS
    4/.B/12 Subject: conf(1ent(al(t+ of gr(e*ances/bar co&2la(nts%
    4/.B/12 Subject: 5ugust 2rth3 2.12 gr(e*ance aga(nst 8(& "esl(e3 <CP=%
    ;/-./12 Subject: ! 1on>t get 1(sbarre1%
    ;/24/12 Subject: RE: #RS :44..2.G1H...l(cense1 as a b(ll collector%%
    ;/24/12 Subject: <"S "et Ta(tel3 confl(ct3 2rofess(onal &(scon1uct3 cr(&(nal &(scon1uct%
    ;/21/12 Subject: a co&2la(nt an1 gr(e*ance aga(nst R7C a22o(nte1 1efen1ers an1 Reno C(t+ 5ttorne+
    Prosecutors3 an1 R(char1 6(ll an1 Case+ 9a0er% 5TT5C67E#TS
    ;/21/12 Subject: gr(e*ance an1 or co&2la(nt% 5TT5C67E#TS
    ;/21/12 Subject: unauthor(Ke1 2ract(ce of la' (n su&&ar+ e*(ct(on 2rocee1(ngs gr(e*ance an1
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    :/:
    Print Close
    Challenge for Cause Etc. COURTESY COPY OF FILING
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 12/24/12 8:04 PM
    To: patrickk@nvbar.org (patrickk@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); davidc@nvbar.org
    (davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); je@eloreno.com (je@eloreno.com);
    cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com);
    mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net);
    ROSEC@NVBAR.ORG (rosec@nvbar.org)
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    12 24 12 0204 refaxed to sbn with corrected caption NOTICE OF APPEARANCE AND 11 15 12 61383 CHALENGE FOR
    CAUSE AND MOTION TO RECUSE ECHEVERRIA AND KENT ETC RECONSIDER BIFURC.pdf

    I am writing to request a fee waiver of the yearly $300 eflex charge
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 12/21/12 5:03 PM
    To: CourtTech@washoecourts.us (courttech@washoecourts.us); filing@washoecourts.us
    (filing@washoecourts.us); judge.hardy@washoecourts.us (judge.hardy@washoecourts.us);
    david.hardy@washoecourts.us (david.hardy@washoecourts.us); joey.hastings@washoecourts.us
    (joey.hastings@washoecourts.us); info@abanet.org (info@abanet.org); rsweet@nvcourts.nv.gov
    (rsweet@nvcourts.nv.gov); training@nvcourts.nv.gov (training@nvcourts.nv.gov);
    staffattorney@nvcourts.nv.gov (staffattorney@nvcourts.nv.gov); zyoung@da.washoecounty.us
    (zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
    stuttle@washoecounty.us (stuttle@washoecounty.us); katy.englehart@americanbar.org
    (katy.englehart@americanbar.org); bill.pritchard@americanbar.org (bill.pritchard@americanbar.org); )
    (patrickk@nvbar.org) (patrickk@nvbar.org); ( (ncjdinfo@judicial.state.nv.us); ( (renodirect@reno.gov); (
    (kadlicj@reno.gov); nvscclerk@nvcourts.nv.gov (nvscclerk@nvcourts.nv.gov);
    tlindeman@nvcourts.nv.gov (tlindeman@nvcourts.nv.gov); janet@ndalclv.org (janet@ndalclv.org);
    ndalc@ndalclv.org (ndalc@ndalclv.org); dgordon@nvcourts.nv.gov (dgordon@nvcourts.nv.gov);
    cherrym@co.clark.nv.us (cherrym@co.clark.nv.us); mfeldman@nvcourts.nv.gov
    (mfeldman@nvcourts.nv.gov); mcherry@nvcourts.nv.gov (mcherry@nvcourts.nv.gov)
    000001
    Dear Second Judicial District Court,

    I am writing based on exigent circumstances to request a fee waiver of the yearly $300 Eflex charge
    as my account is currenly deactivated or disabled. I am not copying the State Bar of Nevada or
    President Flaherty or the Panel Members (Chair John Echeverria, Clark Vellis, Karen Pearl, Stephen
    Kent, or Michael Johnson or Bar Counsel Clark of King becuase I may have had a TPO served
    against me recently (I am not entirely sure, and, given the courthouse sanctuary doctrine, I am not
    sure it is appropriate for the same RJC Bailiff who threatened to "put my foot up your ass" to WCPD
    Jim Leslie, Esq.'s delight, to be attempting serve me anything while I am checking in with the
    Department of Alternative Sentencing, which Judge Sferrazza mandated I do, and which, I guess,
    incidentally, allows for the States to search my home, office, or personall effects (including
    computers, hard drives, etc. and not sure how that "sentence" is not retaliatory given the standard
    sentence is $500 or five days in jail, and I had already served 7...but the sentence sure would seem to
    help the WCDA's Office, Washoe County, the SBN, and others influence and leverage certain things
    from hereforth) just about any hour of the day (despite the fact that the conviction on 11/20/12
    violated Shep v. State in addition to pretty much every other constitutional rights criminal defendants
    have). I think it is possible I will be murdered soon or incarcerated pretexutally and denied any
    ability to file legal documents, so I have to send this out in this manner, but I wish to avoid any ex
    parte contact allegations. I wish my filings of 11/2/12 in 11 cr 26405 and thos I submitted for
    filing but have only been held by the Nevada Supreme Clerk's Office as "received" but not filed in
    61901 will someday see the light of day, including the videos submitted. I am afraid I might be
    violating some TPO if I copy Bar Counsel/NNDB/Panel, etc. on this...but would not mind if it was
    forwarded to them if not violative of any TPO, rules, or laws. Additionally, I think it is
    inappropriate for 60317 to be dismissed, especially given the improperly noticed testimony of WLS's
    Paul Elcano, Judge L. Gardner's bailiff's attendance at the 11/14/12 Hearing, RMC "official
    transcriptionist" Pam Longoni's connection to the 11/14/12 formal disciplinary hearing, the
    multitude willfull violations of my SCR 105(2)(c) rights (including Judge Beesley's participation and
    having the 3,000 pages in a box dropped off to my on 11/8/12 for an 11/14/12 Hearing, where the
    SBN alleges that complies with the SCR 105(2)(c) dictate that I be afforded access to those materials
    "at least 30 days" prior to the 11/14/12 Hearing, particulary where that was co-signed by Panel Chair
    Echeverria and both Echeverria and Bar Counsel and the Chair (at least according to King) have
    repeatedly attempted to thwart my attempts to filing anything in that case, alternatively required me
    to call ahead with 15 minutes warning before appearing to file anything, then calling the police when
    I comply with that strange dictate, then, apparently, applying for a protection order or giving me a
    trespass notice of some sort whenever I point out their fraudulent conduct, and how easily proven it
    is.

    I need this Eflex access to defend myself in the formal disciplinary proceedings against
    me before the State Bar of Nevada, Nevada Supreme Court, and anything that may issue in
    connection with my license to practice patent law before the United States Patent and Trademark
    Office. My eflex username is ZachCoughlin. It is disabled. I live in a rented fifth wheel trailer
    that I rent for about $75 a month plus incidentals. I get food from food pantries. I have no
    000002
    money in my one bank account (a Bank of America account) and its been that way for months. I
    own no real estate or stocks or have any assets beyond simple household furnishings. I am an
    independent jack of all trades/research whose law license is suspened currently in Nevada and I have
    next to no income per month...to the point where I am embarrassed about it and it would probably be
    an exaggeration to say I am making even $200 a month. My 65 year old mother occasionally helps
    me out financially with my rent or some gas money.

    As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla.
    1994) indicate, unsolicited contact with the adjudicatory or investigative entity often involves the
    judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance
    of impropriety judges must strive to avoid.

    I have not been provided (though I believe they are required to) by th RJC a copy of the Record on
    Appeal in CR12-2025. Certainly, DDA Young and the WCDA have been provided access via elfex
    to the 800 page Record on Appeal therein, yet the RJC has failed to mail me my copy. And time is
    of the essence. I have already been prejudiced in that regard and I believe NRS 189.030 has been
    violated in that the RJC has failed to order the transcripts prepared of all hearings in that matter
    yet. Please see CR12-1018 and the recent IFP and Request for Transcript I filed in CR12-2025. I
    need eflex access, further, for many of the cases necessary to defending myself in the SBN v.
    Coughlin SCR 105 Complaint, and to defending myself against the numerous retaliatory prosecutions
    and matters related thereto.

    I respectfully request that I be given immediate EFlex privileges and that the yearly dues thereto be
    waived.

    Further, I believe it would be entirely in appropriate for Judge Elliot to remain on that case, given the
    irregularities of his "randomly" being assigned four of my criminal matters, failure to disclose
    conflict or recuse himself in cv11-01955 and other matters detailed herein.

    As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla.
    1994) indicate, unsolicited contact with the adjudicatory or investigative entity often involves the
    judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance
    of impropriety judges must strive to avoid.

    I have recently been forced to make numerous trips to law libraries far away given the Washoe
    County Law Librarie's contention (disputed by me at the meeting of the Board of Trustess of the WC
    Law Library when the new law librarian's cv was detailed yearlier this year, wherein Judges Weller,
    Walker, and Steinheimmer were present, along with Clerk of Court Orduna Hastings, wherein those
    Judges all deferred to the Washoe County District Attorney's Office rather than address my
    contentions that the WCLL asserts to the public in writing that the "westlaw contract" forbids certain
    things that the contract simply does not forbid, requiring patrons to expend great amounts of money
    to print materials, resulting in collection of revenue by the Court and or Library. I have great
    respect for the WCLL, and would give them huge donations if I had the means, as its the most
    important room in the County, in my opinion). I do have a license to practice before the United
    States Patent and Trademark Office but have never filed anything there and have informally
    represented to USPTO OED Staff Attorney Tom McBride, Esq. that I will not be representing
    000003
    anyone there for the foreseeable future given the extremely encumbering nature of my recent legal
    troubles and defending myself incident thereto. I would greatly appreciate this waiver of the $48 I
    owe pacer and swear under penalty of perjury subject to NRS 53.045 that the information contained
    herein is true and correct.

    I have previously and will again here complaint in writing that Judge Steven Elliott has "randomly"
    (in accord with our local rules) been assigned four of my criminal matters in a row (the appeals of
    the RMC conviction in 11 cr 22176 for petty larceny of a "candy bar and some cough crops" which I
    vehemently dispute and which resulted in my current six month temporary suspension of my law
    license in 60838 (which the State Bar of Nevada managed to get crammed into an unbifurcated
    hearing on 11/14/12 that also included something like 10 copied and pasted alleged violations of the
    Rules of Professional Conduct (none mentioning any direlection of my duties to clients, other than
    Judge Nash Holmes alleging I violating my own duty of competency to myself, etc. where I
    represented myself in a "simple traffic citation" trial on 2/27/12 (held in violation of NRS 178.405
    and NRS 5.071 where Judge Nash Holmes knew of the competency issues, and where Judge Nash
    Holmes continues to violate NRS 189.030 in refusing to process my Notice of Appeal of 3/7/12 and
    those materials submitted thereafter
    37 A.L.R.4th 1004 (Originally published in 1985)
    American Law Reports ALR4th The ALR databases are made current by the weekly addition of relevant new
    cases. Disqualification of judge in state proceedings to punish contempt against or involving himself in open court
    and in his actual presence

    57 A.L.R. 545 (Originally published in 1928)


    American Law Reports ALR The ALR databases are made current by the weekly addition of relevant
    new cases. Necessity that hearing be allowed before imposition of punishment for contempt

    The use of summary criminal contempt power is proper only for charges of misconduct, in open
    court, in the presence of the judge, which disturbs the federal court's business, where all of the
    essential elements of the misconduct are under the eye of the court, are actually observed by the
    court, and where immediate punishment is essential to prevent demoralization of the court's authority
    before the public. 18 U.S.C.A. 401; Fed.Rules Cr.Proc.Rule 42(b), 18 U.S.C.A. F.T.C. v.
    Trudeau, 606 F.3d 382 (7th Cir. 2010).

    Judge Nash Holmes sentenced Coughlin to a summary 5 day incarceration for contempt on 2/27/12,
    signed in an Order stamped 2/28/12 in 11 TR 26800 that, combined with a second bite at the apple
    Order of 3/12/12 in that case attempts to both convict coughlin of "the misdemeanor of criminal
    contempt" in a summary fashion, where there does not seem to be any notice in writing to Coughlin
    onf the 3/12/12 continuation of the Trial and where Coughlin filed a Motion for Continuance of any
    future hearings and Notice of Appeal on 3/7/12 that divested Judge Nash Holmes and the RMC of
    jurisdiction to even hold the 3/12/12 continuation of the Trial (and NRS 178.405, NRS 5.071 further
    prohibited such a proceeding...and its really not at all clear how Judge Nash Holmes feels it is propert
    to file a grievance with the State Bar of Nevada against Coughlin on 3/14/12 on behalf of herself an
    all the other RMC Judges (even the Judges Pro Tem) (which Judge Dilworth vehemently disputes)
    000004
    including Second Judicial Judge L. Gardner's brother, RMC Judge William Gardner (whom refused
    to recuse himself from the criminal trespass conviction Trial against Coughlin in 11 cr 26405, despite
    W. Gardner then himself having a grievance against Coughlin in ng12-0434, and despite his being
    involved in the filing of the grievance against Coughlin in ng12-0435, which consists solely of his
    sister's April 2009 Order sanctioning Coughlin $1,000 (despite Springgate failing to follow NRCP
    11's 21 day safe harbor provisions...so basically Springgate and Judge Linda Gardner (whose 2008
    campaign contributions list Springgate as a donor and Judge Peter Breen, as well, whom removed
    Coughlin from the Mental Health Court in MH12-0032 for Coughlin takign a medication for
    ADHD/treatement resistent depression that Coughlin was specifically told was approved and not
    probibited prior to Coughlin entering into the Mental Health Court contract, and reviewing the
    associated written materials provided by the MHC, Reno Biondo, est. whom subsequently
    fraudulently asserted Coughlin was removed from the MHC for not following program rules (the
    alleged violation was that Coughlin was taking a medication that he had specifically been told was no
    prohibited and that his use of was acceptable. Judge Breen's law clerk at one time was Judge
    Linda Gardner, who recused herself from a case wherein Coughlin represent Robert Bell in Bell v.
    Greer, a case filed on 8/10/11, proving Coughlin was a commercial tenant practicing law at the 121
    River Rock St. location from which Coughlin was summarily evicted, in violation of NRS 40.253
    (much less where Coughlin was required to deposit a $2,275 rent escrow deposit that violated Nevada
    law, in that no corollary to JCRLV 44 had been published and approved by the N. S. Ct, in
    compliance with Nevada's JCRCP 83...) from his former law office, and subsequently subject to a
    custodial arrest and prosecution for trespass, signed by opposing counsel Richard G. Hill (whom lied
    to the RPD about whether he had been at the office in the weeks prior, in an attempt to avoid the
    requirement under the RPC that the lawyer, Hill, withdraw where the likelihood of his becoming a
    witness in the case was assured, where Hill told the RPD it was his client Merliss who "noticed"
    things in the office in the week prior to the criminal trespass arrest, which was fraudulent anyways,
    as detailed in 61901 and 11 cr 22176, especially the 11/2/12 filing in that matter that the RMC did
    not included in the record transmitted on 11/29/12 in cr12-1262 (another 'random" assignement to
    Judge Elliot...whom failed to disclose and recuse himself from Coughlin's wrongful termination suit
    against Washoe Legal Services (who admitted ot fiing Coughlin based solely upon Judge L.
    Gardner's April 2009 Order sanctioning Coughlin (which was impermissibly summary in nature
    anyways and failed to follow the 21 day safe harbor in NRCP 11 required under NRS 7.085) in cv11-
    01955 even where Coughlin was suing for wrongful termination as a former domestic violence
    attorney at WLS, and also suing Committee to Aid Abused Women (CAAW) where Judge Elliott was
    on CAAW's Executive Board, and started the Nevada Domestic Violence Task Force, and where a 25
    year Washoe County District Attorney turned RJC Judge (David Clifton) who was a longtime
    domestic violence prosecutor (working with now Judge Linda Gardner in the domestic violence unit
    of the WCDA, to go along with their both being from Reno High School's Class of 1975, and WLS's
    Director Elcano admitting that Judge Linda Gardner and Master Edmondson has given Coughlin "a
    thumb's up" review in February 2009...shortly before Coughlins' suspension and firing from WLS on
    4/20/09...the day after Coughlin submitted a complaint in writing to WLS and Elcano regarding the
    hostile work environment there...where Elcano and WLS fired Coughlin "solely" based upon Judge
    Gardner's April 2009 Order sanctioning Coughlin for his work in the 3/12/09 and 3/17/09 divorce
    trial in Joshi, DV08-01168...never mind that Coughlin was encumbered preparing a Nevada
    Department of Taxation 20 page appeal brief for Elcano by a 3/10/09 deadline to get Elcano and
    WLS out of the jam where the Lease Agreement for the property Elcano had just moved WLS to
    required WLS, a non-profit 503(c) to pay the private landlord's property taxes...and where WLS
    000005
    management failed to timely respond to Coughlin's request for subpoena fees and other discovery
    related expenses and where Coughlin emails to his then WLS assistant proves he had culled ALR
    support for the positions taken, vis a vis Siragusa, that Judge Gardner had him fired over....Judge L.
    Gardner's 2008 campaign expense reports lists CAAW as well, in addition to WLS's Todd Torvinen,
    Esq., whom specifically approved of the positions Coughlin took in that Joshi divorce Trial upon
    Coughlin following Elcano's direction to seek mentoring and guidance from Torvinen, whom
    managed to get the lawsuit against him dismissed in 60302 and 60317 based upon weasley
    "legibility" arguments regarding the service of process, which the WCSO messed up in 60302 where
    Coughlin was an IFP)

    That under some circumstances, even where immediate summary contempt proceedings
    would be appropriate, it might be necessary for the contemned trial judge to be disqualified
    from sitting therein was recognized by the court in Krueger v State (1977, Fla App D3) 351
    So 2d 47, in which it appeared that the appellate court's primary emphasis was on the lack of
    objective evidence to support the trial judge's finding that a contempt had actually been committed
    by a prosecuting attorney whose intent to appeal a prior ruling had been characterized
    by the trial judge as not only frivolous but "absurd," and who replied to this characterization
    merely by stating that the judge was entitled to his opinion

    Judge Berry's Order in CR12-1018 seems to establish that the RMC had a duty to order the
    transcripts prepared in 11 cr 22176 ("randomly" assigned to Judge Elliot in Department 10 in cr11-
    2064, where he dismissed my appeal based upon not citing to a transcript that I attempted to have
    prepared by the "RMC Official transcriptionist and the only person the RMC will release your audio
    transcripts to and whom can prepare a transcript for you, Pam Longoni"...Ms. Longoni refused to
    prepare my transcript and hung up on me twice in December 2011. Further RMC Judge Howard
    seems to have violated NRS.

    So, the transcripts from the convictions in RMC 11 CR 22176 should have been ordered prepared
    by RMC Judge Kenneth Howard, and his failure to prejudiced Coughlin in the appeal
    ("randomly" assigned to Judge Elliott in Cr11-2064, dismissed by him citing to a civil statue about
    down payments on transcripts), and in 11 TR 26800 (which the RMC and Judge Nash Holmes
    continue to violate NRS 189.030 in failing to process Coughlin's notice of appeal of 3/7/12 etc.
    for. Additionally, Judge Elliott was "randomly" assigned Coughlin's appeal of the criminal
    trespass conviction that RMC Judge W. Gardner failed to recuse himself from in 11 cr 26405, in
    cr12-1262, and dismissed that case where, despite Coughlin showing proof of timely receipt of
    his Notice of Appeal in compliance with NRS 189.010 by both the City Attorney and the RMC,
    000006
    properly submitted for filign by Coughlin, RMC assistant Lisa Wagner is mum about why that Notice
    of Appeal was not filed in by the RMC, as is Judge W. Gardner...Further RMC Donna Ballard is
    certifying Orders from the Second Judicial District Court for SBN Bar Counsel Patrick King that she
    has no right to certify. Further, King is fraudulently alleging to have certified copies of an
    admitting as exhibits in the 11/14/12 hearing against Coughlin in the SBN ng12-0204 of Judge
    Flanagan's 6/28/12 Order awarding against his former co-worker at Hale Lane, Coughlin
    (Flanagan refused to recuse himself despite obvious conflicts set out by Coughlin in cv11-03628)
    a preposterous $42,050 in attorney's fees, against a pro se tenant, whom Flanagan apparently ruled a
    commercial tenant anyway whose rent was les sthan $1,000, though denied the NRS 118A.385 stay afforded such
    litigants.

    SBN King similarly fraudulently asserted the April 2009 Order by Judge L. Gardner in dvb08-01168 was certified
    where he had it admitted as an exhibit (ordered admitted by Panel Chair John Echeverria, who Judge Steven
    Elliott worked for Echeverria's father's law firm, Echeverria and Osborne, and where Chair Echeverria, Judge
    Elliott, and WLS's Paul Elcano all went to Stanford University in the late 1960s together, something none of them
    disclosed until Coughlin pointed it out...and Elcano, Echeverria, Norman Beesley and other Judges went to Reno
    High School together in 1962...along with other former co-workers of Coughlin from Hale Lane (Peek, Dennisson,
    Judge Charles McGee, Judge Salcedo, whom Judge Sferrazza mentioned needing to meet with on the record in
    another retaliatory prosecution against Coughlin in RJC rcr2011-063341, which, again, Judge Elliott was
    "randomly" assigned on 12/6/12, allegedly, in cr12-2025 (which Coughlin has not been provided a copy of the 800
    page record on appeal, which seems to involved Judge Sferrazza, in conjunction with the fraudulent conduct of
    public defendner Jim Leslie, "disenfecting" the record of Coughlin's 2/15/12 Pre-Trial Motions and Coughlin
    8/29/12 Memorandum of Law, etc. (Leslie has no ability to "refuse to join in on" such, especially where Leslie
    was not even attorney of record untilsometime in August 2011 and where Coughlin filed a Notice of Appearance
    to represent himself while he was still a license attorney and to subsitute out the WCPD's office or to at least
    downgrade their involvement to co-counsel in February 2012.)

    Additionally, Coughlin has not received any such "Amended Notice of Appeal" in cr12-1262, despite receiving an
    email indicating one was filed from Eflex...Coughlin's elfex is currently disabled for non-payment, and Coughlin
    hereby request his eflex charges be waived in light of his indigency and the misconduct and irregularities
    mentioned above and previously by Coughlin.

    Coughlin attempted to proved the testimony by RMC Judge Nash Holmes regarding the order of the bathroom
    break and Holme's other patently false and or incorrect statements in her testimony on 11/14/12 at the formal
    disciplinary hearing...however Judge Elliott's former Stanford Classmate (whose father's law firm he worked for),
    Chair Echeverria (who admits to be "boyhood chums" with fellow wine business owner WLS's Elcano, upon
    Coughlin prompting them to divulge further conflicts), Chair John Echeverria refused to allow into evidence the
    audio transcript Coughlin bought from the RMC (well, Coughlin had to have his mother, Very Special Arts
    Nevada's Mary Barker sneak down to the RMC and buy it becuase Coughlin's previous three or four attempts to
    buy it himself were met with obstuctionist tactics by the RMC) for $35, where Bar Counsel King claimed it wasn't
    "certified" and the lack of a written transcript made it "worthless" and "devoid of context" (surely the tape could
    have shown that the sua sponte interrogation by Judge Nash Holmes regarding her questioning Coughlin if he
    was "recording" or had a "recording device" occured AFTER the one and only restroom break in theat 2/27/12 11
    tr 26800 "simple traffic trial" and NRS 22.030(3) requirement for an Affidavit for any factual allegations to
    support a summary contempt order for any conduct occuring in the "immediate presence" of the Judge would
    have been useful, as then RMC Marshal Harley could have maybe gotten his story straight (or Judge Nash Holmes
    could have had some more "help" with her "memory" about what Harley "told" her to support Judge Holmes
    "finding" that Coughlin "probably lied" about such matters in her 2/28/12 Order, and that Coughlin "lied" and
    therefore "violated the Rules of Professional Conduct" in her "second bite at the apple" Order of 3/12/12 (which
    violated NRCP 59(a) in that such a sua sponte altering or amending of what was a "civil contempt" Order must be
    within 10 days of its entry...where Judge Nash Holmes cites to plenary civil contempt statutes in her ORders (NRS
    22.010 and NRS 22.100, curiously avoiding the summary civil contempt statute setting out the Affidavit
    000007
    requirment that Judge Holmes, the RMC, and Marshal Harley benefitted from avoiding, found in NRS 22.030(3)...

    Also, less than 48 hours after Richard G. Hill, Esq. had the RPD arrest Coughlin for jaywalking in RMC 12 CR
    00696 (curiously "transferred" to Judge Nash Holmes by Judge W. Gardner on 2/27/12, from RMC Dept. 1), the
    RPD again arrested Coughlin on 1/14/12 for "misuse of 911"...but that would be politically awkward for RJC
    Judge Clifton to convict Coughlin of in rjc rcr2012-065630, plus, so much better leverage for the SBN (whom
    received emails from RJC Judicial Secretrary Lori Townsend containing Coughlin's 2/21/12 filign in that matter
    and where Townsend offered to send Coughlin's 2/15/12 filing in rcr2011-063341 to the SBN, unprompted...and
    the RJC and SBN are refusing to prove that such transmission by the RJC were not unprompted. Further RMC
    Judge Kenneth Howard and RMC Administrator Cassandra Jackson have sent unprompted correspondence to the
    SBN seeking to have an effect on Coughlin's formal disciplinary hearing, which is judicial misconduct.

    Summary convictions for contempt, during criminal trial, that are unwarranted by the facts will not be
    invulnerable to appellate review. Codispoti v Pennsylvania, 418 US 506, 41 L Ed 2d 912, 94 S Ct 2687, conformed
    to (Pa) 328 A2d 484.
    Denying misdemeanant contemnor an appeal and bail pending appeal, right to which all other misdemeanants
    were absolutely entitled under California law, violated equal protection clause. Bell v Hongisto (DC Cal) 346 F
    Supp 1392.
    Criminal contempt judgments are immediately appealable because they result from a separate and independent
    proceeding to vindicate the authority of the court and are not a part of the original cause. 28 U.S.C.A. 1291.
    Cobell v. Norton, 334 F.3d 1128 (D.C. Cir. 2003).

    33 A.L.R.3d 448
    Appealability of contempt adjudication or conviction
    Exercise by trial judge of his summary power to punish for contempt of court committed in his presence is
    subject to review on appeal. Re Lafferty, 28 Mich App 654, 185 NW2d 189.

    RMC Judge Howard attempted to mislead Coughlin as to his right to appeal and seek review of the NRS
    22.030 civil summary contempt Order he rendered against Coughlin at the conclusion of the 11/30/12 Wal-Mart
    candy bar petty larceny trial in 11 cr 22176 (and now Chair Echeverria is trying to call that one "criminal
    contempt" too...seeking to utilize Bar Counsel King's oft repeated, Claiborne ignoring claim, that SCR 111(5)
    makes and such "conviction" provide "conclusive proof of guilt" and thereby vitiating and Claiborne duty upon
    Bar Counsel of the Panel to ascertain whether a fundamental lapse of due process occurred (or whether such a
    "conviction" was void for lack of jurisdiction or not actually a crime anyways under Schaefer...

    Further WCDA's Office David Watts-Vial may not seek to Quash Coughlin's subpoenas served upon Clerk
    of Court Hastings where Watts-Vial's relation works as a Administrative Assistant to Judge Egan Walker.

    In re Eriksson, 36 So. 3d 588 (Fla. 2010) (judge publicly reprimanded for revoking bond for
    defendant who sought recusal, thereby punishing defendant for exercising legitimate legal right, and
    for employing unduly rigid process in dealing with self-represented litigants, so as to impede their
    ability to obtain relief and protection they sought from court).

    http://www.flcourts.org/gen_public/courted/bin/judicialethicsbenchguide.pdf
    6. What Contact with Investigative or Adjudicatory Bodies Is Permitted?
    The case law and committee opinions advise that a judge may not initiate contact with an
    investigatory or adjudicatory body determining rights, duties, privileges, or immunities of a person
    requesting that the judge contact the body on his or her behalf. Opinion 75-6 (improper to write
    character letter for attorney who is principal in disbarment proceeding); Opinion 75-18 (improper to
    write letter to bar grievance committee or supreme court in disciplinary proceeding or to
    federal judge in criminal sentencing without official request); Opinion 82-15 (improper to write
    letter voluntarily to Board of Bar Examiners); Opinion 89-15 (impermissible to appear before
    000008
    judicial nominating commission to introduce candidate or express opinion about who is best qualified
    to serve as judge...See Judge Sferrazza's letter in 2007 on this and Judge Linda Gardner's submitting
    numerous letters of recommendation from local judges:
    http://www.washoecounty.us/large_files/agendas/071007/35.pdf page 101-104);

    Judge Linda Gardner recused herself from Bell v. Greer admitting to a personal bias against
    Coughlin (maybe stemming from the Mandamus Petition Coughlin file in 54844 agaisnt her,
    which WLS's Elcano claimed to be unaware of in his improperly notice 11/14/12 testimony at
    Coughlin formal disciplinary hearing. Panel Chair Echeverria did not care about SCR
    105(2)(c)'s requirement that such a Designation of Witnesses and Summary of Evidence be
    provided Coughlin "at least" 30 days prior to the 11/14/12 hearing where Bar Counsel King (despite
    no "newly discovered" evidence justiying such, no argument by King in support of such a stance,
    and have been aware of all that either Judge Beelsey or WLS's Elcano (whom both went to
    McGeorge School of Law in 1977 with another witness that day, RMC's Judge Dorothy Nash
    Holmes, though none of divulged that...Judge Beesley also worked with WLS's Karen Sabo at
    Beesley Peck, and attended at 2008 West Fourth St. Bistro WLS fundraising dinner, RMC Judge
    Howard is a 1980 graduate of McGeorge, as is Panel member Stephen Kent, Esq., and Coughlin
    "court appointed defender" Keith Loomis in the RMC, who received multiple ORders granting his
    Withdraw, is a 1982 McGeorge graduate and whom fraudulently refused to assert the claim of right
    defense to the criminal trespass charge set out to him in 11 cr 26405, even where Hill admits to
    having sent writings charging the same $900 per month that was charged for "full use and
    occupancy" and where Washoe County Sheriff's Officer Liz Stuchell admitted in her 2/5/12 email
    to Coughlin that the 11/7/12 Affidavit of Service by Deputy Machen was false in that no personal
    service was effect, therby making Hill and the WCSO the trespasses, along with Casey D. Baker,
    Esq., especially where the "within 24 hours of receipt" language of NRs 40.253(5) made both the
    10/25/11 and 10/27/11 Orders in rev2011-001708 void and or stale, especially where WCSO Roxy
    Silva brazenly brags about the stomping on tenant's rights in open violation of such law where the
    WCSO knows it is too late and any such Lockout ORder is stale. Oh, then there is the locksmith
    from the 11/1/11 lockout at Coughlin former law office admitting that the lockout was effected
    outside the "within 24 hours" required in NRS 40.253 (not to mention Sferrazza's Order fails to
    include that required language...which in no way amounted to a "trespass warning" anyways).

    In re Frank, 753 So. 2d 1228 (Fla. 2000) (retired appellate judge publicly reprimanded for actions
    while on bench, including making false or misleading statements under oath concerning his
    involvement in divorce litigation of his daughter; not recusing himself from appeals based on his
    friendship with attorney in those appeals; improperly interfering with Bar grievance proceeding of
    that attorney; threatening to have son-in-law arrested or committed to psychiatric facility during
    divorce proceedings involving his other daughter).

    Then there is the matter of RJC Clifton on 2/27/12, "somehow" knowing that Judge Elliott would be
    "randomly" assigned the case created by Judge Clifton's 2/27/12 Order for Competency Evaluation
    (the gross misdemeanor of "misuse of emergency services (911)" case rcr2011-065630 necessitated
    the opening of a District Court case, CR12-0376), where Judge Clifton specifically lists "Judge
    Elliott" in that 2/27/12 Order and also list's the evaluator Couglin was required to utilized for the
    evaluation ("Lake's Crossing Bill Davis, Ph.D....who just so happened to file and sign a fraudulent lie
    filled letter in that cr12-0376 case on 4/18/12 resulting in Coughlin being incarcerated from April
    000009
    19th to April 26th, 2012, though Judge Elliott has failed to put the "why" of it in writing in an sort
    of Order...and where DDA Young violated NRS 178.405 in moving for Coughlin to "be remanded
    into custody" (as if asking a question about one's HIPAA rights or telling Bill Davis, Ph.D. that
    Coughlin would need to "check his records" in response to one question justified such a remanding
    into custody or was tantamount to "following all laws"...which DDA Young clearly does not follow
    all laws himself given his horific attempts to coerce from Coughlin, in conjunction with RJC Judge
    Sferrazza and "stand by counsel" WCPD Jim Leslie, Coughlin's Fifth Amendment rights on
    November 19th and 20th, 2012 in rcr2011-063341...see from 4:05 pm to 4:55 pm on 11/19/12 (at
    which time RJC Bailiff John Reyes attempted to extort from Coughlin permission to for the RJC to
    keep (and probably search and or copy under Diaz) Coughlin's laptops and other trial materials
    overnight while Coughlin was in custody, at a time when Coughlin was handcuffed and in custody
    awaiting transport to the Washoe County Jail incident to Judge Sferrazza finding Coughlin in
    contempt for "making arguement while testifying")
    http://www.youtube.com/watch?v=8NsOLy2Unek
    http://www.youtube.com/watch?v=w4c7hyhI1RI Witness "standby counsel" WCPD Jim Leslie
    trying to aid in coercing from Coughlin his Fifth Amendment and other rights (even more than Leslie
    is heard doing on the record during the 8/27, 8/29/, and 9/5/12 Trial dates in 063341) at the 9:05 am
    mark

    Then there is....this by RJC Judge Clifton and WCDA DDA Zachary Norman Young, Esq.:
    http://www.youtube.com/watch?v=WPYCmDZTSXo

    /s/ signed electronically Zach Coughlin


    Zach Coughlin

    law license temporarily suspended in Nevada


    NV Bar No: 9473
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com



    000010
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    court refusing to file documents and exhibits missing
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 12/19/12 1:14 PM
    To: (patrickk@nvbar.org) (patrickk@nvbar.org); (je@eloreno.com) (je@eloreno.com); (davidc@nvbar.org)
    (davidc@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com);
    (mike@tahoelawyer.com) (mike@tahoelawyer.com); (fflaherty@dlpfd.com) (fflaherty@dlpfd.com);
    (skent@skentlaw.com) (skent@skentlaw.com); (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net);
    (ncjdinfo@judicial.state.nv.us) (ncjdinfo@judicial.state.nv.us); (dballard@reno.gov)
    (dballard@reno.gov); (ballardd@reno.gov) (ballardd@reno.gov); (jacksonc@reno.gov)
    (jacksonc@reno.gov); (renodirect@reno.gov) (renodirect@reno.gov); (kadlicj@reno.gov)
    (kadlicj@reno.gov); (joey.hastings@washoecourts.us) (joey.hastings@washoecourts.us);
    (judge.hardy@washoecourts.us) (judge.hardy@washoecourts.us); (rsweet@nvcourts.nv.gov)
    (rsweet@nvcourts.nv.gov); (training@nvcourts.nv.gov) (training@nvcourts.nv.gov);
    (staffattorney@nvcourts.nv.gov) (staffattorney@nvcourts.nv.gov); (zyoung@da.washoecounty.us)
    (zyoung@da.washoecounty.us); (jleslie@washoecounty.us) (jleslie@washoecounty.us);
    (bdogan@washoecounty.us) (bdogan@washoecounty.us); (mkandaras@da.washoecounty.us)
    (mkandaras@da.washoecounty.us); (stuttle@washoecounty.us) (stuttle@washoecounty.us);
    (info@abanet.org) (info@abanet.org); (katy.englehart@americanbar.org)
    (katy.englehart@americanbar.org); (bill.pritchard@americanbar.org) (bill.pritchard@americanbar.org)
    3 attachments
    12 12 12 rcr2011-063341 notice of rjc refusing defendant access to file since 11 19 12 and refusing to
    file in documents 0204.pdf (1388.6 KB) , 20121219_113934 rcr2011-063341 robbin baker cathy
    wood.jpg (1565.6 KB) , 12 19 12 docket in cr12-2025 from sferrazza's shepp violating 2011-063341
    conviction 0204.pdf (254.1 KB)
    To Whom it May Concern,
    Before I get done away with, I just wanted to try to access justice a little bit more. Been having some real issues with Court's just refusing
    to file things (the RJC refusing to file the 12/26/11 Notice of Appeal in rjc rev2011-001708 cited in Judge Flanagan's Order denying my
    appeal (or he cited my failure to file such a NOA in CV11-03628 as allowing him not to consider matters stemming from Judge Sferrazza's
    12/21/11 order "resolving" (no, I did not "agree" to the Order, I made that very clear on the record...).
    Then there is the RJC failing to file my 3/16/12 Notice of Appeal in rjc rev2012-000374, in the other summary eviction by Galye Kern, ESq.
    (Judge Linda Gardner's former law partner, and I sued Judge Linda Gardner in 54844, and her Order in dv08-01168 was cited by Washoe
    Legal Services Elcano as the sole reason for my firing, which led to 60302, and that April 2009 ORder now "mysteriously" became a
    grievance ng12-0435, which Bar Counsel has fraudulently attempted to assert he got from "the clerk of court", but which lacks a certification
    000011
    from Clerk of Court Hastings (Bar Counsel King likes dealing with the Reno Municipal Court whenever possible, going so far as to have it
    certify documents that it lacks authority to certify, then claiming the audio transcripts from the RMC are "not certified...worthless...lacking
    context..." when Coughlin tries to offer them to the Panel on 11/14/12 in SBN. V. Coughlin (ng12-0204, 0434, and 0435...which somehow is
    supposed to address 60838 despite the "conviction" in 60838 not being addressed at all, which is considering the Court's 6/7/12 ORder and
    SCR 111(7) mandate that the matter "is referred to the disciplinary panel for the sole purpose of determining the punishment " for the the
    conviction the subject of the SCR 111(6) petition in 60838 (ie, not for what the SBN and NNDB/Panel did, which is try to tranmogrify RMC
    Judge Nash Holmes various Order in a "simple traffic citation trial" into some SCR 111(5) "conclusive proof of a conviction" of a bunch of
    alleged violations of the Rules of Professional Conduct that Judge Nash Holmes copied and pasted into her second bite at the apple
    3/12/12 Order in rmc 11 tr 26800...then there is judge schroeder ruling that gayle kern doesn't even have to respond to coughlin's recent
    filings pointing out that she mailed the notice of entry of order to an address coughlin had told her was no good anymore in her may 2012
    mailing....then
    there is the rjc issuing an eviction order violative of nrs 40.253(5) on 6/28/12, depsite coughlin's filing a tenant's affidavit with the sparks
    justice court on 6/26/12, which was the forum listed on the notice in which the tenant must file...and coughlin's writying and callign the
    wcso, rjc, sparks justice court, etc., etc. and giving them a heads up on the situation...no matter, Judge schroeder signed the eviction order
    and the wcso office arrested coughlin w here he didn't immediately open his door and where the wcso refused to identify themselves, and
    where the lockout order was obtained by an unlicensed "eviction consulting service process firm", Nevada Court services in rjc rev2012-
    001048, which begat the criminal prosecution fo coughlin in rcr2012-067980 for "resisting or obstructing a public officer" or "false
    statement to a public officer....the rjc and the wcda's office criminal and civil division and the wcso goin' together like bread and meat.
    Then there is Judge Clifton's "disenfecting" the record from anything I am trying to preserve in rjc rcr2012-065630. Most recently he put a
    post-it note "Order" telling Robbin Baker and Cathy Wood to finally file in my 11/28/12 filing in that matter but to file stampe it the day
    after the trial started...so file stampe it 12/12/12...which makes it far less operative.. I had permission to fax file as of 11/28/12, and given
    Judge Clifton removed public defender Dogan as counsel of record substituting in me as a pro se...I was entitled to file that document (I
    believe it was an Motion for Reconsideration of Order allowing wCDA to Amend Complaint (they didn't want to try a "misuse of 911" charge
    against this former domestic violence attorney, where Judge Clifton and Judge Gardner worked together in the domestic violence unit at
    the Washoe County District Attorney's Office and where Coughlinw as granted two protections orders against domestic violence against the
    very peopel he called 911 about, but for which reno pd sargent paul sifre decided to order coughlin arrest for the second time in 2 days (the
    first arrest, on 1/12/12 was a custodial arrest for jaywalking...and in the interim the same officer coughlin filed a written complaint against
    with the rpd on 1/8/12 pulled coughlin over on 1/13/12 with 5 other officers and harrassed him late at night....).
    Plus, the wcpd refused to give coughlin the 8/13 and 8/17/12 cd's of discovery containing the 911 calls in question. DDA Young refused
    to provide Coughlin a copy and Judge Clifton claimed his hands were tied to allow Coughlin access to such discovery (though he was sure
    to "help" the DA out by turning the 11/27/12 hearing into an arraignment, despite earlier stating on the record that it was not permissible
    to do so and how the hearing was for a very limited purpose of hearing argument on the motion to amend the complaint (which was
    amended to a scr 111(6) "serious offense" because a conviction there woudl help bar counsel get rid of coughlin, and help the wcda's office
    out a lot more than a "misue of 911" charge...the amended charge was "obstructing a public officer"...which is specificaly mnetioned in the
    scr 111(6) serious offense rule....though Judge Clifton kept a straight face when indicating to Coughlin "I don't see how "misuse of 911" is
    less worse for you than "obstructing a public officer" under a SCR 111(6) analysis...I really don't. " Yeah. uh....sure.
    Then there is Judge Clifton refusing to file in many other filing by Coughlin in rcr2012-065630.
    Then, Coughlin as of 12/19/12, still has not received the record on appeal in cr12-2025 (one of 4 criminal matters involving Couglin that
    have been "randomly" assigned to Judge Steven Elliot, who worked at Panel Chair Echeverria's father's law firm, sat on CAAW's board and
    presided over Coughlin's wrongful termination suit against CAAW and Washoe Legal SErvices, did not disclose the conflict, failed to recuse
    self, etc...and who went to Stanford in the later 1960s with Elcano (director of WLS) and Panel Chair Echeverria...Oh, and Judge Gardner's
    campgain contributions include some from WLS's Torvingen, expense to CAAW, her brother refused recuse self from criminal trespass
    prosectuion of coughlin in 11 cr 26405...oh, jeez, its exhausting detailing all this over and over....more copy and pasting necessary..
    then judge linda gardner's brother, rmc jduge william gardner failed to file coughlin's timely notice of appeal of the 6/18/12 conviction of
    trespass in 11 cr 26405...for cr12-1262...then the rmc failed to order the transcript prepared in the walmart candy bar case in 11 cr 22176,
    000012
    which became cr11-2064, rmc holds Pam Longoni out as only one who can get the audio to do the transcript, and Longoni refuses to
    prepare the transcript, even where coughlin offerred to pay for it under protest (because nrs 4.14(a) applies to civil cases, not criminal
    appeals by indigents....(rmc Judge HOward refused Coughlin court appointed counsel, even though he failed to rule that jail time was
    absolutely not a possibility, violation aigersinger...and refused even one continuance, though they are freely given to richard g. hill/reno city
    attorney...or stipped to by lew taitel, coughlin's then rmc court appointed defender who is the "staff attoreny" for Nevada Court Services,
    whom Coughlin as suing at the time...so, no on the conflicts check by Taitel...
    Now Judge Clifton and Judge Sferrazza and RJC Administrator STeve Tuttle (with the help of clerk's Robbin Baker and Cathy Wood) have
    forbidden Coughlin from fax filing, only allow him 15 minutes a day to be at the counter to review a file (no matter how much of that 15
    minutes is eaten up with "delays"...), etc., etc. lots of special unpublished "house rules" applicable only to Coughlin...kind of like the
    impermissible rent escrow deposit judge sferrazza order in 10/13/11 in rev2011-001708 in violation of jcrcp 83 in that the rjc has not
    published and had approved by the n. s. ct. a corollary to jcrlv 44...though Judge Clifton managed to find "moot" Coughlin's Motion to Set
    aside that forced rent escrow deposit in light of the fact that Coughlin did deposit that $2,276 dollars....not exactly moot...kind of like Judge
    Clifton saying "your here!" when Coughlin contested the improper notice by public defender leslie of the 12/18/12 hearing in rcr2012-
    067980 that Judge Clifton curiously presided over despite it being a Judge PEarson case and Judge PEarson being at work that day...the
    whole jcrrt rule about cases being randomly assigned doesn't seem all that hard and fast...like when Jduge Clifton was assigned the
    Coughlin v. Park Terrace illegal lockout case, but rjc bailiff sexton came in and moved Jduge SFerrazza onto the matter minutes before the
    hearing, whereupon Judge Clifton had "traffic matters" to rule on....
    then there is the rmc and judge nash holmes refusing to file in and comply with the dictates of nrs 189.030 in 11 tr 26800 where coughlin
    appealed the contempt order of 2/27/12 and 2/28/12....and the whole business of the rmc and its marshall being given coughlin's smart
    phone and micro sd card after it was book into coughlin's personal property at the jail on 2/27/12, when the rmc marshals came to the jail
    on 2/28/12...and apparently..without a court order or warrant, were allowed to take possession of those items and take them back to the
    rmc....and they were returned to coughlin 37 days later, via a 3/30/12 order by judge nash holmes releasing them to coughlin (curious
    considering coughlin's 3/30/12 filign in Judge Beelsey's case in the nvb cadle company v keller 10--05104 exposed that whole confiscating
    coughlin's property in a manner in no way a search incident to arrest....) and where Judge Beelsey, Judge Nash Holmes, and Washoe Legal
    SErvices Elcano all went to McGeorge School of law in 1977....and all three testified at coughlin's 11/14/12 formal disciplinary hearing before
    the panel and sbn....hhmmmmmn....
    and the recent cr12-1262 appeal of the denial of coughlin's motion for new trial did not include the cd/dvds coughlin attached to his
    10/24/12 filign and his 11/2/12 filing (and the 11/2/12 filign was not included in what the rmc transmitted to the district court on 11/29/12?
    funny..... lots of attached cd/dvds turnin' up missin' or "weren't never there" despite Robbin Baker admitting they were in the rjc in
    rcr2011-063341 and rcr2012-065630 in the jduge sferrazza and judge clifton cases...and in Clifton's 065630 City Attorney Bony's letter about
    the subpoenas in 2011-063341 and the envelope addresssed to judge sferrazza is in the file in Clifton's 065630 case? and Judge Clifton
    admits that, on the record in 065630 he "looked at the submission on subpoenas" in the judge sferrazza cases...funny, Judge SFerrazza said
    there was no cd/dvd's attached to any of Coughlin's pre-trial filings.....and judge sferazza signed the 11/16/12 orders on those "submissions
    on subpoenas"...so why would Judge clifton be lookin at them and why are cd/dvd's disappearing?
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    RMC certifying Second Judicial filings to SBN exhibit 16 from 11/14/12
    000013
    was never provided to coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 12/19/12 2:22 AM
    To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); davidc@nvbar.org
    (davidc@nvbar.org); eifert.nta@att.net (eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com);
    mike@tahoelawyer.com (mike@tahoelawyer.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    skent@skentlaw.com (skent@skentlaw.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
    ncjdinfo@judicial.state.nv.us (ncjdinfo@judicial.state.nv.us); dballard@reno.gov (dballard@reno.gov);
    ballardd@reno.gov (ballardd@reno.gov); jacksonc@reno.gov (jacksonc@reno.gov);
    renodirect@reno.gov (renodirect@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov);
    joey.hastings@washoecourts.us (joey.hastings@washoecourts.us); judge.hardy@washoecourts.us
    (judge.hardy@washoecourts.us); rsweet@nvcourts.nv.gov (rsweet@nvcourts.nv.gov);
    training@nvcourts.nv.gov (training@nvcourts.nv.gov); staffattorney@nvcourts.nv.gov
    (staffattorney@nvcourts.nv.gov)
    Dear Administrative Office of the Courts,
    I apologize for the rushed nature of this, however, the SBN, RMC and RJC have been
    putting me through the paces of late and I never know when they will finish the job on
    me, so I want to send this while I can...
    and Chair Echeverria and or SBN Bar Counsel King have a duty of candor and can't
    sneak it into the file as an "exhibit 16" where Coughlin was not provided a copy at the
    hearing on 11/14/12, especially where the 4 exhibits that were included with that filing
    (exhibit 16 EMERGENCY EX I'ARTE MOTION TO DISMISS. VACATE. reset or
    postpone, etc...)
    check out the exhibit page on page 32 of the attachment....notice how none of the
    exhibits were included in what was given to the clerk and court reporter purporting to
    be a "rule of completeness" sufficient copy of that filing presented as Exhibit 16?
    You guys lied enough already (you gave me permission to file by fax, then didn't file
    in my faxed filings...you waived subpoena and subpoena duces tecum fees, then lied
    and said you didn't sufficient to prevent me from being able to call witness (and you
    know that attached keith loomis, esq. subpoena was problematic for you...no wonder
    Pat King disposed of the grievance against Loomis so quick...and then you lied when
    you said you didn't give me permission to issue my own subpoenas (ie, you said I
    would not be required to have them "issued by the court" or embossed or baring a seal
    or any of that, but that I could issue my own subpoenas "in the manner an attorney
    could" despite my current temporary suspension. You guys are lying
    overtime....how many of the Panel are in on it? Vellis? How about you? Its a
    000014
    nice reputation you have Vellis...would be a shame to see it get all associated with this
    despicable miscarriage of justice. Not sure Mike Johnson wants the Supreme Court
    knowing he was texting on his iPhone the whole hearing, or twittering or whatever,
    because he definately wasn't paying attention or looking professional. And as for
    hiding my cd/dvd's attached as exhibits to filings from the Justices of the Nevada
    Supreme Court, Panel Member Stephen Kent (McGeorge Class of 1980, interesting
    that "Chairman Susich" chose the Panel...sure...Pat....Elcano, Beesley (both of whose
    testimony was not noticed until a couple days before the hearing despite nothing about
    it being newly discovered to bar counsel...and why hasn't the Beesley letter ever been
    produced to Coughlin? And Elcano is not a "practicing attorney"...check his SCR 79
    page on www.nvbar.org....inactive status, has been for quite some time...that's why
    "wouldn't he be awfully rusty" comments were made when his name was floated for
    the ECR deal...
    Also, look at the certification by Donna Ballard. She is not authorized to make
    certifications for documents from the Second Judicial District Court. Look closely at
    the language on her certifcations. Her court does not maintain the "originals" in
    cv11-03628, nor in cr11-2064, nor in cr12-1262. That is fraud by both she and Bar
    Counsel King for purporting those documents to be certified. Further, its fraudulent
    for King to (or have Richard G. Hill, Esq. do it) read a quote from a passage of Richard
    G. Hill, Esq.'s associate, Casey Baker, Esq.'s Motion for Attorney's fees and purport it
    to be something ordered by Judge Flanagan. Just because Judge Flanagan quotes to
    something in one of his Order's does not mean he endorses is as a conclusion of law or
    finding of fact or even a part of his Order. He has quoted to things I wrote before.
    He commented on something I wrote being "poignant" in dismissing on 3/27/12
    Hill's Second Motion for Order To Show Cause once Coughlin destroyed Hill's witness,
    contractor Phil Stewart on cross examination at both the 3/23/12 hearing (closely
    following by bar counsel ill advised and cryptic email about "the clerk of court in
    Department 3" writing the SBN about Coughlin's clothing choice or some high school
    gibberish or other. I demand the RMC and Ballard immediately retract those
    "certifications".
    Please consider this as my resume for the staff attorney position with the
    Administrative Office of the Courts and review my filings with the Nevada Supreme
    Court.
    Not sure its appropriate or Panel Chair Echeverria to be sticking his tongue out at me
    000015
    throughout the hearing and grinning demonically like some "Boss Hog"...Also, kind of
    funny to apply the Court's scr 111(7) citation in its 6/7/12 Order about the "sole purpose
    of determining the punishment' to the hearing...but not just to the walmart candy bar
    petty larceny conviction, but instead, to a multitude of RPC violations the SBN and or
    RMC Judge Nash Holmes copied and pasted into an Order. Chair Echeverria
    admitted during the "hearing" on 11/14/12 that he and the Panel and SBN were just
    skippin' past the whole being accused of something and having a trial on it and going
    straight to the sentencing phase...despite none of the RPC violations being "proven"
    (and Judge Nash Holmes, testifying by telephone over Coughlin's objection, was sure
    to point out she "wasn't trying to usurp the function of a formal hearing panel" in her
    3/12/12 Order, upon which Bar Counsel is trying awful hard to tack on an SCR 111(5)
    "conviction is conclusive proof of guilt" easy day at work....but SCR 111 is for
    "criminal convictions", Pat King...next time you feed Judges proposed findings and
    criminal law violation orders, get the statue right, Pat. That Order from a "simple
    traffic citation matter", from which Judge Nash Holmes threw in the Schaefer "clear
    and convicing evidence" standard bar counsel prompted her to insert, in her attempt to
    transmogrify the 3/12/12 resumption of the traffic citation trial in rmc 11 tr 26800 into
    not only a second bit at the apple considering she already issued an order on 2/28/12
    (which was attached to the filing in Judge Beesley's NVB court in the adversary
    proceeding 10-05104 Cadle Company v Keller...which had to alarm Judge Beesley to
    see his 1977 classmate at McGeorge, Judge Nash Holmes and Washoe Legal Services
    Paul Elcano having such trouble with Coughlin (not to mention Judge Beesley's former
    partner at Beesley Peck, Karen Sabo, Esq. was being sued by Coughlin incident to her
    actions at WLS set forth in the wrongful termination lawsuit on appeal with the Court
    in 60302...maybe if Bar Counsel had managed to notice Coughlin on Judge Beesley's
    testimony more than 2 day prior to the hearing, and not in violation of SCR 105(2)(c),
    some of this mess could have been avoided...But another thing is clear...there was no
    "misdemeanor of criminal contempt convictions of Coughlin...ever....that would require
    a citation to NRS 199.340...which is not summary in nature anyways....NRS 22.030
    (Judge Howard cited to the right statute at least), and NRS 22.010 (the one Judge Nash
    Holmes attempted to characterize as a "misdemeanor of criminal contempt" along with
    NRS 22.100, in justifying her summary 5 day incarceration of a pro se attorney in a
    traffic citation trial seconds after he testified that RPD Sargent Tarter "lied when he
    said that..."...and boom....contempt citation, 5 days in jail, no stay...prejudice to
    Coughlin's client's be damned...and the SBN and Judge Nash Holmes are goign to try
    to make hay out of an in forma pauperis application indicating Coughlin employed as a
    "jack of all trades" filed after a trial in 11 tr 26800 wherein Coughlin's being an
    000016
    attorney was discussed extensively? And Bar Counsel wants to object to Coughlin
    entering into evidence or using for impeachment both the audio transcript the RMC
    sold him and the disc of the same hearing the RMC purportedly gave to Bar Counsel,
    then Bar Counsel gave to the Screening Panel, then gave to Coughlin? Yet Donna
    Ballard gets to certify Orders by Judge Flanagan and Judge Elliot (who worked at Chair
    Echeverria's father's law firm, and who went to Stanford from Reno along with Chair
    Echeverria and Washoe Legal Services's Paul Elcano in the later 1960's together....and
    Echeverria and Elcano went to Reno High School together in 1962, and were forced to
    admit they were "boyhood chums"....no mention of the wine business though at the
    hearing or the Basque Board, or the Orlich and Gardner connection with Elcano and
    Coughlin's contention that Elcano admitted to Coughlin in February 2009 that Judge
    Linda Gardner had approved of Coughlin's work at that time after Elcano querried her
    and Elcano citing having done Judge Gardner "a big favor a long time ago" as a basis
    for establishing his strong rapport with Judge Gardner, and, apparently, her veracity or
    something or other.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 2 files to share with you on SkyDrive. To view them, click the links below.
    0204 Coughlin Disciplinary Hearing File cut up with notations revised.pdf.pdf
    12 10 12 065630 final motion recuse conflict continuance with exhibits and cover pages.pdf
    Download all

    protection order against WCPD Jim Leslie, Esq.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 12/18/12 2:08 PM
    To: jleslie@washoecounty.us (jleslie@washoecounty.us); jbosler@washoecounty.us
    (jbosler@washoecounty.us); patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org
    (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com);
    000017
    fflaherty@dlpfd.com (fflaherty@dlpfd.com); zyoung@da.washoecounty.us
    (zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
    stuttle@washoecounty.us (stuttle@washoecounty.us); ncjdinfo@judicial.state.nv.us
    (ncjdinfo@judicial.state.nv.us); mike@tahoelawyer.com (mike@tahoelawyer.com); skent@skentlaw.com
    (skent@skentlaw.com); joey.hastings@washoecourts.us (joey.hastings@washoecourts.us)
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    12 18 12 rjc tpo application against wcpd jim leslie.pdf

    Jim Leslie is a scrappy dude RE: Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 12/14/12 1:24 AM
    To: Leslie, Jim (jleslie@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
    fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
    (fflaherty@dyerlawrence.com); davidc@nvbar.org (davidc@nvbar.org); mpickesq@msn.com
    (mpickesq@msn.com)
    Dear Jim Leslie, Esq.,
    Jim, I need to get my discovery for the resumption of the trial in rjc rcr2012-
    065630...Despite your cries of "wasting county assets" at 9:05am on 11/20/12 when, in
    your standby counsel role, you attempted to assist DDA Young and Judge Sferrazza in
    further coercing from me my Fifth Amendment rights...you seem intent on wasting
    county assets, as your failure to turn over the discovery (the cd recordings of 911 calls
    DDA Young alleges he produced to my WCPD on 8/13/12 and 8/17/12 has not
    materially prejudiced my defense in rcr2012-065630, in much the same way your
    failure to timely transmit my file in rcr2011-063341 did, including your failure to
    produce the results and response and production in connection with the subpoena of
    10/3/12, and given you were note removed as counsel of record until at the earliest
    10/22/12...Kelley Dodma, ECOMM, and you have some 'splainin' to do.
    000018
    Now you allege that you filed a false police report. Jim, please keep a copy of any
    communications you have made to the RPD, and of course the call you reference will
    be subpoenaed, and if there exists any recordings (video/audio, whatever) of the
    "incidents" you describe (not sure dropping of a written request for one's file/discovery
    to your receptionist given the fact that time is of the essence here is "distrubing the
    peace", but, to each his one, I guess...however, its curious you never seem to place any
    restrictions on your continuing to cash your sweet paychecks week after week,
    Jim...now you seem to be seeking some sort of protection against being served written
    notices or having them delivered, or making my ability to do some contingent upon
    your scheduling a meeting (any such meeting would likely terminate after five minutes,
    as they have in the past, with you pulling your Diana Ross-diva act....DDA Young got a
    good knowing laugh out of that one on 12/11/12.....). Jim, please do me a favor and
    reply to this email, copying the SBN and President of the State Bar and describe just
    exactly what occurred during these recent "past several occasions"...and put it in an
    affidavit...also, will you finally put in an affidavit your contentions that you "know"
    your office sent me notice in writing of the 8/6/12 combo-hearing date in 065630 and
    067980 (please also put in writing your refusal to send out subpoenas (easy under nrs
    174.345) to ECOMM for any calls to 911 or dispatch related to me in any way since
    8/20/12) and any dispatch to law enforcements recordings, and recordings made by law
    enforcement or submitted to law enforcement by private parties, since that date as well.
    Please further indicate in writing why you are refusing to send the WCSO a subpoena
    duces tecum for any materials related to me in any way from their civil division (that
    served process of the items detailed in the variosu affidavits of services by Machen et al
    that have become of issue in 11 tr 26800, 067980, etc., etc., subpoena Northwinds
    Lou Cadia and Duane Jakob...)....See, Jim, you are still getting paid, you need to do
    some work here, guy...
    So cute how Biray Dogan, in the 8/21/12 Hearing in 065630 mentioned how he "left a
    voice mail" for Linda Gray, but just couldn't, gosh darn it, get an answer from her about
    whether she did send out written notice of the 8/6/12 combo hearing...(you know, the
    one you testified about during our closed Mardsen-lite conflict hearing in
    063341...where you alleged you "knew" for sure that notice was sent, but then refused
    to provide any specifics as to how you 'knew" or what you did to make sure of that..."
    Gray admitted to Coughlin on the phone that she did not mail out any written notice
    of the 8/6/12 hearing to Coughlin because your office had marked his "PO BOX 3961"
    address as "no longer good" at that time (and the audio of the 7/16/12 aborted Trial date
    000019
    clearlye establishes Coughlin was not provided the 8/6/12 date at that time, because the
    temporary replacement for the suddenly disappeared WCPD Goodnight, and DDA
    Young were directed to meet in the hall/counter after the conclusion of the proceeding
    on 7/16/12 and pick a date and time, by which time Coughlin was taken back into
    custody (where he was serving 18 days in jail due to the fraudulent bail increase in rmc
    12 cr1240 (another bogus "disturbing the peace charge" by the RPD...that even the City
    of Reno prosecutors had to drop (and we all know how adverse they are to dropping
    any charges, ever). Jim, why don't you just go wash the RPD's cars or something if
    you want to suck up to them so bad?
    Please then explain to those listed above why your cross examination of Cory Goble on
    8/29/12 in 063341 seemed to consist solely of an attempt on your part to defeat the NRS
    171.136 problem the State faced, including the exclusionary rule application, where the
    testimony as to the value of the phone by the "victim" Goble was "about $80"
    valuation...well under the $250 needed at the time to support a "oooh, thats a felony"
    grand larceny charge (to quote Officer Duralde), and therein vitiate the legitimacy of
    any such arrest or search incident thereto (unless a citizen's arrest could be
    established....which is what you spent your entire cross of Goble trying to establish, for
    the State's benefit...because you are a sleazy, spiteful, lazy, mean spirited, petty, hateful
    individual whom the DA wants on the case anytime it really, really needs a win. Just
    because you have ascended to Chief Deputy status doesn't mean you are any good at
    what you do, Jim, nor does it, in my opinion, provide some sheen of integrity to your
    act).
    NRS 171.136 When arrest may be made.
    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
    (1) There is a warrant of arrest against the person; and
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or
    arrest the person for another alleged violation or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense
    is committed;
    (e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and the arrest is made in the
    manner provided in NRS 171.137;
    (f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued
    pursuant to NRS 33.017 to 33.100, inclusive;
    000020
    (g) When the person is already in custody as a result of another lawful arrest; or
    (h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
    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
    Subject: Coughlin
    Date: Thu, 13 Dec 2012 00:22:01 +0000
    Mr. 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.
    Chief Deputy Public Defender
    Washoe County Public Defenders Office
    350 South Center Street
    Fifth Floor
    Reno, NV 89509
    000021
    1-800-762-8031
    Direct Dial: 775-337-4828
    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.


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    lawap@nvbar.org (Iawap@ber.org, phIIp@bm.org (phIIp@ber.org,c bar.org)
    (mbm.org,mamrq@dlpfd.com(ahcqpfd.com,mMdycrlawrc)cc.com)
    (mUcrq@dycrIawrcc.com,t)u)Ich@mdcu.org (bIcbvdcu.org, cbmby@dcu.org)
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    000039
    ore oI the Iormal grievance against Skau, Young, Leslie, and Dogan RE: Iormal written grievance
    against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing Irom what was produced by City
    Attorney Skau
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Tue 12/04/12 3:08 PM
    To: complaintsnvbar.org (complaintsnvbar.org); patrickknvbar.org (patrickknvbar.org);
    davidcnvbar.org (davidcnvbar.org); jeeloreno.com (jeeloreno.com); skentskentlaw.com
    (skentskentlaw.com); cvellisbhIs.com (cvellisbhIs.com); miketahoelawyer.com
    (miketahoelawyer.com); eiIert.ntaatt.net (eiIert.ntaatt.net); nevtelassnsbcglobal.net
    (nevtelassnsbcglobal.net); rosecnvbar.org (rosecnvbar.org); laurapnvbar.org
    (laurapnvbar.org); philpnvbar.org (philpnvbar.org); glennmnvbar.org (glennmnvbar.org);
    IIlahertydlpId.com (IIlahertydlpId.com); IIlahertydyerlawrence.com
    (IIlahertydyerlawrence.com); tsusichnvdetr.org (tsusichnvdetr.org); schornsbynvdetr.org
    (schornsbynvdetr.org)
    Dear OIIice oI Bar Counsel, NNDB, Panel, and President Flaherty,
    Please Iorward this email on to John Echeverria, Patrick King and David Clark and the NNDB
    Chairman Susich, SBN President Flaherty, and NNDB Chairman Susich in case they don't get the
    transmission sent here.
    The video and audio and other materials supporting this greivance are available here:
    http://sdrv.ms/YwYabQ
    Please add City Attorney John Kadlic to the grievance as at some point he needs to take responsibility
    Ior all the dirty deeds done not so cheap by his cadre oI malevolent, corrupt, deputy city attorneys.
    Clerk oI Court Peters has been reIusing to allow me to have a Iile stamp copy oI my Iilings, save an
    introductory Iew instances...please Order her to do so.
    While I was never sent the 10/9/12 AIIidavit oI Laura Peters that the SBN and Peters slipped into the
    Formal Disciplinary File, incongruously, inserted, bate stamped, aIter the 10/30/12 Order by Chairman
    Susich (strange...how could it be Iile stamped October 10th, 2012, yet be Iiled aIter Chairman Susich's
    10/30/12 Order? Eventually that AIIidavit was provided to me on 11/8/12 (6 days beIore the Iormal
    disciplinary hearing, buried within 3,000 or more pages oI documents (so instead oI the 27 days to
    review them called Ior by SCR 105(2)(c), I was aIIored only, roughly 3 (depending on how you count
    the "within 3 days prior" in consdiering SCR 105(4) and NRCP 6(a),(e)...
    It is deIinately not my understanding that any Cease and Desist Order by Chair Echeverria or "stay
    away" letter by Patrick King means I can no longer Iile documents in this matter, or that any Iailure by
    Clerk oI Court Peters to provide me a Iile stamped copy oI my Iilings means they are not Iiled or that
    the SBN is Iailing to abide by its express declaration and agreements and pronouncements oI the
    procedural policies and rules applicable to this matter wherein King, Peters, the SBN/Panel/Board have
    Iailed to provide me any written adopted procedural rules, have made numerous declarations and
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    express indications oI speciIic policies and rules attendant to my utilizing subpoenas (which King
    Iraudulently mislead the Panel as to in his Motions to Quash and in his argument during the 11/14/12
    Hearing...noticeably absent is an AIIidavit Irom King regarding what he communicated to Coughlin
    respecting David Clark's ruling on Coughlin's use oI subpoenas and the procedural mechanics attendant
    thereto, or, even more noticeable, is an mention by Laura Peters in her 10/9/12 AIIidavit respecting the
    permission to Iax Iile granted to Coughlin in this matter.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlinhotmail.com
    Zach has a Iile to share with you on SkyDrive. To view it, click the link below.
    110812coughlin 063341 Reno City Attorney Skaur at 25 minute mark violates duty oI candor to
    tribunal and Iairness to opposing counsel considering 11 9 12 email by Skau.wmv
    From: zachcoughlinhotmail.com
    To: homerjreno.gov; skaucreno.gov; zyoungda.washoecounty.us; complaintsnvbar.org;
    patrickknvbar.org; davidcnvbar.org; jeeloreno.com; skentskentlaw.com; cvellisbhIs.com;
    miketahoelawyer.com; eiIert.ntaatt.net; nevtelassnsbcglobal.net; rosecnvbar.org;
    laurapnvbar.org; philpnvbar.org; glennmnvbar.org; IIlahertydlpId.com;
    IIlahertydyerlawrence.com; tsusichnvdetr.org; schornsbynvdetr.org; bdoganwashoecounty.us;
    jlesliewashoecounty.us
    Subject: Iormal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing Irom
    what was produced by City Attorney Skau
    Date: Tue, 4 Dec 2012 14:07:52 -0800
    Dear OIIice oI Bar Counsel,
    This is a Iormal grievance against City Attorney Skau, Public DeIender Jim Leslie and Biray Dogan,
    and DDA Zach Young.
    A portion oI a recent email Irom City Attorney Skau reads:
    "Fwd: FW: Case No. RCR2011-063341
    From: Creighton C. Skau (skaucreno.gov)
    Sent: Fri 11/09/12 11:45 AM
    To: zachcoughlinhotmail.com
    Cc: Jeannie Homer (HomerJreno.gov)
    1 attachment
    photo|1|.JPG (181.2 KB)
    Dear Mr. Coughlin,
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    Please be advised that Judge SIeraza authorized service upon you by email in an Order.
    Accordingly, authorized service has already been eIIected.
    Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
    alternatives:
    1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
    UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
    purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
    you to obtain the documents, as set Iorth hereaIter.
    2. The Court provided us with an address which you provided to the Court. That address is 1471
    E. 9th St.,
    Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
    but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
    you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
    the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
    leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
    3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
    pick up at our OIIice, third Iloor oI City Hall.
    Please be advised that Judge SIeraza authorized service upon you by email in an Order.
    Accordingly, authorized service has already been eIIected.
    Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
    alternatives:
    1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
    UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
    purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
    you to obtain the documents, as set Iorth hereaIter.
    2. The Court provided us with an address which you provided to the Court. That address is 1471
    E. 9th St.,
    Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
    but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
    you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
    the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
    leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
    3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
    pick up at our OIIice, third Iloor oI City Hall...."
    But, a listen to around the 9:25 am mark on the audio transcript Iorm the RJC Javs recording oI the
    11/8/12 hearing in rcr2011-063341 reveals Mr. Skau Iraudulently procurred Couglin's attendance at the
    11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented Irom
    eIIecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only
    Coughlin's Iormal disciplinary hearing but also the petty larceny trial oI 11/19 and 11/20 and is a
    straight scum bag move by Creig Skau.
    Judge SIerrazza granted Coughlin a waiver oI witness Iees Ior subpoenas and subpoena duces tecums
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    at the 48 minute mark oI the second wmv Iile Irom the JAVS audio transwcript oI the 10/22/12
    Hearing in RCR2012-063341.
    Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a
    JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he Iails to inIorm the court oI
    the waiver oI service signed by an individual who indicated she had authority to do so, Gricela Alvarez
    (whom, somehow, Judge SIerrazza was apparently aware oI and had opinions on....curiously).
    Speaking oI scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs
    recording 112012coughlin1 Ior rcr2011-063341 (really, everything Jim Leslie did in this case or any
    other in "representing" Coughlin is hall oI Iame sleazy) "I can jump in as stand by counsel iI you Ieels
    he is dragging his Ieet, your honor...He's wasting county assets."...Really, Jim, this is a grievance
    against you Ior seeking to coerce a waiver oI Coughlin's IiIth amendment rights incident to your reIusal
    to utilize any oI the exculpatory media Coughlin provided you at either the Supression Hearing or the
    Trial..and a greivance against DDA Young Ior similarly coercing a waiver oI Coughlin's FiIth
    Amendment rights (you really need to listent to the last Iile Ior 11/19 and the Iirst Ior 11/20 to get an
    idea oI the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC
    BailiIIs asked iI they could keep Coughlin's laptops over night...but there is some really bad audio on
    there with Judge SIerrazza and DDA Young getting completely coercive with respect to a waiver oI
    Coughlin's FiIth Amendment rights and "you can't put on anything else or any evidence, YOU NEED
    TO TESTIFY!" and Young "you Honor, it was my understanding that you let mr. Coughlin out oI
    custody on the condition that he testiIy! II he won't do it TAKE HIM BACK INTO CUSTODY!"
    add to the grievance against young the Iraudulent testimony and argument he put on where he knows or
    should have know that the rpd duralde did not receive any reports Irom dispatch oI "a possible Iight"
    where Duralde had leIt his vehicle and the text screen therein prior to the 11:27:11 pm text Irom
    dispatch, and thereIore, such allegations oI a report Irom dispatch oI "a possible Iight" did not bare on
    Duralde's probable cause/reasonable suspicion analysis. Iurther young put on perured testimony by
    Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when Young was
    provide a video wherein Zarate admits he only inIerred that. Oh, and Coughlin hereby swears he never
    received any such 11/7/12 motion, Iaxed or otherwise Irom Dogan or his assitant Tibbals or anyone
    with the WCPD.
    And then there is Jim Leslie Iailing to make a hearsay objection when DDA Young asks OIIicer
    Duralde what some unnamed bystanders told him upon arriving...yet, every bit oI video evidence and
    or testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to
    hearing "the man with the six pack" threaten to throw the iPhone "in the river iI someone doesn't claim
    it right now" was continually excluded as "hearsay"....
    A recent email to Judge SIerrazza and DDA Young (which Judge SIerrazza ordered Coughlin to send
    him):
    Dear Judge SIerrazza and DDA Young,
    This correspondence is Iurther in line with Judge SIerrazza's previous instruction to me to send him
    emails aIter the trial directed to my issues with Mr. Leslie's representation (I am too tired to Iully set
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    those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
    this just because it seems like the right thing to do).
    SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
    by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
    himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
    receiving, | 484 P.2d 565 | but not oI both
    Perhaps one oI my biggest complaints about the ineIIective assistance oI counsel by Mr. Leslie (and to
    a much, much lesser extent that oI Mr. Goodnight) relates to Leslie's Iailure to utilize any oI the work I
    did to prep this case. For instance, Leslie whiIIed (perhaps intentionally so) on the extent to which
    RPD OIIicer Duralde and Rosa could not have received the dispatch text oI 11:27:11 pm reporting
    Goble's since proven Iraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so,
    OIIicer Duralde and DDA Young are stuck with anything the OIIicer could "hear" on the Dispatch
    recordings (and those provided by City Attorney Skau provide a basis Ior mistrial where the cd lacks
    Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid oI anything Ior the 6
    minutes in which the detaining and arrest occurs (and Iurther, DDA Young and the State were served a
    request Ior discovery by Goodnight in November and subpoena which required production oI those
    "dispatch logs or recordings...." Yet DDA Iailed to. Then he put on testimon and made argument that
    this "report Irom dispatch oI a possible Iight" was the main justiIication Ior the pat down and search
    incident to arrest and led to a justiIication Ior not excluding anything "discerned incident to the pat
    down"...the only problem is is that Duralde and Rosa already are marked as on the scene by 11:26:00
    pm, and thereIore could not have read the text screens in their vehicles to recieved the text only
    11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to which
    Coughlin's 911 call is not reported accurately at all Iurther underscores the unIairness oI depriving
    Coughlin the right to cross examine Duralde and the dispatchers.
    A review oI the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to
    Judge SIerrazza ordering him to produce in response to my subpoena duces tecum to Kelley Odom and
    ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two oI the 911
    calls are missing. There is no audio oI any RPD-ECOMM/Dispatch communications between the
    11:28:17 pm mark and the 11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm
    did not know I was Iilming/recording the arrest. Had I not captured a recording oI the arrest, how little
    would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many
    things revealed by the arrest recording contradict what OIIicer Duralde put in his Supplemental
    Declaration and Narrative and the two witness statements? Further, where Zarate does not allege to
    have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on
    8/29/12 does testiIy to seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw
    it light up Irom all the way across the skate park...but wait...come November 19th, 2012 he changes his
    story and decides he saw it light up Irom "2 to 3 Ieet away Irom Coughlin"....There a movie Iloating
    around somewhere out there that does a timeline oI all these calls, all these videos, superimposes the
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    dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
    And one problem Ior DDA Young and Duralde is Iound in the State's 2/21/12 Opposition, on page 5,
    wherein Young writes: "In the instant case, the pat-down search oI the DeIendant was proper under the
    totality oI the circumstances. Prior to arriving, OIIicer Duralde learned that the scene involved a loud
    disturbance with possible Iight, thereby immediately raising the concern oI weapons and the saIety oI
    all those present." And, oI course, OIIicer Duralde responded splendidly to Coach Young's, er, DDA
    Young's training regime and sang the "possible Iight...report Irom dispatch oI a possible Iight" tune all
    the live long day...which was the basis Ior the reasonable suspicion Ior the pat-down (and Judge
    SIerrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less
    obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the
    Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson
    admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on
    video and audio recordings into the record...despite Duralde testiIying to a multitude oI double hearsay
    (and not even capture on a recording so close in time to the arrest and at the very same location,
    involving the majority oI the players in the arrest itselI...).
    It was in the same 11/30/11 email Irom WCPD Goodnight to Coughlin that included the Narrative by
    OIIicer Duralde (which has, in the Iooter oI the 4 page document, a Iooter indicating a "printed on"
    date oI 11/28/11
    Zarate's testimony respecting the scant statements he actually made to OIIicer Duralde reveal the extent
    to which OIIicer Duralde paints on to witness statement more speciIic, particularized Iacts in support oI
    the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" oI "busting" and
    attorney whom dared to answer one oI the oIIicer's questions by asking a question seeking clariIication
    as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a Iinding oI
    either "reasonable suspicion" to conduct a "weapons check pat down" (the OIIicer's did not receive the
    text Irom dispatch reporting Goble's second 911 call wherein he Iraudulently alleged that "someone just
    socked a minor" (reIerring to the instance where then 18 year old Austin Lichty (who is captured on the
    video oI the moments(Iile named: VID20110820232423 austin lichty templeton goble zarate chan
    rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in length) lying in
    asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition
    to Goodnights 2/14/12 Motion to Suppress, both Goble, Lichty, and Zarate all have motivations
    apparent which preclude them Irom being deemed "reliable citizen witnesses" and OIIicer Duralde
    indeed did have, and admitted to in his testimony at trial to being aware oI, the "gross inconsistencies"
    Goodnight pointed out between the hearsay and double hearsay Duralde testiIied to at trial aIter
    "reIreshing his recollection" upon a review oI either his "Supplemental Declaration" (an attachment to
    the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
    question....how was it not misconduct by the State and prejudicial to the point oI declaring a mistrial or
    at least not, as Judge Pearson did in a curious recorded hearing on
    But here is the biggest problem Ior the RPD and the State...the screen lock that Goble and Templeton
    testiIied to (the password Ior the phone)...and when Goble alleges Duralde gave him back the
    phone...and the call into the iPhone at 11:33 pm Irom OIIicer Duralde's phone...and the call Irom the
    iPhone b
    Perhaps the worst thing Ior the State and the RPD here is that two hostile witnesses (in addition to
    Coughlin's various statements related thereto, during his testimony and on the media admitted into
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    evidence) testiIied that RPD OIIicer Duralde committed misconduct by lying about the purported order
    or point in time in relation to the arrest and search oI Coughlin and Duralde's Iirst coming into
    possession oI the iPhone. Goble testiIied that Duralde removed the phone Irom Coughlin's pocket and
    that Duralde had the phone with him when he Iirst presented to Goble to ask question related to the
    phone and to veriIy ownership oI the phone (which would include gathering the phone number Ior the
    iPhone, which necessarily would mean that Duralde's allegation oI only searching Coughlin aIter
    perIorming some call to the iPhone and hearsaying it vibrate (even though multiple witness
    (Templeton, Zarate, Goble, Lichty testiIied that they heard no such buzzing or vibrating oI the phone,
    hostile witnesses all) Goble testiIied that Duralde already had the iPhone prior to Goble conIerring
    with Duralde or otherwise giving Duralde any phone number to call in an attempt to veriIy the phone
    revealing an incoming call LED display scree light up alert (Goble's statements that the phone would
    "light up" and that he, as Duralde quotes him in the Narrative, "could not hear the phone
    I have 30 days Irom the date oI conviction to report a conviction to the State Bar oI Nevada and the
    United States Patent and Trademark OIIice (USPTO) Ior these two convictions "possessing or
    receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
    I note that WCPD Jim Leslie, while still attorney oI record Ior me on this cases RCR2011-063341, had
    served (see attached) a subpoena on ECOMM and Kelley Odom on 10/03/12. Given that Mr. Leslie
    was not relieved as my counsel until at the earliest 10/22/12 (so Judge SIerrazza's contention that
    Coughlin "has had Iorever to get his deIense ready in this case" and that "no continuance will be
    granted on account oI the Iormal disciplinary hearing beIore the State Bar oI Nevada" being scheduled
    just 5 days prior to the 11/19/12 resumption oI trial in rcr2011-063341 (and despite Judge SIerrazza
    indicated some canon preventing him Irom testiIying at the Iormal disciplinary proceeding...that didn't
    stop 063341 being speciIically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin,
    as was Judge CliIton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
    Townsend Irom sending into the SBN Coughlin's 2/12/12 Iiling in that Judge CliIton case rcr2012-
    065630 and oIIering to send into the SBN Coughlin's 2/15/12 Iiling in 063341). Add to that the Iact
    that Coughlin never received Irom Leslie Goble's call records until Leslie Iinally released them o
    October 30th, 2012...and it really is not accurate to say Coughlin had "Iorever" to prepare his case.
    Coughlin had to pull together a deIense in his Iormal disciplinary hearing beIore the SBN despite the
    SBN gipping him out oI every aspect oI SCR 105(2)(c) (ie, not 30 days notice oI the hearing on
    11/14/12 aIter service oI the Complaint and Designation oI Witnesses and Summary oI Evidence is
    aIIected pursuant to SCR 109 and SCR 105(4)...But the point is, iI the RJC and both oI you want to be
    associate with a SchaeIIer style Mirch-ing, then this may be your chance. But you won't be able to say
    you didn't have plenty oI opportunities to put this thing aside, because there are a multitude.
    It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena
    duces tecum....Mr. Leslie's Iailure to turn over anything to me in the "hand oII transmittal" he insisted
    upon (despite a digital transmission being required per the Order oI Judge SIerrazza, I believe) requires
    some explanation.
    So to requiring explanation is the Iact that the cd provided by Reno City Attorney Skau in an apparent
    good Iaith attempt to comply with Judge SIerrazza ordering him to comply with the subpoena duces
    tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it oI
    8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin
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    Lichty's cellular phone, 775 233 8593, which Goble is seen in the attached still Irame picture culled
    Irom a video Coughlin took oI the moments prior to the arrival oI the RPD, being handed by the "man
    with the gauged ears" Lichty reIerred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton
    testiIying that they do not know that man and did not know him prior to that night at all....Coughlin
    respectIully demanded oI the RPD OIIicers, at the time oI his arrest, that they gather the identiIy oI the
    "man with the gauged ears", however, OIIicer Duralde et al reIused to (claiming Coughlin's allegations
    oI their having attacked him and attempting to steal his bike and or dog, reach into his pockets, and
    push him up against oncoming traIIic on the Center Street bridge were "unsubstantiated"). Oddly, in the
    attached still Irame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin
    Lichty that Goble utilized to make his two 911 calls that evening, the Iirst (iI the Iile name time
    stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
    ECOMM text logs reveal an E911 entry oI 11:23:36 pm (its unknown whether the exact time a 911 call
    comes in is designated on the "Calls Ior Service Inquiry Response" Coughlin was provided recently).
    The EComm text logs reveals a second E911 entry Ior the 775 233 8593 number (belonging to Austin
    Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law
    license away Irom me Ior at least 5 years, iI not Iorever....and DDA Young...over some alleged "skater
    sets his iPhone down on the concrete in the middle oI the ice rink plaza downtown on 8/20/11 at 11:20
    pm ish in Reno, "man with a six pack oI beer" picks it up, oIIers it up, receiving no response threatens
    to "throw it in the river iI someone doesn't claim it immediately" whereupon Goble's Iriend Nate Zarate
    apparently (according to RPD Duralde's Narrative oI unknown origin date") told Goble he saw
    Coughlin pick it up oII the ground (as Duralde recounts hearing Irom Goble in his Narrative)
    contain the 911 call by Coughlin
    So, in the Iile named "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11
    PM SourceID 17 063341 duralde i'll be out on him" one can hear OIIicer Duralde indicating he will
    "be out on him on the Center Street bridge" aIter he has leIt his squad care and is shortly to appear in
    the video Coughlin Iilmed oI the arrest, title:
    Then, OIIicer Rosa is proven to be on the bridge and not in his squad car reading texts Irom dispatch n
    the Iollowing time stamped Iile: "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20,
    2011 11-26-30 PM SourceID 12 RPD Rosa saying charles 396 on the other end"
    Further, OIIicer Duralde's arrival on the scene is notated in the dispatch log at the
    Its not at all clear why Goodnight only apparently received then Iorwarded to his client on November
    30th, 2011 the "Original Supplemental" containing OIIicer Duralde's Narrative, that is still oI
    indeterminate date oI origin (there are a number oI "date oI printing" variations...).
    That I know oI, there were three 911 calls (two by Goble, one by Coughlin, in that order):
    1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc oI phone susps os leIt on
    post lighting up in sups pock RP screaming at susp
    2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone
    just socked a minor, waive that cop down 10 10 with open line
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    3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call Irom phone with open
    line yelling re stealing phone people cheering cops are here then call disconnects
    And Coughlin Iilmed three videos that night oI the arrest that are relevant, two just prior to the RPD
    arriving (and actually, while Rosa and Duralde were already on the scene and out oI their vehicles aIter
    teh 11:26:00 pm mark as indicated by the Ecomm recordings and dispatch logs...
    1. VID20110820232413 your all on tape now goble and Iriends.3gp 8 seconds long
    2. VID20110820232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery
    Coughlin jusrt prior to RPD rcr.3gp 46 seconds
    3. VID20110820232801 oIIicer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
    And the AT&T call records Ior the iPhone reveal only Iour calls occurred in or out during the relevant
    time Irame:
    Goble's AT&T records:
    44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
    45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
    46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
    47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
    Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..."
    Previous to that, DDA Young had successIully kept every single witness Irom speciIically identiIying
    who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'.
    But, Goble is a selI involved twit, who snaps his Iingers "Oh, that's Colton" 8 Ieet Irom Judge SIerrazza
    and swaggers out oI the court room. And Leslie reIused to seek admission oI the misconduct oI a
    prosecution witness....Goble, batterying Coughlin with a lit cigarette, that Coughlin capture on tape, on
    June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on
    6/7/12...and had his law license suspended in 60838 Iour hours later by a 3 Justice Panel (including
    Justice Hardesty, whom recused himselI Irom Coughlin's wrongIul termination suit against Washoe
    Legal Services...and you might not like me Ior that suit, but iI you look at the circumstances oI my
    Iiring therein (I was hurrying to Iinish a non-proIit gets stuck with the building's private landlord's
    property taxes appeal due on 3/10/12 Ior Paul Elcano, and had a Trial beIore Judge Linda Gardner in a
    divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty oI research
    beIorehand...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
    Iigure that out...WLS took 6 weeks to cut a check Ior subpoena Iees....the usual)...
    Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence
    exclusively hearsay testimony (oIten unattributed to anyone in particular) to support his win on the
    "suIIicient probable cause to support a search incident to arrest" despite NRS 171.136 Iorbidding such
    an arrest (where Duralde obviously overcharged the alleged crime as a "Ielony grand larceny"...even
    making smug commentary about the "certain beneIits oI charging this as a Ielony" and saying "oooh,
    that's a Ielony", both matters that Leslie insisted reIraining Irom getting into while he was attorney oI
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    record, and Iurther, despite Coughlin complying with NRS 174.345 (even splurging on the return
    receipt requested to go along with the certiIied mail Ior Duralde) Coughlin was denied the right to cross
    examine the arresting oIIicer...which is too bad considering his Narrative alternately claims that Goble
    told him they
    DDA Young's complaint Iails to alleged someone other than Coughlin stole the property, which it must,
    to support the receiving or possessing stolen property charge.
    COUNT II. POSSESSION OF STOLEN PROPERTY, a violation oI NRS 205.275, a misdemeanor, in
    the manner Iollowing, to wit:
    That the said deIendant on or about the 20th day oI August, 2011, at Reno Township, within the County
    oI Washoe, State oI Nevada, did willIully and unlawIully possess or withhold stolen goods having a
    value less than Two Hundred FiIty Dollars ($250.00), to wit: an iPhone, at or near 1 North Center
    Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, Ior his own gain
    or to prevent the true owner Irom again possessing said property, knowing that the property was
    obtained by means oI larceny or under such circumstances as should have caused a reasonable man to
    know that such goods were so obtained.
    POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that
    the property was stolen by another. "
    It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574.
    Must allege the good were received Irom someone other than the deIendant: Gaddis, 424 U.S. 544,
    Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
    Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted oI violating 18
    U.S.C. 2113(a), (b), and (d) cannot also be convicted oI receiving or possessing the robbery
    proceeds in violation oI 2113(c). HeIlin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
    "(2) the State Iailed to prove beyond a reasonable doubt that the automobile had been stolen by a
    person other than plaintiII in error, a...The next assignment oI error is that the State Iailed to prove
    beyond all reasonable doubt that the automobile in question was stolen by some person other than
    plaintiII inerror. To sustain a conviction oI receiving stolen property the prooI must show (1) that the
    property has, in Iact, been stolen by a person other than the one charged with receiving it; (2) that the
    one charged with receiving it has actually received the property stolen or aided in concealing it; (3) that
    the receiver knew the property was stolen at the time he received it and (4) that he received the
    property Ior his own gain or to prevent the owner Irom possessing it. (People v. Piszczek,404 Ill. 465.)
    ProoI oI these essential elements constituting the crime oI receiving stolen property may be made by
    circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96
    N.E.2d 446.
    PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that iI a
    criminal conviction is to be upheld,
    | 21 Ill. App.3d 980 |
    the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394
    Ill. 325, 327 (1946)), and must contain the nature and elements oI the oIIense in order that the
    deIendant may Iully prepare a deIense and be aIIorded the constitutionally intended protection against
    double jeopardy. (People v. GriIIin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the indictment,
    drawn upon the conclusional premise that the property was stolen, Iails to allege that it was stolen by a
    person other than the one charged with receiving such property and, by this omission, creates the
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    presumption that the possessor stole the property himselI. Since one person cannot be both the thieI and
    the receiver oI stolen property nor receive stolen property Irom himselI, the Iact that the property
    received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310
    Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v. Harris, 394 Ill. 325,
    329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860,
    863-864 (1971).) Lacking this element, the indictment Iailed to charge the oIIense oI receiving stolen
    property under section 16-1(d). A conviction under an indictment which does not charge an oIIense is
    void. People v. Edge,406 Ill. 490 (1950).
    The judgment is, thereIore, reversed....
    I Ieel that the majority has misconstrued the eIIicacy oI section 16-1(d) in arriving at a conclusion not
    urged by the deIendant. The omission oI the words "stolen by another" in the indictment does not create
    the presumption that deIendant had himselI stolen the property Irom the owner. The use oI the words "*
    * * knowingly obtain control oI stolen property * * * under such circumstances that would reasonably
    induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly
    implies that when deIendant obtained control oI the property in question (in any manner whatsoever),
    the property had already been stolen by another. That is the plain and ordinary meaning oI the
    indictment.
    I believe the majority may be conIusing what can and cannot be reasonably implied Irom evidence
    introduced at trial with what may be implied Irom the clear phrasing oI the indictment. At trial it is not
    | 21 Ill. App.3d 981 |enough Ior the prosecution to merely show that the property in question was
    stolen property and that the deIendant was in possession oI that property in order to prove the oIIense
    oI theIt under 16-1(d) (the Iormer oIIense oI receiving stolen property). (People v. Baxa (1972), 50
    Ill.2d 111, 277 N.E.2d 876.) The deIendant's unexplained possession oI stolen property soon aIter a
    theIt is evidence that the deIendant stole the property himselI but is not evidence oI deIendant's
    receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
    860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology oI the indictment herein
    permits a reader oI the indictment to Iind, even aIter only a cursory reading, the necessary elements oI
    the oIIense, i.e., that the property was already stolen by another when the deIendant received it.
    While it may be true that the addition oI the words "stolen by another" would make the indictment
    more explicit, the addition oI these words would only be grammatically redundant and mere surplusage
    legally.
    The indictment, thereIore, was suIIicient to charge the deIendant with an oIIense under 16-1(d)(1).
    AIter a thorough examination oI the record, I do not believe that the evidence produced at trial was
    suIIicient to Iind the deIendant guilty beyond a reasonable doubt. For this reason I, too, would reverse
    the deIendant's conviction."
    Appellant correctly argues that the standard oI proving value, Ior conviction, is the same in "receiving"
    cases as in "larceny" and "theIt" cases. He erroneously urges that the state Iailed to meet that standard
    under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "|t|he true
    criterion Ior the value oI property taken is the Iair market value oI the property at the time and place it
    was stolen iI there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF,
    CLARK COUNTY 504 P.2d 695 (1972).
    SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
    by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
    himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
    receiving, | 484 P.2d 565 | but not oI both. People v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870 (Cal.
    11/60
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    1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States,
    365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States, 418 F.2d 567 (5 Cir.1969);
    Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court
    declined to give it. This was error, and later acknowledged by the court to be such when it set aside the
    receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner
    oI handling the error eIIectively cured it. The error was not cured by the setting aside oI the receiving
    conviction since there is no way oI knowing whether a properly instructed jury would have Iound the
    deIendant guilty oI burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both
    convictions should have been set aside and a new trial ordered"
    State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an
    essential element oI the crime oI receiving stolen goods..17. Criminal Law. In prosecution Ior receiving
    stolen goods, where instruction given by court Iollowed language oI statute with reIerence to accused's
    intention to prevent the |61 Nev. 330, Page 336| owner Irom again possessing property, deIendant was
    not entitled to instruction which told jury that goods must have been received with Iraudulent intent oI
    depriving owner oI the immediate possession thereoI. Comp. Laws, sec. 10335."
    BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court oI Nevad: "At the
    conclusion oI a preliminary examination, Henny Bernier was ordered to stand trial Ior possession oI
    stolen property, a violation oI NRS 205.275.1 Bernier then petitioned Ior a writ oI habeas corpus
    contending the evidence adduced by the prosecution was insuIIicient to establish probable cause that
    she had committed the charged oIIense. The district court considered and denied her petition and
    Bernier here reasserts the same contention.
    Bernier does not deny having possessed the property; rather, she argues the prooI did not show that she
    knew the property was stolen and that such knowledge cannot be inIerred Irom mere possession.
    We agree that mere possession is insuIIicient to establish the requisite knowledge..."
    "Under Nevada law, Lane could not be convicted oI both robbery and receiving stolen property. This
    court reversed a conviction Ior possessing stolen property on the ground that the legislature did not
    intend to compound the punishment Ior larceny or robbery by permitting a conviction Ior receipt or
    possession oI the stolen property against the person who took the property. Point v. State, 102 Nev.
    143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
    State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that Ior a charge
    oI possession oI stolen property to stand, there must be a showing oI all the elements, and
    that iI even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
    206, 94 P. 218 (1908). Possession oI stolen property does not in itselI prove guilt oI the oIIense. Staab
    v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden oI prooI oI all three elements rests
    with the
    attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606
    NYS 2d 607.
    Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
    Judge Nash Holmes continues to reIuse to allow Couglin to appeal the "summary criminal contempt"
    Order, even though, given the incarceration was served, it is a Iinally appealable order, see Gilman 275
    V. Comm 474, 657 SE 2d 474.
    BiIurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474
    Terrell v. Miss. Bar 635 So 2d 1377. Matt oI Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem
    929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook
    12/60
    000051
    88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
    1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d
    515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
    Whether Goble had "ownership" in iphone matter 920 P.2d 112
    Sheely 102 p.2d 96
    Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
    26405 and 03628 trespass case:
    unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
    Woods 19 NYS 2d 683
    Regan 425 NYS 2d 725
    Iorio, 410 NYS 2d 195
    Russell v Kalian, 414 A.2d 462: expired warrant Ior eviction no good
    Leese v Horne, 47 P.2d 316
    Burhams, 89 P.3d 629
    Between the Iollowing two timestamped recordings Iinally provided by City Attorney Skau (WCPD
    Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
    prior to the arrival oI the peace to stay peaceIul in Coughlin's reIerences the then recent murder oI
    Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
    theIt oI a purse, and Lelise preIers to spend his time chiming in, unprompted, on the regard, arrogantly
    enough, that he can assist the court iI it Ieels Coughlin is "draggin' his Ieet" incident to the inappropriat
    placement by Judge SIerrazza oI Leslie as "stanby counsel" which really amounted to no more than yet
    another coercive practice put in place by Judge SIerrazza to Iurther his stated goal oI avenging the
    criticisms Coughlin levied upon him incident to Judge SIerrazza's incredibly questionable on-the-Ily
    pandering/remixing oI his Order oI 10/13/11 (iI Coughlin, as he, in Iact did, deposit a "rent escrow" oI
    $2,275, SIerrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawIul
    detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge SIerrazza on the
    record that "the use oI the term "Trial" was unIortunate, Your Honor..." whereupon Judge SIerrazza .
    You are to his constituency by remixing is previous order regardless oI the extent to which Coughlin
    was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they
    are and where only those aspects oI a summary proceeding that in year to the landlords beneIit were
    adhered to where is all oI the procedural and discovery protections attendant to a plenary unlawIul
    detainer trial and the ability to bring counterclaims were matters Coughlin was precluded Irom
    accessing by judge SIerrazza. Just Rosin is interesting approach to landlord tenant matters continued on
    with respect to the manner in which service was aIIected on November 3 in violation the courthouse
    sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division Iiling oIIice no less
    (and that is the same bailiII Plamondon managed to take the Iilings Coughlin submitted online
    November 15 out oI the criminal division Iiling oIIice oI the Reno justice court where Robbin Baker it
    Mr. Coughlin let them in her position well prior to the 5 PM closing oI that Iiling oIIice and with DVDs
    attached to those Iilings Coughlin swears under penalty oI perjury that Ms. Baker admitted this to him
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID
    18.mp3
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
    5.mp3
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    In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed Irom
    representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public deIender applying
    good nicely peers deciding that the night was doing too much to assist Coughlin in deIending himselI
    and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy
    session while Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good
    night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial
    on July 16, 2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought
    to the court in custody seeded Jeremy Bosler was suddenly Iilling in Ior Goodnight with and indication
    Goodnight's December 19, 2011 Iile stamp discovery requests served upon the stay and district attorney
    Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the DeIendant,
    ZACHARY BARKER COUGHLIN, by and through his attorney oI record, Joseph W. Goodnight,
    Deputy Public DeIender, and hereby requests the Iollowing discovery pursuant to NRS 174.235 to NRS
    174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
    conIessions made by the DeIendant or any witness, or copies thereoI, within the possession, custody or
    control oI the State, the existence oI which is known or by the exercise oI 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." It is telling the extent to which on the
    record at that July 16 trial date Washoe County public deIender Jeremy Bosler indicated that Jim Leslie
    would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And
    that Leslie would be prepared to try the case by Friday and that the court could step matter Ior trial on
    Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have
    completed all the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the
    case whether or not that evinced any sort oI concern Ior his client, ability to zealously advocate on his
    client behalI or willingness to do so, or indication that Jim Leslie Ielt that the judges oI the Reno Justice
    Court would hold him to a standard oI care at all tending to indicate that Mr. Leslie has any skin in this
    game whatsoever.
    Clearly there is a bases Ior mistrial here were Jim Leslie's entire contribution to the representation oI
    Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing
    disregard Ior the rules oI proIessional conduct an intentional maniIestation oI Leslie's desire to secure a
    conviction the Washoe County District Attorney's OIIice and therein secure added boys Irom local law
    enIorcement District Attorney's OIIice and perhaps the Reno justice court itselI. Further Reno
    Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County
    public deIenders oIIice in connection with February 27, 2012 clandestine status conIerence between
    Biray Dogan and Zach Young which neither Dogan nor Young has ever reIuted whether they they have
    been sworn prior thereto or not an especially where Dogan's coworker down the hall civil division
    deputy Dist. Atty. Mary has been involved throughout the conIiscation without a search warrant or
    court order oI any kind (or at least one ever served on Coughlin in any manner) oI Coughlin smart
    phone and micro SD card incident Judy impermissible summary contempt Iinding by judge Nash
    Holmes just two hours aIter the clandestine status conIerence between Dogan young on February 27,
    2012 in RMC case 11 TR 26800 Ior which Dogan and Young stipulated to a continuance in 06 RGC
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    065630 in light oI the scheduling conIlict between that traIIic citation trial in the Reno Muni court
    which stemmed Irom Coughlin's being retaliated against vice RPD Sargent Tarter in connection with
    Coughlin telling Tarter one oI the top 30 highest-paid city oI Reno employees oI and admission to
    taking bribes Irom Richard Hill by RPD oIIicer Chris Carter Junior incident to Carter placing Coughlin
    in handcuIIs pursuant to a custodial arrest based upon a criminal complaint Ior trespass Iind by Richard
    Hill on November 13, 2011. That criminal trespass conviction has now become the subject oI a Nevada
    Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent
    Marcia Lopez oI the misconduct by herselI oIIicer Chris Carter, Jr. Richard G. Hill, Esq. and his
    landlord client, and a summary eviction matter that judge SIerrazza presided over wherein judge
    SIerrazza purportedly controlled the civil division oI the Reno justice court to the extent that Coughlin's
    notice oI appeal on December 26 submitted Ior Iiling December 26, 2011 was not Iile stamped by the
    civil division staII oI the Reno justice court. This impropriety is Iurther problematic where Coughlin
    had served upon the Reno justice court's custodian oI records and she civil clerk Karen Stancil (whom
    Richard Hill reIerences in his January 12, 2012 letter her grievance against Coughlin to the State Bar oI
    Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar oI Nevada, which
    ultimately became one oI the three grievances depicted numerically in the caption oI the SBN v.
    Zachary Barker Coughlin SCR 105 Complaint Iiled by the State Bar stamped August 23, 2012 (in
    addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial
    in 11 TR 26800 held in violation oI NRS 178.405 by way oI NRS 5.071 (RJC and RMC under one
    rooI, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC
    judges including then Administrativ Judge William Gardner, who reIused to recuse himselI Irom the
    criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's Iormer
    law oIIice upon Coughlin being subject to a custodial arrest by oIIicer Chris Carter on November 13,
    2011, resulting in a criminal trespass conviction oI Coughlin in 11 CR 26405 where it RPD Sargent
    Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or
    her partner oIIicer Carter issued caught Coughlin a trespass warning prior to eIIectuating a custodial
    arrest on that day in where Lopez also admits none oI those individuals or anyone present that day
    identiIied themselves as law enIorcement prior to landlord meritless kicking down the door to a
    crawlspace about 5 Ieet high underneath the Iormer home law oIIice wherein Coughlin was Iound at a
    time when Coughlin still had not receive back Irom the Reno justice court the impermissible $2275 rent
    escrow deposit judge SIerrazza ordered in violation oI Nevada law considering judge SIerrazza's
    admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was
    correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule
    44 that may support the secret quote house rules been Iact in the civil division oI the Reno justice court
    wherein tenants were in summary eviction matters were subject to Iorced rent escrow deposit in
    violation oI justice court rules civil procedure 83 and that the Reno justice court had neither published
    nor had approved by the Nevada Supreme Court any sort oI corollary to justice court rule Las Vegas
    rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongIul arrest connected thereto
    occurred even where the Washoe County SheriII's oIIice deputy Machen Iiled a Ialse aIIidavit on
    November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction
    Decision and Order and the October 27th Findings oI Fact, Conclusion oI Law, and Order oI Summary
    Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial oI
    Coughlin Irom which Judge William Gardner reIused to recuse himselI despite the Iact that his sister
    judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the
    "Clerk oI Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
    sanctioning Coughlin incident to a divorce matter where and he was representing a victim oI domestic
    violence on behalI oI our Washoe legal services (a rather interesting approach by Iormer prosecutor
    15/60
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    judge Linda Gardner in comparison to the extremely light touch demonstrated by judge SIerrazza and
    judge CliIton oI the Reno justice court incident to deputy district attorney Young's repeated
    malIeasance misconduct violations stays pending competency or evaluations Iailure to turn over
    exculpatory materials Iailure to propound discovery Iailure to respond reasonable discovery requests
    demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions
    oI Coughlin this year Ior charges which young either amended to in advance implicating Supreme
    Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint Irom a misuse oI 911
    charge to do a charge more deleterious to Coughlin's proIessional license as a lawyer and/or patent
    agent by amending the charge nearly a year aIter the January 14, 2012 arrest in the matter to a charge
    that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good Iaith eIIort
    to achieve a plea-bargain and resolve what is a messy case the city oI Reno Police Department and
    emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-
    000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services
    or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely
    suspect rolling this year by judge Schroeder oI the Reno justice court against Coughlin in the extremely
    quick like 40 min. Irom Iiling quick issuance oI up temporary protection order to Richard G Hill on
    January 12, 2012 in connection with Hill's Iraudulent abuse oI process and Ialse statements to police
    oIIicers aIIecting the arrest custodial arrest oI Coughlin on January 12, 2012 will jaywalking (Hill lied
    to RPD oIIicer Hollingsworth in alleging that Coughlin had already lost his appeal oI summary eviction
    matter in 1708 Barber which judge SIerrazza presided and which was then on appeal beIore judge
    Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney Iee award against
    Pro per appellant Coughlin in the appeal oI the summary eviction order issued by Judge SIerrazza and
    1708 on March 30, 2012 incident to and motion Ior attorneys Iees Iiled by Casey D Baker oI Hill's
    oIIice on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty.
    young Iastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom
    "randomly" was assigned to Coughlin appeal oI the petty larceny conviction oI a candy bar and some
    cough drops Irom Walmart in 11 CR 22176 (the sole basis Ior Coughlin's current temporary suspension
    oI his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming Irom an arrest on
    September 9, 2011 that was violative oI Nevada law where tribal police oIIicers aIIected a custodial
    arrest Ior a misdemeanor (much less one not alleged to have occurred in their presence) in violation oI
    the express dictate against doing so Iound in NRS 171.1255 should especially where Walmarts sole
    witness testiIying at the petty larceny trial, would be dentist Thomas Frontino, whom testiIied on behalI
    oI the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest Ior misdemeanor petty
    larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard just seeing
    $83 worth oI groceries allegedly consuming a candy bar and or some cough drops while doing so...
    Despite the Iact that that Walmart alleges to have had absolutely no video Iootage supportive oI its
    allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and
    where French you admit that his supervisors had previously indicated to hand a desire to retaliate
    against Coughlin in connection with Coughlin's questioning
    some oI Walmarts policies and where John Ellis oI the W. 7th St., Walmart in any as yet unknown loss
    prevention associate speciIically and expressly threatening abuse oI process against Coughlin on July 7,
    2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and
    customer service managers many oI whom have had that position Ior over a decade routinely claim do
    not remember the return policy or restated in a manner that depart substantially Irom the policy which
    Walmart holds out to the public on its website Walmart.com and which on that website speciIically
    makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the
    convenient Ior getting in misremembering oI Walmarts managers may indicate the policy actually is.
    16/60
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    Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 aIIected a
    citizen"s arrest oI Coughlin on that date in connection with the alleged petty larceny by Coughlin oI a
    candy bar and some cough drops which conveniently Ior the Reno Police Department just days aIter
    Coughlin Iiled a written complaint detailing the police misconduct by Reno Police Department oIIicer
    Grohl and Rossa incident to the arrest oI Coughlin the wrongIul arrest oI Coughlin on August 20, 2011
    in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin
    (despite the Iact that the majority viewpoint throughout American jurisprudence that one cannot be
    charged with both petty larceny and receiving stolen property oI the same item particularly where the
    receiving oI the item is alleged to have been Irom oneselI aIter one had larceny is the item lending an
    inIerence that Joe SIerrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as
    possible to aIIect the leverage over Coughlin to mitigate the liability Reno justice court may Iace in
    connection with its numerous since is violating about law respecting the manner in which evictions are
    carried out and or the misconduct oI local law enIorcement and prosecutors in carrying out retaliatory
    arrest and prosecution oI Coughlin where the judiciary in Washoe County is oII criticizes being overly
    inIluenced by the District Attorney's OIIice. That Walmart petty larceny conviction stemmed Irom a
    trial beIore Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school oI law
    whom Coughlin's twice Iormer Reno Municipal Court appointed public deIender Keith Loomis (not in
    the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed deIender there despite
    his express Iailure to rule that jail time was not a possibility in his pretrial order and where mandatory
    authority exists requiring that he then appoint Coughlin court appointed counsel particularly where
    Coughlin established his indigency. Judge Howard's malIeasance in connection with that conviction oI
    Coughlin extends Iurther the extent that he early on in that November 30 trial on it in 2011 reviews
    Coughlin Ior causing the November 14 trial setting to have been continued only to in a 3 min. add-on at
    the conclusion oI the hearing which are trial which judge Howard down such a matter oI public
    concern that he Five city oI Reno employees at the courthouse until nine o'clock at night to get it done
    that in Iact judge Howard admitted he was wrong with respect to the cause oI the continuance oI the
    14th 2012 trial that was not Coughlin Iault that all and where the Reno Municipal Court had previously
    granted a continuance to the city oI Reno prosecutor's in the very criminal trespass prosecution oI
    Coughlin stemming Irom Richard G Hill Esquire's criminal trespass complaint (connected to the
    summary eviction matter over which judge SIerrazza presided) where the Reno Municipal Court Ireely
    granted Richard G are the product the city oI Reno prosecutor's a continuance in light oI Richard G
    Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week
    vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge
    SIerrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction
    matter 1708 required by law within 10 days oI Coughlin Iiling his motion to contest personal property
    lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging
    Coughlin reIused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as
    Janice admitted when judge SIerrazza called her is oI his own witness at the December 20, 2012
    hearing that was Iinally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be
    able to control the justice court in his desired to prevent such a hearing been set until he returned Irom
    his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to
    contest personal property lien judge SIerrazza ordered Karen Stancil and Joslyn John is oI the Iiling
    oIIice oI the Reno justice court to Iile in unsworn statements purporting to prove that Coughlin
    somehow Iailed to allow the justice court to setting hearing on his motion to contest personal property
    lien however that doesn't explain the extent to which bailiII Plamondon was able to apparently without
    Coughlin's permission serve Coughlin a violation oI the courthouse century Dr. and a notice oI it
    November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was
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    seeking axis justice court Iiling oIIice Ior something unrelated to bailiII Plamondon's desire to aIIect
    service oI some notice oI the hearing upon Coughlin.
    Keith Loomis, Esq., RMC, court appointed deIendner, admits to having been close Iriends with in law
    school and to this day Loomis himselI in 1982 graduate McGeorge school law along with wash County
    Dist. Atty. Richard Gammick, both oI whom were one year ahead oI Reno justice court judge CliIton
    whom recently granted 2004 graduate McGeorge school oI law deputy district attorney Zach young in
    order taking away the ability to Iile by Iax Irom Coughlin a privilege that is accorded any other
    criminal deIendants in the Reno justice court despite the Iact that that order was granted at the
    November 27, 2012 hearing at which Coughlin's then attorney public deIender Biray Dogan was
    relieved as counsel and where at that hearing Dogan himselI admitted that he had not received the
    motion young alleged who Iiled on November 26, 2012 seeking such an order Irom judge CliIton
    barring Coughlin's ability to Iax Iile or send young it a Iax oI any sort apparently or perhaps Tom
    despite the Iact that Coughlin had merely comply with judge CliIton's request that he provide judge
    CliIton something supportive oI Coughlin's contention that Biray Dogan had utterly Iailed her by the
    advocacy zealous are not oI any sort whatsoever incident to his quote representation oI Coughlin" in
    065630).
    (again, judge SIerrazza as a Iormal tribal judge and director oI Indian legal services and Coughlin's
    Iormer client Pete Eastman, recently admitted to Coughlin both oI the State Bar oI Nevada
    communicated he and his wiIe Ialse assertions respecting a non-existent order against Coughlin by
    Nevada Bankruptcy Court Judge Beesley (the State Bar oI Nevada listed as having a specialization in
    creditors rights at www.nvbar.org) (Iormer law practice partners with an individual Irom Washoe Legal
    Services whom Coughlin is suing in 60302, Karen Sabo, Esq., Iormerly oI Beesley Peck, LTD and
    whom trashed Coughlin's work beIore him and in Nevada Bankruptcy Court at Coughlin's November
    14, 2012 Iormal disciplinary hearing to which judge Beesley's testiIying was not noticed to Coughlin
    previous to the hearing and in violation oI Supreme Court rule 109 a violation made all the worse in
    light oI the Iact it bar counsel Pat King had known oI any involvement oI judge Beesley in any matters
    relative to the ultimate Supreme Court rule 105 complaint against Coughlin Ior over six months at least
    and so in no way can be said to just stuII I his last-minute supplementing judge Beesley and
    milquetoast attempts to provide Coughlin S supplemental designation oI witness and summary oI
    evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services
    Executive Director Paul TESTIMONY at the hearing (both oI those gentlemen attended McGeorge
    school oI law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both oI them
    oIIered strong opinions disapproving oI Coughlin's competency as an attorney at the hearing despite the
    Iact that neither oI them could provide anything in the way oI speciIicity with regard to what issues
    they would take with any oI the work they reviewed oI Coughlin's or judge Beesley's case Iilings in
    judge beIore judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court
    Rule 121's conIidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin
    Iormal disciplinary hearing him on behalI oI recently as oI November 8, 2012 reinstated attorney
    Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 Irom his clients and
    using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge
    Beesley sees competency in Mr. Harris and could overlook the $755,000 Ior my client where it be $14
    worth oI candy bars and cough drops Irom Coughlin and Coughlin's March 30, 2012 Iiling in Cadle Co.
    v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at
    2:30 pm in representing Mr. Keller that was aIIected by the Iraudulently procured order Ior summary
    eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire
    18/60
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    Brown judge Schroeder oI the Reno justice court wherein the audio record Irom that proceeding
    indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary
    eviction case against Coughlin through despite Judge Schroeder admittedly having had a diIIerent order
    oI hearing the cases planned Ior that morning docket and despite the Iact that the Iax header on the
    summary eviction order that was hurriedly moved through indicates a time stamping oI a 8:24 am Ior a
    hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County SheriII's oIIice deputies
    Cannizzaro entered and broke into Coughlin's rental sometime shortly aIter 1 PM that same day,
    3/15/12, without announcing themselves as law enIorcement and where they entered with their guns
    and/or pagers drawn in and immediately placed Coughlin in handcuIIs and told him he was detained in
    contrast to the typical procedures carried out by the SheriII's oIIice incident to evictions in Washoe
    County. Incident to that summary eviction (where the docket, at least, more review is necessary,
    indicates that Kern and Western Nevada Management's Sue King switched up their basis Ior an eviction
    all the sudden in their 3/15/12 Iiling oI a Landlord's AIIidavit that suddenly changed the basis Ior
    seeking an eviction to one Ior non-payment oI rent (seemingly in response to Coughlin Pre Hearing
    BrieI pointing out the diIIiculties they would Iace under Glazer in pursuing a No Cause, particularly
    against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the
    Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably
    sublessors to Coughlin). in the third grievance against Coughlin Iorming SCR 105 complaint Ior which
    a Iormal disciplinary hearing, the grievance Iiled by Judge Dorothy Nash Homes in NG12-0402.
    Judge Beesley and Judge Nash Holmes attended McGeorge School oI Law together in 1977. Perhaps,
    the Iiling that Judge Beesley was reIerring to when he threw Coughlin under the bus at Coughlin's
    11/14/12 Iormal disciplinary hearing (with one oI the three grievance numbers listed in the Complaint,
    which the SBN and Panel will claim also IulIilled the Hearing required by 60838 Ior the Wal-Mart
    candy bar conviction that resulted in the current now 5 month long suspension oI Coughlin's license to
    practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin Iiled the Iollowing:
    Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
    Entered: 3/30/2012 BrieI
    Docket Text: BrieI in Opposition to Notice oI DeIault and Praecipe/Intent to take DeIault with
    CertiIicate oI Service Filed by ZACH COUGHLIN on behalI oI SAMANTHA L. HALL, ROBERT
    KELLER (Related document(s)49 Notice oI Entry oI DeIault Iiled by PlaintiII CADLE CO.)
    (Attachments: # (1) AIIidavit AIIidavit oI Counsel Coughlin Ior Keller in Support oI Opposition# (2)
    Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals
    and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding
    excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 Iax to rmc
    regarding deIiciency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND
    MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
    In submitting that somewhat inIlammatory 3/30/12 Iiling (which curiously seemed to immediately
    result in Judge Nash Holmes entering an Order oI the same date in 11 TR 26800 whereby she Order
    Coughlin's property released to him, though DDA Mary Kandaras dragged her Ieet until April 7th, 2012
    beIore Iinally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
    admitted to having released to the City oI Reno Marshals on 2/28/12, denied having the micro sd card,
    denied the micro sd ever being booked into property, alleged to have given Judge SIerrazza's Iormer
    tribal court BailiII and Iormer Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the
    19/60
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    jail at Coughlin's request to get Coughlin's keys so Eastman could arrange Ior Coughlin's dog Jackson
    Pawluck to be Ied and cared Ior during Coughlin's summary 5 day incarceration).
    Coughlin put his client's interest ahead oI his own (where Coughlin would arguably be better oII letting
    the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card conIiscating without a
    warrant/5 day summary contempt jail sentence Ior testiIying that an RPD Sargent lied in connection
    with his testimony about the Richard G. Hill, Esq. retaliatory issuance oI three traIIic citations outside
    Hill's law oIIice, where RPD Sargent John Tarter told Coughlin to leave aIter Coughlin presented upon
    being released Irom jail incident to a three-day stay stemming Irom Hill's line 2 Reno Police
    Department oIIicers and managing caught to get Coughlin subject to custodial trespassing arrest
    (detailed at length in 61901) and Hill reIusing to give Coughlin his drivers license law accuser clients
    Iiles and Coughlin reporting to Sargent John Tarter at that time that three days prior to that Reno Police
    Department oIIicer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him
    as he too was on Richard Hill's payroll that RPD OIIicer Chris Carter, Jr admitted to Coughlin: "Yes,
    Richard Hill pays me a lot oI money so I arrest who he says to arrest and I do what he says to do..." and
    where both oIIicer Carter and Sargent Marcia Lopez reIused to undertake any diligent inquiry response
    to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill Ior the Iull
    rental value oI the 121 River rock property Ior the month oI November that was commiserate with the
    same $900 that Coughlin was previously charged Ior the Iull use an occupancy oI the premises. The
    lackluster Iailure to query Hill with any diligence by both oIIicer Carter and Sargent Lopez is
    reminiscent oI what Reno Municipal Court Court appointed deIender Keith Loomis Esquire in 1982
    graduate McGeorge school oI law told Coughlin at an April 10, 2012 trial date in that criminal trespass
    matter wherein Reno Municipal Court judge William Gardner reIused to recuse himselI Irom hearing
    that case against Coughlin despite the Iact that at that time he had Iiled a grievance with the State Bar
    oI Nevada against Coughlin by way oI the NG 12 0434 grievance that his Iellow RMC judge Dorothy
    Nash Holmes Iiled
    Judge Beesley Iormerly partnered with now Washoe Legal Services child advocacy director Karen
    Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes conIiscating
    Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any
    permissible interpretation oI a search incident to arrest given Coughlin property had been booked into
    his personal property at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily
    sentencing Coughlin to 5 days in jail Ior contempt, despite citing to a non summary civil contempt
    statute in NRS 22.010 and NRS 22.100, but characterizing her Order as Iinding Coughlin guilty oI the
    "misdemeanor oI criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt
    statute, which is not summary in nature, and thereIore requires more due process, and despite Judge
    Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even
    said what Holme's alleged he did in rendering her "second bit at the apple" oI 3/12/12 in comparision to
    her 2/28/12 Order Finding DeIendant in Contempt and Imposing Sanctions...In Nevada, a Summary
    Contempt Order under NRS 22.030 (which is civil in nature) Ior conduct not committed in the
    immediate presence oI the Court (such as the alleged conduct involving a restroom and disassembling a
    smart phone or recording device and hiding some component part thereoI in the restroom that Judge
    Nash Holmes murkily, hazily, and vaguely testiIied to during Coughlin's 11/14/12 Iormal disciplinary
    hearing, and which she included in the Order she rendered in that traIIic citation case stemming Irom
    Coughlin being told to leave Hill's law oIIice upon appearing their demanding his keys, wallets, driver's
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    000059
    license, and client's Iiles shortly aIter being released Irom a 3 day custodial arrest stay in jail incident to
    Hill's criminal trespass Complaint against Coughlin at Coughlin's Iormer home law oIIice (in RJC2011-
    001708, the eviction matter presided over by Judge SIerrazza). Like the Order Judge Linda Gardner
    claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis
    FV11-03383 (see attached in Exhibit 1), Judge SIerrazza attempted to characterize the Order he entered
    on 12/21/12 Iollowing a very contentious six hour hearing on Coughlin's November 17th, 2011 Iiled
    stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to Contest
    Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was
    certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge SIerrazza
    may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere
    wherein Richard Hill was permitted to joke along with Reno justice court bailiIIs radius in chieI bailiII
    Sexton as to the Iact that he to quote would like to stick some things up Coughlin's ass" in reIerence to
    multiple incidents where Reno justice court bailiIIs had either as bailiII arrested told Coughlin that he
    would put his Ioot oI Coughlin's ass or made commentary as chieI Sexton did to Coughlin respecting
    Sexton's indication oI Coughlin on two diIIerent occasions the week oI Thanksgiving 2011 that
    Coughlin indicated that the Iiling oIIice and/or not attempt to Iile documents so close to the 5 PM
    closing time oI the Iiling oIIice. (see attached in Exhibit 1).
    and him him him him and him In Iact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes,
    inaccurately:
    "4. We represent Dr. Matthew MerIiss, a physician Irom Chico, CaliIornia. Dr. Merliss owns the
    property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was leased to
    Mr. Coughlin and his then-girlIriend. The lease expired in February 2011. The girlIriend leIt the
    community in approximately May 2011. Dr. Merliss contacted us in approximately August 2011 to
    assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that
    there were habitability issues with the property that justiIied his withholding rent. All oI his clahns
    were decided adversely to his position at the eviction hearing. Justice oI the Peace Peter SIerazza
    ordered Coughlin evicted Irom the premises eIIective November 1, 2011. On that date, the Washoe
    County SheriIIs Department perIormed their normal eviction procedure: locks were changed and the
    eviction notice was posted on the Iront door. We videotaped the home and its contents at that time.
    Upon inspection over the next Iew days, it became apparent that "somebody" was breaking into the
    home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at
    the home on River Rock Street. As we walked through the home, it was obvious that"
    One, it is not true Ior Hill to write "The lease expired in February 2011." The Standard Rental
    Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in
    accordance with the NRS 118A holdover tenant provision. Further, it is not accurate Ior Hill to write
    "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with
    Coughlin's Iormer co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment
    payments to make up Ior the Iact that she took Coughlin's $450 contribution to the $900 Ior each oI the
    months oI May 2011 and June 2011 and only sent the landlord Merliss $550 Ior May 2011 and nothing
    Ior June 2011. Coughlin provided Ms. Ulloa with $450 Ior each oI those months, and thereIore, in
    combination with Dr. Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa Irom
    a grand larceny charge oI a variety to which the two petty larceny charges Coughlin Iaced shortly aIter
    Ms. Ulloa's secretly absconding with Coughlin's rental contributions (which Coughlin was only made
    aware, and the concomitant rent due, upon an August 11th, 2011 email Irom the landlord Merliss).
    21/60
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    Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 beIore Judge
    SIerrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices,
    in violation oI NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an
    agreement with Coughlin Ior a rent deduction oI $350 going Iorward in exchange Ior Coughlin
    "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artiIicial turI
    installation Coughlin had installed in an enterprising approach which the landlord's landscaper Ior the
    other property Merliss owned next door and his quasi real estate broker property manager Darlene
    Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually
    claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn
    Service to "deal with the weeds" at Coughlin's Iormer home law oIIice. "Dealing with the weeds", to
    Green Action Lawn Service, included tearing up Coughlin's artiIicial turI installation leaving Street
    causing Coughlin's law oIIice substantial losses lost proIits time away Irom work and expenses
    associated with immediately mitigating the criminal conduct oI green action lawn service where they
    not only tore up the artiIicial turI installation even though they knew it was there prior to submitting
    their bid Ior services to landlord Merliss, who apparently did not realize or remember that he had also
    assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange Ior Coughlin
    quote dealing with the weeds. Green action lawn service sought close the artiIicial turI installation
    Coughlin put into place oI his Iormer law oIIice the week prior to their tearing it up and leaving
    industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
    Hill's grievance oI 1/14/12 to the SBN goes on to allege:
    "Someone had been in there since I had last been in several days beIore. Dr. Merliss discovered that the
    basement door was barricaded (not locked) Irom the inside. The Reno Police Department was
    summoned. They tried to coax whoever was in the basement out, without success. AIter Dr. Merliss had
    to kick the door down, it "was discovered that Mr. Coughlin had broken in and was in the basement. He
    was arrested and is presently Iacing criminal trespass charges in Reno Municipal Court. See case no. 11
    CR 26405 21. He is also Iacing a contempt motion in Iront oI Judge SIerrazza in the eviction case.
    SIerazza has stayed that matter pending the resolution oI the criminal trial. That was scheduled Ior
    January 10, 2012, but was continued at the request oI Mr. Coughlin's new attorney.
    5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628,
    pending in Department 7. As part oI the eviction process, a lien was asserted against the personal
    property that Coughlin leIt behind at the home. On November 16, 2011, Coughlin Iiled a motion to
    contest the landlord's lien in the Reno Justice Court. The court tried to promptly set a hearing, but
    Coughlin reIused to cooperate in setting the matter, and the court took it oII calendar. Coughlin then
    reinitiated that process and a hearing was held in December, at which time the court heard evidence oI
    Coughlin's lack oI cooperation in setting the November hearing. You may also want to contact Reno
    Justice Court staII, and in particular, chieI clerk Karen Stancil, about Mr. Coughlin's abusive treatment
    oI her and her staII. AIter the hearing, the court issued an Order granting Coughlin a two-day time
    window to remove his personal property. The Iirst day was Thursday, December 22, 20 11. AIter
    Coughlin was allowed into the home that Iirst day, he sent out an e-mail to the eIIect that because he
    had appealed Judge SIerazza's order, he was entitled to a stay oI proceedings and was to resume in the
    home. As a result, he did very little to remove any oI his personal property that day. On Friday,
    December 23, 2011, aIter he learned, again, that his stay had been denied, Coughlin assembled a small
    crew and they were able to remove a substantial amount oI his personal property. (You need to
    understand that Mr. Coughlin is a hoarder. We have the photos and videos iI you would like to see
    22/60
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    them.) However, Mr. Coughlin did not get all oI his property out. For example, I counted 13 car seats
    that he had somehow managed to get down into the basement.
    Having Iailed to remove all oI his belongings, Mr. Coughlin then moved beIore Judge Flanagan Ior a
    temporary restraining order to prevent the disposal oI his abandoned property in accordance with Judge
    SIerazza's order. Attached is Mr. Coughlin's motion, my oIIice's opposition, and Mr. Coughlin's reply.
    These documents demonstrate Mr. Coughlin's complete and utter incompetence as an attorney.
    On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request Ior a temporary restraining order.
    On January 12, 2011, the contractor hired to clean the house commenced work. Mr. Coughlin Ilagged
    the contractor down in traIIic when he (the contractor) was on his way to the dump with the abandoned
    property Irom the house. Coughlin called the police, who arrived at the transIer station. Coughlin was
    Ialsely asserting that the contractor had tried to run hin1 over. He also told the police "
    The ECOMM recordings (at least what Skau decided to divulge, Iinally) can be described thusly:
    PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory Goble's
    Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM SourceID 43
    Duralde saying 153 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM SourceID 46
    Rosa saying 396 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM SourceID 13
    reporting party advised they are now at Iirst and center.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM SourceID 21
    probably Duralde saying 153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM SourceID 12
    RPD Rosa saying charles 396 on the other end.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM SourceID 14
    unintellible short statement sounds like guilt nexus.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM SourceID 41
    probably Duralde saying Reno C153 twenty three.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM SourceID 43
    probably a dispatcher saying c153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM SourceID 17
    Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID 18
    Probably a dispatcher saying Charles 153.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID 17
    Dispatcher indicating Reno C153 wagon available Ior a male.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID 26
    someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID 42
    probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID 28
    odd by somebody c153 seems to split in middle yet still one Iile.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID 22
    23/60
    000062
    Duralde saying Reno c153 rtI returning.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID 27
    Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
    5 Rosa saying Charles 396.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM SourceID
    19 Rosa saying 29 white male.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM SourceID
    24 man saying come and split that up then Iemale dispatcher saying go ahead with that.wav
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlinhotmail.com
    --Forwarded Message Attachment--
    Close Print
    in compliance with Judge SIerrazza Order oI 9/5/12 FW: Zach Coughlin has shared a Iolder with you
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Tue 11/27/12 8:26 AM
    To: psIerrazzawashoecounty.us (psIerrazzawashoecounty.us); zyoungda.washoecounty.us
    (zyoungda.washoecounty.us)
    re:rcr2011-063341
    Dear Judge SIerrazza and DDA Young,
    I am sending this in compliance with Judge SIerrazza's indication that I should send him materials aIter
    the trial the bare on the ineIIective assistance oI counsel claim and or the coerced waiver oI my FiIth
    Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the
    email oI 11/5/2012 Irom Court Administrator Mr. Tuttle and the inadvertent Iaxing oI numerous Iilings
    to the wrong Iax number by myselI.
    https://skydrive.live.com/redir?resid43084638F32F5F28!5141&authkey!APibWiVXTMSWkw0
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    24/60
    000063
    Tel and Fax: 949 667 7402
    ZachCoughlinhotmail.com
    in compliance with Judge SIerrazza Order oI 9/5/12 FW: Zach Coughlin has shared a Iolder with you
    View photos Download all
    You are invited to view Zach's album. This album has 43 Iiles.
    11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdI
    4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion Ior new trial basis.pdI
    11 21 12 notice oI non service 063341 needs ex 1.pdI
    11 21 12 Notice oI Irregularities 063341 with ex 1 started revised.pdI
    11 30 11 063341 CoughlinDiscovery Received11.30.11 rotated.pdI
    11 16 12 skau grievance materials combined 0204 063341.pdI
    11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdI
    11 13 12 063341 submission oI materials and motion Ior order dmv and cell records or
    subpoena.pdI
    11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text
    oI motion no exhibits.pdI
    2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed
    pdIIactpro more nuance.pdI
    Iinal Motion Ior Mistrial and Memorandum oI Law State v Coughlin rcr2011-063341 -
    Copy.pdI
    pre trial brieI state oI nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd
    and tagged jbig2 lossy.pdI
    2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD
    RMC 11 CR 00696 WCSO SUSICH ME.pdI
    pre trial brieI state oI nevada v coughlin rcr2011-063341.pdI
    rcr11-063341 notice oI appearance coughin Iile 3 3 2012.pdI
    rcr11-063341 aIIidavit in support oI motion to Iile pre-trail motions late bw - Copy.pdI
    11 27 12 complete with ex 1 063341 notice oI developments.pdI
    11 26 12 0204 Notice oI Hill and Baker MalIeasance Ior Motion Ior New Disciplinary Hearing
    or Trial 063341 1708 60331 61383.pdI
    6 25 12 Order Ior Sanctiosn 03628 0204 Flanagan $40K in attorneys Iees summary eviction
    appeal.pdI
    10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing
    Order to Baker 1708 0204.pdI
    From: stuttlewashoecounty.us
    To: zachcoughlinhotmail.com
    CC: CWoodwashoecounty.us; RBakerwashoecounty.us
    Subject: RE: Zach Coughlin has shared a Iolder with you
    Date: Mon, 5 Nov 2012 18:39:02 0000
    Mr. Coughlin:
    25/60
    000064
    Reno Justice Court has no record oI your attempted Iiling on 10/18/12. II you choose to pursue this
    Iiling action, you will need to bring the documents in because we do not accept Iilings via email. Any
    documents Iiled with the court will be retained by the court and we will not make copies Ior you, the
    DA or PD. Providing the appropriate parties copies oI your Iiling is your responsibility, not the court.
    You may also bring in your conIirmation oI transmission Irom the 10/18/12 Iiling attempt and we will
    retain that receipt as part oI the court record. Steve
    Steve Tuttle
    Court Administrator
    Reno Justice Court
    From: Zach Coughlin |mailto:zachcoughlinhotmail.com|
    Sent: Saturday, November 03, 2012 9:39 PM
    To: Tuttle, Steve
    Subject: Zach Coughlin has shared a Iolder with you
    Dear Mr. Tuttle,
    I perused the Iile in RCR2011-063341 and noticed that the document I submitted Ior Iiling on or about
    10 18 12 was not Iile stamped or even in the Iile, though I have conIirmation oI receipt oI transmission.
    Can you please indicate why it is not appearing in the Iile and Iind attached another copy oI the exhibit
    1 thereto.
    https://skydrive.live.com/redir?resid43084638F32F5F28!3600
    Zach has 460 Iiles to share with you on SkyDrive. To view them, click the links below.
    102611coughlin2 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy
    Spencer.wmv
    102611coughlin1 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy
    Spencer.wmv
    101211coughlin CRC 11-063341 Competency Evaluation Hearing that got continued.wmv
    090512coughlin2 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
    wcso.wmv
    082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
    wcso.wmv
    071612coughlin rcr2011-063341 rjc .wmv
    082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
    wcso.wmv
    26/60
    000065
    082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
    Goble Zarate testimony - Copy.wmv
    082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
    Goble Zarate testimony.wmv
    090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
    Goble Zarate testimony.wmv
    090512coughlin4 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    090512coughlin7 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    090512coughlin6 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    090512coughlin1 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde - Copy.wmv
    082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
    Goble Zarate testimony.wmv
    090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
    090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
    Share your Iiles with
    IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF
    TRIAL AND IN CASE ANYTHING GOES MISSING AGAIN
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Thu 11/29/12 4:57 PM
    To: stuttlewashoecounty.us (stuttlewashoecounty.us); zyoungda.washoecounty.us
    (zyoungda.washoecounty.us); psIerrazzawashoecounty.us (psIerrazzawashoecounty.us);
    rjcwebwashoecounty.us (rjcwebwashoecounty.us)
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    27/60
    000066
    ZachCoughlinhotmail.com
    Zach has 43 Iiles to share with you on SkyDrive. To view them, click the links below.
    11 29 12 063341 MOTION FOR NEW TRIAL FINAL WITH 217 MENTION.pdI
    EX1 063341 FINAL.pdI
    data-2012-11-24-17-43-52 063341 11 19 12 lichty admits phone did not vibrate.wav
    data-2012-11-24-17-44-12.wav
    data-2012-11-24-18-40-33.wav
    data-2012-11-24-18-40-47.wav
    data-2012-11-24-18-43-05.wav
    data-2012-11-24-18-45-14.wav
    data-2012-11-24-18-49-41.wav
    data-2012-11-24-18-49-41(1).wav
    data-2012-11-24-18-53-39.wav
    data-2012-11-24-18-53-39(1).wav
    data-2012-11-24-19-00-18.wav
    data-2012-11-24-19-00-18(1).wav
    data-2012-11-24-19-21-24.wav
    data-2012-11-24-19-21-24(1).wav
    data-2012-11-24-19-26-17.wav
    data-2012-11-24-19-31-25.wav
    data-2012-11-24-19-37-26.wav
    data-2012-11-24-19-40-46.wav
    Download all
    911 calls missing Irom what was produced by City Attorney Skau
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Mon 12/03/12 2:53 AM
    To: psIerrazzawashoecounty.us (psIerrazzawashoecounty.us); zyoungda.washoecounty.us
    (zyoungda.washoecounty.us)
    Dear Judge SIerrazza and DDA Young,
    This correspondence is Iurther in line with Judge SIerrazza's previous instruction to me to send him
    emails aIter the trial directed to my issues with Mr. Leslie's representation (I am too tired to Iully set
    those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
    this just because it seems like the right thing to do).
    SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
    by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
    himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
    receiving, | 484 P.2d 565 | but not oI both
    28/60
    000067
    Perhaps one oI my biggest complaints about the ineIIective assistance oI counsel by Mr. Leslie (and to
    a much, much lesser extent that oI Mr. Goodnight) relates to Leslie's Iailure to utilize any oI the work I
    did to prep this case. For instance, Leslie whiIIed (perhaps intentionally so) on the extent to which
    RPD OIIicer Duralde and Rosa could not have received the dispatch text oI 11:27:11 pm reporting
    Goble's since proven Iraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so,
    OIIicer Duralde and DDA Young are stuck with anything the OIIicer could "hear" on the Dispatch
    recordings (and those provided by City Attorney Skau provide a basis Ior mistrial where the cd lacks
    Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid oI anything Ior the 6
    minutes in which the detaining and arrest occurs (and Iurther, DDA Young and the State were served a
    request Ior discovery by Goodnight in November and subpoena which required production oI those
    "dispatch logs or recordings...." Yet DDA Iailed to. Then he put on testimon and made argument that
    this "report Irom dispatch oI a possible Iight" was the main justiIication Ior the pat down and search
    incident to arrest and led to a justiIication Ior not excluding anything "discerned incident to the pat
    down"...the only problem is is that Duralde and Rosa already are marked as on the scene by 11:26:00
    pm, and thereIore could not have read the text screens in their vehicles to recieved the text only
    11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to which
    Coughlin's 911 call is not reported accurately at all Iurther underscores the unIairness oI depriving
    Coughlin the right to cross examine Duralde and the dispatchers.
    A review oI the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to
    Judge SIerrazza ordering him to produce in response to my subpoena duces tecum to Kelley Odom and
    ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two oI the 911
    calls are missing. There is no audio oI any RPD-ECOMM/Dispatch communications between the
    11:28:17 pm mark and the 11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm
    did not know I was Iilming/recording the arrest. Had I not captured a recording oI the arrest, how little
    would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many
    things revealed by the arrest recording contradict what OIIicer Duralde put in his Supplemental
    Declaration and Narrative and the two witness statements? Further, where Zarate does not allege to
    have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on
    8/29/12 does testiIy to seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw
    it light up Irom all the way across the skate park...but wait...come November 19th, 2012 he changes his
    story and decides he saw it light up Irom "2 to 3 Ieet away Irom Coughlin"....There a movie Iloating
    around somewhere out there that does a timeline oI all these calls, all these videos, superimposes the
    dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
    And one problem Ior DDA Young and Duralde is Iound in the State's 2/21/12 Opposition, on page 5,
    wherein Young writes: "In the instant case, the pat-down search oI the DeIendant was proper under the
    totality oI the circumstances. Prior to arriving, OIIicer Duralde learned that the scene involved a loud
    disturbance with possible Iight, thereby immediately raising the concern oI weapons and the saIety oI
    all those present." And, oI course, OIIicer Duralde responded splendidly to Coach Young's, er, DDA
    Young's training regime and sang the "possible Iight...report Irom dispatch oI a possible Iight" tune all
    the live long day...which was the basis Ior the reasonable suspicion Ior the pat-down (and Judge
    SIerrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less
    obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the
    Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson
    admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on
    29/60
    000068
    video and audio recordings into the record...despite Duralde testiIying to a multitude oI double hearsay
    (and not even capture on a recording so close in time to the arrest and at the very same location,
    involving the majority oI the players in the arrest itselI...).
    It was in the same 11/30/11 email Irom WCPD Goodnight to Coughlin that included the Narrative by
    OIIicer Duralde (which has, in the Iooter oI the 4 page document, a Iooter indicating a "printed on"
    date oI 11/28/11
    Zarate's testimony respecting the scant statements he actually made to OIIicer Duralde reveal the extent
    to which OIIicer Duralde paints on to witness statement more speciIic, particularized Iacts in support oI
    the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" oI "busting" and
    attorney whom dared to answer one oI the oIIicer's questions by asking a question seeking clariIication
    as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a Iinding oI
    either "reasonable suspicion" to conduct a "weapons check pat down" (the OIIicer's did not receive the
    text Irom dispatch reporting Goble's second 911 call wherein he Iraudulently alleged that "someone just
    socked a minor" (reIerring to the instance where then 18 year old Austin Lichty (who is captured on the
    video oI the moments(Iile named: VID20110820232423 austin lichty templeton goble zarate chan
    rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in length) lying in
    asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition
    to Goodnights 2/14/12 Motion to Suppress, both Goble, Lichty, and Zarate all have motivations
    apparent which preclude them Irom being deemed "reliable citizen witnesses" and OIIicer Duralde
    indeed did have, and admitted to in his testimony at trial to being aware oI, the "gross inconsistencies"
    Goodnight pointed out between the hearsay and double hearsay Duralde testiIied to at trial aIter
    "reIreshing his recollection" upon a review oI either his "Supplemental Declaration" (an attachment to
    the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
    question....how was it not misconduct by the State and prejudicial to the point oI declaring a mistrial or
    at least not, as Judge Pearson did in a curious recorded hearing on
    But here is the biggest problem Ior the RPD and the State...the screen lock that Goble and Templeton
    testiIied to (the password Ior the phone)...and when Goble alleges Duralde gave him back the
    phone...and the call into the iPhone at 11:33 pm Irom OIIicer Duralde's phone...and the call Irom the
    iPhone b
    Perhaps the worst thing Ior the State and the RPD here is that two hostile witnesses (in addition to
    Coughlin's various statements related thereto, during his testimony and on the media admitted into
    evidence) testiIied that RPD OIIicer Duralde committed misconduct by lying about the purported order
    or point in time in relation to the arrest and search oI Coughlin and Duralde's Iirst coming into
    possession oI the iPhone. Goble testiIied that Duralde removed the phone Irom Coughlin's pocket and
    that Duralde had the phone with him when he Iirst presented to Goble to ask question related to the
    phone and to veriIy ownership oI the phone (which would include gathering the phone number Ior the
    iPhone, which necessarily would mean that Duralde's allegation oI only searching Coughlin aIter
    perIorming some call to the iPhone and hearsaying it vibrate (even though multiple witness
    (Templeton, Zarate, Goble, Lichty testiIied that they heard no such buzzing or vibrating oI the phone,
    hostile witnesses all) Goble testiIied that Duralde already had the iPhone prior to Goble conIerring
    with Duralde or otherwise giving Duralde any phone number to call in an attempt to veriIy the phone
    revealing an incoming call LED display scree light up alert (Goble's statements that the phone would
    "light up" and that he, as Duralde quotes him in the Narrative, "could not hear the phone
    30/60
    000069
    I have 30 days Irom the date oI conviction to report a conviction to the State Bar oI Nevada and the
    United States Patent and Trademark OIIice (USPTO) Ior these two convictions "possessing or
    receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
    I note that WCPD Jim Leslie, while still attorney oI record Ior me on this cases RCR2011-063341, had
    served (see attached) a subpoena on ECOMM and Kelley Odom on 10/03/12. Given that Mr. Leslie
    was not relieved as my counsel until at the earliest 10/22/12 (so Judge SIerrazza's contention that
    Coughlin "has had Iorever to get his deIense ready in this case" and that "no continuance will be
    granted on account oI the Iormal disciplinary hearing beIore the State Bar oI Nevada" being scheduled
    just 5 days prior to the 11/19/12 resumption oI trial in rcr2011-063341 (and despite Judge SIerrazza
    indicated some canon preventing him Irom testiIying at the Iormal disciplinary proceeding...that didn't
    stop 063341 being speciIically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin,
    as was Judge CliIton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
    Townsend Irom sending into the SBN Coughlin's 2/12/12 Iiling in that Judge CliIton case rcr2012-
    065630 and oIIering to send into the SBN Coughlin's 2/15/12 Iiling in 063341). Add to that the Iact
    that Coughlin never received Irom Leslie Goble's call records until Leslie Iinally released them o
    October 30th, 2012...and it really is not accurate to say Coughlin had "Iorever" to prepare his case.
    Coughlin had to pull together a deIense in his Iormal disciplinary hearing beIore the SBN despite the
    SBN gipping him out oI every aspect oI SCR 105(2)(c) (ie, not 30 days notice oI the hearing on
    11/14/12 aIter service oI the Complaint and Designation oI Witnesses and Summary oI Evidence is
    aIIected pursuant to SCR 109 and SCR 105(4)...But the point is, iI the RJC and both oI you want to be
    associate with a SchaeIIer style Mirch-ing, then this may be your chance. But you won't be able to say
    you didn't have plenty oI opportunities to put this thing aside, because there are a multitude.
    It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena
    duces tecum....Mr. Leslie's Iailure to turn over anything to me in the "hand oII transmittal" he insisted
    upon (despite a digital transmission being required per the Order oI Judge SIerrazza, I believe) requires
    some explanation.
    So to requiring explanation is the Iact that the cd provided by Reno City Attorney Skau in an apparent
    good Iaith attempt to comply with Judge SIerrazza ordering him to comply with the subpoena duces
    tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it oI
    8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin
    Lichty's cellular phone, 775 233 8593, which Goble is seen in the attached still Irame picture culled
    Irom a video Coughlin took oI the moments prior to the arrival oI the RPD, being handed by the "man
    with the gauged ears" Lichty reIerred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton
    testiIying that they do not know that man and did not know him prior to that night at all....Coughlin
    respectIully demanded oI the RPD OIIicers, at the time oI his arrest, that they gather the identiIy oI the
    "man with the gauged ears", however, OIIicer Duralde et al reIused to (claiming Coughlin's allegations
    oI their having attacked him and attempting to steal his bike and or dog, reach into his pockets, and
    push him up against oncoming traIIic on the Center Street bridge were "unsubstantiated"). Oddly, in the
    attached still Irame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin
    Lichty that Goble utilized to make his two 911 calls that evening, the Iirst (iI the Iile name time
    stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
    ECOMM text logs reveal an E911 entry oI 11:23:36 pm (its unknown whether the exact time a 911 call
    31/60
    000070
    comes in is designated on the "Calls Ior Service Inquiry Response" Coughlin was provided recently).
    The EComm text logs reveals a second E911 entry Ior the 775 233 8593 number (belonging to Austin
    Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law
    license away Irom me Ior at least 5 years, iI not Iorever....and DDA Young...over some alleged "skater
    sets his iPhone down on the concrete in the middle oI the ice rink plaza downtown on 8/20/11 at 11:20
    pm ish in Reno, "man with a six pack oI beer" picks it up, oIIers it up, receiving no response threatens
    to "throw it in the river iI someone doesn't claim it immediately" whereupon Goble's Iriend Nate Zarate
    apparently (according to RPD Duralde's Narrative oI unknown origin date") told Goble he saw
    Coughlin pick it up oII the ground (as Duralde recounts hearing Irom Goble in his Narrative)
    contain the 911 call by Coughlin
    So, in the Iile named "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11
    PM SourceID 17 063341 duralde i'll be out on him" one can hear OIIicer Duralde indicating he will
    "be out on him on the Center Street bridge" aIter he has leIt his squad care and is shortly to appear in
    the video Coughlin Iilmed oI the arrest, title:
    Then, OIIicer Rosa is proven to be on the bridge and not in his squad car reading texts Irom dispatch n
    the Iollowing time stamped Iile: "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20,
    2011 11-26-30 PM SourceID 12 RPD Rosa saying charles 396 on the other end"
    Further, OIIicer Duralde's arrival on the scene is notated in the dispatch log at the
    Its not at all clear why Goodnight only apparently received then Iorwarded to his client on November
    30th, 2011 the "Original Supplemental" containing OIIicer Duralde's Narrative, that is still oI
    indeterminate date oI origin (there are a number oI "date oI printing" variations...).
    That I know oI, there were three 911 calls (two by Goble, one by Coughlin, in that order):
    1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc oI phone susps os leIt on
    post lighting up in sups pock RP screaming at susp
    2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone
    just socked a minor, waive that cop down 10 10 with open line
    3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call Irom phone with open
    line yelling re stealing phone people cheering cops are here then call disconnects
    And Coughlin Iilmed three videos that night oI the arrest that are relevant, two just prior to the RPD
    arriving (and actually, while Rosa and Duralde were already on the scene and out oI their vehicles aIter
    teh 11:26:00 pm mark as indicated by the Ecomm recordings and dispatch logs...
    1. VID20110820232413 your all on tape now goble and Iriends.3gp 8 seconds long
    2. VID20110820232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery
    Coughlin jusrt prior to RPD rcr.3gp 46 seconds
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    3. VID20110820232801 oIIicer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
    And the AT&T call records Ior the iPhone reveal only Iour calls occurred in or out during the relevant
    time Irame:
    Goble's AT&T records:
    44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
    45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
    46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
    47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
    Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..."
    Previous to that, DDA Young had successIully kept every single witness Irom speciIically identiIying
    who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'.
    But, Goble is a selI involved twit, who snaps his Iingers "Oh, that's Colton" 8 Ieet Irom Judge SIerrazza
    and swaggers out oI the court room. And Leslie reIused to seek admission oI the misconduct oI a
    prosecution witness....Goble, batterying Coughlin with a lit cigarette, that Coughlin capture on tape, on
    June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on
    6/7/12...and had his law license suspended in 60838 Iour hours later by a 3 Justice Panel (including
    Justice Hardesty, whom recused himselI Irom Coughlin's wrongIul termination suit against Washoe
    Legal Services...and you might not like me Ior that suit, but iI you look at the circumstances oI my
    Iiring therein (I was hurrying to Iinish a non-proIit gets stuck with the building's private landlord's
    property taxes appeal due on 3/10/12 Ior Paul Elcano, and had a Trial beIore Judge Linda Gardner in a
    divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty oI research
    beIorehand...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
    Iigure that out...WLS took 6 weeks to cut a check Ior subpoena Iees....the usual)...
    Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence
    exclusively hearsay testimony (oIten unattributed to anyone in particular) to support his win on the
    "suIIicient probable cause to support a search incident to arrest" despite NRS 171.136 Iorbidding such
    an arrest (where Duralde obviously overcharged the alleged crime as a "Ielony grand larceny"...even
    making smug commentary about the "certain beneIits oI charging this as a Ielony" and saying "oooh,
    that's a Ielony", both matters that Leslie insisted reIraining Irom getting into while he was attorney oI
    record, and Iurther, despite Coughlin complying with NRS 174.345 (even splurging on the return
    receipt requested to go along with the certiIied mail Ior Duralde) Coughlin was denied the right to cross
    examine the arresting oIIicer...which is too bad considering his Narrative alternately claims that Goble
    told him they
    DDA Young's complaint Iails to alleged someone other than Coughlin stole the property, which it must,
    to support the receiving or possessing stolen property charge.
    COUNT II. POSSESSION OF STOLEN PROPERTY, a violation oI NRS 205.275, a misdemeanor, in
    the manner Iollowing, to wit:
    That the said deIendant on or about the 20th day oI August, 2011, at Reno Township, within the County
    oI Washoe, State oI Nevada, did willIully and unlawIully possess or withhold stolen goods having a
    value less than Two Hundred FiIty Dollars ($250.00), to wit: an iPhone, at or near 1 North Center
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    000072
    Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, Ior his own gain
    or to prevent the true owner Irom again possessing said property, knowing that the property was
    obtained by means oI larceny or under such circumstances as should have caused a reasonable man to
    know that such goods were so obtained.
    POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that
    the property was stolen by another. "
    It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574.
    Must allege the good were received Irom someone other than the deIendant: Gaddis, 424 U.S. 544,
    Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
    Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted oI violating 18
    U.S.C. 2113(a), (b), and (d) cannot also be convicted oI receiving or possessing the robbery
    proceeds in violation oI 2113(c). HeIlin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
    "(2) the State Iailed to prove beyond a reasonable doubt that the automobile had been stolen by a
    person other than plaintiII in error, a...The next assignment oI error is that the State Iailed to prove
    beyond all reasonable doubt that the automobile in question was stolen by some person other than
    plaintiII inerror. To sustain a conviction oI receiving stolen property the prooI must show (1) that the
    property has, in Iact, been stolen by a person other than the one charged with receiving it; (2) that the
    one charged with receiving it has actually received the property stolen or aided in concealing it; (3) that
    the receiver knew the property was stolen at the time he received it and (4) that he received the
    property Ior his own gain or to prevent the owner Irom possessing it. (People v. Piszczek,404 Ill. 465.)
    ProoI oI these essential elements constituting the crime oI receiving stolen property may be made by
    circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96
    N.E.2d 446.
    PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that iI a
    criminal conviction is to be upheld,
    | 21 Ill. App.3d 980 |
    the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394
    Ill. 325, 327 (1946)), and must contain the nature and elements oI the oIIense in order that the
    deIendant may Iully prepare a deIense and be aIIorded the constitutionally intended protection against
    double jeopardy. (People v. GriIIin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the indictment,
    drawn upon the conclusional premise that the property was stolen, Iails to allege that it was stolen by a
    person other than the one charged with receiving such property and, by this omission, creates the
    presumption that the possessor stole the property himselI. Since one person cannot be both the thieI and
    the receiver oI stolen property nor receive stolen property Irom himselI, the Iact that the property
    received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310
    Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v. Harris, 394 Ill. 325,
    329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860,
    863-864 (1971).) Lacking this element, the indictment Iailed to charge the oIIense oI receiving stolen
    property under section 16-1(d). A conviction under an indictment which does not charge an oIIense is
    void. People v. Edge,406 Ill. 490 (1950).
    The judgment is, thereIore, reversed....
    I Ieel that the majority has misconstrued the eIIicacy oI section 16-1(d) in arriving at a conclusion not
    urged by the deIendant. The omission oI the words "stolen by another" in the indictment does not create
    the presumption that deIendant had himselI stolen the property Irom the owner. The use oI the words "*
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    * * knowingly obtain control oI stolen property * * * under such circumstances that would reasonably
    induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly
    implies that when deIendant obtained control oI the property in question (in any manner whatsoever),
    the property had already been stolen by another. That is the plain and ordinary meaning oI the
    indictment.
    I believe the majority may be conIusing what can and cannot be reasonably implied Irom evidence
    introduced at trial with what may be implied Irom the clear phrasing oI the indictment. At trial it is not
    | 21 Ill. App.3d 981 |enough Ior the prosecution to merely show that the property in question was
    stolen property and that the deIendant was in possession oI that property in order to prove the oIIense
    oI theIt under 16-1(d) (the Iormer oIIense oI receiving stolen property). (People v. Baxa (1972), 50
    Ill.2d 111, 277 N.E.2d 876.) The deIendant's unexplained possession oI stolen property soon aIter a
    theIt is evidence that the deIendant stole the property himselI but is not evidence oI deIendant's
    receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
    860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology oI the indictment herein
    permits a reader oI the indictment to Iind, even aIter only a cursory reading, the necessary elements oI
    the oIIense, i.e., that the property was already stolen by another when the deIendant received it.
    While it may be true that the addition oI the words "stolen by another" would make the indictment
    more explicit, the addition oI these words would only be grammatically redundant and mere surplusage
    legally.
    The indictment, thereIore, was suIIicient to charge the deIendant with an oIIense under 16-1(d)(1).
    AIter a thorough examination oI the record, I do not believe that the evidence produced at trial was
    suIIicient to Iind the deIendant guilty beyond a reasonable doubt. For this reason I, too, would reverse
    the deIendant's conviction."
    Appellant correctly argues that the standard oI proving value, Ior conviction, is the same in "receiving"
    cases as in "larceny" and "theIt" cases. He erroneously urges that the state Iailed to meet that standard
    under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "|t|he true
    criterion Ior the value oI property taken is the Iair market value oI the property at the time and place it
    was stolen iI there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF,
    CLARK COUNTY 504 P.2d 695 (1972).
    SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
    by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
    himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
    receiving, | 484 P.2d 565 | but not oI both. People v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870 (Cal.
    1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States,
    365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States, 418 F.2d 567 (5 Cir.1969);
    Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court
    declined to give it. This was error, and later acknowledged by the court to be such when it set aside the
    receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner
    oI handling the error eIIectively cured it. The error was not cured by the setting aside oI the receiving
    conviction since there is no way oI knowing whether a properly instructed jury would have Iound the
    deIendant guilty oI burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both
    convictions should have been set aside and a new trial ordered"
    State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an
    essential element oI the crime oI receiving stolen goods..17. Criminal Law. In prosecution Ior receiving
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    000074
    stolen goods, where instruction given by court Iollowed language oI statute with reIerence to accused's
    intention to prevent the |61 Nev. 330, Page 336| owner Irom again possessing property, deIendant was
    not entitled to instruction which told jury that goods must have been received with Iraudulent intent oI
    depriving owner oI the immediate possession thereoI. Comp. Laws, sec. 10335."
    BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court oI Nevad: "At the
    conclusion oI a preliminary examination, Henny Bernier was ordered to stand trial Ior possession oI
    stolen property, a violation oI NRS 205.275.1 Bernier then petitioned Ior a writ oI habeas corpus
    contending the evidence adduced by the prosecution was insuIIicient to establish probable cause that
    she had committed the charged oIIense. The district court considered and denied her petition and
    Bernier here reasserts the same contention.
    Bernier does not deny having possessed the property; rather, she argues the prooI did not show that she
    knew the property was stolen and that such knowledge cannot be inIerred Irom mere possession.
    We agree that mere possession is insuIIicient to establish the requisite knowledge..."
    "Under Nevada law, Lane could not be convicted oI both robbery and receiving stolen property. This
    court reversed a conviction Ior possessing stolen property on the ground that the legislature did not
    intend to compound the punishment Ior larceny or robbery by permitting a conviction Ior receipt or
    possession oI the stolen property against the person who took the property. Point v. State, 102 Nev.
    143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
    State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that Ior a charge
    oI possession oI stolen property to stand, there must be a showing oI all the elements, and
    that iI even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
    206, 94 P. 218 (1908). Possession oI stolen property does not in itselI prove guilt oI the oIIense. Staab
    v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden oI prooI oI all three elements rests
    with the
    attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606
    NYS 2d 607.
    Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
    Judge Nash Holmes continues to reIuse to allow Couglin to appeal the "summary criminal contempt"
    Order, even though, given the incarceration was served, it is a Iinally appealable order, see Gilman 275
    V. Comm 474, 657 SE 2d 474.
    BiIurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474
    Terrell v. Miss. Bar 635 So 2d 1377. Matt oI Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem
    929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook
    88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
    1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d
    515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
    Whether Goble had "ownership" in iphone matter 920 P.2d 112
    Sheely 102 p.2d 96
    Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
    26405 and 03628 trespass case:
    unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
    Woods 19 NYS 2d 683
    Regan 425 NYS 2d 725
    Iorio, 410 NYS 2d 195
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    Russell v Kalian, 414 A.2d 462: expired warrant Ior eviction no good
    Leese v Horne, 47 P.2d 316
    Burhams, 89 P.3d 629
    Between the Iollowing two timestamped recordings Iinally provided by City Attorney Skau (WCPD
    Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
    prior to the arrival oI the peace to stay peaceIul in Coughlin's reIerences the then recent murder oI
    Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
    theIt oI a purse, and Lelise preIers to spend his time chiming in, unprompted, on the regard, arrogantly
    enough, that he can assist the court iI it Ieels Coughlin is "draggin' his Ieet" incident to the inappropriat
    placement by Judge SIerrazza oI Leslie as "stanby counsel" which really amounted to no more than yet
    another coercive practice put in place by Judge SIerrazza to Iurther his stated goal oI avenging the
    criticisms Coughlin levied upon him incident to Judge SIerrazza's incredibly questionable on-the-Ily
    pandering/remixing oI his Order oI 10/13/11 (iI Coughlin, as he, in Iact did, deposit a "rent escrow" oI
    $2,275, SIerrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawIul
    detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge SIerrazza on the
    record that "the use oI the term "Trial" was unIortunate, Your Honor..." whereupon Judge SIerrazza .
    You are to his constituency by remixing is previous order regardless oI the extent to which Coughlin
    was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they
    are and where only those aspects oI a summary proceeding that in year to the landlords beneIit were
    adhered to where is all oI the procedural and discovery protections attendant to a plenary unlawIul
    detainer trial and the ability to bring counterclaims were matters Coughlin was precluded Irom
    accessing by judge SIerrazza. Just Rosin is interesting approach to landlord tenant matters continued on
    with respect to the manner in which service was aIIected on November 3 in violation the courthouse
    sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division Iiling oIIice no less
    (and that is the same bailiII Plamondon managed to take the Iilings Coughlin submitted online
    November 15 out oI the criminal division Iiling oIIice oI the Reno justice court where Robbin Baker it
    Mr. Coughlin let them in her position well prior to the 5 PM closing oI that Iiling oIIice and with DVDs
    attached to those Iilings Coughlin swears under penalty oI perjury that Ms. Baker admitted this to him
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID
    18.mp3
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
    5.mp3
    In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed Irom
    representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public deIender applying
    good nicely peers deciding that the night was doing too much to assist Coughlin in deIending himselI
    and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy
    session while Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good
    night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial
    on July 16, 2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought
    to the court in custody seeded Jeremy Bosler was suddenly Iilling in Ior Goodnight with and indication
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    Goodnight's December 19, 2011 Iile stamp discovery requests served upon the stay and district attorney
    Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the DeIendant,
    ZACHARY BARKER COUGHLIN, by and through his attorney oI record, Joseph W. Goodnight,
    Deputy Public DeIender, and hereby requests the Iollowing discovery pursuant to NRS 174.235 to NRS
    174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
    conIessions made by the DeIendant or any witness, or copies thereoI, within the possession, custody or
    control oI the State, the existence oI which is known or by the exercise oI 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." It is telling the extent to which on the
    record at that July 16 trial date Washoe County public deIender Jeremy Bosler indicated that Jim Leslie
    would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And
    that Leslie would be prepared to try the case by Friday and that the court could step matter Ior trial on
    Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have
    completed all the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the
    case whether or not that evinced any sort oI concern Ior his client, ability to zealously advocate on his
    client behalI or willingness to do so, or indication that Jim Leslie Ielt that the judges oI the Reno Justice
    Court would hold him to a standard oI care at all tending to indicate that Mr. Leslie has any skin in this
    game whatsoever.
    Clearly there is a bases Ior mistrial here were Jim Leslie's entire contribution to the representation oI
    Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing
    disregard Ior the rules oI proIessional conduct an intentional maniIestation oI Leslie's desire to secure a
    conviction the Washoe County District Attorney's OIIice and therein secure added boys Irom local law
    enIorcement District Attorney's OIIice and perhaps the Reno justice court itselI. Further Reno
    Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County
    public deIenders oIIice in connection with February 27, 2012 clandestine status conIerence between
    Biray Dogan and Zach Young which neither Dogan nor Young has ever reIuted whether they they have
    been sworn prior thereto or not an especially where Dogan's coworker down the hall civil division
    deputy Dist. Atty. Mary has been involved throughout the conIiscation without a search warrant or
    court order oI any kind (or at least one ever served on Coughlin in any manner) oI Coughlin smart
    phone and micro SD card incident Judy impermissible summary contempt Iinding by judge Nash
    Holmes just two hours aIter the clandestine status conIerence between Dogan young on February 27,
    2012 in RMC case 11 TR 26800 Ior which Dogan and Young stipulated to a continuance in 06 RGC
    065630 in light oI the scheduling conIlict between that traIIic citation trial in the Reno Muni court
    which stemmed Irom Coughlin's being retaliated against vice RPD Sargent Tarter in connection with
    Coughlin telling Tarter one oI the top 30 highest-paid city oI Reno employees oI and admission to
    taking bribes Irom Richard Hill by RPD oIIicer Chris Carter Junior incident to Carter placing Coughlin
    in handcuIIs pursuant to a custodial arrest based upon a criminal complaint Ior trespass Iind by Richard
    Hill on November 13, 2011. That criminal trespass conviction has now become the subject oI a Nevada
    Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent
    Marcia Lopez oI the misconduct by herselI oIIicer Chris Carter, Jr. Richard G. Hill, Esq. and his
    landlord client, and a summary eviction matter that judge SIerrazza presided over wherein judge
    SIerrazza purportedly controlled the civil division oI the Reno justice court to the extent that Coughlin's
    notice oI appeal on December 26 submitted Ior Iiling December 26, 2011 was not Iile stamped by the
    civil division staII oI the Reno justice court. This impropriety is Iurther problematic where Coughlin
    38/60
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    had served upon the Reno justice court's custodian oI records and she civil clerk Karen Stancil (whom
    Richard Hill reIerences in his January 12, 2012 letter her grievance against Coughlin to the State Bar oI
    Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar oI Nevada, which
    ultimately became one oI the three grievances depicted numerically in the caption oI the SBN v.
    Zachary Barker Coughlin SCR 105 Complaint Iiled by the State Bar stamped August 23, 2012 (in
    addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial
    in 11 TR 26800 held in violation oI NRS 178.405 by way oI NRS 5.071 (RJC and RMC under one
    rooI, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC
    judges including then Administrativ Judge William Gardner, who reIused to recuse himselI Irom the
    criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's Iormer
    law oIIice upon Coughlin being subject to a custodial arrest by oIIicer Chris Carter on November 13,
    2011, resulting in a criminal trespass conviction oI Coughlin in 11 CR 26405 where it RPD Sargent
    Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or
    her partner oIIicer Carter issued caught Coughlin a trespass warning prior to eIIectuating a custodial
    arrest on that day in where Lopez also admits none oI those individuals or anyone present that day
    identiIied themselves as law enIorcement prior to landlord meritless kicking down the door to a
    crawlspace about 5 Ieet high underneath the Iormer home law oIIice wherein Coughlin was Iound at a
    time when Coughlin still had not receive back Irom the Reno justice court the impermissible $2275 rent
    escrow deposit judge SIerrazza ordered in violation oI Nevada law considering judge SIerrazza's
    admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was
    correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule
    44 that may support the secret quote house rules been Iact in the civil division oI the Reno justice court
    wherein tenants were in summary eviction matters were subject to Iorced rent escrow deposit in
    violation oI justice court rules civil procedure 83 and that the Reno justice court had neither published
    nor had approved by the Nevada Supreme Court any sort oI corollary to justice court rule Las Vegas
    rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongIul arrest connected thereto
    occurred even where the Washoe County SheriII's oIIice deputy Machen Iiled a Ialse aIIidavit on
    November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction
    Decision and Order and the October 27th Findings oI Fact, Conclusion oI Law, and Order oI Summary
    Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial oI
    Coughlin Irom which Judge William Gardner reIused to recuse himselI despite the Iact that his sister
    judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the
    "Clerk oI Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
    sanctioning Coughlin incident to a divorce matter where and he was representing a victim oI domestic
    violence on behalI oI our Washoe legal services (a rather interesting approach by Iormer prosecutor
    judge Linda Gardner in comparison to the extremely light touch demonstrated by judge SIerrazza and
    judge CliIton oI the Reno justice court incident to deputy district attorney Young's repeated
    malIeasance misconduct violations stays pending competency or evaluations Iailure to turn over
    exculpatory materials Iailure to propound discovery Iailure to respond reasonable discovery requests
    demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions
    oI Coughlin this year Ior charges which young either amended to in advance implicating Supreme
    Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint Irom a misuse oI 911
    charge to do a charge more deleterious to Coughlin's proIessional license as a lawyer and/or patent
    agent by amending the charge nearly a year aIter the January 14, 2012 arrest in the matter to a charge
    that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good Iaith eIIort
    to achieve a plea-bargain and resolve what is a messy case the city oI Reno Police Department and
    emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-
    39/60
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    000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services
    or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely
    suspect rolling this year by judge Schroeder oI the Reno justice court against Coughlin in the extremely
    quick like 40 min. Irom Iiling quick issuance oI up temporary protection order to Richard G Hill on
    January 12, 2012 in connection with Hill's Iraudulent abuse oI process and Ialse statements to police
    oIIicers aIIecting the arrest custodial arrest oI Coughlin on January 12, 2012 will jaywalking (Hill lied
    to RPD oIIicer Hollingsworth in alleging that Coughlin had already lost his appeal oI summary eviction
    matter in 1708 Barber which judge SIerrazza presided and which was then on appeal beIore judge
    Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney Iee award against
    Pro per appellant Coughlin in the appeal oI the summary eviction order issued by Judge SIerrazza and
    1708 on March 30, 2012 incident to and motion Ior attorneys Iees Iiled by Casey D Baker oI Hill's
    oIIice on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty.
    young Iastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom
    "randomly" was assigned to Coughlin appeal oI the petty larceny conviction oI a candy bar and some
    cough drops Irom Walmart in 11 CR 22176 (the sole basis Ior Coughlin's current temporary suspension
    oI his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming Irom an arrest on
    September 9, 2011 that was violative oI Nevada law where tribal police oIIicers aIIected a custodial
    arrest Ior a misdemeanor (much less one not alleged to have occurred in their presence) in violation oI
    the express dictate against doing so Iound in NRS 171.1255 should especially where Walmarts sole
    witness testiIying at the petty larceny trial, would be dentist Thomas Frontino, whom testiIied on behalI
    oI the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest Ior misdemeanor petty
    larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard just seeing
    $83 worth oI groceries allegedly consuming a candy bar and or some cough drops while doing so...
    Despite the Iact that that Walmart alleges to have had absolutely no video Iootage supportive oI its
    allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and
    where French you admit that his supervisors had previously indicated to hand a desire to retaliate
    against Coughlin in connection with Coughlin's questioning
    some oI Walmarts policies and where John Ellis oI the W. 7th St., Walmart in any as yet unknown loss
    prevention associate speciIically and expressly threatening abuse oI process against Coughlin on July 7,
    2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and
    customer service managers many oI whom have had that position Ior over a decade routinely claim do
    not remember the return policy or restated in a manner that depart substantially Irom the policy which
    Walmart holds out to the public on its website Walmart.com and which on that website speciIically
    makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the
    convenient Ior getting in misremembering oI Walmarts managers may indicate the policy actually is.
    Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 aIIected a
    citizen"s arrest oI Coughlin on that date in connection with the alleged petty larceny by Coughlin oI a
    candy bar and some cough drops which conveniently Ior the Reno Police Department just days aIter
    Coughlin Iiled a written complaint detailing the police misconduct by Reno Police Department oIIicer
    Grohl and Rossa incident to the arrest oI Coughlin the wrongIul arrest oI Coughlin on August 20, 2011
    in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin
    (despite the Iact that the majority viewpoint throughout American jurisprudence that one cannot be
    charged with both petty larceny and receiving stolen property oI the same item particularly where the
    receiving oI the item is alleged to have been Irom oneselI aIter one had larceny is the item lending an
    inIerence that Joe SIerrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as
    possible to aIIect the leverage over Coughlin to mitigate the liability Reno justice court may Iace in
    connection with its numerous since is violating about law respecting the manner in which evictions are
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    carried out and or the misconduct oI local law enIorcement and prosecutors in carrying out retaliatory
    arrest and prosecution oI Coughlin where the judiciary in Washoe County is oII criticizes being overly
    inIluenced by the District Attorney's OIIice. That Walmart petty larceny conviction stemmed Irom a
    trial beIore Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school oI law
    whom Coughlin's twice Iormer Reno Municipal Court appointed public deIender Keith Loomis (not in
    the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed deIender there despite
    his express Iailure to rule that jail time was not a possibility in his pretrial order and where mandatory
    authority exists requiring that he then appoint Coughlin court appointed counsel particularly where
    Coughlin established his indigency. Judge Howard's malIeasance in connection with that conviction oI
    Coughlin extends Iurther the extent that he early on in that November 30 trial on it in 2011 reviews
    Coughlin Ior causing the November 14 trial setting to have been continued only to in a 3 min. add-on at
    the conclusion oI the hearing which are trial which judge Howard down such a matter oI public
    concern that he Five city oI Reno employees at the courthouse until nine o'clock at night to get it done
    that in Iact judge Howard admitted he was wrong with respect to the cause oI the continuance oI the
    14th 2012 trial that was not Coughlin Iault that all and where the Reno Municipal Court had previously
    granted a continuance to the city oI Reno prosecutor's in the very criminal trespass prosecution oI
    Coughlin stemming Irom Richard G Hill Esquire's criminal trespass complaint (connected to the
    summary eviction matter over which judge SIerrazza presided) where the Reno Municipal Court Ireely
    granted Richard G are the product the city oI Reno prosecutor's a continuance in light oI Richard G
    Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week
    vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge
    SIerrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction
    matter 1708 required by law within 10 days oI Coughlin Iiling his motion to contest personal property
    lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging
    Coughlin reIused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as
    Janice admitted when judge SIerrazza called her is oI his own witness at the December 20, 2012
    hearing that was Iinally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be
    able to control the justice court in his desired to prevent such a hearing been set until he returned Irom
    his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to
    contest personal property lien judge SIerrazza ordered Karen Stancil and Joslyn John is oI the Iiling
    oIIice oI the Reno justice court to Iile in unsworn statements purporting to prove that Coughlin
    somehow Iailed to allow the justice court to setting hearing on his motion to contest personal property
    lien however that doesn't explain the extent to which bailiII Plamondon was able to apparently without
    Coughlin's permission serve Coughlin a violation oI the courthouse century Dr. and a notice oI it
    November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was
    seeking axis justice court Iiling oIIice Ior something unrelated to bailiII Plamondon's desire to aIIect
    service oI some notice oI the hearing upon Coughlin.
    Keith Loomis, Esq., RMC, court appointed deIendner, admits to having been close Iriends with in law
    school and to this day Loomis himselI in 1982 graduate McGeorge school law along with wash County
    Dist. Atty. Richard Gammick, both oI whom were one year ahead oI Reno justice court judge CliIton
    whom recently granted 2004 graduate McGeorge school oI law deputy district attorney Zach young in
    order taking away the ability to Iile by Iax Irom Coughlin a privilege that is accorded any other
    criminal deIendants in the Reno justice court despite the Iact that that order was granted at the
    November 27, 2012 hearing at which Coughlin's then attorney public deIender Biray Dogan was
    relieved as counsel and where at that hearing Dogan himselI admitted that he had not received the
    motion young alleged who Iiled on November 26, 2012 seeking such an order Irom judge CliIton
    barring Coughlin's ability to Iax Iile or send young it a Iax oI any sort apparently or perhaps Tom
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    000080
    despite the Iact that Coughlin had merely comply with judge CliIton's request that he provide judge
    CliIton something supportive oI Coughlin's contention that Biray Dogan had utterly Iailed her by the
    advocacy zealous are not oI any sort whatsoever incident to his quote representation oI Coughlin" in
    065630).
    (again, judge SIerrazza as a Iormal tribal judge and director oI Indian legal services and Coughlin's
    Iormer client Pete Eastman, recently admitted to Coughlin both oI the State Bar oI Nevada
    communicated he and his wiIe Ialse assertions respecting a non-existent order against Coughlin by
    Nevada Bankruptcy Court Judge Beesley (the State Bar oI Nevada listed as having a specialization in
    creditors rights at www.nvbar.org) (Iormer law practice partners with an individual Irom Washoe Legal
    Services whom Coughlin is suing in 60302, Karen Sabo, Esq., Iormerly oI Beesley Peck, LTD and
    whom trashed Coughlin's work beIore him and in Nevada Bankruptcy Court at Coughlin's November
    14, 2012 Iormal disciplinary hearing to which judge Beesley's testiIying was not noticed to Coughlin
    previous to the hearing and in violation oI Supreme Court rule 109 a violation made all the worse in
    light oI the Iact it bar counsel Pat King had known oI any involvement oI judge Beesley in any matters
    relative to the ultimate Supreme Court rule 105 complaint against Coughlin Ior over six months at least
    and so in no way can be said to just stuII I his last-minute supplementing judge Beesley and
    milquetoast attempts to provide Coughlin S supplemental designation oI witness and summary oI
    evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services
    Executive Director Paul TESTIMONY at the hearing (both oI those gentlemen attended McGeorge
    school oI law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both oI them
    oIIered strong opinions disapproving oI Coughlin's competency as an attorney at the hearing despite the
    Iact that neither oI them could provide anything in the way oI speciIicity with regard to what issues
    they would take with any oI the work they reviewed oI Coughlin's or judge Beesley's case Iilings in
    judge beIore judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court
    Rule 121's conIidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin
    Iormal disciplinary hearing him on behalI oI recently as oI November 8, 2012 reinstated attorney
    Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 Irom his clients and
    using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge
    Beesley sees competency in Mr. Harris and could overlook the $755,000 Ior my client where it be $14
    worth oI candy bars and cough drops Irom Coughlin and Coughlin's March 30, 2012 Iiling in Cadle Co.
    v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at
    2:30 pm in representing Mr. Keller that was aIIected by the Iraudulently procured order Ior summary
    eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire
    Brown judge Schroeder oI the Reno justice court wherein the audio record Irom that proceeding
    indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary
    eviction case against Coughlin through despite Judge Schroeder admittedly having had a diIIerent order
    oI hearing the cases planned Ior that morning docket and despite the Iact that the Iax header on the
    summary eviction order that was hurriedly moved through indicates a time stamping oI a 8:24 am Ior a
    hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County SheriII's oIIice deputies
    Cannizzaro entered and broke into Coughlin's rental sometime shortly aIter 1 PM that same day,
    3/15/12, without announcing themselves as law enIorcement and where they entered with their guns
    and/or pagers drawn in and immediately placed Coughlin in handcuIIs and told him he was detained in
    contrast to the typical procedures carried out by the SheriII's oIIice incident to evictions in Washoe
    County. Incident to that summary eviction (where the docket, at least, more review is necessary,
    indicates that Kern and Western Nevada Management's Sue King switched up their basis Ior an eviction
    42/60
    000081
    all the sudden in their 3/15/12 Iiling oI a Landlord's AIIidavit that suddenly changed the basis Ior
    seeking an eviction to one Ior non-payment oI rent (seemingly in response to Coughlin Pre Hearing
    BrieI pointing out the diIIiculties they would Iace under Glazer in pursuing a No Cause, particularly
    against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the
    Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably
    sublessors to Coughlin). in the third grievance against Coughlin Iorming SCR 105 complaint Ior which
    a Iormal disciplinary hearing, the grievance Iiled by Judge Dorothy Nash Homes in NG12-0402.
    Judge Beesley and Judge Nash Holmes attended McGeorge School oI Law together in 1977. Perhaps,
    the Iiling that Judge Beesley was reIerring to when he threw Coughlin under the bus at Coughlin's
    11/14/12 Iormal disciplinary hearing (with one oI the three grievance numbers listed in the Complaint,
    which the SBN and Panel will claim also IulIilled the Hearing required by 60838 Ior the Wal-Mart
    candy bar conviction that resulted in the current now 5 month long suspension oI Coughlin's license to
    practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin Iiled the Iollowing:
    Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
    Entered: 3/30/2012 BrieI
    Docket Text: BrieI in Opposition to Notice oI DeIault and Praecipe/Intent to take DeIault with
    CertiIicate oI Service Filed by ZACH COUGHLIN on behalI oI SAMANTHA L. HALL, ROBERT
    KELLER (Related document(s)49 Notice oI Entry oI DeIault Iiled by PlaintiII CADLE CO.)
    (Attachments: # (1) AIIidavit AIIidavit oI Counsel Coughlin Ior Keller in Support oI Opposition# (2)
    Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals
    and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding
    excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 Iax to rmc
    regarding deIiciency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND
    MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
    In submitting that somewhat inIlammatory 3/30/12 Iiling (which curiously seemed to immediately
    result in Judge Nash Holmes entering an Order oI the same date in 11 TR 26800 whereby she Order
    Coughlin's property released to him, though DDA Mary Kandaras dragged her Ieet until April 7th, 2012
    beIore Iinally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
    admitted to having released to the City oI Reno Marshals on 2/28/12, denied having the micro sd card,
    denied the micro sd ever being booked into property, alleged to have given Judge SIerrazza's Iormer
    tribal court BailiII and Iormer Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the
    jail at Coughlin's request to get Coughlin's keys so Eastman could arrange Ior Coughlin's dog Jackson
    Pawluck to be Ied and cared Ior during Coughlin's summary 5 day incarceration).
    Coughlin put his client's interest ahead oI his own (where Coughlin would arguably be better oII letting
    the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card conIiscating without a
    warrant/5 day summary contempt jail sentence Ior testiIying that an RPD Sargent lied in connection
    with his testimony about the Richard G. Hill, Esq. retaliatory issuance oI three traIIic citations outside
    Hill's law oIIice, where RPD Sargent John Tarter told Coughlin to leave aIter Coughlin presented upon
    being released Irom jail incident to a three-day stay stemming Irom Hill's line 2 Reno Police
    Department oIIicers and managing caught to get Coughlin subject to custodial trespassing arrest
    (detailed at length in 61901) and Hill reIusing to give Coughlin his drivers license law accuser clients
    Iiles and Coughlin reporting to Sargent John Tarter at that time that three days prior to that Reno Police
    43/60
    000082
    Department oIIicer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him
    as he too was on Richard Hill's payroll that RPD OIIicer Chris Carter, Jr admitted to Coughlin: "Yes,
    Richard Hill pays me a lot oI money so I arrest who he says to arrest and I do what he says to do..." and
    where both oIIicer Carter and Sargent Marcia Lopez reIused to undertake any diligent inquiry response
    to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill Ior the Iull
    rental value oI the 121 River rock property Ior the month oI November that was commiserate with the
    same $900 that Coughlin was previously charged Ior the Iull use an occupancy oI the premises. The
    lackluster Iailure to query Hill with any diligence by both oIIicer Carter and Sargent Lopez is
    reminiscent oI what Reno Municipal Court Court appointed deIender Keith Loomis Esquire in 1982
    graduate McGeorge school oI law told Coughlin at an April 10, 2012 trial date in that criminal trespass
    matter wherein Reno Municipal Court judge William Gardner reIused to recuse himselI Irom hearing
    that case against Coughlin despite the Iact that at that time he had Iiled a grievance with the State Bar
    oI Nevada against Coughlin by way oI the NG 12 0434 grievance that his Iellow RMC judge Dorothy
    Nash Holmes Iiled
    Judge Beesley Iormerly partnered with now Washoe Legal Services child advocacy director Karen
    Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes conIiscating
    Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any
    permissible interpretation oI a search incident to arrest given Coughlin property had been booked into
    his personal property at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily
    sentencing Coughlin to 5 days in jail Ior contempt, despite citing to a non summary civil contempt
    statute in NRS 22.010 and NRS 22.100, but characterizing her Order as Iinding Coughlin guilty oI the
    "misdemeanor oI criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt
    statute, which is not summary in nature, and thereIore requires more due process, and despite Judge
    Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even
    said what Holme's alleged he did in rendering her "second bit at the apple" oI 3/12/12 in comparision to
    her 2/28/12 Order Finding DeIendant in Contempt and Imposing Sanctions...In Nevada, a Summary
    Contempt Order under NRS 22.030 (which is civil in nature) Ior conduct not committed in the
    immediate presence oI the Court (such as the alleged conduct involving a restroom and disassembling a
    smart phone or recording device and hiding some component part thereoI in the restroom that Judge
    Nash Holmes murkily, hazily, and vaguely testiIied to during Coughlin's 11/14/12 Iormal disciplinary
    hearing, and which she included in the Order she rendered in that traIIic citation case stemming Irom
    Coughlin being told to leave Hill's law oIIice upon appearing their demanding his keys, wallets, driver's
    license, and client's Iiles shortly aIter being released Irom a 3 day custodial arrest stay in jail incident to
    Hill's criminal trespass Complaint against Coughlin at Coughlin's Iormer home law oIIice (in RJC2011-
    001708, the eviction matter presided over by Judge SIerrazza). Like the Order Judge Linda Gardner
    claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis
    FV11-03383 (see attached in Exhibit 1), Judge SIerrazza attempted to characterize the Order he entered
    on 12/21/12 Iollowing a very contentious six hour hearing on Coughlin's November 17th, 2011 Iiled
    stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to Contest
    Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was
    certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge SIerrazza
    may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere
    wherein Richard Hill was permitted to joke along with Reno justice court bailiIIs radius in chieI bailiII
    Sexton as to the Iact that he to quote would like to stick some things up Coughlin's ass" in reIerence to
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    000083
    multiple incidents where Reno justice court bailiIIs had either as bailiII arrested told Coughlin that he
    would put his Ioot oI Coughlin's ass or made commentary as chieI Sexton did to Coughlin respecting
    Sexton's indication oI Coughlin on two diIIerent occasions the week oI Thanksgiving 2011 that
    Coughlin indicated that the Iiling oIIice and/or not attempt to Iile documents so close to the 5 PM
    closing time oI the Iiling oIIice. (see attached in Exhibit 1).
    and him him him him and him In Iact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes,
    inaccurately:
    "4. We represent Dr. Matthew MerIiss, a physician Irom Chico, CaliIornia. Dr. Merliss owns the
    property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was leased to
    Mr. Coughlin and his then-girlIriend. The lease expired in February 2011. The girlIriend leIt the
    community in approximately May 2011. Dr. Merliss contacted us in approximately August 2011 to
    assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that
    there were habitability issues with the property that justiIied his withholding rent. All oI his clahns
    were decided adversely to his position at the eviction hearing. Justice oI the Peace Peter SIerazza
    ordered Coughlin evicted Irom the premises eIIective November 1, 2011. On that date, the Washoe
    County SheriIIs Department perIormed their normal eviction procedure: locks were changed and the
    eviction notice was posted on the Iront door. We videotaped the home and its contents at that time.
    Upon inspection over the next Iew days, it became apparent that "somebody" was breaking into the
    home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at
    the home on River Rock Street. As we walked through the home, it was obvious that"
    One, it is not true Ior Hill to write "The lease expired in February 2011." The Standard Rental
    Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in
    accordance with the NRS 118A holdover tenant provision. Further, it is not accurate Ior Hill to write
    "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with
    Coughlin's Iormer co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment
    payments to make up Ior the Iact that she took Coughlin's $450 contribution to the $900 Ior each oI the
    months oI May 2011 and June 2011 and only sent the landlord Merliss $550 Ior May 2011 and nothing
    Ior June 2011. Coughlin provided Ms. Ulloa with $450 Ior each oI those months, and thereIore, in
    combination with Dr. Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa Irom
    a grand larceny charge oI a variety to which the two petty larceny charges Coughlin Iaced shortly aIter
    Ms. Ulloa's secretly absconding with Coughlin's rental contributions (which Coughlin was only made
    aware, and the concomitant rent due, upon an August 11th, 2011 email Irom the landlord Merliss).
    Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 beIore Judge
    SIerrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices,
    in violation oI NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an
    agreement with Coughlin Ior a rent deduction oI $350 going Iorward in exchange Ior Coughlin
    "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artiIicial turI
    installation Coughlin had installed in an enterprising approach which the landlord's landscaper Ior the
    other property Merliss owned next door and his quasi real estate broker property manager Darlene
    Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually
    claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn
    Service to "deal with the weeds" at Coughlin's Iormer home law oIIice. "Dealing with the weeds", to
    Green Action Lawn Service, included tearing up Coughlin's artiIicial turI installation leaving Street
    causing Coughlin's law oIIice substantial losses lost proIits time away Irom work and expenses
    45/60
    000084
    associated with immediately mitigating the criminal conduct oI green action lawn service where they
    not only tore up the artiIicial turI installation even though they knew it was there prior to submitting
    their bid Ior services to landlord Merliss, who apparently did not realize or remember that he had also
    assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange Ior Coughlin
    quote dealing with the weeds. Green action lawn service sought close the artiIicial turI installation
    Coughlin put into place oI his Iormer law oIIice the week prior to their tearing it up and leaving
    industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
    Hill's grievance oI 1/14/12 to the SBN goes on to allege:
    "Someone had been in there since I had last been in several days beIore. Dr. Merliss discovered that the
    basement door was barricaded (not locked) Irom the inside. The Reno Police Department was
    summoned. They tried to coax whoever was in the basement out, without success. AIter Dr. Merliss had
    to kick the door down, it "was discovered that Mr. Coughlin had broken in and was in the basement. He
    was arrested and is presently Iacing criminal trespass charges in Reno Municipal Court. See case no. 11
    CR 26405 21. He is also Iacing a contempt motion in Iront oI Judge SIerrazza in the eviction case.
    SIerazza has stayed that matter pending the resolution oI the criminal trial. That was scheduled Ior
    January 10, 2012, but was continued at the request oI Mr. Coughlin's new attorney.
    5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628,
    pending in Department 7. As part oI the eviction process, a lien was asserted against the personal
    property that Coughlin leIt behind at the home. On November 16, 2011, Coughlin Iiled a motion to
    contest the landlord's lien in the Reno Justice Court. The court tried to promptly set a hearing, but
    Coughlin reIused to cooperate in setting the matter, and the court took it oII calendar. Coughlin then
    reinitiated that process and a hearing was held in December, at which time the court heard evidence oI
    Coughlin's lack oI cooperation in setting the November hearing. You may also want to contact Reno
    Justice Court staII, and in particular, chieI clerk Karen Stancil, about Mr. Coughlin's abusive treatment
    oI her and her staII. AIter the hearing, the court issued an Order granting Coughlin a two-day time
    window to remove his personal property. The Iirst day was Thursday, December 22, 20 11. AIter
    Coughlin was allowed into the home that Iirst day, he sent out an e-mail to the eIIect that because he
    had appealed Judge SIerazza's order, he was entitled to a stay oI proceedings and was to resume in the
    home. As a result, he did very little to remove any oI his personal property that day. On Friday,
    December 23, 2011, aIter he learned, again, that his stay had been denied, Coughlin assembled a small
    crew and they were able to remove a substantial amount oI his personal property. (You need to
    understand that Mr. Coughlin is a hoarder. We have the photos and videos iI you would like to see
    them.) However, Mr. Coughlin did not get all oI his property out. For example, I counted 13 car seats
    that he had somehow managed to get down into the basement.
    Having Iailed to remove all oI his belongings, Mr. Coughlin then moved beIore Judge Flanagan Ior a
    temporary restraining order to prevent the disposal oI his abandoned property in accordance with Judge
    SIerazza's order. Attached is Mr. Coughlin's motion, my oIIice's opposition, and Mr. Coughlin's reply.
    These documents demonstrate Mr. Coughlin's complete and utter incompetence as an attorney.
    On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request Ior a temporary restraining order.
    On January 12, 2011, the contractor hired to clean the house commenced work. Mr. Coughlin Ilagged
    the contractor down in traIIic when he (the contractor) was on his way to the dump with the abandoned
    property Irom the house. Coughlin called the police, who arrived at the transIer station. Coughlin was
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    Ialsely asserting that the contractor had tried to run hin1 over. He also told the police "
    The ECOMM recordings (at least what Skau decided to divulge, Iinally) can be described thusly:
    PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory Goble's
    Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM SourceID 43
    Duralde saying 153 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM SourceID 46
    Rosa saying 396 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM SourceID 13
    reporting party advised they are now at Iirst and center.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM SourceID 21
    probably Duralde saying 153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM SourceID 12
    RPD Rosa saying charles 396 on the other end.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM SourceID 14
    unintellible short statement sounds like guilt nexus.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM SourceID 41
    probably Duralde saying Reno C153 twenty three.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM SourceID 43
    probably a dispatcher saying c153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM SourceID 17
    Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID 18
    Probably a dispatcher saying Charles 153.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID 17
    Dispatcher indicating Reno C153 wagon available Ior a male.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID 26
    someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID 42
    probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID 28
    odd by somebody c153 seems to split in middle yet still one Iile.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID 22
    Duralde saying Reno c153 rtI returning.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID 27
    Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
    5 Rosa saying Charles 396.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM SourceID
    19 Rosa saying 29 white male.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM SourceID
    24 man saying come and split that up then Iemale dispatcher saying go ahead with that.wav
    Zach Coughlin
    47/60
    000086
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlinhotmail.com
    Zach has 24 Iiles to share with you on SkyDrive. To view them, click the links below.
    PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory
    Goble's Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-11 PM
    SourceID 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell phone susp os also
    loud verb disturb.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM
    SourceID 43 Duralde saying 153 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM
    SourceID 46 Rosa saying 396 en route.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM
    SourceID 13 reporting party advised they are now at Iirst and center.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM
    SourceID 21 probably Duralde saying 153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM
    SourceID 12 RPD Rosa saying charles 396 on the other end.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM
    SourceID 14 unintellible short statement sounds like guilt nexus.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM
    SourceID 41 probably Duralde saying Reno C153 twenty three.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM
    SourceID 43 probably a dispatcher saying c153.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM
    SourceID 17 Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
    PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM
    SourceID 18 Probably a dispatcher saying Charles 153.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID
    17 Dispatcher indicating Reno C153 wagon available Ior a male.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID
    26 someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-16-41 AM SourceID
    13 Duralde indicated he will be en route to main station to drop oII Coughlin's smartphone Ior
    copying data prior to depart.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID
    42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID
    28 odd by somebody c153 seems to split in middle yet still one Iile.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID
    22 Duralde saying Reno c153 rtI returning.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID
    27 Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
    PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-41 AM SourceID
    6 Duralde's wiIe Jessica c151 reno, Alaksa can you switch to share some inIormation call please.wav
    48/60
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    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM
    SourceID 5 Rosa saying Charles 396.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM
    SourceID 19 Rosa saying 29 white male.wav
    SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM
    SourceID 24 man saying come and split that up then Iemale dispatcher saying go ahead with
    that.wav
    11 30 12 063341 updated motion Ior new trial with ex 1 attached in 2 pages per Iormat.pdI
    Download all
    --Forwarded Message Attachment--
    Close Print
    Case No. RCR2011-063341
    From: Jeannie Homer (HomerJreno.gov)
    Sent: Thu 11/08/12 2:48 PM
    To: zachcoughlinhotmail.com
    3 attachments
    Motion Ior Protective Order toQuash Subpoenas and Ior Protective Order Regarding Issuance
    oISubpoenas.pdI (2.2 MB) , Motion Ior Protective Order toQuash Subpoenas and Ior Protective Order
    Regarding Issuance oI Subpoenas|Part 2|.pdI (1442.4 KB) , Ex Parte Emergency Order
    PendingHearing.pdI (81.0 KB)
    Please see attached documents Irom Creig Skau, Deputy City Attorney:
    1) Motion Ior Protective Order to Quash Subpoenas and Ior Protective Order Regarding Issuance oI
    Subpoenas (part 1 & 2)
    2) Ex Parte Emergency Order Pending Hearing (set Ior November 13, 2012 at 9:00a.m.)
    Thank you.
    Jeannie Homer
    Legal Secretary
    1 East First Street, 3rd Floor
    Reno, Nevada 89505
    (775)334-2050
    (775)334-2420/Iax
    homerjreno.gov
    ATTORNEY-CLIENT PRIVILEGE
    This e-mail message transmission and any documents, Iiles or previous e-mail messages attached to it
    are conIidential, and are protected by the attorney-client privilege and/or work product doctrine. II you
    are not the intended recipient or a person responsible Ior delivering it to the intended recipient you are
    49/60
    000088
    hereby notiIied that any review, disclosure, copying, dissemination, distribution or use oI any oI the
    inIormation contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. II you
    have received this transmission in error, please immediately notiIy us by Iorwarding this e-mail to the
    sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
    Fwd: FW: Case No. RCR2011-063341
    From: Creighton C. Skau (skaucreno.gov)
    Sent: Fri 11/09/12 11:45 AM
    To: zachcoughlinhotmail.com
    Cc: Jeannie Homer (HomerJreno.gov)
    1 attachment
    photo|1|.JPG (181.2 KB)
    Dear Mr. Coughlin,
    Please be advised that Judge SIeraza authorized service upon you by email in an Order.
    Accordingly, authorized service has already been eIIected.
    Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
    alternatives:
    1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
    UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
    purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
    you to obtain the documents, as set Iorth hereaIter.
    2. The Court provided us with an address which you provided to the Court. That address is 1471
    E. 9th St.,
    Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
    but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
    you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
    the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
    leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
    3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
    pick up at our OIIice, third Iloor oI City Hall.
    The Judge's signed Order, entered November 8, 2012, states:
    IN THE JUSTICE COURT OF RENO TOWNSHIP
    COUNTYOF WASHOE, STATE OF NEVADA
    STATE OF NEVADA,
    PlaintiIIs,
    vs.
    COUGHLIN, ZACHARY BARKER
    DeIendant.
    50/60
    000089
    CASE NO.: RCR2011-063341
    DEPT. NO.: 2
    EX PARTE EMERGENCY ORDER PENDING HEARING
    This matter has come beIore the Court based upon the Iollowing circumstances:
    A. The Reno City Attorney`s OIIice ('RCAO) represents a number oI City oI Reno employees
    who have been named in subpoenas. The RCAO contacted Court personnel on November 7, 2012 to
    request a time to appear Ior an order shortening time regarding a motion to quash and Ior protective
    order. Due to the proximity oI the trial date in this matter, November 19, 2012, the Court directed the
    RCAO to Iile and serve its substantive motion and provide notice that the matter would be heard on
    November 8, 2012 at 9:00 am. The City oI Reno Iiled its motion on November 7, 2012.
    B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared
    on behalI oI the RCAO and the City employees requesting protective relieI. Zack Young was present
    in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belieI that the
    Public DeIender`s oIIice represented Mr. Coughlin, that the Public DeIender was served believing this
    was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himselI this morning and
    attempted to call and leIt a voice mail message with a phone number believed to be Mr. Coughlin`s at
    8:30 this morning.
    C. The Court is advised that the Public DeIender, Jeremy Bosler and the City oI Reno ChieI
    Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and Iiled requests Ior
    relieI similar to the RCAO`s requests.
    D. The Court read the RCAO`s motion in preparation Ior the hearing. Due to the absence oI notice
    to Mr. Coughlin, no argument was received on the merits oI the motion. However, the Court Iinds that
    the RCAO`s motion and supporting materials present a suIIicient evidentiary basis to issue this Order.
    The Court deeming itselI suIIiciently inIormed and good cause appearing thereIore,
    IT IS HEREBY ORDERED as Iollows:
    1. A hearing on the merits oI these matters is hereby set beIore this Court Ior 9:00 a.m. on
    November 13, 2012. Oral presentations shall be limited to 10 minutes each. The Clerk shall notiIy Mr.
    Bosler and Mr. Wong oI the hearing.
    51/60
    000090
    2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance
    with NRS 174.305 is hereby quashed. Any subpoena not personally served by a non-party or otherwise
    properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on
    any other grounds such as relevancy or undue burden until the hearing on the merits.
    3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), eIIective until the hearing
    on this matter on November 13, 2012, to the eIIect that upon service oI this Order on DeIendant
    Zachary Barker Coughlin, DeIendant Coughlin shall not thereaIter issue or cause to be issued or serve
    or attempt to serve or cause to be served any subpoena or subpoena duces tecum in this case unless he
    has Iirst presented the proposed subpoena or subpoena duces tecum to the Court Ior the Court`s review
    regarding adequacy, relevancy and necessity oI the subpoena or subpoena duces tecum, and suIIiciency
    oI the proposed method oI service.
    4. Counsel Irom the Reno City Attorney`s OIIice is directed to promptly attempt to serve a copy oI
    this Order and the RCAO`s motion and any supplements by personal service upon Zachary Barker
    Coughlin at the address in the Court`s Iile, 1471 E. 9th Street, Reno, NV 89512, with a copy mailed to
    said address. Service shall also be attempted by email at 'zachcoughlinhotmail.com.
    Dated this |8| day oI November, 2012.
    /s/
    JUSTICE OF THE PEACE
    The City oI Reno's Motion states:
    JOHN J. KADLIC
    RenoCityAttorney
    CREIGTON SKAU
    Deputy City Attorney
    NevadaState Bar No. 34
    P.O. Box1900
    Reno, Nevada 89505
    (775) 334-2050
    (775) 334-2420 Fax
    Attorneys Ior City oI Reno
    IN THE JUSTICE COURT OF RENO TOWNSHIP
    COUNTYOF WASHOE, STATE OF NEVADA
    STATE OF NEVADA, Case No. RCR2011-063341
    PlaintiIIs, Dept. No. 2
    vs.
    COUGHLIN, ZACHARY BARKER,
    /
    MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE
    ORDER REGARDING ISSUANCE OF SUBPOENAS
    52/60
    000091
    COMES NOW, City oI Reno ('City), as the employer and on behalI oI Reno Police
    Department OIIicers Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley and Reno
    Emergency Communication Center employees Savannah Montgomery and Scott Weese (and any other
    City employees (collectively 'City employees) whose names were unreadable in subpoenas), by and
    through their counsel oI record, John J. Kadlic, Reno City Attorney, and Creig Skau, Deputy City
    Attorney, and hereby moves this Court Ior an order to quash the subpoenas claimed to have been served
    on Ior these City employees in violation oI Justice Court Rules oI Civil Procedure (JCRCP) 45 and Ior
    the entry oI a protective order pursuant to the
    ///
    JCRCP 26. This Motion is based upon the attached memo oI Points and Authorities, the attached
    Exhibits and any additional or Iurther evidence the Court deems just and proper.
    I. Statement oI Facts
    The Iollowing procedural background is relevant to this matter:
    On October 26, 2012, City oI Reno Emergency Communication Center employees (ECOMM) Suzy
    Rogers and Kelley Odom received emails Irom Zach Coughlin containing nine (9) Subpoenas, copies
    oI which are attached as Exhibit '1 and incorporated herein by reIerence.
    On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail inIorming him,
    among other things, the City oI Reno Police Report and City oI Reno ECOMM materials regarding
    Case Number RMC 2011-063341were available Ior pick-up provided he submit payment to the City oI
    Reno Ior $108. A copy oI the letter is attached as Exhibit '2 and incorporated herein by reIerence. On
    November 5, 2012, this same letter was sent again to Mr. Coughlin by certiIied mail to the same two
    addresses.
    This correspondence also inIormed Mr. Coughlin that the Iour (4) subpoenas he claimed to have served
    regarding the appearance oI the City employees Ron Rosa, Thomas Alaksa, Savannah Montgomery and
    Scott Weese were ineIIective because oI a Iailure to comply with JCRCP 45(a) and/or JCRCP 45(b).
    The letter indicated because service oI the subpoenas Ior these Iour (4) individuals was ineIIective,
    these individuals would not be appearing on November 19, 2012. (Exhibit '2).
    On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a 'Notice oI Errata and
    Revised Supplemental Motion For a New Trial by sliding them
    through the security glass in the Iront oIIice oI the Reno Police Department at approximately 4:50 p.m.
    aIter being told the oIIice was closed. Three (3) subpoenas contained in this packet are duplicates. As
    such, this packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM
    employees Kelley Odom and Suzy Rogers. A copy oI this packet is attached as Exhibit '3 and
    incorporated herein by reIerence.
    On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM
    employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in earlier
    subpoenas duces tecum. These subpoenas also contained multiple pages oI requests Ior materials
    unrelated to Case RMC RCR2011-063341. A copy oI these documents is attached as Exhibit '4 and
    incorporated herein by reIerence.
    On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call Irom Mr. Coughlin
    regarding the letter this oIIice mailed on November 2, 2012. Among other things, Mr. Coughlin did not
    indicate he would be withdrawing his subpoenas Ior Ron Rosa, Thomas Alaksa, Savannah
    Montgomery and Scott Weese. Mr. Coughlin did state to have these witnesses ready Ior trial.
    On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum
    containing seventeen (17) pages oI blended documents regarding matters pending beIore Reno Justice
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    Court on November 19, 2012 and the State Bar OI Nevada Northern Nevada Disciplinary Board to the
    Reno Police Department. The subpoena duces tecum on the Iirst page oI the packet contains many
    unreadable names. A copy oI the packet is attached as Exhibit '5.
    On November 6, 2012 City employee Marshall Joe Harley was handed a packet oI materials Irom an
    unidentiIied person. The cover sheet oI the packed is entitled 'Subpoena Duces Tecum regarding
    Case RCR2011-063341. This document also appears to contain names oI other individuals but the
    handwriting is unreadable. It is not known iI the other individuals on this subpoena are City
    employees. A headnote on the Subpoena indicates that iI the requested documents are e-mailed to Mr.
    Coughlin, personal appearance may not be required. A copy oI the packet is attached as Exhibit '6.
    II. Argument :
    A. Service
    JCRCP 45 addresses subpoenas. In pertinent part it states:
    (b) Service.
    (1) A subpoena may be served by any person who is not a party and is not less than 18 years oI age.
    Service oI a subpoena upon a person named therein shall be made by delivering a copy thereoI to such
    person and, iI the person's attendance is commanded, by tendering to that person the Iees Ior one day's
    attendance and the mileage allowed by law. When the subpoena is issued on behalI oI the State or an
    oIIicer or agency thereoI, Iees and mileage need not be tendered. Prior notice, not less than 15 days, oI
    any commanded production oI documents and things or inspection oI premises beIore trial shall be
    served on each party in the manner prescribed by Rule 5(b).
    The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on
    October 26, 2012 and November 3, 2012 and re-delivered to the Reno Police Department on November
    2, 2012 and November 6, 2012 commanding the appearance oI the many diIIerent City employees
    above are deIicient and ineIIective as they Iail to comply with personal service requirement oI JCRCP
    45(b). Accordingly, service was ineIIective and all oI the subpoenas should be quashed.
    In addition to the Iailure oI personal service, all oI Mr. Coughlin`s subpoenas reIerenced in Exhibits
    '1, '3, '4 and '5, also:
    Violate JCRCP 45(a)(1)(D) in that they do not set Iorth the text oI subdivisions (c) and (d) oI JCRCP
    45.
    Violate JCRCP 45(b)(1) which states that a 'subpoena may be served by any person who is not a party
    to the proceeding. All oI the subpoenas were e-mailed to City ECOMM employees Kelley Odom,
    Kariann Beechler and Suzy Rogers on October 26,
    2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2,
    2012 and November 6, 2012 by Mr. Coughlin, a party in this matter.
    Violate JCRCP 45(b)(1) which states that service oI a subpoena commanding attendance requires that
    payment Ior one day`s attendance and the mileage allowed by law. No witness Iee or mileage Iee has
    been submitted by Mr. Coughlin Ior the appearance any named City employee.
    Violate JCRCP 45(c) which states that a party or attorney responsible Ior the issuance and service oI a
    subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to
    the subpoena. Mr. Coughlin is serving a litany oI subpoenas on many City departments and City
    employees regarding this case. However, he is also serving subpoenas on City departments and City
    employees on a multitude oI other cases and proceedings that are unrelated to the instant action. These
    subpoenas are unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing, seek
    inIormation that is irrelevant to this action and violate the applicable procedural rules.
    54/60
    000093
    Based on the above, the requirements oI JCRCP Rule 45 have not been met and the subpoenas Ior
    all City employees to appear on November 19, 2012 must be quashed. The City
    also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom,
    Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not
    relate to the City or to this matter.
    B. Protective Order
    In accordance with JCRCP 26, the City seeks a protective order in this matter. As described above, Mr.
    Coughlin, a Nevada attorney with a suspended license, is abusing the subpoena process granted to him
    by this Court. He is e-mailing multiple City employees or dropping oII the same subpoenas (some oI
    which relate to this matter and many which relate to a State Bar proceeding or other criminal matters)
    at multiple City departments. This is creating conIusion and leading to a waste oI time and resources
    oI public saIety employees. As an attorney, Mr. Coughlin should be aware oI the subpoena process.
    This is not the Iirst matter in which Mr. Coughlin has abused a court procedural matter. For this
    Court`s inIormation, Reno Municipal Court Judge Holmes issued a Sua Sponte Order Denying RelieI
    Sought in Improper Document on March 13, 2012 Iinding, among other things, that Mr. Coughlin
    Iailed to Iollow proper legal procedure in preparing and Iiling motions in a matter pending beIore that
    Court and that Mr. Coughlin blatantly abused that Court`s Iax Iiling process. As such, that Court
    ordered that Mr. Coughlin be prohibited Irom Iaxing any documents to that Court. A copy oI this
    Order is attached as Exhibit '7.
    Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectIully seeks an Order
    Irom this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this
    Court Ior review prior to issuance and service to ensure Mr. Coughlin is seeking relevant inIormation
    regarding a speciIic case and is Iollowing the appropriate legal process.
    III. CONCLUSION
    Based on the above, it is respectIully requested that this Court issue an order:
    To quash the subpoenas Ior Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel
    Harley or any other City employee whose names were unreadable in the subpoenas Ior Iailure to
    comply with JCRCP Rule 45;
    To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann
    Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the
    City or to this matter because they Iailed to comply with JCRCP Rule 45.
    Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any
    subpoena he intends to serve in this matter to this Court Ior review prior to issuance and service to
    ensure Mr. Coughlin`s subpoenas are relevant and Iollow the appropriate legal process.
    AFFIRMATION
    The undersigned does hereby aIIirm that the preceding document Iiled in this court does not
    contain the social security number oI any person.
    RESPECTFULLY SUBMITTED this day oI November, 2012.
    JOHN J. KADLIC
    Reno City Attorney
    By:
    CREIGTON SKAU
    Deputy City Attorney
    55/60
    000094
    P.O. Box 1900
    Reno, NV 89505
    Attorneys Ior City oI Reno
    As to the other matters addressed by you below, I work in the Civil Division and I have no
    knowledge or authority to address them. I suggest that you take up those matters with the attorney(s)
    assigned to them.
    Sincerely,
    Creig Skau
    Deputy Reno City Attorney
    -----Original Message-----
    From: Jeannie Homer homerjreno.gov~
    To: "'bonyrreno.gov'" bonyrreno.gov~, "'skaucreno.gov'" skaucreno.gov~
    Date: Fri, 09 Nov 2012 08:50:18 -0800
    Subject: FW: Case No. RCR2011-063341
    FYI
    From: Zach Coughlin |mailto:zachcoughlinhotmail.com|
    Sent: Thursday, November 08, 2012 8:36 PM
    To: HomerJreno.gov; complaintsnvbar.org; hazlett-stevenscreno.gov; robertspreno.gov;
    kadlicjreno.gov; IIlahertydlpId.com; patrickknvbar.org; tsusichnvdetr.org
    Subject: RE: Case No. RCR2011-063341
    couldn't open them, and I don't accept service oI anything Iorm you... See Allison Ormaas comments
    on 3/12/12 in 11 tr 26800 with respect to your oIIices violation oI the RMC Rules to the extent there is
    not diIIerence technologically anymore between an email and a Iax:
    Rule 5: Motions/Pleadings by Facsimile
    A. All rules and procedures that apply to motions/pleadings Iiled in person at the court shall also
    apply to motions/pleadings Iiled by Iacsimile, except as otherwise speciIied in this rule.
    B. All motions/pleadings Iiled by Iacsimile will only be accepted through the clerk's oIIice (775-
    334-3824).
    C. Except by prior court approval, a motion/pleading by Iacsimile shall not exceed IiIteen (15) pages
    in length, including the cover sheet and exhibits. A document shall not be split into multiple
    transmissions to avoid the page limitation.
    D. Each transmitted page shall bear sequential numbers in the transmission.
    E. All persons are eligible to use motion/pleading-by-Iacsimile procedures.
    F. All motions/pleadings Iiled by Iacsimile must be accompanied by a cover sheet which must
    include the person`s name, address, Iax number and telephone number.
    G. All Iacsimile motions/pleadings Iiled by an attorney must include the attorney's name, the Iirm`s
    56/60
    000095
    name, address, Iax number and telephone number. In addition, the attorney`s state bar number must be
    conspicuously displayed on the cover sheet.
    H. All motions /pleadings Iiled by Iacsimile must be accompanied by prooI oI service. Service may
    be accomplished by Iacsimile when the receiving party is a governmental agency, an attorney, or with
    the consent oI the receiving party. II service oI the motion/pleading is accomplished by Iacsimile the 3-
    day allowance Ior mailing shall not be computed into the time Ior response.
    I. A deIense attorney Iiling a motion/pleading in the Iirst instance must also Iile a proper
    authorization to represent.
    J. Any motion /pleading received by the court aIter 4:30 p.m. or on a non-court day shall be Iiled on
    the Iollo wing court day.
    Rule 6: Continuances
    No continuance shall be granted, including a stipulated continuance, except Ior good cause. A motion
    or stipulation Ior continuance must state the reason thereIore and whether or not any continuance has
    previously been sought or granted.
    Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where
    (despite Rich HIll getting a continuance agree to by then court appointed deIense counsel Lew Taitel,
    whose business partners Coughlin was suing in CV11-03015 and or CV11-03126, Taitel agreed to a
    continuance, in violation oI Coughlin's speedy trial right, where Hill needed to go on a six week
    vacation in 11 cr 26405) Roberts at Iirst agreed, in writing, to a continuance in response to Coughlin's
    request Ior one in 11 CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8
    violations on the day oI Trial, 11/30/12 by reIusing the stipulate to a continuance an blaming it on the
    Court.
    Pursuant to RMCR Rule 5(H), the City Attorney's OIIice does not have my consent to service via any
    means other than the traditional snail mail, usps, or personal service. And I am not currently included
    amongst those who are "attorneys", so you are stuck with that. Your oIIice on the other hand, Iits
    within both the 'governmental agency" and "attorney exceptions"...someone needs to tell Christopher
    Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served
    where he has been. Take, Ior instance
    Further, does your oIIice represent any oI the RMC's court appointed deIenders? Taitel, in 11 CR
    26405, Iailed to Iollow RMC Rules in withdrawing Irom representation:
    Rule 3: Authorization to Represent
    A. Attorneys representing deIendants shall promptly serve written notice oI their appearance with
    the City Attorney and Iile the same with the Court.
    B. An attorney desiring to withdraw Irom a case shall Iile a motion with the court and serve the City
    Attorney with the same. The court may rule on the motion or set a hearing.
    Further, these RMCR's seem to change out oI the blue, is there some record oI what changes were
    made and when?
    Hazlett-Steven's lies, in part, helped secure a dismissal oI my appeal in cr12-1262 (the appeal oI the
    Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner
    as to why Coughlin has a conIirmation oI delivery oI his timely under NRS 189.010 Notice oI Appeal
    in 11 cr 26405, yet D2 Iailed to Iile it, and the appeal in cr12-1262 was dismissed in light oI the
    combination oI both asserting, in one way or another, that the Notice oI Appeal was not received in a
    57/60
    000096
    timely manner. The delivery conIirmations say otherwise.
    Please remit $250,000 in the Iorm oI a certiIied check to the address below within 10 days in settlement
    oI these torts. SBN, please provide to me the grievance number associate with this new grievance that
    is created upon the successIul transmission oI this email.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlinhotmail.com
    utbound Iax report
    Inbox
    x
    Voxox noreplyvoxox.com
    Jun 27
    to me
    Hi zachcoughlin,
    You r Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
    ( 17753344226).
    Your Fax was delivered 08:54:28 PM on 2012-06-27.
    xoxo,
    The Voxox Team
    This message was intended Ior renoattorneygmail.com. Want to control which emails you receive
    Irom Voxox? Get Voxox: http://download.voxox.com and adjust your NotiIications in the
    Settings/PreIerences window. Voxox by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA
    92109.
    Voxox noreplyvoxox.com
    Jun 27
    58/60
    000097
    to me
    Hi zachcoughlin,
    Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
    ( 17753344226).
    Your Fax was delivered 09:16:58 PM on 2012-06-27.
    Voxox noreplyvoxox.com
    Jun 28
    to me
    Hi zachcoughlin,
    Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
    ( 17753344226).
    Your Fax was delivered 08:13:34 AM on 2012-06-28.
    Voxox noreplyvoxox.com
    Jun 28
    to me
    Hi zachcoughlin,
    Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
    ( 17753344226).
    Your Fax was delivered 09:04:24 AM on 2012-06-28.
    Voxox noreplyvoxox.com
    Jun 28
    to me
    59/60
    000098
    Hi zachcoughlin,
    Your Fax was successIully sent to 3ad3I15b-3a33-4863-a6cd-7934ec8I8b32general693298
    ( 17753343859).
    Your Fax was delivered 09:05:24 AM on 2012-06-28.
    Date: Thu, 8 Nov 2012 14:48:18 -0800
    From: HomerJreno.gov
    To: zachcoughlinhotmail.com
    Subject: Case No. RCR2011-063341
    Please see attached documents Irom Creig Skau, Deputy City Attorney:
    1) Motion Ior Protective Order to Quash Subpoenas and Ior Protective Order Regarding Issuance oI
    Subpoenas (part 1 & 2)
    2) Ex Parte Emergency Order Pending Hearing (set Ior November 13, 2012 at 9:00a.m.)
    Thank you.
    Jeannie Homer
    Legal Secretary
    1 East First Street, 3rd Floor
    Reno, Nevada 89505
    (775)334-2050
    (775)334-2420/Iax
    homerjreno.gov
    ATTORNEY-CLIENT PRIVILEGE
    This e-mail message transmission and any documents, Iiles or previous e-mail messages attached to it
    are conIidential, and are protected by the attorney-client privilege and/or work product doctrine. II you
    are not the intended recipient or a person responsible Ior delivering it to the intended recipient you are
    hereby notiIied that any review, disclosure, copying, dissemination, distribution or use oI any oI the
    inIormation contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. II you
    have received this transmission in error, please immediately notiIy us by Iorwarding this e-mail to the
    sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
    60/60
    000099
    Print Close
    State Bar of Nevada refusing to file stamp Respondent's pleadings
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 12/03/12 10:48 AM
    To: Patrick King ( (patrickk@nvbar.org); (davidc@nvbar.org) (davidc@nvbar.org); (tsusich@nvdetr.org)
    (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (mike@tahoelawyer.com)
    (mike@tahoelawyer.com); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
    (eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com); (skent@skentlaw.com)
    (skent@skentlaw.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); schornsby@nvdetr.org
    (schornsby@nvdetr.org)
    Please incorporate by reference all my filings with the Nevada Supreme Court into any
    answer or responsive pleadings you find I have filed.
    http://caseinfo.nvsupremecourt.us/public/caseSearch.do
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 30 files to share with you on SkyDrive. To view them, click the links below.
    12 1 12 ex 1 to notice to that laura peters is 0204 screen print bz.pdf
    12 1 12 ex 1 to notice that laura peters affidavit is whopper chocked 0204 bate stamped.pdf
    12 1 30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs
    attachment.pdf
    6 7 12 email to gammick and @nvbar.org four hours before 60838 suspension order 0204.htm
    6 9 12 Petty theft conviction leads to Reno lawyer's suspension - News - ReviewJournal.com.pdf
    6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
    6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
    6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
    6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
    6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
    6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
    8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
    000100
    8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
    8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
    8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
    10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
    10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
    10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
    10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
    10 22 12 60203 garin's respondent's brief back from tiff.pdf
    Download all
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; mike@tahoelawyer.com;
    complaints@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; skent@skentlaw.com
    Subject: RE: Mr Coughlin
    Date: Wed, 21 Nov 2012 21:22:16 -0800
    Dear SBN and Panel
    The Disciplinary Hearing File that Pat King purported to have copied and provided to
    me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
    not being filestamped...). Echeverria's very ruling on filing he was not mailed (to
    the extent that was the case, and perhaps it was a test) concedes at least the
    approval of filign by fax (express indication of the permissibility thereof in
    accordance with SCR 105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
    Please confirm that my filings, all of them, including the Motion to Show Cause of
    10/2/12, starting on bate stamp 02849 have been provided to all Panel members as
    the SBN has repeatedly indicated they would be (included the copying of all
    attachments, including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a
    file stamp (and it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs
    indicates...which means the SBN failed to Oppose the Motion to Dismiss, and the
    Complaint was dismissed prior to any other purported proof of service being
    effected (or spurious assertions of Coughlin dodging service given his numerous
    000101
    written correspondences and calls offering to meet Reno Carson or the SBN...until
    Coughlin finally just gave the SBN his physical address on 10/23/12, despite safety
    concerns....)
    Who gave you this order that you attached in the email of your's included below (the
    8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
    King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
    Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
    Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
    through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
    2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
    of these grievances? Did Mr. Susich disclose that conflict incident to the problems
    Maureen Cole had in carrying out the duties of her job as an attorney for the NV
    DETR and NERC?
    Please copy me on anything proving Chairman Susich so disclosed that conflict.
    Additionally, more and more frequently, when I question Laura Peters on some
    misstatement or attempt to mislead that she makes, she starts talking about getting a
    "protection order" or otherwise seeking to abuse process. Speaking of abusing
    process, due process namely, Peters was caught signing Certificates of Mailing for
    10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes
    system that Peters knew would not be picked up by the SBN's mail carrier the day the
    certificate of mailing indicated the would be, or at least were placed...Please explain
    how your office's certified mailing procedures work and comply with federal law.
    Additionally, I have review the materials you had Sierra Legal Duplicating provide
    and there is no indication of where materials such as the 8 28 12 Order sanctioning
    Coughlin generated from or whom transmitted them to the SBN. I had a discussion
    with Bar Counsel Clark over a year ago about whether there was some centralized
    method of keeping track of Orders sanctioning attorneys. He indicated there was not.
    Please indicate then, who provided you the various different Orders sanctioning
    Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
    Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial
    Family Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of
    Court for Department 3" (ie, of the Municipal Court's Department 3, which you fail to
    specify in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you
    000102
    that day about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even
    talkin' 'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out
    and about.) Pat, you are going to look like such an unbelievably compromised,
    crooked, and inept Bar Counsel when it is displayed what a tenuous thread each and
    every aspect of all these half baked grievances hang from.
    Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
    that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
    SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
    Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
    Panel is now in possession of the certified audio of the following transcripts:
    April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
    the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
    SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
    attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
    and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
    light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
    Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
    based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
    recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
    Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
    1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
    2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
    You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
    minute mark wherein the following exchange took place:
    Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
    April 2009 grievance onto the State Bar in the last two weeks
    Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
    Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
    Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
    will continue to be your attorney today."
    At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
    herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River
    Rock Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction
    where the nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any
    eviction notice or even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a
    case wherein Coughlin was representing a single father in a custody dispute based upon a judicial canon (see
    atached).

    King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
    000103
    grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434,
    and ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
    failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
    for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
    drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82
    worth of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see
    60838 and 61426:
    60838 Walmart case with Court's June 7th, 2012 Order suspending
    Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
    61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
    entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
    S
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
    0204 Coughlin Disciplinary Hearing File.pdf
    10 31 12 Order by Echeverria 0204.pdf
    12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
    12 15 11 22176 2064 Order by Howard on transcript costs.pdf
    11 21 12 notice of non service 063341 needs ex 1.pdf
    031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
    Download all
    > From: PatrickK@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: FW: Mr Coughlin
    > Date: Thu, 30 Aug 2012 20:48:18 +0000
    >
    > Good Afternoon Mr. Coughlin,
    >
    > Attached is an Order that pertains to you.
    >
    > I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
    expect to file an Answer?
    000104
    >
    > Thank you.
    >
    > Patrick King
    000105
    Print Close
    State Bar of Nevada refusing to file stamp Respondent's pleadings
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 12/03/12 10:48 AM
    To: Patrick King ( (patrickk@nvbar.org); (davidc@nvbar.org) (davidc@nvbar.org); (tsusich@nvdetr.org)
    (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (mike@tahoelawyer.com)
    (mike@tahoelawyer.com); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
    (eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com); (skent@skentlaw.com)
    (skent@skentlaw.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); schornsby@nvdetr.org
    (schornsby@nvdetr.org)
    Please incorporate by reference all my filings with the Nevada Supreme Court into any
    answer or responsive pleadings you find I have filed.
    http://caseinfo.nvsupremecourt.us/public/caseSearch.do
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 30 files to share with you on SkyDrive. To view them, click the links below.
    12 1 12 ex 1 to notice to that laura peters is 0204 screen print bz.pdf
    12 1 12 ex 1 to notice that laura peters affidavit is whopper chocked 0204 bate stamped.pdf
    12 1 30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs
    attachment.pdf
    6 7 12 email to gammick and @nvbar.org four hours before 60838 suspension order 0204.htm
    6 9 12 Petty theft conviction leads to Reno lawyer's suspension - News - ReviewJournal.com.pdf
    6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
    6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
    6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
    6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
    6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
    6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
    8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
    000106
    8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
    8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
    8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
    10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
    10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
    10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
    10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
    10 22 12 60203 garin's respondent's brief back from tiff.pdf
    Download all
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; mike@tahoelawyer.com;
    complaints@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; skent@skentlaw.com
    Subject: RE: Mr Coughlin
    Date: Wed, 21 Nov 2012 21:22:16 -0800
    Dear SBN and Panel
    The Disciplinary Hearing File that Pat King purported to have copied and provided to
    me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
    not being filestamped...). Echeverria's very ruling on filing he was not mailed (to
    the extent that was the case, and perhaps it was a test) concedes at least the
    approval of filign by fax (express indication of the permissibility thereof in
    accordance with SCR 105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
    Please confirm that my filings, all of them, including the Motion to Show Cause of
    10/2/12, starting on bate stamp 02849 have been provided to all Panel members as
    the SBN has repeatedly indicated they would be (included the copying of all
    attachments, including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a
    file stamp (and it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs
    indicates...which means the SBN failed to Oppose the Motion to Dismiss, and the
    Complaint was dismissed prior to any other purported proof of service being
    effected (or spurious assertions of Coughlin dodging service given his numerous
    000107
    written correspondences and calls offering to meet Reno Carson or the SBN...until
    Coughlin finally just gave the SBN his physical address on 10/23/12, despite safety
    concerns....)
    Who gave you this order that you attached in the email of your's included below (the
    8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
    King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
    Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
    Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
    through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
    2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
    of these grievances? Did Mr. Susich disclose that conflict incident to the problems
    Maureen Cole had in carrying out the duties of her job as an attorney for the NV
    DETR and NERC?
    Please copy me on anything proving Chairman Susich so disclosed that conflict.
    Additionally, more and more frequently, when I question Laura Peters on some
    misstatement or attempt to mislead that she makes, she starts talking about getting a
    "protection order" or otherwise seeking to abuse process. Speaking of abusing
    process, due process namely, Peters was caught signing Certificates of Mailing for
    10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes
    system that Peters knew would not be picked up by the SBN's mail carrier the day the
    certificate of mailing indicated the would be, or at least were placed...Please explain
    how your office's certified mailing procedures work and comply with federal law.
    Additionally, I have review the materials you had Sierra Legal Duplicating provide
    and there is no indication of where materials such as the 8 28 12 Order sanctioning
    Coughlin generated from or whom transmitted them to the SBN. I had a discussion
    with Bar Counsel Clark over a year ago about whether there was some centralized
    method of keeping track of Orders sanctioning attorneys. He indicated there was not.
    Please indicate then, who provided you the various different Orders sanctioning
    Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
    Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial
    Family Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of
    Court for Department 3" (ie, of the Municipal Court's Department 3, which you fail to
    specify in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you
    000108
    that day about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even
    talkin' 'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out
    and about.) Pat, you are going to look like such an unbelievably compromised,
    crooked, and inept Bar Counsel when it is displayed what a tenuous thread each and
    every aspect of all these half baked grievances hang from.
    Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
    that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
    SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
    Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
    Panel is now in possession of the certified audio of the following transcripts:
    April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
    the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
    SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
    attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
    and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
    light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
    Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
    based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
    recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
    Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
    1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
    2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
    You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
    minute mark wherein the following exchange took place:
    Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
    April 2009 grievance onto the State Bar in the last two weeks
    Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
    Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
    Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
    will continue to be your attorney today."
    At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
    herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River
    Rock Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction
    where the nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any
    eviction notice or even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a
    case wherein Coughlin was representing a single father in a custody dispute based upon a judicial canon (see
    atached).

    King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
    000109
    grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434,
    and ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
    failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
    for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
    drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82
    worth of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see
    60838 and 61426:
    60838 Walmart case with Court's June 7th, 2012 Order suspending
    Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
    61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
    entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
    S
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
    0204 Coughlin Disciplinary Hearing File.pdf
    10 31 12 Order by Echeverria 0204.pdf
    12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
    12 15 11 22176 2064 Order by Howard on transcript costs.pdf
    11 21 12 notice of non service 063341 needs ex 1.pdf
    031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
    Download all
    > From: PatrickK@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: FW: Mr Coughlin
    > Date: Thu, 30 Aug 2012 20:48:18 +0000
    >
    > Good Afternoon Mr. Coughlin,
    >
    > Attached is an Order that pertains to you.
    >
    > I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
    expect to file an Answer?
    000110
    >
    > Thank you.
    >
    > Patrick King
    PLEASE DIGITALLY TRANSMIT MY ENTIRE FILE TO ME
    IMMEDIATELY
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/30/12 3:12 AM
    To: jbosler@washoecounty.us (jbosler@washoecounty.us); bdogan@washoecounty.us
    (bdogan@washoecounty.us); complaints@nvbar.org (complaints@nvbar.org)
    just an hour and a half before Dogan's retaliatory "clandestine status conference" with
    DDA Young on 2/27/12 wherein he obtained an Order for Competency Evaluation from
    Judge Clifton. Please indicate whom Judge Nash Holmes is referring to from your
    office in her March 14th, 2012 letter to the SBN. Please email me my entire file and
    or fax it to me immediately, I have the trial in less than 14 days.
    Dear SBN, please file this as a formal grievance against Mr. Dogan including his utter
    failure to communicate with me as his client, beyond just generally doing absolutely
    nothing to defend the case, appearing in court, lying about whether he served or had
    served his Motion to Quash of 11/7/12 on me in rcr2011-063341, then smirking at me,
    and failing to display candor to the tribunal despite having any opportunity to
    afterwards, in addition to cackling from the peanut gallery with Jim Leslie during my
    Trial.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: bdogan@washoecounty.us
    000111
    Subject: RE: arraignment
    Date: Mon, 27 Feb 2012 12:04:46 -0800
    Dear Mr. Dogan,
    Was it abnormal for my case to be assigned to you on January 17th, 2012, prior to any
    arraignment? You and I discussed Chris Fortier calling and writing me ahead of
    the February 14th, 2012 arraignment as well. Is there some reason you were docketed
    as attorney of record well in advance of the arraignment, which, apparently, is contrary
    to the established practice in the RJC vis a vis WCPD's being assigned to cases?
    It is my understanding, from your email late last Friday, that the status conference that
    was set for today at 1:30 pm has been cancelled, though it has yet to be rescheduled.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    Subject: RE: arraignment
    Date: Fri, 24 Feb 2012 16:29:04 -0800
    From: BDogan@washoecounty.us
    To: zachcoughlin@hotmail.com
    Your case has been continued. I will send the new court date by mail.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, February 22, 2012 6:36 AM
    To: Dogan, Biray
    Subject: arraignment
    'Sup Biray,
    I went and got the arraignment done today....Judge Pearson informed me we have a
    mandatory 2/27 1:30 STATUS Conference RJC with in rcr12-065630
    However, I already had a "Trial" set in bench trial 11 tr 26800 RMC (ticket number 544281) 1pm feb 27th Judge
    Holmes (talk to cashiers) right of way stop sign, can you get a continuanc brokered on the status conference.
    Judge Pearson said you are my attorney of record in this matter, though you haven't been communicating with me
    much far as I can tell and you guys hung up on me last we spoke.
    Hope to hear from you, amigo,
    000112
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000113
    Print Close
    11 23 12 AMENDED SUPPLEMENTAL TO RESPONDENT'S
    EMERGENCY MOTION TO SET ASIDE, ALTER OR AMEND ALL
    ORDERS SO FAR BY NNDB, SBN, PANEL, OR BOARD, AND
    NOTICE OF IRREGULARITIES OF PROCEEDINGS THUS FAR
    and SUPPLEMENT TO VERIFIED ANSWER OR RESPONSE TO
    WHATEVER EX
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/23/12 5:32 PM
    To: (je@eloreno.com) (e@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (davidc@nvbar.org)
    (davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
    (eifert.nta@att.net); (mike@tahoelawyer.com) (mike@tahoelawyer.com); (patrickk@nvbar.org)
    (patrickk@nvbar.org); (skent@skentlaw.com) (skent@skentlaw.com); fflaherty@dlpfd.com
    (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org
    (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org)
    Please find attached and let me know if you want yours faxed as well
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    11 23 12 0204 RESPONDENT'S AMENDED SUPPLEMENTAL WITH EX 1 ATTACHED ALL 2025 BATE STAMPED PAGES OF
    IT.pdf

    Chief Marshal Roper and Marshal Harley on setting the record straight
    in NG12-0435
    000114
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/23/12 4:09 PM
    To: roperj@reno.gov (roperj@reno.gov); harleyj@reno.gov (harleyj@reno.gov); je@eloreno.com
    (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com (cvellis@bhfs.com);
    eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
    patrickk@nvbar.org (patrickk@nvbar.org); christensend@reno.gov (christensend@reno.gov);
    mike@tahoelawyer.com (mike@tahoelawyer.com); davidc@nvbar.org (davidc@nvbar.org);
    fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
    (fflaherty@dyerlawrence.com); stuttle@washoecounty.us (stuttle@washoecounty.us); wongd@reno.gov
    (wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov); mkandaras@da.washoecounty.us
    (mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
    bdogan@washoecounty.us (bdogan@washoecounty.us); jleslie@washoecounty.us
    (jleslie@washoecounty.us); holmesd@reno.gov (holmesd@reno.gov)
    Dear Panel, Judge Nash Holmes, Chief Roper, Marshal Harley, Bar Counsel, et al,
    I apologize for using email to communicate here, but my current indigency and time
    constraints so require it. Further, I in no way wish to violate any Orders by any of the
    RMC Judges respecting emailing or contacting the RMC in connection with specific
    cases, and submit this limited correspondence in the hopes that my interpretation of any
    such Orders is in line with reality and will forgive at least this limited use of email
    outside of any attempt to file anything in any of the matters in which I am a party
    before the RMC. The exigency involved here relates primarily to the enormous
    deference that will be given to the Panel's decision in the SBN v. Coughlin disciplinary
    matter, and my desire to have the Panel afforded every opportunity to have all essential
    information necessary to arrive at a just decision at its disposal. What follows is in part
    a request and in part a recognition of the extent to which Judge Nash Holmes's action
    during the 2/27/12 Trial in 11 TR 26800 may likely have been the best thing to have
    had done, owing to her vast experience in these and a great deal many other matters,
    and, hopefully, will have an upbeat result stemming therefrom.
    At the Double R Blvd. Northern Office of the State Bar of Nevada, RMC Judge Nash
    Holmes, on 11/14/12, testified under oath and indicated something along the lines of
    the following:
    During the 11 TR 26800 "simple traffic citation Trial" on 2/27/12, starting at about 3
    pm, Judge Holmes interrogated Coughlin as various points throughout the Trial as to
    whether he was recording the proceedings (without permission), and or whether he had
    a "recording device" (whether every laptop anyone brings to Court would be
    considered a "recording device" to Judge Holmes is not exactly clear).
    000115
    Judge Holmes then testified that after an initial round of interrogation of Coughlin as to
    whether he was recording the proceedings and or had a "recording device" that
    Coughlin got "all sneakity" and said he was not, but then "quote, 'took the Fifth' then
    immediately asked to be allowed to use the restroom...and I ordered Marshal Joel
    Harley to accompany him there...and it was reported to me that while in the restroom
    Coughlin disassembled a recording device and hid some part of it in the restroom..."
    (Coughlin recounts this testimony from memory, and admittedly, it is far from
    verbatim).
    It is categorically false (though not necessarily maliciously so) for Judge Nash Holmes to
    assert, in the audio record on 3/12/12 the order of events and when she asked Coughlin her
    questions about recording, considering when a restroom break took place and exactly what it
    is she asked Coughlin and when, and what his responses were, and when some allegations by
    "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio
    transcript reads 7 minutes into the audio record the RMC provided the SBN:
    Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering
    from some extreme form of mental illness. during the trial I asked the defendant attorney
    repeatedly if he was recording the proceedings he denied that vehemently a few times and
    then he quote took the fifth a few other times and then he requested to be excused to go
    to the bathroom and the Marshal later reported to me that while the gentleman was in the
    bathroom he disassembled a recording device in his pocket and took the memory out of it
    and it was later found in that, uh, by the Marshal no one else had gone into the bathroom
    and that was retrieved and it was put into his possession at the Sheriff's office and when
    they booked him into jail for the contempt charge that was booked into evidence and I
    asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme
    Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
    One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
    hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
    Perhaps NRS 178.405 in the context of NRS 5.073 should have some baring on anything said or done
    or Ordered by Judge Nash Holmes following her statement at the 7 minute mark that "It appears to me
    in this case that the defendant is suffering from some extreme form of mental illness." To the extent
    000116
    any question of Coughlin's competency was communicated to or brought to Judge Nash Holmes
    attention prior to the 2/27/12 3:00pm start of the Trial in 11 TR 26800, that proceeding should have
    been stayed or suspended, especially if the WCPD's Office made such communnications in close
    temporal proximity to the 1:31 pm 2/27/12 Order for Competency Evaluation by Judge Clifton in
    RCR2011-065630. And arguably, given the same office (in a broad sense) in which DDA Z. Young and
    DDA Kandaras work, it is arguably a basis for conflicting out the WCDA's Office from any one of the
    three prosecutions is has maintained against Coughlin this year (especially considering the issues related
    to whether the WCSO's timely effected the lockout of 11/1/11 in the eviction from Coughlin's former
    home law office, which, given the recent admissions by the locksmith there that day, and the Reno
    Carson Messenger receipt from the day prior, and Casey Baker, Esq's testimony related to his
    interactions with the WCSO on October 28th, 2012 during his sworn testimony at the criminal trespass
    trial before RMC Judge Garder on 6/18/12, and the RJC's failure to even move to Quash Coughlin's
    subpoenaing records related to the fax logs and confrimation of transmission or receipt incident to the
    RJC's "usual custom and practice" of faxing eviction Orders to the WCSO for service (like those in the
    Richard Hill/Casey Baker Summary Eviction "Trial" involving Coughlin's former home law office, and the
    "within 24 hours of receipt" language found within NRS 40.253 (the Order is void or invalid after that
    point, in which case, it would mean Hill and or Baker were the trespassers, not Coughlin, regardless, its
    inappropriate for RMC court appointed defender Loomis to categorically refuse to assert any claim of
    right defense that such a criminal trespass defendant may wish to assert for, say, Richard Hill admits to
    charging the same rent under a "storage of personal property" that was previously charged for "full use
    and occupancy". Nonetheless, posting an Eviction Order that does not contain stay away language
    (much less the fact that is does not have the required "within 24 hours" language called for by the
    statute) is not tantamount to posting a no trespassing sign, further, Hazlett-Stevens making arguments
    in his closing as to matters not in evidence (allegations of living in the residence) is reversible error, and
    for Judge Gardner to do as Judge Howard did, an prevent the City Attorney from even having to Oppose
    Coughlin's Motion for New Trial, is further indication of the extent to which Coughlin's reactions during
    the 2/27/12 Trial, however offputting, are not totally unfounded. Further, that which Judge Nash
    Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be
    testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her
    mental processes" loophole, as he has done. But, actually, a review of the Hardesty/Mirch dynamic
    may dictate that Coughlin would have been fairly limited in that regard anyways, nonetheless, Judge
    Nash Holmes appeared, to her credit, and answered some questions. The answers revealed an
    opportunity put forward now to clear some things up, though the constraints of the Disciplinary Hearing
    format, some disagreements over what the SBN communicated to Coughlin with respect to the rules
    that would be applied to him vis a vis NRCP 45 subpoenas (whether, he, as a suspended attorney could
    issues a subpoena (Coughlin maintains the Bar/Panel/Board did give him such authority) and whether
    any witness fee or subpoena decus tecum fee must be paid by Coughlin (Coughlin maintains he was
    provided indications upon which he reasonably relied that he would not be so required in additions to
    the rules or practicies attached to the service thereof), and other factors severely limited the extent to
    which the opportunity created by Judge Nash Holmes testimony was realized to its full potential. That
    necessitated this correspondence. Coughlin recalls the first time he saw opposing counsel allege he
    was lying in a filing, it was one of the early one's by Richard Hill's former associate Casey Baker, alleging
    "outright lies". It was upsetting, especially considering how unfair and baseless the allegations
    seemed...and Coughlin nows wishes he would have done and said some things differently incident to
    000117
    his testimony relative to RPD Sargent Tarter and Judge Nash Holmes's own testimony, and intends to
    address the extent to which objectionable conduct by opposing counsel can often times become a sort
    of learned characteristic perpetuating a race to, if not the ethical gutter, at least a preponderance of
    Rambo litigating. To some extent the incidents with Marshal Harley and RCA Ormaas may be fallout
    from that. Important too, however, is to consider whether the "courthouse sanctuary" doctrine has
    some application, however confusing it may be, where the WCSO may be hired by private parties to
    conduct service, and the Marshals are only extending intra-governmental courtesies in assisting in the
    manner in which Marshal Harley did on 2/27/12. Richard Hill gets the "oopsies" a lot. Oppsie, I
    asked for $20K in attorney's fee incident to a summary eviction at the trial court level, despite that not
    being supportable under NRS 69.020, Hill says. Oopsie, I left the window unit air conditioner in the
    exposed to the street by the Lakemill lodge window at your former home law office, which was then
    robbed, but for which I still managed to charge you full rental value at full use and occupancy rates,
    though I had you subject to an arrest for custodial trespass anyways, Hill and Baker say.
    (at the 9 minute 48 second mark of the first audio file attached from 2/27/12)
    "Judge: Sir, I would like you to raise your hand to be sworn, because its my experience that people who
    represent themselves tend to testify a whole lot when they are asking other people questions, so let's
    just start that way and then we won't have to do it later, so swear him in and then we'll get going
    Marshal: Testimony (inaudible)...you are about to (inaudible) understand (inaudible) truth, whole truth,
    nothing but truth, solemnly?
    Coughlin: Yes, Sir?"
    However, from there, throughout the Trial Judge Nash Holmes interrupts Coughlin during his
    questioning of Tarter to indicate to Coughlin that he is asking questions and not testifying, or that he
    will have an opportunity to make some point when its his turn to testify, if he chooses to testify, etc.,
    etc, and eventually Judge Nash Holmes asks Coughlin, after the restroom break, if he intends to testify
    on his own behalf..."Nor does the trial judge's speculation that Appellant might use his closing
    argument to present unsworn testimony." Soto, 139 S.W.3d at 857.
    The transcript from the 2/27/12 certified audio recording of the traffic citation Trial
    at the 1 hour and 6 minute 18 second mark of the running time (yes the certified audio transcript is
    provided in a FTR format that necessitates installing TheRecord Player, but for the ease of the
    receipients of this correspondnece, Coughlin convereted the audio therein exactly as it was into a more
    workable format, .mp3 files, split into two files for 2/27/12 (before and after the one restroom break)
    and one file for the continuation fo the trial on 3/12/12) of file one:
    000118
    Judge Nash Holmes (Judge): Sir, Mr. Coughln, sit down, I am done with you.
    Coughlin: Just to preserve for the record, Your Honor.
    Judge: Sit down, sit down, your're done. For the record the defendant is looking in his pockets and
    behind his back and turning around and clowning around and showing utter disprespect for this court
    and if you say another word or do another little antic like that you are going out of this Court in
    handcuffs. Do you have any other witnesses? Prosecutor?
    Prosecutor Ormaas: No, Your Honor, the City rests.
    Judge: Sir, do you wish to testify?
    Coughlin: Can I call Officer Tarter as my own witness?
    Judge: you can call anyone you wish to testify.
    Coughlin: I am sorry, Your Honor, but I really need to use the restroom.
    Judge: You have two minutes. Marshal (Harley), you will escort him to the restroom, don't take
    anything with you, Sir...
    Coughlin: Can I take my notes with me?
    Judge:No, turn them upside down.
    Coughlin: Can I take the one page?
    Judge: No, turn them upside down.
    Coughlin: Really?
    Judge: Turn them upside down. Marshal you will go with him to the restroom.
    Coughlin: Will I be able to go into the stall alone? Just checking.
    Judge: You have two minutes. You have two minutes.
    Coughlin: Okay.
    (that ends the first audio file attached for 2/27/12, which represents the entirety of the proceeding
    prior to the ONLY restroom break during that Trial)
    (Start of the second audio file of 2/27/12, which represents the entirety of the proceedings of that day
    following the ONLY restroom break of the day).
    Coughlin: (re-enters courtroom): Thank you, Your Honor.
    000119
    Judge: Okay, we are back on the record in 11 TR 26800. Mr. Coughlin, are you recording these
    proceedings?
    Coughlin: No, Your Honor.
    Judge: Do you have any sort of devices in your pocket?
    Coughlin: I believe what is in my pocket is private, Your Honor.
    Judge: I want to know if you have any sort of recording devices in your pocket!
    Coughlin: I believe that is a Fourth Amendment issue, Your Honor.
    Judge: I am asking you, are you are recording anything from these proceedings in your pocket without
    Court permission?
    Coughlin: I believe that is a Fourth Amendment issue.
    Judge: Sir?
    Coughlin: And, no, I'm not.
    Judge: Okay, proceed, do you have any questions for this witness (RPD Sargent John Tarter) that are
    different from the area that we gave gone over already.
    Coughlin: Well, I would like to ask a follow up on the rolling stop citation..." (thereafter Judge Nash
    Holmes does not ask any other questions of Coughlin in any way related to recording or recording
    devices, nor did Judge Nash Holmes ask any questions of anyone related to recording or recording
    devices besides. Judge Nash Holmes did ask, before the restroom break, of Coughlin, if Coughlin had
    any evidence or proof to support his contention that he attempted to provide to either Reno City
    Attorney Wong or Ormaas discovery or information related to the statement to Coughlin, incident to
    the November 13th, 2011 custodial criminal trespass arrest of Coughlin at his former law office incident
    to an impermissible summary eviction of a commercial tenant not based on the non-payment of rent
    (ie, a No Cause Eviction Notice was posted and a Landlord's Affidavit alleged a No Cause basis for
    proceeding).
    On the second audio file from 2/27/12, at the 5 minute mark, the follow occurs on the record:
    "Coughlin: was I there? Do I remember the name of the other officer who was there with him who
    went into Richard Hill's law office for twenty minutes with him and hung out?
    Judge: If you mention the name Richard Hill again I am going to hold you in contempt because I have
    told you repeatedly to stick to the relevant issues about the boulevard stop."
    000120
    (At the 11:17 minute mark of the second audio from 2/27/12 the following occurs on the record):
    Judge: Officer (RPD Sargent Tarter), you are excused. Sir, do you intend to testify?
    Coughlin: Yes, Your Honor.
    Judge: Then testify, you don't need to take the stand, you can testify right there, you don't have to ask
    yourself questions, just give me a short narrative version of what happened, and don't refer to yourself
    in the third person, he was sworn in at the beginning of the case, don't refer to yourself in the third
    person, just tell me what happened.
    Coughlin: Yes, your honor, I reported a bribe to Sargent Tarter, then he retaliated against me.
    Judge: Sir! Sir! Keep it relevant!
    Reno City Attorney Ormaas: Objection, move to strike!
    Judge: Keep it relevant about whether or not the boulevard stop occurred and what happened:
    Coughlin: Sargent Tarter perjured his testimony today
    Judge: Sir, Sir, answer about the boulevard stop.
    Coughlin: Yes, Your Honor, this incident occurred when I went over to Richard Hill's office.
    Judge: Sir.
    Coughlin: I can't get into that? Okay.
    Judge: Sir, boulevard stop.
    Coughlin: Sargent Tarter lied today when he...
    Judge: All right, Sir!
    Coughlin: about the boulevard stop, I am saying...I disagree
    Judge: take him into custody, you are in contempt of court, you will spend the next five days in jail, this
    court is finished, this matter is continued
    Coughlin: Your Honor I move for a stay, I have a trial..and I have clients who need me
    Judge: that is your problem, Sir. For the record you are in contempt of court because you have been
    insubordinate, you have disregarded all of my requests, directions, orders, cajoling, my efforts to get
    you to follow the instructions of the court, to act like a lawyer, or even to act like a defendant
    representing himself in this court, you have made faces, belittled, you have argued, you have played,
    you have been ridiculous in this courtroom and brought up issues that are irrelevant and immaterial
    and to disrupt this proceeding, and there are only five or six people here that you could disrupt, you
    have done everything you can to divert from the matter at question and to keep us from resolving the
    000121
    issue of whether or not you have committed the traffic violation of the boulevard stop, and you are in
    utter contempt of this court and have done nothing to deal with the facts of this case...you are being an
    obstinate jackass, I am having a hard time believing you are a lawyer, you obviously missed the class on
    on evidence, courtroom decorum and on criminal law..."
    Coughlin was taken into custody whereupon a search incident to arrest was performed in the holding
    area/back room of the RMC by Marshal Joel Harley with Marshal Scott Coppa assisting, and Marshal
    Coppa was one of two Marshals transporting Coughlin to the Washoe County Detention Facility where
    he served the 5 days in jail Judge Nash Holmes ordered (and the RMC refused to return the $100 that
    Coughlin's mother paid into the RMC when counter clerk "Tom" promised her the Court would issue an
    Order resulting in Coughlin being released from jail one day early...however, aside from the WCDC
    walking Coughlin down in handcuffs from his cell to the booking desk and back, there was no release
    from custody and Coughlin's mother was not returned her $100 payment in exchange for an early
    release by either the RMC or the WCDC.
    While conducting the search incident to arrest, RMC Marshal Harley went through Coughlin's pockets
    and took out a simple flip style cell phone, a smart phone, a micro sd card, and an electronic shaver.
    Upon taking possession of the micro sd card Marshal Harley immediately began interrogating
    Coughlin as to whether it would work with the smartphone, then directed another Marshal to "go tell
    the Judge that Coughlin was recording!" without any other support for such an accusation. None of
    this occurred in the restroom and Chief Marshal Roper has indicated to Coughlin that Marshal Harley, in
    carrying out Judge Nash Holmes Order to escort Coughlin to the restroom, did not actually go in the
    restroom, but rather waited outside its door.
    I ask that Chief Marshal Roper, Marshal Harley, and Marshal Coppa correct the misrepresentations
    made by Judge Nash Holmes (whether or not they were purposeful or where something was lost in
    translation and the affidavit requirement of NRS 22.030 for "contempt not in the immediate presence
    of the Court" was not followed by Judge Nash Holmes incident to her 2/28/12 Order, wherein Judge
    Nash Holmes writes, on page 2 of her 2/28/12 Order Finding the Defendnat in Contempt of Court and
    Imposing Sanctions: "The matter was called at apprxoimately 3:00p.m. and concluded withoua verdict
    about 4:30 p.m. after the court held the defendnat in criminal contempt of court for his behavior and
    activites committed in the direct presence of this court during the trial. The court finds that
    defendant's contemptuous conduct conside of his ....deceitful...behavior during trial, all of which
    appeard to be done to vex an 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...."9) defendant's
    lying to the court in response to direct questions posed by the court with regard to his recording the
    proceedings...(page 3)...The court finds that the defendnat's actions were intentional and done in utter
    disregard and contempt for the court, an in the presence of the cour, for purposes of disrupting and
    delaying the proceedins and dishonoring the rule of law and this court, and constitute the misdemeanor
    of criminal contempt, a violation of NRS 22.010. Good cause appearing therefore, the following
    000122
    sanctions are imposed: IT IS ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at
    the Wahoe County Regional Detnetion Facility for the term of five (5) days, from the time he was taken
    into custody on this court's order on February 27, 2012, and that sentence shall not be reduced for any
    reason..." The time stamping on that 2/28/12 Order Finding the Defendant in Contempt of Court
    and Imposing Sanctions indicate "3:47". Washoe County Sheriff's Office personnel Deputy Hodge,
    Patricia Beckman, RMC
    Somehow, in her 2/28/12 Order (and during the Trial) Judge Nash Holmes found it relevant that,
    allegedly, the RPD "gave Coughlin a break" over his driver's license being expired (actually, Coughlin's
    then valid, current, driver's license was being withheld by Richard G. Hill, Esq., as Coughlin reported to
    Sargent Tarter...and it was likely an old DL that the RPD is referring to as "expired" when mentioning
    the "break", which, again, was somehow relevant enough to find its way into the Order, but the
    withholding of Coughlin's then current, valid DL by Hill was sustained as irrelevant during the Trial (and
    in fact seems to have been one of a myriad of vague basis for issuing a summary criminal contempt
    Order requiring then licensed attorney with client's depending upon him, Coughlin, immediately being
    taken to the WCDC for 5 days in jail...).
    Coughlin hereby requests the RMC, WCDA, and WCDC to indicate the extent to which his property was
    booked into his personal property at the WCDC, only to have the WCDC and or WCDA release the
    property to the City of Reno Marshals the following day, well after any timeframe to conduct a search
    incident to arrest (NNDB Member Mary Kandaras was involved in this matter, and in fact, despite Judge
    Nash Holmes ordering the property released on 3/30/12, it took until 4/7/12 and approval by Mary
    Kandaras before the property was so released. wcso12-1805 c-47951.
    With local attorney Pam Wilmore standing, watching, and or hearing/participating in the conversations,
    on or about March 21st, 2012 WCSO's P. Beckman handed Coughlin a note that read "Per Judges
    Orders, call Marshal Deighton" and provided a phone number for Coughlin to seek further explanation
    as to the admission that the City of Reno Marshals had returned to the jail on 2/28/12 and retrieved
    items of Coughlin's personal property, including his "flip" phone, his smart phone, and his micro sd
    card. Deputy Hodge's admission that, contrary to the indications by WCSO Cummings and Campbell
    that the micro sd card was released to Coughlin's agent on 2/29/12, but rather, was not so release,
    combined with his statement that the smartphone, micro sd card, etc. were released to the Marshals
    because it would be easier for Coughlin to get his property back through them, reveal that a search not
    incident to arrest occurred here by the RMC on 2/28/12 and or the City of Reno Marshals, or, to be fair,
    at least some sort of "seizure" did (especially considering that upon the smartphone and micro sd card
    finally being returned to Coughlin on or about 4/7/12 by WCSO Deputy Iver, Brandi Berriman, and
    Patricia Beckman (and only after "Maddy" got approval from DDA Kandaras, and after Coughlin was
    threatened with abuse of process by Deputy Beatson). The RMC's Marilyn Tognoni also made some
    indications respecting the smartphone and micro sd card to Coughlin. Perhaps, the allusion
    000123
    to wcso12-1805 c-47951 in Judge Nash Holmes 3/30/12 Order Releasing Coughlin's property indicates
    whether a warrant or some other lawful Order allowed for the Marshals to retrieve those items a day
    after they were booked into Coughlin's personal property at the jail...but Coughlin has not been
    provided any such Warrant or Order and hereby requests that he be so provided a copy of it now, and
    that, given important data was lost to Coughlin upon his discovery the micro sd card and smartphone
    had been wiped, that any copies of the data then stored therein be provided to Coughlin (the Diaz case
    in the Ninth Circuit seems to provided a great deal of latitude to law enforcement to search digital data
    within the reach of one whom is subject to a custodial arrest, and perhaps even copy it...in which
    case....is would be appreciate if a copy thereof could be provided to Coughlin, and some compensation
    for the extent to which his 32 GB micro sd card was rendered useless upon its return, as was his HTC
    G2 cell phone (which never quite worked the same from then on and was rendered totally inoperative
    a short time thereafter...the 32 GB micro sd card having an approximate value of $85 and the HTC G2
    smartphone a used value of around $175.00).
    I know I write in the third person sometimes (its tough representing yourself, especially when time
    requires lots of copying and pasting, etc., etc) and that it can appear awkward.
    I would appreciate the parties receiving this correspondence who have any knowledge of the events
    detailed herein (especially with respect to the false accusations related to recordings, disassembling,
    and hiding component parts of devices in the RMC restroom as detailed on the record on 3/12/12 in 11
    TR 26800 and again in Judge Nash Holmes testimony at the 11/14/12 Disciplinary Hearing for NG12-
    0434 (and NG12-0204, and NG12-0435) to set the record straight.
    For a verbatim or close to it transcription of what Judge Nash Holmes testified to at the Disciplinary
    Hearing on 11/14/12 (including those matters she purported to repeat details related to what variosu
    RMC Marshals told her regarding Coughlin, on would likely need get the transcript or any recordings
    from the CCR assigned to that Hearing, Carol Hummel, and given Coughlin's current indigency, any
    requirement that Coughlin pay up front for the transcript would make review prohibitive, and Coughlin
    hereby requests of the Panel a fee waiver or deferment of such costs in that regard):
    Linda Shaw, Owner, Sunshine Reporting Services - Reno
    1895 Plumas St,
    Reno, NV 89509,
    (775) 323-3411
    000124
    Sunshine Reporting Services
    Eric Nelson
    CCR Longoni
    (775) 323-3411
    fax (775) 323-2749
    151 Country Estates Circle
    Reno, Nevada 89511
    Carol Hummel
    (775) 827-9120/
    fax (775) 827-9120
    chummel@charter.net
    In her 3/12/12 Order in 11 TR 26800, a transmogrification of sorts appears to occur, turning a "simple
    traffic citation trial" into a Disciplinary Hearing, albeit one of a summary nature, with an absent
    Respondent. That Order read, in relevant part:
    "Based upon the total circumstances of this case, the in-court performance of the
    defendant, as observed by this court, the written documents faxed to the court for filing by
    this defendant, the statements and behavior of this defendant and his overall conduct herein,
    this court finds, by clear and convincing evidence, that Zachary Barker Coughlin, an attorney
    licensed to practice law in the State of Nevada, has committed numerous acts of attorney
    misconduct, including, but not limited to, violating the following Rules of Professional
    Conduct:
    000125
    8.4(c}-engaging in dishonesty, fraud, deceit or misrepresentation;
    8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
    3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
    3 .l-defending in a proceeding by asserting or controverting an issue without a basis in
    fact and with matters that are known to be frivolous;
    3.2-failure to make reasonable efforts to expedite litigation. and, in fact, taking
    extreme measures to delay litigation;
    3.4(c)-being unfair to opposing counsel by continually alluding to matters the lawyer
    does not reasonably believe are relevant or supported by admissible evidence;
    1.3-failing to act with reasonable diligence and promptness; and
    1. I-lack of competence in his practice and appearances before this court.
    In addition, Zachary Barker Coughlin, likely also violated Nevada Supreme Court Rule
    229, section 2(b), as amended by ADKT 449 on August 1, 2011, by surreptitiously recording
    the traffic citation trial of February 27,2012 without the advance permission of this court and
    then lying to this court when questioned about it and denying that he had done so.
    Whether or not there are medical reasons to explain Mr. Coughlin's actions is not for
    this court to decide. He has become nothing less than a vexatious litigant to Reno Municipal
    Court due to his unorthodox, disruptive, bizarre and irrational methods and practices that go
    beyond the pale of anything that is civil, ethical. professional or competent. Good cause
    appearing therefore, the court orders as follows:
    IT IS ORDERED that this matter is continued, and all proceedings relating thereto are
    tolled, until further order of this court, while the matter of attorney Zachary Barker Coughlin
    is referred to the State Bar of Nevada;
    IT IS ORDERED that no further action shall be taken by the Reno City Attorney's
    000126
    Office, or the clerks or staff of Reno Municipal Court, in the above-entitled case, pending
    further order of this court;
    IT IS ORDERED that Zachary Barker Coughlin is barred and forbidden from faxing,
    emailing, delivering. having delivered, serving. presenting for filing. personally or otherwise,
    any motion or document to Reno Municipal Court, in the above-entitled case, pending further
    order of this court."
    One, Coughlin is not emailing this correspondence in that "above titled case (11 TR 26800) but in
    connection with matters outside that case. Three, it is really not at all clear how Judge Nash Holmes
    could make all those rulings, and only after having done that, decide to suspend the proceedings for a
    Competency Evaluation, given the import of NRS 178.405:
    NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
    defendant; notice of suspension to be provided to other departments.
    NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
    defendant; notice of suspension to be provided to other departments.
    1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial,
    when upon conviction the defendant is brought up for judgment or when a defendant who has been placed on
    probation or whose sentence has been suspended is brought before the court, if doubt arises as to the
    competence of the defendant, the court shall suspend the proceedings, the trial or the pronouncing of the
    judgment, as the case may be, until the question of competence is determined.
    2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any
    other departments of the court of the suspension in writing. Upon receiving such notice, the other departments
    of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to
    be competent.
    NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court.
    000127
    1. The justice shall, within 10 days after the notice of appeal is filed, transmit to the clerk of the district court
    the transcript of the case, all other papers relating to the case and a certified copy of the docket.
    2. The justice shall give notice to the appellant or the appellants attorney that the transcript and all other
    papers relating to the case have been filed with the clerk of the district court.
    3. If the district judge so requests, before or after receiving the record, the justice of the peace shall transmit
    to the district judge the sound recording of the case.
    NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
    collection of fees.
    1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
    practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
    district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
    5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
    thereof are called into question.
    2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
    jurisdictional limits of the municipal court.
    (Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
    NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
    docket and of any other appropriate records to be kept by the municipal court, which form may vary from
    court to court according to the number and kind of cases customarily heard and whether the court is
    designated as a court of record pursuant to NRS 5.010.
    City Attorney Ormaas sure could be made to explain her statements on the record regarding whether
    the citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right
    at it and given what she said in court. Also, the whispering with Marshal Harley, and the bits about
    Coughlin reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's
    responses thereto on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
    000128
    Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording
    anything or whether he possessed a "recording device" until AFTER the one and only restroom break Judge
    Nash Holmes mentions on the audio record. Judge Nash Holmes did ask Coughlin if he had any proof that City
    Attorney's Wong and Ormaas failed, in some way, to received or follow up on some offer by Coughlin to
    provide materials related to Coughlin's contentions respecting the statement madAnd that sua sponte
    interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH
    HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED
    AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S
    EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME
    OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME
    WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
    STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd,
    considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630
    and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors
    and public defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12
    status conference between young and dogan that neither YOung nor Dogan wish to testify about...but which
    seems to have been held anyways after a written communication of its being reset was transmitted to Coughlin
    by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group
    meetings amongst Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the
    record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
    got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for
    Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately
    11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was
    duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab makes
    his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That,
    and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive
    document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on
    2/27/12...never mind Young tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin
    competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in
    RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010)
    here in Northern nevada..
    Coughlin didn't received the 2/28/12 Contempt Order in 11 tr 26800 until July 2012...but did file a Notice of
    Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash Holmes
    continues to refuse to follow NRS 189.010-050
    It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily
    by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a
    contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For
    we held in the Oliver case that a person charged with contempt before a "one-man grand jury" could not be
    000129
    summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his
    immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin
    violated in both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being known
    how to comply with, not sufficient warning, violat Houston v Eighth Judicial District (Nev.).
    See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
    "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
    HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
    entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe
    she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate,
    particulary where she not only purports to issue a "summary criminal contempt" conviction against an
    attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic
    citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That
    Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something
    on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge
    Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
    musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts
    of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to
    Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge
    Nash HOlmes, Judge William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite
    find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR
    26405 (the appeal was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal
    of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
    was denied based upon a civil preparation of transcript down payment rule, in that criminal appeal, where the
    RMC has a thing in place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the
    audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the
    transcript's preparation would absolutely not start until a down payment was made. Plus, even where Coughlin
    caved to the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
    communications (there may be an issue of the email Longoni holding out to the public issuing a
    "bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon
    information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf too...
    In her March 14th, 2012 grievance against Coughlin to the SBN Judge Nash Holmes details some concerns she
    has with Coughlin's work as a self representing attorney defending a traffic citation (now NG12-0434, and
    perhaps, NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in
    King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
    3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need
    to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King
    now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009
    Order was not filed by the RMC Judges?
    000130
    AS to the application of the "courthouse sanctuary" doctrine to RMC Marshal Harley serving the Order to Show
    Cause upon Coughlin at approximately 1:25 pm in one of the conference rooms right outside the interior of
    Courtroom B at the RMC:
    http://caselaw.findlaw.com/ny-district-court/1372465.html
    "THE LAW
    (COURTHOUSE SANCTUARY)
    Despite antagonistic dicta to the contrary; most modern era precedent dealing with the issue of
    Courthouse Sanctuary from service of process have held that New York State residents receive no such
    immunity protections. Baumgartner v. Baumgartner, 273 A.D. 411, 77 N.Y.S.2d 668 (1st Dept.1948);
    Department of Housing Preservation, City of New York v. Koenigsberg, 133 Misc.2d 893, 509 N.Y.S.2d 270
    (N.Y. Civ.Ct.1986); Ford Motor Credit Co. v. Bobo, N.Y.L.J., 1 Misc.3d 901(A), 2003 WL 22928513 (Dec. 17,
    2003, J. Miller, Nassau Co. Dist. Ct.) These cases hold that the Courthouse Sanctuary is only available to
    foreign state residents who come into New York's Courts to contest jurisdiction. This doctrine has been
    slightly expanded to include New York residents who enter the jurisdiction of a New York Court of limited
    territorial jurisdiction to contest jurisdiction. See Palazzo v. Conforti, 50 N.Y.S.2d 706 (N.Y. Civ.Ct.1944);
    Singer v. Reising, 154 Misc. 239, 276 N.Y.S. 714 (Queens County 1935).
    The Baumgartner Appellate Division panel also acknowledges a limited Courthouse Sanctuary rule for
    New York residents if such service would constitute a disturbance directly tending to interrupt the
    proceedings of the Court or to impair the respect due its authority. This rule by itself would not be
    applicable to the instant case as service of process was effected in the Courtroom but outside the Court's
    presence and in between calendar calls.
    STATE RESIDENCY IMMUNITY DISTINCTION?
    The English Common Law made no New York State residency distinction. The doctrine of immunity from
    arrest of a litigant attending a trial of an action to which he is a party found early recognition and dates back to
    the book of 13 Henry IV, J.B. Sampson v. Graves, 208 A.D. 522, 203 N.Y.S. 729 (1st Dept.1924). This is for
    the obvious reason that England had no sovereign states. The privilege is not a creature of statute, but was
    created and deemed necessary for the due administration of justice. See Matthews v. Tufts, 87 N.Y. 568
    (1882); citing to Van Lien v. Johnson (N.Y. Ct. Appeals, unreported 1871).
    The logical question now arises, exactly when did New York's Appellate Court's recognize a residency distinction
    for application of the Courthouse Sanctuary? The answer is that the Court of Appeals never
    established such a rule. In contra point of fact, the Court of Appeals has opined that:
    It is the policy of the law to protect suitors and witnesses from arrests upon civil process while coming to
    and attending the court and while returning home. Upon principle as well as upon authority their
    immunity from the service of process for the commencement of civil actions against them is absolute eundo,
    morando et redeundo. Person v. Grier, 66 N.Y. 124 (1876). Emphasis Added.
    In this unanimous opinion, the Court of Appeals expressly addressed the New York State resident immunity
    distinction and established in its dicta that whether any distinction should or does in fact exist, is at least
    doubtful. This immunity is one of the necessities of the Administration of Justice, and Court's would often
    be embarrassed if suitors or witnesses, while attending Court, could be molested with process. It is noted
    that Person involved a foreign state resident. In establishing the sanctuary doctrine, the Court stated that

    Appeals is also applying the protective rule to New York residents.
    000131
    The basis of the Courthouse Sanctuary rule is that parties should be allowed to contest jurisdiction
    Z
    essentially allows the plaintiff to use a defective default judgment as a weapon to compel the defendant to
    submit to the service of process. Ford Motor Credit Co. v. Bobo; cite supra. The location of an
    individual's residence does little to legitimize such a mockery. Absent the compulsion of clear controlling
    precedent; this Court will not condone such a situation..."
    NRS 266.595 Appeals. Appeals to the district court may be taken from any final judgment of the municipal
    court in accordance with the provisions of NRS 5.073.
    NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
    collection of fees.
    1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
    practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
    district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
    5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
    thereof are called into question.
    2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
    jurisdictional limits of the municipal court.
    (Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
    NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
    docket and of any other appropriate records to be kept by the municipal court, which form may vary from
    court to court according to the number and kind of cases customarily heard and whether the court is
    designated as a court of record pursuant to NRS 5.010.
    NRS 5.010 General requirements for court; designation as court of record. There must be in each
    city a municipal court presided over by a municipal judge. The municipal court:
    1.Must be held at such place in the city within which it is established as the governing body of that city
    may by ordinance direct.
    2.May by ordinance be designated as a court of record.
    000132
    The personal service by Marshal Harley of the Order to Show Cause in the appeal of the summary eviction
    matter from Coughlin's former home law office at 121 River Rock St, with Richard G. Hill, Esq. as opposing
    counsel in CV11-03628, occurred while Coughlin was speaking to RCA Ormaas in attempts to resolve the matter
    (11 TR 26800 a traffic citation matter wherein RPD Sargent Tarter and other officers responded to Richard G.
    Hill, Esq.'s office on 11/15/12 (its possible both Hill and Coughlin called the police and or 911...can't remember)
    when Coughlin appeared there after being released from 3 days in jail incident to the 11/13/12 criminal
    trespass arrest (now a conviction and discussed in that attached materials, some of which appear on the
    Nevada Supreme Court's site under case 61901, the conviction stemming from 11 CR 26405 before RMC
    Administrative Judge W. Gardner, the brother of District Court Judge Linda Gardner whose April 2009 Order
    sanctioning Coughlin was cited by Washoe Legal Services at the cause for his firing, and led to 60302, now on
    appeal...
    I would really just like to move on from all of this, but this is a time of exigent circumstances, and if the RMC
    and the City of Reno Marshals do not take affirmative steps to disavow the unsworn hearsay Judge Nash
    Holmes attributed in her supposedly sworn testimony at Coughlin's 11/14/12 Disciplinary Hearing, it may be
    that a negligent hiring, training, or supervision cause of action may acrue against various Marshals, even
    personally (and its not so clear Mr. Christensen and the City of Reno would extend any purported
    representation to such personal liability, for, say, slander or libel).
    NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be deemed contempts:
    1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in judicial duties
    at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial proceeding.
    2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or in its immediate vicinity,
    tending to interrupt the due course of the trial or other judicial proceeding.
    3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
    4. Disobedience of a subpoena duly served, or refusing to be sworn or answer as a witness.
    5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge at
    chambers.
    6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the presence of a
    juror concerning an action in which the juror has been impaneled to determine, or in any manner approaching or interfering with such juror
    with the intent to influence the verdict.
    7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or process of the
    court.
    [1911 CPA 452; RL 5394; NCL 8941](NRS A 1983, 843)

    NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court; affidavit or
    statement to be filed when contempt committed outside immediate view and presence of court; disqualification of judge.
    1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may be
    punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection, the court or judge shall
    enter an order that:
    (a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
    000133
    (b) Finds the person guilty of the contempt; and
    (c) Prescribes the punishment for the contempt.
    2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit must be
    presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters or arbitrators.
    3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence of the
    court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the contempt over the objection of
    the person. The provisions of this subsection do not apply in:
    (a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was entered in such
    court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings for the violation of the judgment or
    decree.
    (b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been established in the judicial
    district.
    NRS 22.100 Penalty for contempt.
    1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall determine whether the person
    proceeded against is guilty of the contempt charged.
    2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be imposed on the person
    not exceeding $500 or the person may be imprisoned not exceeding 25 days, or both.
    3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt pursuant to subsection 3
    of NRS 22.010, the court may require the person to pay to the party seeking to enforce the writ, order, rule or process the reasonable
    expenses, including, without limitation, attorneys fees, incurred by the party as a result of the contempt.
    NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one of the following kinds shall be
    guilty of a misdemeanor:
    1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its immediate view and presence,
    and directly tending to interrupt its proceedings or to impair the respect due to its authority;
    2. Behavior of like character in the presence of a referee, while actually engaged in a trial or hearing pursuant to an order of
    court, or in the presence of a jury while actually sitting in the trial of a cause or upon an inquest or other proceeding authorized by law;
    3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or referee;
    4. Willful disobedience to the lawful process or mandate of a court;
    5. Resistance, willfully offered, to its lawful process or mandate;
    6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer any legal and proper
    interrogatory;
    7. Publication of a false or grossly inaccurate report of its proceedings; or
    8. Assuming to be an attorney or officer of a court or acting as such without authority.
    ARTICLE IV - Judicial Department
    Sec.4.010Municipal Court. The Municipal Court must include one department and may include
    additional departments in the discretion of the City Council. If the City Council determines to create additional
    departments, it shall do so by resolution and may appoint additional municipal judges to serve until the next
    election.
    000134
    (Ch. 662, Stats. 1971 p. 1976; ACh. 553, Stats. 1973 p. 881; Ch. 373, Stats. 1979 p. 645; Ch. 208, Stats. 1985
    p. 675; Ch. 9, Stats. 1993 p. 21)
    Sec.4.020Municipal Court: Qualifications of Municipal Judge; salary.
    1.A Municipal Judge must be:
    (a)An attorney licensed to practice law in the State of Nevada.
    (b)A qualified elector within the City.
    2.A Municipal Judge shall not engage in the private practice of law.
    3.The salary of a Municipal Judge must be:
    (a)Fixed by resolution of the City Council.
    (b)Uniform for all judges in the Municipal Court.
    (Ch. 662, Stats. 1971 p. 1976; ACh. 343, Stats. 1973 p. 422; Ch. 553, Stats. 1973 p. 881; Ch. 98, Stats. 1977
    p. 211; Ch. 561, Stats. 1977 p. 1395; Ch. 208, Stats. 1985 p. 675; Ch. 599, Stats. 1993 p. 2501; Ch. 327, Stats.
    1999 p. 1369)
    Sec.4.030Disposition of fines. All fines and forfeitures for the violation of ordinances shall be
    paid to the City Clerk in the manner to be prescribed by ordinance.
    (Ch. 662, Stats. 1971 p. 1977)
    Sec.4.040Procedure, additional judges. The practice and proceedings in the Court must conform
    as nearly as practicable to that of justices courts in similar cases. Upon the written request of the City
    Manager an additional temporary Municipal Judge may be provided for so long as the City Council authorizes
    additional compensation for such a Judge. Whenever a person is sentenced to pay a fine, the Court may
    adjudge and enter upon the docket a supplemental order that the offender may, if he or she desires, work on
    the streets or public works of the City at the rate of $25 for each day. The money so earned must be applied
    against the fine until it is satisfied.
    CONTEMPT
    Acts or omissions constituting, generally, 22.010
    Affidavit of facts constituting, 22.030
    Affidavits presented in bad faith, NRCP 56(g), JCRCP 56(g)
    Appearance, failure of defendant to make, 22.130
    Arrest
    000135
    Bond, 22.070
    Excuses for not bringing arrested person before court, 22.140
    Illness of defendant, effect, 22.140
    Attorneys at law
    Bar examination, early release of results, SCR 68
    Discharged, failure to deliver certain materials to client, 7.055
    Bail
    Violation of conditions deemed contempt, 178.484
    Commercial premises, violations of writ of restitution, 118C.210
    Commission in presence of court or judge, 22.030
    Compelling performance, imprisonment, 22.110
    Court order, violation, 1.250, 22.010
    Court reporters, 656.240
    Criminal, 193.110, 193.300, 199.340
    Custodial parent, failure to comply with visitation orders, 125C.030, 125C.040
    Discharge from arrest, 22.070
    Disqualification of judge or justice, making of charge not punished as contempt, 1.225, 1.230
    Documents, refusal to permit inspection, NRCP 37(b)(2), JCRCP 37(b)(2)
    Failure to perform specific acts directed by judgment, 22.010, NRCP 70, JCRCP 70
    Imprisonment, 22.100, 22.110
    Indictment for contemptuous conduct, 22.120
    Justice courts, civil proceedings, 74.040
    Material witness granted immunity, failure to testify, 178.576
    Misconduct by defendant during criminal trial, 175.387
    Municipal court may punish for, 266.570
    000136
    Punishment, 22.030, 22.100, 22.120
    Reentry on real property after ejectment, 22.020
    Refusal to answer or be sworn, 22.010, 50.195, NRCP 37(b)(1), JCRCP 37(b)(1)
    Sheriffs duties, 22.060, 50.205
    Subpoenas, failure to obey
    Deemed contempt, 22.010, 174.385
    Witnesses, forfeitures and damages, 50.195
    Summary punishment, 22.030
    Trials for contempt
    By court or jury, 22.100
    Disqualification of judge, 22.030
    Investigating charge, 22.090
    The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
    Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
    land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
    making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
    Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
    all the information necessary to issue a citation" explanations (including Crawfords
    lying under oath that Coughlin didn't provide his driver's license to him on September
    9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
    arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
    officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
    chance to explain how she prosecutes cases based upon arrests by tribal officers for
    misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
    officers under NRS 171.1255.
    I was forced to cross examine/interact with a represented party at the 11/14/12
    Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
    greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
    Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
    000137
    NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
    officer employed by Indian tribe.
    1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of
    Indian Affairs or a person employed as a police officer by an Indian tribe may make an
    arrest in obedience to a warrant delivered to him or her, or may, without a warrant,
    arrest a person:
    (a) For a public offense committed or attempted in the officer or agents presence.
    (b) When a person arrested has committed a felony or gross misdemeanor, although not
    in the officer or agents presence.
    (c) When a felony or gross misdemeanor has in fact been committed, and the officer or
    agent has reasonable cause for believing the person arrested to have committed it.
    (d) On a charge made, upon a reasonable cause, of the commission of a felony or gross
    misdemeanor by the person arrested.
    (e) When a warrant has in fact been issued in this State for the arrest of a named or
    described person for a public offense, and the officer or agent has reasonable cause to
    believe that the person arrested is the person so named or described.
    (f) When the peace officer has probable cause to believe that the person to be arrested
    has committed a battery upon that persons spouse and the peace officer finds
    evidence of bodily harm to the spouse.
    2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
    (a) Within the boundaries of an Indian reservation or Indian colony for an offense
    committed on that reservation or colony; or
    (b) Outside the boundaries of an Indian reservation or Indian colony if the officer or
    agent is in fresh pursuit of a person who is reasonably believed by the officer or agent
    to have committed a felony within the boundaries of the reservation or colony or has
    committed, or attempted to commit, any criminal offense within those boundaries in
    the presence of the officer or agent.
    For the purposes of this subsection, fresh pursuit has the meaning ascribed to
    000138
    it in NRS 171.156.
    Please see the photograph in the attached materials of the RSIC Officer taking
    Coughlin's driver's license from him, thereby vitiating his assertion that an arrest was
    an available option due to Couglin not providing his driver's license to the Officers.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 9 files to share with you on SkyDrive. To view them, click the links below.
    11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 1 of 2.pdf
    11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 2 of 2.pdf
    11TR26800 031412 RMC continuation of trial Nash Ormaas Hill traffic citation 031412_20120312-
    1033_01cd003b8f0851d0.mp3
    11TR26800 RMC 022712 part 2 of 2 from 2 27 12 031412_20120227-1621_01ccf56bce224540.mp3
    11TR26800 RMC 022712 part 1 of 2 from 2 27 12 031412_20120227-1507_01ccf5618f76c460 (2).mp3
    CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
    NG12-0204.pdf
    CR12-1262 appeal.pdf
    11 2 12 file stamped complete notice of errata and revised supplemental 26405 1708 0204.pdf
    11 15 11 rpd tarter redacted 0204 0434 26800 police report ormaas retaliation.pdf
    Download all

    please indicate some response to my subpoena and discovery requests
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    000139
    Sent: Thu 11/22/12 1:18 PM
    To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us
    (zyoung@da.washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
    complaints@nvbar.org (complaints@nvbar.org)
    3 attachments
    exhibit 1 to 61901 10 24 12 filing opposition.pdf (9.4 MB) , 10 24 12 stamped motion for leave to file
    opposition 61901 0204 12-33724.pdf (228.4 KB) , 11 2 12 file stamped complete w 195 ex and dvd
    notice of errata and revised supplemental 26405 1708 0204.pdf (979.7 KB)
    Dear Mr. Dogan and DDA Young,
    Please find attached updated discovery relevant to the RCR2012-065630 matter, especially considering Sargent
    Paul Sifre's ordering both the 1/12/12 custodial jaywalking arrest and the 1/14/12 "misuse of 911" arrest (though
    Sargent Kim Bradshaw appears to have a connection to those in addition to the July 3, 2012 "disturbing the peace"
    arrest in 12 CR 12420.
    Mr. Dogan, I am formally requesting that you send the Reno Police Department Custodian of Records (Doreen and
    Harriet Neumann et al) and the ECOMM (Kelley Odom, Kariann Beechler
    a subpoena and supboena duces tecum for all police reports, documentations, recordings of any kind, etc., etc.
    related to the 10 incarcerations of Zachary B. Coughlin (dob 9/27/76) since 8/19/11, including the dispatch tapes
    of communications between the RPD and Ecomm dispatchers.
    Please note that the "possible fight" report that the RPD alludes to in its arrest report of 1/12/12 is similar to the
    now debunked arguments in court and in pleadings on file and questions asked eliciting testimony thereto by DDA
    Young and RPD Officer Duralde in RCR2011-063341.
    It is my understanding the Richard Hill and or one of his contractors (possibly Phil Stewart of Nevada Building
    Industries) called RPD Dispatch or 911 (or possibly just called a Sargent or Officer of their choosing directly) and
    that what was communicated therein resulted in RPD response appropriate to reports of a "possible fight".
    Please include in the discovery materials the calls that RPD Officer Hollingsworth alludes to in the videos from
    that day that Coughlin can authenticate and verify as he filmed them (which show Hill lying to Officer
    Hollingsworth where he alleges Coughlin, on 1/12/12, had already "lost his appeal" in that appeal of the summary
    eviction from his law office (not true, as the Order denying the appeal was entered 3/30/12)...
    This is also a formal complaint/police report of the extortionate threats made by Hill and apparent filing of false
    police reports where Hill lies to the RPD (like he did in the 11/13/12 custodial arrest that is now detailed in 61901
    and that attached filing in 11 CR 26405) to effect a false arrest of Coughlin.
    Please respond in some way, Mr. Dogan as to whether you have complied with my requests that you subpoena
    Sargent Sifre, Sarget Zach Thew (relevant to a claim of right defense that may arise given Sargent Thews
    directions to Coughlin in the days prior to the arrest of 1/14/12) and Sargent Marcia Lopez and Officer Chris
    Carter...Sargent Lopez's testimony will be particulary important given the motive she and the RPD had to harass
    and retaliate against Coughlin arising from Coughlin, on 1/13/12, getting Sargent Lopez to admit on video that she
    and Carter committed misconduct and fraud incident to teh 11/13/12 arrest of Coughlin fro criminal trespass in 11
    CR 26405.
    Further, please subpoena RPD Officer Travis Look (one of the "arresting officers" in 065630 whom utilized
    excessive force, along with then trainee Wesley Leedy, at the direction of Sargent Paul Sifre, despite Officer
    Hollingsworth indicated to Coughlin on video that Coughlin was not violating the law, and therefore, no lawful
    warning or order having been given to Coughlin). Additionally, please subpoena Richard Hill, Casey Baker,
    and Phi Stewart, Christopher Allaback, and Laura Foreshee to testify regarding the arrest.
    000140
    Further, Mr. Dogan and Mr. Young, the RPD had a multitude of recordings device out and recording that night,
    yet none have been propounded to me....I am hereby reiterating my request to be provided that mandatory
    discovery, regardless of the extent to which the DA's Office does not feel it excuplatory in nature or where,
    predictably, Mr. Dogan and the WCPD don't see it's utility. Speaking of not seeing any utility...Mr. Dogan, what
    is it you have done, in any way, to advocate on my behalf in this matter?
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org;
    fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
    cvellis@bhfs.com; eifert.nta@att.net; rhrc@laketahoelaw.com; stuttle@washoecounty.us; kadlicj@reno.gov;
    wongd@reno.gov; schornsby@nvdetr.org
    Subject: new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105
    Complaint
    Date: Wed, 14 Nov 2012 06:46:53 -0800
    Dear Panel and Bar Counsel,
    Please find the attach additional discovery the Reno City Attorney's Office gave me
    today related to the custodial jaywalking arrest of 1/12/12, at which time Richard Hill
    applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD
    Officer Look took a special trip to the jail to attempt to serve the TPO for Hill).
    Please see attached the video of the arrest and interactions prior thereto, and consider
    the lack of accuracy in Hill and Baker's Second Motion to Show Cause, Judge
    Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause
    Hearing (which WCSO Deputy Machen, the same one who filed a false affidavit
    incident to the summary eviction order posting and lockout on 11/1/11 in the Richard
    Hill eviction cases rev2011-001708 served on Coughlin, by way of violating the
    "courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
    case Coughlin did not require personal service anyways...this was hazing by Hill and
    the RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11
    TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD
    Sargent Tarter telling Coughlin to leave Hill's office upon going there after being
    released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12
    000141
    resulting in a wrongful arrest for criminal trespass of Coughlin by RPD Officer Chris
    Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer
    Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee
    Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
    report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for
    "misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage
    the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable
    cause basis for doing so. Further, both Hill and Officer Leedy substantially
    misrepresent what Officer Hollingsworth said. Additionally, should Officer
    Hollingsworth had indeed told Coughlin that what he was doing was legal but that the
    Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve
    cooperation, that would violate Soldal v. Cook County, which is essentially what RPD
    Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which
    les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes
    a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky
    associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-
    way believing RPD Officer Carter's statement on 11/15/11 that "Richard G. Hill pays
    me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's
    merely attributing the statement that RPD Carter said to Carter is not misconduct.
    Hill's making up things about a "crack pipe and bag of weed" and "large quantity of
    pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see
    that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that
    mentions this "large quantity of pills"). If you knew all the Thursday nights I spent
    since 2003 with Coe, and now deceased Judge Bob, and so many others, you would
    realize how infinitely tacky Hill's conduct is.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
    1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
    7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204
    25 page discovery northwind ncs krebs reduced size.pdf
    000142
    1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-
    000018 0204 Leed.pdf
    SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
    1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
    4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
    11 9 12 61901 amendment to opposition.pdf
    11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder
    ptthoa 0204.pdf
    10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
    bifurcate atty client severe hearing trialotjl.pdf
    bifurcate atty client severe hearing trial.pdf
    CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
    NG12-0204 BF.pdf
    Download all

    000143
    Print Close
    Formal request for names of those on my Screening Panel`
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/22/12 12:39 PM
    To: tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org);
    patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
    (cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net
    (eifert.nta@att.net); skent@skentlaw.com (skent@skentlaw.com); davidc@nvbar.org
    (davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
    (fflaherty@dyerlawrence.com)
    I am writing to formally request the names of those who were on the Screening Panel
    incident to the current SCR 105 SBN v. Coughlin Complaint in ng12-0204, etc.
    Rule 105. Procedure on receipt of complaint.
    1. Investigation.
    (a)
    Investigation and screening panel review. Investigations shall be initiated and conducted by bar counsel or
    bar counsel's staff or other investigative personnel at bar counsel's direction prior or pursuant to the
    opening of a grievance file. At the conclusion of an investigation of a grievance file, bar counselshall
    recommend in writing dismissal with or without prejudice, referral to diversion or mentoring pursuant to
    Rule 105.5, a letter of caution, a private reprimand, or the filing of a written complaint for formal hearing.
    The recommendation shall be promptly reviewed by a screening panel. A screening panel shall consist of
    three members of the disciplinary board, appointed by the chair in accordance with Rule 103(6). Two of the
    three reviewers must be members of the bar. By majority vote they shall approve, reject, or modify the
    recommendation, or continue the matter for review by another screening panel
    Given the Board's inclusion of numerous individuals with patent conflicts (DDA Kandaras (intimately
    involved in the opposition's causes in a number of matters, including the apparent search and seizure of my
    smart phone and micro sd card incident to summary "misdemeanor of criminal contempt" Order (that
    cited to a non summary civil contempt statue in NRS 22.010, yet attempted to utilized the summary nature
    of NRS 22.030 (only without complying with the Affidavit requirement for conduct not in the "immediate
    presence" of Judge Nash Holmes, all while purporting to be a criminal misdemeanor charge a la NRS
    199.340 (very creative, and very, very duplicitous to boot coming from a Judge...and add to that an attempt
    to further Bar Counsels SCR 111(5) aims by including the "find by clear and convincing evidence" burden
    of proof standard necessary to prove an ethical violations of the RPD in a disciplinary hearing setting....
    Then there is Richard Hill's best friend, David Hamilton being on the Board (and SBN King has curiously
    redacted nearly any mention of Hill in his 8/23/12 Complaint (for which there remains no return of service
    filed in the Disciplinary File (and any attempt by the SBN to assert that the certified mailing of 8/23/12 is
    sufficient is fraudulent, see Coughlin's recent sworn Affidavit or Declaration under penalty of perjury as to
    000144
    the SBN, Panel, and NNDB's representations in that regard, especially in light of SCR 105(4). Further is
    is fraudulent and displays a lack of candor to assert that SCR 106 provides insulation from subpoena where
    it speaks merely to causes of action, and any immunity therein surely has its limits, otherwise Pat King
    would probably go biting Respondent's in their jugular's like the vampire he is.
    Also, please formally provide me a copy of any rules of procedure or other applicable policies, practices,
    rules, procedures, or dictates adopted by the Panel and or the NNDB or SBN that attach to these
    disciplinary proceedings, such as the one of 11/14/12 (and the 45 days from the Panel's designation will run
    real soon, so to get a non-void for lack of jurisdiction Disciplinary Hearing set and noticed, the SBN, Panel,
    and NNDB is hereby advised to take note of that fact and proceed accordingly. Further, Coughlin objects
    to the SBN, Panel, and Board's depriving him of his Sixth Amendment right to confront his accuser in this
    quasi-criminal setting, particularly where the SBN still refuses to divulge the complainant in the NG12-0435
    grievance, or which Clerk of Court or whoever it was that forwarded that April 2009 Order to the SBN.

    And to the extent the Complaint has been curiously disinfected to redact mention of Richard G. Hill, Esq.,
    allegations in Hill's 1/14/12 unsigned grievance letter to the SBN (while they waited to hear back on their
    Milsner v Carstarphen case from the Nevada Supreme Court) attached to the SBN's 2/14/12 letter to
    Coughlin (which King fraudulently attempted to assert at the 11/14/12 Hearing that Coughlin somehow
    failed to respond to, or to respond timely, particularly where the bate stamped Disciplinary File as late
    provided by King on 11/8/12 (in violation of SCR 105(2)(c)) is a textbook case of fraudulent ommission and
    obfuscation....see the "Folders" for each grievance (the folder listing Linda Gardner as the grievance filer is
    particularly interesting considering is consists only of a online blog entry about prosecutorial misconduct,
    and given that Linda Gardner and her brother, the one who refused to recuse himself from the criminal
    trespass matter where Richard G. Hill signed the Complaint and the RPD has admitted to fraud incident
    thereto on tape, 11 CR 26405, are both lifelong prosecutors.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Judge Howard and Cassandra Jackson want to explain
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/22/12 12:56 AM
    To: je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); davidc@nvbar.org
    (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
    (eifert.nta@att.net); mike@tahoelawyer.com (mike@tahoelawyer.com); patrickk@nvbar.org
    (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); skauc@reno.gov (skauc@reno.gov);
    000145
    robertsp@reno.gov (robertsp@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov);
    wongd@reno.gov (wongd@reno.gov)
    6 attachments
    DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) , 12 16 11 email to
    plongoni@charter.net longoni and 12 21 11 email to ballardd@reno.gov regarding longoni 22176
    26800 0204 0435.pdf (22.7 KB) , 10 9 12 Affidavit of Laura Peters 0204 never sent to Coughlin no
    proof of service, yet file stamped.pdf (1516.8 KB) , 12 15 11 22176 2064 Order by Howard on
    transcript costs.pdf (92.8 KB) , 12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
    (110.8 KB) , 11 16 12 skau grievance materials combined 0204 063341.pdf (1943.8 KB)

    How RMC handouts and agreements with Pam Longoni are not violating NRS 189.030
    and NRS 4.14(a)

    RCA Skau wants to explain his lies about the judge authorize service by email for an
    unnoticed hearing where Skau sought to argue email service was insufficient when it
    came to his people...Then RCA Hazlett-Stevens want to explain his mysterious claims
    to have not received the Notice of Appeal in cr12-1262 or why he puts on perjured
    testimony by Richard G. Hill, Esq., RCA Pam Roberts would like to explain the same
    for 11 cr 22176. RCA Allison Ormaas wants to explain what she was whispering in
    RMC Marshal Harley's ears on 2/27/12 and whether it was about the same failure to
    chart follow up on, or report RPD Chris Carter's admission that "Richard Hill pays me a
    lot of money, so I arrest who he says to and do what he says to do...", just like Reno
    City Attorney Chief Criminal Deputy Dan Wong explained he was surely not going to
    do to when Coughlin made the same report to him on 1/19/12....

    SBN Clerk of Court Laura Peters wants to explain how she approved fax filing for
    Coughlin on 9/11/12, and how her Affidavit of 10/9/12 wound up in the Disciplinary
    file only made available to Coughlin 5 days before the hearing (with thousands of pages
    of filler and duplicates to hide the little it contained...which in the case of Linda
    Gardner's grievance, was a mysterious printout from a blog and no more...no cover
    letter, no nothing...and Kings email where he purports that the "Clerk of Court" sent
    him the Order still has not been clarified, though Joey Orduna Hastings, Clerk of Court
    of the Second Judicial District Court wants to indicate whether she sent it to the SBN,
    or, more likely, the Clerk of Court of one of the Muni Court Departments (probably
    Judge Nash Holmes' in D3, considering her 3/23/12 email to the SBN about Coughlin's
    clothing choices to check on a traffic citation at a munic court filing office window...)
    who got ahold of District Court Judge Linda Gardners April 2009 Order when Judge
    L. Gardner passed it to her brother, RMC William Gardner, who refused to recuse
    himself from Coughlin's criminal trespass case based upon Richard Hill's Complaint,
    000146
    but did manage to pass his sister's Order around to his fellow Judges and hold meetings
    with them about how to get back at Coughlin for pointing out things they do that violate
    due process rights and other laws. Like those requiring a stay of proceedings when a
    defendants competency is brought into question. DDA Young is great at violating
    those laws, and bossing Judge Sferrazza around in court, demanding he take into
    custody anyone who doesn't do just exactly what DDA Young wants and or give just
    exactly the answer he is looking for....

    Pat King, Laura Peters and David Clark want to explain how their statements and
    corresponence with Coughlin respecting his right to issue subpoenas and waiver of
    witness fees of fees for subpoena duces tecums departed remarkably from the sudden
    about face on that issue when the Motions to Quash started coming in, though the
    Disciplinary Hearing of 11/14/12 went on just they same, right....


    Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper,
    and Marshal Joel Harley,
    Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment
    violation if the person was guilty of the crime you suspected him of committing when
    you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy
    Sleazy, WCPD Jim Leslie by muscling over indigent criminal defendants for him when
    Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to
    Jimmy's rescue and tells Coughlin, Leslie at his side, that "I'm going to put my foot up
    your ass..." Reyes watches defendants get put in jail for months day in day out for doing
    less than that....
    Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for
    information on the transmission of the Eviction Order in rjc 2011-001708 to the
    Washoe County Sheriff's Office.
    Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits
    of service he files, and Maureen and Roxy's assertions that the "receipt" of the eviction
    Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must
    effect the lockout "within 24 hours of receipt of the Order"...and Casey Baker, Esq.
    wants to explain his testimony of 6/18/12 when he explained what he did with the
    Sheriff's Office on October 28th, 2011...and Reno Carson Messenger service want to
    explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
    000147
    pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple
    minutes to 5 pm, and definitely not sooner than 4:48 pm, despite Machens 11/1/11
    Affidavit of Service (that his supervisor Stuchell had to admit was false in that it alleged
    "personal service" where the WCSO admits no one was home (and the locksmith totally
    refutes Hill's testimony of 6/18/12 "they tried to serve it to you but you ran away..."
    (really, Rich, becaue Casey didn't testify to that, but he did say that you weren't even
    there that day, so what do you base that sworn allegations on Rich, besides your desire
    to mitigate your liability for all your misdeeds there?).
    Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash
    Holmes got "confused" on in her "sworn testimony"...which is shaping up to look at lot
    like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
    disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash
    Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways. The
    attached audio from the Hearing and Judges Nash Holmes various Orders (which reveal
    a disturbing attempt to mix and match various civil and criminal contempt statutes,
    some plenary, some summary, and add the transmogrification of a "simple traffic
    citation Trial" into some sort of Summary Disciplinary Hearing...which SBN Bar
    Counsel Pat King is only too happy to sign on to, eager to kick back and rely on SCR
    111(5) after having fed Judge Nash Holmes the instruction to make sure to copy and
    paste as many sections of the Rules of Professional Conduct into an "Order" that is sure
    to point out the burden of proof necessary for a "ethical violation" finding in a
    Disciplinary Hearing setting. The only thing less transparent than this awkward attempt
    by Bar Counsel and Judge Nash Holmes to get 'r done was the brother and sister act by
    Judge William Gardner and his sister Judge Linda Gardner, complimented, of course,
    by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge L.
    Gardner's April 2009 Order sanctioning Coughlin, which Washoe Legal Services's Paul
    Elcano cited as the sole reason for Coughlin's firing (and which begat the Mandamus
    Petition against L. Gardner in 54844, the wrongful termination suit against WLS in
    60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner refused
    to recuse himself from, etc., etc.
    WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS
    178.405 and the communications with RMC Judge Nash Holmes regarding the 2/27/12
    Order for Competency Evaluation that should have prevented her from even holding the
    Trial (the one that occurred right after RMC Marshal Harley served a civil eviction
    appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve
    000148
    Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received
    in connection with his being the attorney of record and an e-filer on that matter...see
    Caplow).
    RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about
    their misconduct in 11 CR 26405 and the extent to which Richard Hill and his client,
    Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405
    and 61901.
    Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v.
    Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on that too..
    RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who
    was working that night of the 8/20/11 arrest that started a year in which Coughlin was
    arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one
    for "misuse of 911" even though Coughlin received two protection orders in FV12-
    00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the
    night upon his walking to his car after being released from jail on a 15 degree night on
    1/13/12, where five other RPD Officers helped Officer Duralde with the pressing matter
    of the sudden disappearance of Coughlin's license plate...), (all suspiciously close in
    time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12 with the
    RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying that
    dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a
    possible fight" thus supporting their reponse and the associated Terry Stop weapons
    check frisk pat down and custodial arrest for a misdemeanor allegedly occuring outside
    their presence after 7 pm:
    NRS 171.136 When arrest may be made.
    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
    (1) There is a warrant of arrest against the person; and
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another
    alleged violation or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is
    committed;
    000149
    (e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the manner
    provided in NRS 171.137;
    (f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued pursuant to NRS
    33.017 to 33.100, inclusive;
    (g) When the person is already in custody as a result of another lawful arrest; or
    (h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
    The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
    Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
    land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
    making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
    Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
    all the information necessary to issue a citation" explanations (including Crawfords
    lying under oath that Coughlin didn't provide his driver's license to him on September
    9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
    arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
    officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
    chance to explain how she prosecutes cases based upon arrests by tribal officers for
    misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
    officers under NRS 171.1255.
    I was forced to cross examine/interact with a represented party at the 11/14/12
    Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
    greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
    Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
    NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
    officer employed by Indian tribe.
    1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
    employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
    her, or may, without a warrant, arrest a person:
    (a) For a public offense committed or attempted in the officer or agents presence.
    (b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
    s presence.
    (c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause
    for believing the person arrested to have committed it.
    (d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
    person arrested.
    (e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
    offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
    000150
    described.
    (f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
    upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
    2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
    (a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
    or colony; or
    (b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
    person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
    reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
    the presence of the officer or agent.
    For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
    Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts
    with my father, Palmer v. Pioneer, etc.
    So, this is the Elcano approach...he gets an email on 4/19/12 that is a written
    employment law centered complaint from an employee...and he has the employee
    suspended within days thereafter...then claims to have not received the email, then
    adopts some Duluth Model "Power and Control" wheel co-opting or leveraging of
    "treatment" or armchair psychiatry...
    Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79. Stephen
    Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction resulting in 6/7/12
    temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82 (twice
    Coughlin's RMC court appointed counsel, allowed to withdraw with pay both times,
    refused to advocate in any way). Gammick, McGeorge '82. Springgate, McGeorge '85
    (opposing consel in ng12-0435 asking for sanctions in divorce case closing argument).
    Kandaras, McGeorge '91 (Deputy District Attorney involved in warrantless seizure of
    Coughlin's smart phone. DDA Z. Young, McGeorge '04. Hazlett-Stevens, McGeorge,
    '06.
    What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned
    Coughlin about "recording devices" and or whether he was recording BEFORE the one
    restroom break, purposefully changing the order of the questioning and the restroom
    break to suggest some furtive activity on Coughlin's part, which Judge Nash Holmes
    then further attempted to amplify in her assertion that Marshal Joel Harley was ordered
    to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin
    000151
    "disassembled a recording device" in the restroom and "hid a part or portion of it in the
    restroom"
    Fraud on the court Conduct of counsel in omitting portion of deposition when
    deposition is read into record, and giving impression that entire document is being
    proffered, resulting in buttressing of his party's position is fraud on the court warranting
    the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d). Sierra Glass &
    Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119, rehearing denied.
    It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events
    and when she asked Coughlin her questions about recording, considering when a restroom break took place
    an exactly what it is she asked Couglin and when, and what his responses were, and when some allegations
    by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript
    reads 7 minutes into the audio record the RMC provided the SBN:
    Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some
    extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
    recording the proceedings he denied that vehemently a few times and then he quote took the fifth a
    few other times and then he requested to be excused to go to the bathroom and the Marshal later
    reported to me that while the gentleman was in the bathroom he disassembled a recording device in
    his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one
    else had gone into the bathroom and that was retrieved and it was put into his possession at the
    Sheriff's office and when they booked him into jail for the contempt charge that was booked into
    evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme
    Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
    One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
    hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
    NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement
    at the 7 minute mark that "It appears to me in this case that the defendant is suffering from some extreme
    form of mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start
    of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert
    to half baked "can't ask the judge about her mental processes" loophole, as he has done.
    Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple
    traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to get his driver's
    license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez and
    Officer Carter's explanations thereof in 11 CR 26405 and 61901) and three days spent in jail, upon being
    released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John Tarter,
    RMC Marshal Joel Harley, just before Trial (when Judge Nash Holmes couldn't be found and WCPD
    000152
    Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of Coughlin in
    rcr2012-065630 at 1:31 pm...and the 11 TR 26800 Trial starting late, not at 1 pm as noticed, but at 3
    pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein they
    brainstormed ways of combating Coughlin's championing of due process rights for the disenfranchised...
    City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the
    citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and
    given what she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin
    reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto
    on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
    Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was
    recording anything or whether he possessed a "recording device" until AFTER the one and only
    restroom break Judge Nash Holmes mentions on the audio record. And that sua sponte interrogation
    of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH
    JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL
    PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL
    PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY
    CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT
    UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY
    BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S
    ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
    STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that
    was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr
    26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that
    local law enforcement and prosecutors and public defenders were non too happy with Coughlin...and
    consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that
    neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
    written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the
    time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst
    Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the record in
    11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
    got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation
    for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin
    of approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr2011-
    063341 to add a charge that was duplicative, even where YOung failure to allege theft or
    possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case
    a RPC 3.8 violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which
    YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an
    Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind
    YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in
    cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC
    000153
    11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs
    5.010) here in Northern nevada..
    Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a
    Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge
    Nash HOlmes continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript,
    yay....
    It is true that contempt committed in a trial courtroom can under some circumstances be punished
    summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a
    trial judge of a contempt committed in his immediate presence in open court cannot be likened to the
    proceedings here. For we held in the Oliver case that a person charged with contempt before a "one-
    man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge to
    punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S. 257.
    Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also
    orders no sufficiently detailed or capable of being known how to comply with, not sufficient warning,
    violate Houston v Eighth Judicial District (Nev.).
    See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur
    " in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have
    misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash
    HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again,
    maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on
    unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to issue a
    "summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes
    appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR
    105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to sign an
    affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record,
    under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash
    HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
    musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing
    evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar
    Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
    Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge
    Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin
    faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was
    dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11
    cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
    was denied based upon a civilpreparation of transcript down payment rule, in that criminal appeal,
    where the RMC has a thing in place with this Pam Longoni that violates Nevada law in that it
    000154
    refused to give Coughlin the audio cd of the trial for some time, insisting only Longoni would be
    allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down
    payment was made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly
    hung up the phone on him and otherwise ignored his communications (there may be an issue of the
    email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit as
    to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his
    request to the number the RMC held out for her on her behalf too...
    In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps,
    NG12-0435 (stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed
    Court (I'd bet its from the RMC Clerk of Court, whom King purported to have certified documents
    from a Court she doesn't even work for at the 11/14/12 Disciplinary Hearing...but then again, Panel
    Chair Echeverria allow WLS's Elcano to certify documents just because he claimed to have watched
    a tape of a hearing, where Elcano is neither a licensed attorney, nor does he work for any Court....),
    depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12
    email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
    3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that
    would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to
    the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting
    of Judge L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court
    Orduna Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to
    bar counsel reads:
    "
    Re: Zachary Barker Coughlin, Nevada Bar No. 9473
    Dear Mr. Clark:
    This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker
    Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this attorney being
    experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what should be
    a simple traffic citation case are self-explanatory and are included, together with copies of massive documents Me.
    Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also included.
    He failed to appear for the second one this past Monday.
    I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge
    being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him between cases very
    easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
    th
    St. #2
    Reno NY 89512), although I heard today he may be living in his vehicle somewhere. We do have an address for his
    mother, however, as she recently posted part of a fine for him.
    000155
    Judge Ken Howard, Department 4, had a case on Mr.Coughlin late last year that is now on appeal to the Second
    Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in his court with Mr.
    Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order, simply
    because they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made you
    some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him and
    him and him and him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You
    can see his behavior in my traffic citation case does not appear to bean isolated incident.
    It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant
    was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed for Contempt of Court and
    they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
    You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your
    pursuit of this matter. Mr.Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff and
    even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a caseof some urgency,
    and I apologize for taking two days to get this package to you; our IT person was ill and could not make the copies of
    the audios of Mr.Coughlin's hearings until today, and I felt it was important that the audios be included in the materials
    to be considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
    appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of
    law in Northern Nevada and could be jeopardizing someone's freedom or property interests. "
    Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily proven
    to be patently false at Disciplinary Hearings (to the extent one is allowed to offer such proof, which Panel
    Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5) vacation with
    his "Clerk of Court" Laura Peters...whose lies about SCR 105(4) resulted in Panel Chair Echeverria
    quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King filed on behalf
    of his former co-worker at the AG's Office, Reno City Attorney Dan Wong...While the other Reno City
    Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve you by
    email"...
    Sincerely
    000156
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe
    Swobe's contacts with my family
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/22/12 12:37 AM
    To: skent@skentlaw.com (skent@skentlaw.com); eifert.nta@att.net (eifert.nta@att.net);
    complaints@nvbar.org (complaints@nvbar.org); cvellis@bhfs.com (cvellis@bhfs.com);
    davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
    (tsusich@nvdetr.org); jgarin@lipsonneilson.com (jgarin@lipsonneilson.com);
    snordstrom@lipsonneilson.com (snordstrom@lipsonneilson.com); fflaherty@dlpfd.com
    (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); roperj@reno.gov
    (roperj@reno.gov); duralden@reno.gov (duralden@reno.gov); duraldej@reno.gov (duraldej@reno.gov);
    lopezm@reno.gov (lopezm@reno.gov); carterc@reno.gov (carterc@reno.gov); tarterj@reno.gov
    (tarterj@reno.gov); leedyw@reno.gov (leedyw@reno.gov); lookt@reno.gov (lookt@reno.gov);
    sifrep@reno.gov (sifrep@reno.gov); weavera@reno.gov (weavera@reno.gov); millero@reno.gov
    (millero@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
    bdogan@washoecounty.us (bdogan@washoecounty.us); voldenburg@rsic.org (voldenburg@rsic.org);
    kcrawford@rsic.org (kcrawford@rsic.org); dbraunworth@rsic.org (dbraunworth@rsic.org);
    jreyes@washoecounty.us (jreyes@washoecounty.us); stuttle@washoecounty.us
    (stuttle@washoecounty.us)
    8 attachments
    10 25 12 61901 opposition (Filed Motion Motion for leave to file opposition or opposition to scr
    111(4) petition)_001 - Copy.pdf (225.1 KB) , 11 2 12 file stamped complete notice of errata and
    revised supplemental 26405 1708 0204.pdf (884.6 KB) , contempt scr 119(2) in re coughlin 60838
    (Filed Motion Motion for Order to Show Cause or Contempt Order Against Bar Counsel and
    NNDB)_001.pdf (294.3 KB) , 6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf (2.2 MB) , 6
    11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process
    60838 0204.pdf (129.1 KB) , 11 9 12 stamped 60302 Notice of Lack of Access with both parts of
    exhibit 1.pdf (5.0 MB) , 10 31 11 receipt 1708 lockout wcso 26405 03628 60331 within 24 hours hill
    tried to get at 5 01pm versus baker oct 28th testimony from Memo of Costs - EX 1 (4-3-12).pdf (19.7
    KB) , 11 1 11 locksmith receipt wcso lockout from Memo of Costs - EX 1 (4-3-12)-2 compare 6 18
    testimony when the locksmith finally got there.pdf (79.3 KB)
    Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper,
    000157
    and Marshal Joel Harley,

    Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment
    violation if the person was guilty of the crime you suspected him of committing when
    you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy
    Sleazy, WCPD Jim Leslie by muscling over indigent criminal defendants for him when
    Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to
    Jimmy's rescue and tells Coughlin, Leslie at his side, that "I'm going to put my foot up
    your ass..." Reyes watches defendants get put in jail for months day in day out for
    doing less than that....

    Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for
    information on the transmission of the Eviction Order in rjc 2011-001708 to the
    Washoe County Sheriff's Office.

    Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits
    of service he files, and Maureen and Roxy's assertions that the "receipt" of the eviction
    Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must
    effect the lockout "within 24 hours of receipt of the Order"...and Casey Baker, Esq.
    wants to explain his testimony of 6/18/12 when he explained what he did with the
    Sheriff's Office on October 28th, 2011...and Reno Carson Messenger service want to
    explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
    pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple
    minutes to 5 pm, and definitely not sooner than 4:48 pm, despite Machens 11/1/11
    Affidavit of Service (that his supervisor Stuchell had to admit was false in that it
    alleged "personal service" where the WCSO admits no one was home (and the
    locksmith totally refutes Hill's testimony of 6/18/12 "they tried to serve it to you but
    you ran away..." (really, Rich, becaue Casey didn't testify to that, but he did say that
    you weren't even there that day, so what do you base that sworn allegations on Rich,
    besides your desire to mitigate your liability for all your misdeeds there?).
    Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash
    Holmes got "confused" on in her "sworn testimony"...which is shaping up to look at lot
    like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
    disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash
    Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways.
    The attached audio from the Hearing and Judges Nash Holmes various Orders
    (which reveal a disturbing attempt to mix and match various civil and criminal
    000158
    contempt statutes, some plenary, some summary, and add the transmogrification of a
    "simple traffic citation Trial" into some sort of Summary Disciplinary Hearing...which
    SBN Bar Counsel Pat King is only too happy to sign on to, eager to kick back and rely
    on SCR 111(5) after having fed Judge Nash Holmes the instruction to make sure to
    copy and paste as many sections of the Rules of Professional Conduct into an "Order"
    that is sure to point out the burden of proof necessary for a "ethical violation" finding
    in a Disciplinary Hearing setting. The only thing less transparent than this awkward
    attempt by Bar Counsel and Judge Nash Holmes to get 'r done was the brother and
    sister act by Judge William Gardner and his sister Judge Linda Gardner, complimented,
    of course, by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge
    L. Gardner's April 2009 Order sanctioning Coughlin, which Washoe Legal Services's
    Paul Elcano cited as the sole reason for Coughlin's firing (and which begat the
    Mandamus Petition against L. Gardner in 54844, the wrongful termination suit against
    WLS in 60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner
    refused to recuse himself from, etc., etc.
    WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS
    178.405 and the communications with RMC Judge Nash Holmes regarding the 2/27/12
    Order for Competency Evaluation that should have prevented her from even holding
    the Trial (the one that occurred right after RMC Marshal Harley served a civil eviction
    appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve
    Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received
    in connection with his being the attorney of record and an e-filer on that matter...see
    Caplow).
    RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about
    their misconduct in 11 CR 26405 and the extent to which Richard Hill and his client,
    Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405
    and 61901.
    Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v.
    Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on that too..
    RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who
    was working that night of the 8/20/11 arrest that started a year in which Coughlin was
    arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one
    for "misuse of 911" even though Coughlin received two protection orders in FV12-
    000159
    00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the
    night upon his walking to his car after being released from jail on a 15 degree night on
    1/13/12, where five other RPD Officers helped Officer Duralde with the pressing
    matter of the sudden disappearance of Coughlin's license plate...), (all suspiciously
    close in time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12
    with the RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying
    that dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a
    possible fight" thus supporting their reponse and the associated Terry Stop weapons
    check frisk pat down and custodial arrest for a misdemeanor allegedly occuring outside
    their presence after 7 pm:
    NRS 171.136 When arrest may be made.
    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
    (1) There is a warrant of arrest against the person; and
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or
    arrest the person for another alleged violation or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense
    is committed;
    (e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the
    manner provided in NRS 171.137;
    (f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued
    pursuant to NRS 33.017 to 33.100, inclusive;
    (g) When the person is already in custody as a result of another lawful arrest; or
    (h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
    The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
    Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
    land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
    making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
    Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
    all the information necessary to issue a citation" explanations (including Crawfords
    lying under oath that Coughlin didn't provide his driver's license to him on September
    9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
    arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
    officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
    000160
    chance to explain how she prosecutes cases based upon arrests by tribal officers for
    misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
    officers under NRS 171.1255.
    I was forced to cross examine/interact with a represented party at the 11/14/12
    Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
    greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
    Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.

    NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police


    officer employed by Indian tribe.
    1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
    employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
    her, or may, without a warrant, arrest a person:
    (a) For a public offense committed or attempted in the officer or agents presence.
    (b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
    s presence.
    (c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable
    cause for believing the person arrested to have committed it.
    (d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
    person arrested.
    (e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
    offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
    described.
    (f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
    upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
    2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
    (a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
    or colony; or
    (b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
    person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
    reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
    the presence of the officer or agent.
    For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
    Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts
    with my father, Palmer v. Pioneer, etc.
    000161
    So, this is the Elcano approach...he gets an email on 4/19/12 that is a written
    employment law centered complaint from an employee...and he has the employee
    suspended within days thereafter...then claims to have not received the email, then
    adopts some Duluth Model "Power and Control" wheel co-opting or leveraging of
    "treatment" or armchair psychiatry...
    Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79.
    Stephen Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction resulting
    in 6/7/12 temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82
    (twice Coughlin's RMC court appointed counsel, allowed to withdraw with pay both
    times, refused to advocate in any way). Gammick, McGeorge '82. Springgate,
    McGeorge '85 (opposing consel in ng12-0435 asking for sanctions in divorce case
    closing argument). Kandaras, McGeorge '91 (Deputy District Attorney involved in
    warrantless seizure of Coughlin's smart phone. DDA Z. Young, McGeorge '04.
    Hazlett-Stevens, McGeorge, '06.
    What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned
    Coughlin about "recording devices" and or whether he was recording BEFORE the one
    restroom break, purposefully changing the order of the questioning and the restroom
    break to suggest some furtive activity on Coughlin's part, which Judge Nash Holmes
    then further attempted to amplify in her assertion that Marshal Joel Harley was ordered
    to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin
    "disassembled a recording device" in the restroom and "hid a part or portion of it in the
    restroom"
    Fraud on the court Conduct of counsel in omitting portion of deposition when
    deposition is read into record, and giving impression that entire document is being
    proffered, resulting in buttressing of his party's position is fraud on the court
    warranting the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d).
    Sierra Glass & Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119,
    rehearing denied.
    It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events
    and when she asked Coughlin her questions about recording, considering when a restroom break took
    000162
    place an exactly what it is she asked Couglin and when, and what his responses were, and when some
    allegations by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio
    transcript reads 7 minutes into the audio record the RMC provided the SBN:
    Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some
    extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
    recording the proceedings he denied that vehemently a few times and then he quote took the fifth a
    few other times and then he requested to be excused to go to the bathroom and the Marshal later
    reported to me that while the gentleman was in the bathroom he disassembled a recording device in
    his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one
    else had gone into the bathroom and that was retrieved and it was put into his possession at the
    Sheriff's office and when they booked him into jail for the contempt charge that was booked into
    evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated
    Supreme Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
    One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
    hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
    NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her
    statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering from
    some extreme form of mental illness." Further, that which Judge Nash Holmes had communicated to her
    prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have
    Bar Counsel assert to half baked "can't ask the judge about her mental processes" loophole, as he has
    done.
    Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple
    traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to get his driver's
    license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez
    and Officer Carter's explanations thereof in 11 CR 26405 and 61901) and three days spent in jail, upon
    being released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John
    Tarter, RMC Marshal Joel Harley, just before Trial (when Judge Nash Holmes couldn't be found and
    WCPD Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of
    Coughlin in rcr2012-065630 at 1:31 pm...and the 11 TR 26800 Trial starting late, not at 1 pm as noticed,
    but at 3 pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein
    they brainstormed ways of combating Coughlin's championing of due process rights for the
    disenfranchised...
    City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the
    citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and
    given what she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin
    reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto
    on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
    Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything
    or whether he possessed a "recording device" until AFTER the one and only restroom break Judge Nash Holmes
    000163
    mentions on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER
    THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW
    COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER
    COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH
    OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A
    BIT UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE
    THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT
    INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT
    Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on
    in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time
    (lots of reasons for and indications that local law enforcement and prosecutors and public defenders were non too
    happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and
    dogan that neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
    written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time Judge
    Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about Coughlin that
    RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of
    Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for Competency Evaluation of
    Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was
    still smarting from a filing by Coughlin of approximately 11/28/12, which resultd in Young promptly amending
    his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege theft
    or possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8
    violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which YOung did by filing in
    rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the
    WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that
    case despite the Order finding Coughlin competent in cr12-0376 didn't even get signed and entered until
    5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs
    178.405 (including within NRs 5.010) here in Northern nevada..
    Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of
    Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
    continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
    It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by
    the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a contempt
    committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the
    Oliver case that a person charged with contempt before a "one-man grand jury" could not be summarily tried.
    [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his immediate presence in
    open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176
    and 11 tr 26800, also orders no sufficiently detailed or capable of being known how to comply with, not sufficient
    warning, violate Houston v Eighth Judicial District (Nev.).
    See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
    "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
    HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
    entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she
    is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary
    where she not only purports to issue a "summary criminal contempt" conviction against an attorney, but also
    where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a
    000164
    full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to
    sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record, under
    oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes phone in
    her testimony, and it probably won't even be sworn testimony, but rather just some musings by Judge Nash
    Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of things outside her
    jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the Subpoenas
    Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge
    William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of
    Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal
    was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176
    conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based
    upon a civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in
    place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the trial
    for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation would
    absolutely not start until a down payment was made. Plus, even where Coughlin caved to the payment
    demands..Longoni repeatedly hung up the phone on him and otherwise ignored his communications (there may be
    an issue of the email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit
    as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his request to
    the number the RMC held out for her on her behalf too...
    In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435
    (stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed Court (I'd bet its from the
    RMC Clerk of Court, whom King purported to have certified documents from a Court she doesn't even work for
    at the 11/14/12 Disciplinary Hearing...but then again, Panel Chair Echeverria allow WLS's Elcano to certify
    documents just because he claimed to have watched a tape of a hearing, where Elcano is neither a licensed
    attorney, nor does he work for any Court....), depending upon whom you ask and what King means by "Clerk of
    Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of
    Court of Department 3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna
    Hastings that would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to
    the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L.
    Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have
    anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
    "
    Re: Zachary Barker Coughlin, Nevada Bar No. 9473
    Dear Mr. Clark:
    This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker
    Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this attorney
    being experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what
    should be a simple traffic citation case are self-explanatory and are included, together with copies of massive documents
    Me. Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also
    included. He failed to appear for the second one this past Monday.
    I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge
    000165
    being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him between cases very
    easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
    th
    St.
    #2 Reno NY 89512), although I heard today he may be living in his vehicle somewhere. We do have an address for his
    mother, however, as she recently posted part of a fine for him.
    Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to the
    Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in his court with
    Mr. Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order,
    simply because they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made
    you some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him
    and him and him and him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court.
    You can see his behavior in my traffic citation case does not appear to be an isolated incident.
    It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant
    was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed for Contempt of Court and
    they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
    You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your
    pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff and
    even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a case of some urgency,
    and I apologize for taking two days to get this package to you; our IT person was ill and could not make the copies of
    the audios of Mr. Coughlin's hearings until today, and I felt it was important that the audios be included in the materials
    to be considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
    appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of
    law in Northern Nevada and could be jeopardizing someone's freedom or property interests. "
    Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily
    proven to be patently false at Disciplinary Hearings (to the extent one is allowed to offer such proof, which
    Panel Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5)
    vacation with his "Clerk of Court" Laura Peters...whose lies about SCR 105(4) resulted in Panel Chair
    Echeverria quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King
    filed on behalf of his former co-worker at the AG's Office, Reno City Attorney Dan Wong...While the other
    Reno City Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve
    you by email"...
    000166

    Sincerely
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 35 files to share with you on SkyDrive. To view them, click the links below.
    11 16 11 voicemail from Tim regarding Washoe Legal Service's Elcano's attempt to settle lawsuit with treatment routine
    60302 ng12-0204.mp3
    3 8 11 voice mail from Tim Coughlin to Zach Coughlin regarding SBN's Coe Swobe's contacting him for WLS's Elcano
    ng12-0204.mp3
    4 27 09 email from WLS's Elcano to Coughlin to call SBN's Swobe ng12-0204.pdf
    June_2008_Nevada_Lawyer In re Mirch compare to ng12-0204.pdf
    11 16 12 skau grievance materials combined 0204 063341.pdf
    2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal harley.pdf
    2 27 12 Order For Competency Evaluation Judge Clifton RCR2012-065630 1 31 pm file stamp rjc rmc schroeder nash
    holmes young dogan 26800 26405 loomis - Copy.pdf
    3 7 12 rmc 11 cr 26405 loomis gardner 178.405 Coughlin Trial Setting 26800 00696 063341 065630.pdf
    3 8 12 26800 nash barker denial return of bail $100 wcso rmc 0204 00696.pdf
    3 8 12 Coughlin Trial Setting 11 cr 26405 april 10 8 am trial loomis gardner 650630 26800 0032 0376.pdf
    3 9 12 needs stamped 11 tr 26800 0204 MOTION TO RETURN CELL PHONES; MOTION TO SET ASIDE SUMMARY.pdf
    3 12 12 rmc 11 tr 26800 order judge nash holme suspending case and referring to the SBN enhanc.pdf
    3 13 12 158 pm 26800 Nash rmc SUA SPONTE ORDER DENYING RELIEF SOUGHT IN IMPROPER DOCUMENT.pdf
    3 13 12 1238pm 11 TR 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT RPD WCSO
    RMC RJC NASH KING CLARK SBN check.pdf
    3 13 1238 pm 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT 0204 0434.pdf
    3 16 12 sbn grievance king with ng12-0434 nash 26800 of 3 14 12 and ng12-0434 4 10 09 linda gardner sanction
    order 00696 26405.pdf
    3 30 12 nash order releasing property 26800 0204 0434 cleaned up-3.pdf
    5 4 12 goodnight email 063341 26405 26800 regarding mhc loomis hazlett-stevens 0204 0434.pdf
    5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844 dd.pdf
    5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844.pdf
    Download all

    000167
    RE: Mr Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 11/21/12 9:22 PM
    To: Patrick King (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); tsusich@nvdetr.org
    (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
    (eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com)
    Dear SBN and Panel
    The Disciplinary Hearing File that Pat King purported to have copied and provided to
    me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
    not being filestamped...). Echeverria's very ruling on filing he was not mailed (to the
    extent that was the case, and perhaps it was a test) concedes at least the approval of
    filign by fax (express indication of the permissibility thereof in accordance with SCR
    105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
    Please confirm that my filings, all of them, including the Motion to Show Cause of
    10/2/12, starting on bate stamp 02849 have been provided to all Panel members as the
    SBN has repeatedly indicated they would be (included the copying of all attachments,
    including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a file stamp (and
    it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs indicates...which
    means the SBN failed to Oppose the Motion to Dismiss, and the Complaint was
    dismissed prior to any other purported proof of service being effected (or spurious
    assertions of Coughlin dodging service given his numerous written correspondences
    and calls offering to meet Reno Carson or the SBN...until Coughlin finally just gave
    the SBN his physical address on 10/23/12, despite safety concerns....)
    Who gave you this order that you attached in the email of your's included below (the
    8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
    King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
    Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
    Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
    through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
    000168
    2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
    of these grievances? Did Mr. Susich disclose that conflict incident to the problems
    Maureen Cole had in carrying out the duties of her job as an attorney for the NV DETR
    and NERC?
    Please copy me on anything proving Chairman Susich so disclosed that conflict.
    Additionally, more and more frequently, when I question Laura Peters on some
    misstatement or attempt to mislead that she makes, she starts talking about getting a
    "protection order" or otherwise seeking to abuse process. Speaking of abusing
    process, due process namely, Peters was caught signing Certificates of Mailing for
    10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes system
    that Peters knew would not be picked up by the SBN's mail carrier the day the
    certificate of mailing indicated the would be, or at least were placed...Please explain
    how your office's certified mailing procedures work and comply with federal law.
    Additionally, I have review the materials you had Sierra Legal Duplicating provide and
    there is no indication of where materials such as the 8 28 12 Order sanctioning
    Coughlin generated from or whom transmitted them to the SBN. I had a discussion
    with Bar Counsel Clark over a year ago about whether there was some centralized
    method of keeping track of Orders sanctioning attorneys. He indicated there was not.
    Please indicate then, who provided you the various different Orders sanctioning
    Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
    Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial Family
    Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of Court
    for Department 3" (ie, of the Municipal Court's Department 3, which you fail to specify
    in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you that day
    about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even talkin'
    'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out and
    about.) Pat, you are going to look like such an unbelievably compromised, crooked,
    and inept Bar Counsel when it is displayed what a tenuous thread each and every
    aspect of all these half baked grievances hang from.
    Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
    that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
    SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
    Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
    000169
    Panel is now in possession of the certified audio of the following transcripts:
    April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
    the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
    SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
    attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
    and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
    light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
    Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
    based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
    recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
    Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
    1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
    2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
    You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
    minute mark wherein the following exchange took place:
    Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
    April 2009 grievance onto the State Bar in the last two weeks
    Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
    Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
    Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
    will continue to be your attorney today."
    At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
    herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River Rock
    Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction where the
    nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any eviction notice or
    even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a case wherein Coughlin
    was representing a single father in a custody dispute based upon a judicial canon (see atached).

    King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
    grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434, and
    ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
    failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
    for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
    drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82 worth
    of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see 60838 and
    61426:
    60838 Walmart case with Court's June 7th, 2012 Order suspending
    Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
    61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
    entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
    S
    000170
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
    0204 Coughlin Disciplinary Hearing File.pdf
    10 31 12 Order by Echeverria 0204.pdf
    12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
    12 15 11 22176 2064 Order by Howard on transcript costs.pdf
    11 21 12 notice of non service 063341 needs ex 1.pdf
    031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
    Download all
    > From: PatrickK@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: FW: Mr Coughlin
    > Date: Thu, 30 Aug 2012 20:48:18 +0000
    >
    > Good Afternoon Mr. Coughlin,
    >
    > Attached is an Order that pertains to you.
    >
    > I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
    expect to file an Answer?
    >
    > Thank you.
    >
    > Patrick King
    RE: Mr Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 11/21/12 8:58 PM
    To: Patrick King (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); tsusich@nvdetr.org
    (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
    (eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com)
    000171
    Dear SBN and Panel
    Please be sure to listen to the attached voice mails from my Dad, Tim Coughlin, MD,
    talking about Washoe Legal Services Paul Elcano and the State Bar of Nevada's Paul
    Elcano running their hustle on our family.
    The Disciplinary Hearing File that Pat King purported to have copied and provided to
    me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
    not being filestamped...). Echeverria's very ruling on filing he was not mailed (to the
    extent that was the case, and perhaps it was a test) concedes at least the approval of
    filign by fax (express indication of the permissibility thereof in accordance with SCR
    105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
    Please confirm that my filings, all of them, including the Motion to Show Cause of
    10/2/12, starting on bate stamp 02849 have been provided to all Panel members as the
    SBN has repeatedly indicated they would be (included the copying of all attachments,
    including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a file stamp (and
    it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs indicates...which
    means the SBN failed to Oppose the Motion to Dismiss, and the Complaint was
    dismissed prior to any other purported proof of service being effected (or spurious
    assertions of Coughlin dodging service given his numerous written correspondences
    and calls offering to meet Reno Carson or the SBN...until Coughlin finally just gave
    the SBN his physical address on 10/23/12, despite safety concerns....)
    Who gave you this order that you attached in the email of your's included below (the
    8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
    King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
    Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
    Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
    through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
    2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
    of these grievances? Did Mr. Susich disclose that conflict incident to the problems
    Maureen Cole had in carrying out the duties of her job as an attorney for the NV DETR
    and NERC?
    000172
    Please copy me on anything proving Chairman Susich so disclosed that conflict.
    Additionally, more and more frequently, when I question Laura Peters on some
    misstatement or attempt to mislead that she makes, she starts talking about getting a
    "protection order" or otherwise seeking to abuse process. Speaking of abusing
    process, due process namely, Peters was caught signing Certificates of Mailing for
    10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes system
    that Peters knew would not be picked up by the SBN's mail carrier the day the
    certificate of mailing indicated the would be, or at least were placed...Please explain
    how your office's certified mailing procedures work and comply with federal law.
    Additionally, I have review the materials you had Sierra Legal Duplicating provide and
    there is no indication of where materials such as the 8 28 12 Order sanctioning
    Coughlin generated from or whom transmitted them to the SBN. I had a discussion
    with Bar Counsel Clark over a year ago about whether there was some centralized
    method of keeping track of Orders sanctioning attorneys. He indicated there was not.
    Please indicate then, who provided you the various different Orders sanctioning
    Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
    Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial Family
    Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of Court
    for Department 3" (ie, of the Municipal Court's Department 3, which you fail to specify
    in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you that day
    about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even talkin'
    'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out and
    about.) Pat, you are going to look like such an unbelievably compromised, crooked,
    and inept Bar Counsel when it is displayed what a tenuous thread each and every
    aspect of all these half baked grievances hang from.
    Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
    that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
    SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
    Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
    Panel is now in possession of the certified audio of the following transcripts:
    April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
    the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
    SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
    attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
    000173
    and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
    light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
    Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
    based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
    recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
    Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
    1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
    2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
    You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
    minute mark wherein the following exchange took place:
    Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
    April 2009 grievance onto the State Bar in the last two weeks
    Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
    Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
    Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
    will continue to be your attorney today."
    At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
    herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River Rock
    Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction where the
    nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any eviction notice or
    even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a case wherein Coughlin
    was representing a single father in a custody dispute based upon a judicial canon (see atached).

    King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
    grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434, and
    ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
    failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
    for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
    drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82 worth
    of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see 60838 and
    61426:
    60838 Walmart case with Court's June 7th, 2012 Order suspending
    Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
    61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
    entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
    S
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    000174
    ZachCoughlin@hotmail.com
    Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
    10 31 12 Order by Echeverria 0204.pdf
    11 21 12 notice of non service 063341 needs ex 1.pdf
    12 15 11 22176 2064 Order by Howard on transcript costs.pdf
    12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
    031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
    3 8 11 voice mail from Tim Coughlin to Zach Coughlin regarding SBN's Coe Swobe's hustle for WLS's Elcano ng12-
    0204.mp3
    Download all
    > From: PatrickK@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: FW: Mr Coughlin
    > Date: Thu, 30 Aug 2012 20:48:18 +0000
    >
    > Good Afternoon Mr. Coughlin,
    >
    > Attached is an Order that pertains to you.
    >
    > I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
    expect to file an Answer?
    >
    > Thank you.
    >
    > Patrick King
    FW: Bar Admission and employment
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/20/12 7:46 AM
    To: fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org);
    je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); schornsby@nvdetr.org
    (schornsby@nvdetr.org); tsusich@nvdetr.org (tsusich@nvdetr.org); cvellis@bhfs.com
    (cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
    (nevtelassn@sbcglobal.net); eifert.nta@att.net (eifert.nta@att.net); (davidc@nvbar.org)
    (davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org)
    1 attachment
    ed collection of materials for State Bar of Nevada Grievance against Peter Christiansen, Kevin Kelly,
    Michael Sanft, Patrice Eichman, etc adobe 4 and later grey.pdf (17.1 MB)
    000175

    Subject: RE: Bar Admission and employment
    Date: Fri, 5 Nov 2004 21:26:35 -0800
    From: bobarker@barkermartin.com
    To: zachcoughlin@hotmail.com
    Zach- This seems unusual. If there was an agreement for a flat fee representation it should be supported by a written fee
    agreement. You, Tim and I should have a conference call. I am surprised by what appears to be inattentiveness on
    Christiansen's part. For not we need to focus on getting you admitted and deal with Christiansen after your admission.
    Please arrange a conference call with you, Tim and me. Thanks. Bo
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Fri 11/5/2004 5:16 PM
    To: Bo Barker
    Subject: RE: Bar Admission and employment
    Bo,
    Here is Christiansen's offices most recent email. I will also forward
    emails from the state bar's director of admissions.
    \
    Zach,
    1. I will attempt to mail you another copy of your file.
    Please
    confirm you mailing address to me in an e-mail. We have tried
    to mail
    your file to you on two occasions the last of which was October
    2003 to
    the address you provided of 631 Humboldt Frt, Reno, NV 89509.
    Our mail
    was returned. As to your request for "complete" copy of your
    file, we
    always send complete copies of files upon the request of a
    client.
    2. There is no itemization for the services rendered to you.
    Mr.
    Christiansen charged you a flat fee to handle your hearings with
    the
    State Bar which fee was paid by your father. Mr. Christiansen
    continued
    to monitor your case as a courtesy and no such itemized records
    were
    kept for time we did not charge you.
    3. On September 10, 2003, after my conversation with Ms.
    Eichman's
    000176
    assistant, I set forth in my e-mail to you the specific
    procedure for
    which to have your admittance to the Stat Bar reconsidered. You
    were to
    prepare a letter of intent and forward it to our office. No
    such letter
    was ever received from you. The letter was due to the State bar
    on or
    before October 1, 2003.
    4. Other than an invoice from our office, I do not see a signed
    fee
    agreement in your file. I will send you any billing records I
    have
    along with a copy of your file when you send me confirmation of
    your
    billing address.
    Kelley Huff
    Christiansen Law Offices
    520 South Fourth Street
    Las Vegas, Nevada 89101
    (702) 384-5563
    khuff@christiansenlaw.com
    -----Original Message-----
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Sunday, October 31, 2004 2:02 PM
    To: Kelly Huff
    Subject: Re: File: State Bar Admittance
    Dear Miss Huff,
    I would like another copy of my file. Please send Mr. Barker
    one as
    well.
    Please send me a thorough status report
    and do not to send my file to storage. Also, I am requesting
    a complete copy of my file (including all materials that your
    office has
    recently submitted to the State Bar) and an itemization of the
    services your office has rendered in regard to this matter.
    This is the
    second time I have made such a request for an itemized
    statement.
    I would like a response to my request of last month that your
    office
    indicate whether it ever submitted anything to further this
    matter along
    to
    the State Bar or Supreme Court on or around the October 2003
    000177
    expiration
    of
    the deferral order issued in December of 2002. My records
    indicate that
    I
    made repeated requests that your office do so. If no request
    was sent,
    please indicate what, if any actions your office took to further
    this
    matter
    along between December of 2002 and the present. Please don't
    forget the
    itemized statement of the services you have rendered at this
    point.
    Please send me a copy of any fee agreement in your possession.
    Sincerely,
    Zach Coughlin
    >From: "Kelly Huff" <khuff@christiansenlaw.com>
    >To: "Zach Coughlin" <zachcoughlin@hotmail.com>
    >Subject: Re: File: State Bar Admittance
    >Date: Wed, 27 Oct 2004 15:24:44 -0700
    >MIME-Version: 1.0
    >Received: from lawserver.christiansenlaw.com ([24.234.45.95])
    by
    >mc7-f18.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Wed,
    27 Oct
    2004
    >15:28:04 -0700
    >X-Message-Info: JGTYoYF78jGhpAquzv3dzm/M2o+Bg2I5
    >Message-ID:
    ><F44EE6CE7264924B9F92F6844D350DAE8FAA@lawserver.christiansenlaw.com>
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    State
    Bar
    >Admittance
    >Thread-Index: AcS8c8KjeND+3BnuS1u7pXCaabj6Iw==
    >Return-Path: khuff@christiansenlaw.com
    >X-OriginalArrivalTime: 27 Oct 2004 22:28:04.0264 (UTC)
    >FILETIME=[39A63A80:01C4BC74]
    >
    >Zach,
    >
    >We received a letter yesterday from Bo Barker inquiring into
    the status
    >of your file with our office. Mr. Christiansen has also
    reviewed the
    000178
    >various e-mails sent to Mike and me with regard to your file.
    Per Mr.
    >Christiansen, all the documentation you have submitted to our
    office
    >along with the Stipulation you signed has been submitted to the
    State
    >Bar of Nevada. As such, Mr. Christiansen has concluded his
    >representation of your interests and will now be closing out
    your file
    >with our office. Therefore, there is nothing to communicate to
    Mr.
    >Barker. Although one has already been provided to you, if you
    would
    >like another copy of your file, please contact me within the
    next 10
    >days before your file is sent to storage. All other questions
    you may
    >have with regard to your admittance to practice in Nevada may
    be
    >directed to the State Bar office.
    >
    >If you have any further questions, please feel free to contact
    our
    >office.
    >
    >Kelley Huff
    >Christiansen Law Offices
    >520 South Fourth Street
    >Las Vegas, Nevada 89101
    >(702) 384-5563
    >khuff@christiansenlaw.com
    >
    >From: "Bo Barker" <bobarker@barkermartin.com>
    >To: <zachcoughlin@hotmail.com>
    >Subject: RE: Bar Admission and employment
    >Date: Thu, 4 Nov 2004 13:38:22 -0800
    >MIME-Version: 1.0
    >Received: from exchange.lawoffice.barkermartin.com ([207.225.248.213]) by
    >mc9-f5.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Thu, 4 Nov 2004
    >13:38:23 -0800
    >X-Message-Info: JGTYoYF78jE7aK1HQZaqWDI/9/uD8ns9
    >X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
    >Content-class: urn:content-classes:message
    >Message-ID:
    ><A09D62B72306C94ABF2385B7C2069B6C2E2679@exchange.lawoffice.barkermartin.com>
    >X-MS-Has-Attach: X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and
    >employment
    >Thread-Index: AcS/k0yXO3hkWRcBQsu32m0Me1fYJADIs7/A
    >Return-Path: bobarker@barkermartin.com
    >X-OriginalArrivalTime: 04 Nov 2004 21:38:23.0554 (UTC)
    000179
    >FILETIME=[9C4FFA20:01C4C2B6]
    >
    >Zach- I think that the best thing to be done is for either you or me,
    >perhaps me, ask for a complete copy of your file from Christiansen.
    >This should be done immediately, certainly before the passage of 14
    >days. Please track me down on my cell phone and lets talk and decide
    >who asks for the file. Then, I think that you should retain a well
    >qualified attorney to represent you in getting your bar status approved.
    >Please call me as soon as possible. (206)718-5757. Best regards,
    >
    >
    >Bo Barker
    >Barker Martin, P.S.
    >Construction Defect and
    >Homeowner Association Attorneys
    >720 Seventh Avenue, Suite 300
    >Seattle, WA 98104-1960
    >Direct: (206) 381-9806 x100
    >Fax: (206) 381-9807
    >www.barkermartin.com
    >
    >-----Original Message-----
    >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    >Sent: Sunday, October 31, 2004 1:48 PM
    >To: Bo Barker
    >Subject: RE: Bar Admission and employment
    >
    >HI Bo,
    >
    >I have no idea what is going on. THis is pretty much in line with their
    >representation of me so far. Its just be a nightmare with these guys.
    >Originally I went to me first hearing with the NV bar and didn't have
    >representation. It went on for three and a half hours then I started
    >crying. so the stopped the hearing and said they were going to give me
    >a referral to three different lawyers who would represent me on a pro
    >bono basis. then this lawyer coe swobe, from in reno calls me and
    >refers me to christiansen. the guy who was at the hearing and said he
    >would refer me to a pro bono lawyer is name Kevin Kelly, and if you do a
    >google search for him in las vegas it will reveal an article about how
    >he owns this strip club, the spearmint rhino. Apparently he is the one
    >who suggested christiansen.
    >christiansen sent me to a psychologist who revealed that he is one of
    >kevin kelly's best friends, the psychologist that is. this seemed like
    >a rather big conflict of interest. Christiansen revealed that he would
    >not do my case pro bono, but would for 5K, which my dad paid him. I
    >felt kind of required to use him as my attorney, but it was stupid and
    >lazy of me not to check this out more, but I trusted Coe Swobe and the
    >bar committee. It seems that when the october 2003 date came, marking
    >the end of the supreme courts deferral period, that christiansen's
    >office didn't do anything to get the process moving along. So a year
    >passed. I have written christiansen's office requesting them to answer
    >whether they ever mailed a letter to the bar or court requesting
    >consideration of my case. Around october 2003 I was calling everyone
    >involved, christiansen, the bar, the supreme court, etc, to try to
    000180
    >figure out how to get the process moving. I got conflicting answers but
    >made sure to request that christiansen submit the request for
    >consideration. I passed the July 2001 bar exam. It seems like
    >christiansen's never submitted the request, so my case just sat there.
    >This seems like malpractice to me. Also, there were times were I made 5
    >or 6 phone calls over a 8 week period and never got a response from
    >Christiansen's office. I'll email them the requests you suggested.
    >I'll call you soon. In the meantime I have pulled all the nevada case
    >law in regard to character and fitness applications and am writing a
    >brief in favor of my admission. My aa sponsor, who is an attorney of
    >some stature in reno, finally signed off the letter of recommendation I
    >drafted for myself.
    >Also, I am getting proof of some community service I have done and
    >attendance at aa meetings and have requested that several lawyers in AA
    >write me letters of recommendation.
    >One really frustrating person is Coe Swobe. He is an old lawyer who
    >runs the bar's "lawyers concerned for lawyers" section, a substance
    >abuse prevention entity. He is really lazy and pretty oblivious of how
    >long this ordeal has gone on and how very little I did to deserve this
    >treatment.
    >Perhaps a call from you or my sponsor Kelly will help get his
    >recommendation, which appears to be fairly important. He is the one who
    >recommended this lawyer, and it wouldn't surprise me if he made the
    >recommendation with hardly any knowledge of the guy. Kelly often
    >remarks on Coe's laziness and incompetence. I would like to request a
    >refund from Christiansen, but I am not doing anything right now in that
    >regard.
    >
    >Thanks,
    >zach
    >
    >
    > >From: "Bo Barker" <bobarker@barkermartin.com>
    > >To: <zachcoughlin@hotmail.com>
    > >Subject: RE: Bar Admission and employment
    > >Date: Sat, 30 Oct 2004 13:55:49 -0700
    > >MIME-Version: 1.0
    > >Received: from exchange.lawoffice.barkermartin.com ([207.225.248.213])
    > >by mc8-f23.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Sat, 30
    > >Oct 2004
    > >13:56:11 -0700
    > >X-Message-Info: JGTYoYF78jG9ZXbx0t2orsERNDwBpif/
    > >X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
    > >Content-class: urn:content-classes:message
    > >Message-ID:
    > ><A09D62B72306C94ABF2385B7C2069B6C053DB7@exchange.lawoffice.barkermartin
    > >.com>
    > >X-MS-Has-Attach: X-MS-TNEF-Correlator:
    > ><A09D62B72306C94ABF2385B7C2069B6C053DB7@exchange.lawoffice.barkermartin
    > >.com>
    > >Thread-Topic: Bar Admission and employment
    > >Thread-Index: AcS+QPH57EnxkswMTuehm8oP9HEp1wAf8/gr
    > >Return-Path: bobarker@barkermartin.com
    > >X-OriginalArrivalTime: 30 Oct 2004 20:56:11.0796 (UTC)
    000181
    > >FILETIME=[E3339D40:01C4BEC2]
    > >
    > >Zach- Do you understand what is going on? Is Mr. Christiansen
    >withdrawing?
    > > If so, why? What was Tim's relationship with Christiansen? You
    >should
    > >tell them not to send your file to storage and to provide you with a
    > >status report. Their statement: "Although one has already been
    > >provided to you, if you would like another copy of your file, please
    > >contact me within the next 10 days before your file is sent to
    > >storage." is confusing. Tell them you want a copy of what ever was
    > >referred to by the word "one." Also tell them you want a status report
    >
    > >and not to send your file to storage. Finally, tell them you want a
    > >complete copy of your file and an itemization of the
    > >services they have rendered for you. By their statement: "All other
    > >questions you may have with regard to your admittance to practice in
    > >Nevada may be directed to the State Bar office." it would appear that
    > >they are refusing to represent you further. I think that he is not
    > >treating you well. Have you had problems with this office? Please
    > >give me a call to discuss. Bo
    > >
    > >________________________________
    > >
    > >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    > >Sent: Fri 10/29/2004 10:25 PM
    > >To: Bo Barker
    > >Subject: RE: Bar Admission and employment
    > >
    > >
    > >
    > >HI Bo,
    > >
    > >I just got this email from Christiansen's secretary.
    > >i have pulled about 30 NV Supreme Court Cases pertaining to Character
    > >and Fitness issues and bar applicant's admissions and am working on a
    > >brief in favor of my admission at present. Perhaps you could read over
    >
    > >it before I send it in.
    > >
    > >
    > >THanks,
    > >
    > >
    > >Zach
    > >
    > >ps, I pasted the email below
    > >
    > >Zach,
    > >
    > >We received a letter yesterday from Bo Barker inquiring into the status
    >
    > >of your file with our office. Mr. Christiansen has also reviewed the
    > >various e-mails sent to Mike and me with regard to your file.
    000182
    > >Per Mr.
    > >Christiansen, all the documentation you have submitted to our office
    > >along with the Stipulation you signed has been submitted to the State
    > >Bar of Nevada. As such, Mr. Christiansen has concluded his
    > >representation of your interests and will now be closing out your file
    > >with our office. Therefore, there is nothing to communicate to Mr.
    > >Barker. Although one has already been provided to you, if you would
    > >like another copy of your file, please contact me within the next 10
    > >days before your file is sent to storage. All other questions you may
    > >have with regard to your admittance to practice in Nevada may be
    > >directed to the State Bar office.
    > >
    > >If you have any further questions, please feel free to contact our
    > >office.
    > >
    > >Kelley Huff
    > >Christiansen Law Offices
    > >520 South Fourth Street
    > >Las Vegas, Nevada 89101
    > >(702) 384-5563
    > >khuff@christiansenlaw.com
    > >
    > >
    > >
    > >
    > > >From: "Bo Barker" <bobarker@barkermartin.com>
    > > >To: <zachcoughlin@hotmail.com>
    > > >Subject: RE: Bar Admission and employment
    > > >Date: Thu, 21 Oct 2004 12:40:05 -0700
    > > >MIME-Version: 1.0
    > > >Received: from exchange.lawoffice.barkermartin.com
    > > >([207.225.248.213]) by mc5-f8.hotmail.com with Microsoft
    > > >SMTPSVC(5.0.2195.6824); Thu, 21 Oct
    > >2004
    > > >12:40:07 -0700
    > > >X-Message-Info: JGTYoYF78jHCcITVD+zs6qbFmOAlmrcH
    > > >Content-class: urn:content-classes:message
    > > >Message-ID:
    > > ><A09D62B72306C94ABF2385B7C2069B6C2E2379@exchange.lawoffice.barkermart
    > > >in.com>
    > > >X-MS-Has-Attach: X-MimeOLE: Produced By Microsoft Exchange
    > > >V6.5.7226.0
    > > >X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and employment
    > > >Thread-Index: AcS3A/1iQw5I3vTATe6Dyu594Y+ICAAoZF0g
    > > >Return-Path: bobarker@barkermartin.com
    > > >X-OriginalArrivalTime: 21 Oct 2004 19:40:07.0224 (UTC)
    > > >FILETIME=[C4C97380:01C4B7A5]
    > > >
    > > >Zach-
    > > >Good news from you. Be persistent and patient. Keep me posted as to
    >
    > > >what I can do to help. I think of you often and am wishing the best
    > > >for you.
    > > >
    000183
    > > >
    > > >Bo Barker
    > > >Barker Martin, P.S.
    > > >Construction Defect and
    > > >Homeowner Association Attorneys
    > > >720 Seventh Avenue, Suite 300
    > > >Seattle, WA 98104-1960
    > > >Direct: (206) 381-9806 x100
    > > >Fax: (206) 381-9807
    > > >www.barkermartin.com
    > > >
    > > >-----Original Message-----
    > > >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    > > >Sent: Wednesday, October 20, 2004 5:21 PM
    > > >To: Bo Barker
    > > >Subject: RE: Bar Admission and employment
    > > >
    > > >Hi Bo,
    > > >Thanks for the letter, I appreciate it. Also, thanks for the letter
    > > >to Christiansen's office, I think it is really good and will help. I
    >
    > > >am sorry if I sent you the wrong address. I am applying to firms and
    >
    > > >knocking on doors. I have done everything that the emails you
    > > >mentioned requested.
    > > >I'll keep you informed.
    > > >
    > > >Thanks,
    > > >Zach
    > > >ps. My resume is attached.
    > > >
    > > > >From: "Bo Barker" <bobarker@barkermartin.com>
    > > > >To: <zachcoughlin@hotmail.com>
    > > > >Subject: Bar Admission and employment
    > > > >Date: Wed, 20 Oct 2004 13:15:14 -0700
    > > > >MIME-Version: 1.0
    > > > >Received: from exchange.lawoffice.barkermartin.com
    > > > >([207.225.248.213]) by mc7-f24.hotmail.com with Microsoft
    > > > >SMTPSVC(5.0.2195.6824); Wed, 20 Oct 2004
    > > > >13:15:16 -0700
    > > > >X-Message-Info: JGTYoYF78jGQL0qHRj71gv2EbGDzBZ0+
    > > > >Content-class: urn:content-classes:message
    > > > >X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
    > > > >Message-ID:
    > > > ><A09D62B72306C94ABF2385B7C2069B6C2E233D@exchange.lawoffice.barkerma
    > > > >rtin
    > > > >.com>
    > > > >X-MS-Has-Attach: yes
    > > > >X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and employment
    > > > >Thread-Index: AcSyEIi4MBQu8XTbTx+lK/BWoB3W8AEzBdIQ
    > > > >Return-Path: bobarker@barkermartin.com
    > > > >X-OriginalArrivalTime: 20 Oct 2004 20:15:16.0835 (UTC)
    > > > >FILETIME=[83CCCB30:01C4B6E1]
    > > > >
    000184
    > > > >Zach-
    > > > >The letter I sent to Christiansen was returned for an incorrect
    > > >address.
    > > > >I had it spelled Christianson and at 520 S. 5th Street. It should
    > > > >have
    > > >
    > > > >been Christiansen on 4th Street. Attached find a revised copy of
    > > > >my revised letter as signed and sent today.
    > > > >
    > > > >I note in reviewing the emails you sent me that there were certain
    > > > >steps you were advised to take. Have you taken all steps advised
    > > > >in Pat Eichman's email to you of Monday, March 8, 2004 nad in
    > > > >Michael Sanft's email to you of Monday, July 5, 2004? If not, I
    > > > >advise you to
    > > >do so.
    > > > >
    > > > >You faxed me a resume that was smudged and unreadable. If you will
    >
    > > > >email me or mail me a ledgible copy I will make what suggestions
    > > > >for revision that I think might be helpful for you.
    > > > >
    > > > >I continue to believe that the best possible thing that you could
    > > > >do for yourself is to knock on door after door after door until you
    >
    > > > >get a job in Reno clerking for a lawfirm. This will give you some
    > > > >experience
    > > >
    > > > >and history in the law and it will set you up for some good
    > > > >reference letters to the Suproeme Court. In your interviewing
    > > > >process, I would tell the prospective employer that you really need
    >
    > > > >and want a job and that you would be willing to do an assignment
    > > > >for free just to demonstrate your capability and tenacity. Be
    > > > >candid and tell them about your admission problems. Tell them that
    >
    > > > >you are committed to making some life changes. The longer that you
    >
    > > > >put off finding employment, the harder it will be to break the
    > > > >cycle. Zach, I would close the bed business imediately. It will
    > > > >not serve your best
    > > >interests.
    > > > >
    > > > >I know from first hand experience how hard it can be to get a job.
    > > > >When I interviewed during spring break of my third year in law
    > > > >school, I knocked on at least 50 doors, calling cold trying to find
    >a job.
    > > > >This effort produced not a single offer and not even a single
    > > > >exptression of interest in me as a possible employee. I was very
    > > > >discouraged. Later in life after practicing for 8 years I was
    > > > >fired from my firm after I had earned a partnership. I tried again
    >
    > > > >to find a
    > > >
    > > > >job. For a long time I had no success in this 1978 effort. This
    000185
    > > > >was particularly embarassing to me as I had gotten married only a
    > > > >month before. I felt terrible. I found that I had to be very
    >persistent.
    > > > >
    > > > >I know you must be feeling discouragement among other things. I am
    >
    > > > >sure that with your brains and talent things will work out for you
    > > > >if you are persistent and keep focused.
    > > > >
    > > > >Let me know what I can do to help. Good luck, Zach.
    > > > >
    > > > >Bo Barker
    > > > >Barker Martin, P.S.
    > > > >Construction Defect and
    > > > >Homeowner Association Attorneys
    > > > >720 Seventh Avenue, Suite 300
    > > > >Seattle, WA 98104-1960
    > > > >Direct: (206) 381-9806 x100
    > > > >Fax: (206) 381-9807
    > > > >www.barkermartin.com
    > > > >
    > > > >-----Original Message-----
    > > > >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    > > > >Sent: Thursday, October 14, 2004 10:08 AM
    > > > >To: Bo Barker
    > > > >Subject: Hello, the smudged fax
    > > > >
    > > > >Hi Bo,
    > > > >Sorry for the smudged fax. I am mailing you the documents and some
    >
    > > > >email correspondence between christiansen's office and myself.
    > > > >Please be aware that they likely think the delays were caused by
    > > > >me, and this may be true.
    > > > >I read your introductory letter and it looks great.
    > > > >I am mailing this stuff today.
    > > > >Thanks,
    > > > >Zach
    > > > >
    > > > >_________________________________________________________________
    > > > >Get ready for school! Find articles, homework help and more in the
    > > > >Back
    > > >
    > > > >to School Guide! http://special.msn.com/network/04backtoschool.armx
    > > > >
    > > > ><< C041020SignedLettertoC_senLawoffice.pdf >>
    > > >
    > > >_________________________________________________________________
    > > >Express yourself instantly with MSN Messenger! Download today - it's
    > > >FREE!
    > > >hthttp://messenger.msn.click-url.com/go/onm00200471ave/direct/01/
    > >
    > >_________________________________________________________________
    > >Is your PC infected? Get a FREE online computer virus scan from
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    > >Security. http://clinic.mcafee.com/clinic/ibuy/campaign.asp?cid=3963
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    > >
    > ><< winmail.dat >>
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    grievance against Creig Skau, Esq., Reno City Attorney's Office
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/19/12 6:49 AM
    To: complaints@nvbar.org (complaints@nvbar.org)
    Dear SBN OBC,
    I believe Pat King is conflicted off of handling this grievance, but please check with the
    Boss..
    Please write back immediately with the grievance number, and provide the grievance
    numbers for all the previous grievances that I have filed, yet Bar Counsel has failed to
    respond to. All grievances filed by Zach Coughlin have been mailed to the State Bar
    of Nevada by certified mail as well. Please divulge the conflicts of interest before I
    bring them up. Pat sure can cook up a good Panel...He chooses Smiley Kent because
    of Mike Smiley Rowe, Esq. and Ken'ts 1980 McGeorge School of law pedigree
    (providing a nice connection to Judge Nash Holmes, class of '77, Judge Kenneth
    Howard, class of '81...anyways, this is a formal grievance against Reno City Attorney
    Creig Skau, Esq. to the extent he seems to have violated RPC's related to candor to the
    tribunal and fairness to opposing counsel (even a suspended attorney like myself) in
    securing my attendance at an impromptu 11/13/12 Hearing the day before my
    Disciplinary Hearing (which just happens to be when the District Attorney's Office
    decided to respond, however, deficiently, to my subpoenas...
    000187
    Anyways, the attached materials demonstrate ex parte extra judicial contacts with the
    court and the judge, and apparent lying to get me to the hearing by asserting that Judge
    Sferrazza had authorized service via email of Skau's ex parte motion to quash my
    subpoenas, which he sought to quash based upon alleged service insufficiencies...go
    figure. In fairnes to Mr. Skau, however, it can be a real moving target trying to
    figure out what Judge Sferrazza's Orders are at any one given time (sometimes a court
    date is noticed in writing as a "Trial" and continually referred to on the record as a
    "Trial" after Judge Sferrazza has ruled that the tenant has "established a genuine issue
    of material fact" sufficient to meet the summary judgment standard as applicable to
    summary eviction proceedings under the Anvui decision (as he did both at the 10/13/11
    summary eviction proceeding in RJC 2011-0001708, and again at the 10/25/11 Trial (it
    was noticed in writing as a Trial, etc., etc.) on the unlawful detainer matter (where
    Coughlin still was precluded from bringing third party claims or conducting discovery,
    or granted the 20 days to respond to a Complaint under JCRCP 109, etc., etc..in some
    summary plenary souffle' pastiche, kinda like...well, kind of like the SBN's Pat
    King...you go the last minute shift of the 11/14/12 Disciplinary Hearing in NG12-0204
    to a McGeorge SOL 1977-79 reunion of sorts, with most of the witnesses or exhibits
    not even being served in the DowSoE or any Supplemental DoW until after the
    hearing.
    Oh, that reminds me, as for the 11/14/12 Hearing, beyond the fact that I was having
    severe aching in my hands hands preventing me from taking notes as I would have
    normally, Chair Echeverria issued an Order which he did not appear to have
    jurisdiction to enter refusing to allow me to audio record the proceeding...and given my
    ADHD and MDD, I ask that sufficient accommodations be made under the ADA to
    ameliorate that discrimination and disparate impact/disparate treatment I was seemingly
    maliciously subjected to, given Chair Echeverria's constant haranguing of me regarding
    my conditions. PLEASE HAVE ALL RECORDINGS, RECORDS, AND OR
    DOCUMENTATION (INCLUDING EVEN THE ROUGHEST DRAFTS OF THE
    TRANSCRIPT SUNSHINE REPORTING SERVICES'S CAROL HUMMEL (AND
    THAT FIRM REALLY WAS CONLICTED OUT OF PARTICIPATING GIVEN ITS
    ASSOCIATION WITH THE RMC'S PAM LONGONI AND MS. LONGONI'S
    FRAUDULENT CONDUCT IN CONNECTION WITH THE DUE PROCESS
    CHALLENGED CONVICTION AND SUBSEQUENT APPEAL (DISMISSED DUE
    TO MS. LONGONI, THE RMC'S EXCLUSIVE TRANSCRIPTIONIST THAT THEY
    FORCE ON DEFENDANT'S, FRAUDULENT FAILURE TO PREPARE AND
    000188
    TRANSMIT THE THE TRANSCRIPT IN 11 CR 22176...WHICH PROVIDED A
    NICE COUNTERPOINT TO RENO CITY ATTORNEY PAMELA ROBERTS
    VIOLATING THE RPD, INCLUDIG RPC 3.9 AND NRS 171.1255 IN
    PROSECUTING ME INCIDENT TO A MISDEMEANOR ARREST BY A TRIBAL
    POLICE OFFICER WHERE WAL-MART AND THE CITY ATTORNEY ADMIT
    THAT NO ONE WITH WAL-MART EFFECTED A CITIZEN'S ARREST (THAT
    WOULD EXPOSE THE DEEP POCKETS TO TOO MUCH LIABILITY....WHY DO
    THAT WHEN THEY KNOW ITS SO HARD TO FIGHT CITY HALL
    PARTICULARLY FOR THOSE THAT DON'T OWN THEIR VERY OWN PIECE
    OF IT, some might say....).
    Please email me those transcripts, recordings, and associate materials right away AND
    REALIZE THIS CORRESPONDENCE PLACES THE STATE BAR OF NEVADA
    OFFICE OF BAR COUNSEL ON A LITIGATION HOLD NOTICE WITH RESPECT
    TO ALL MATERIALS CONNECTED TO THE MATTERS SET FORTH IN THIS
    WRITING.
    Also, I am very, very uncomfortable with something Pat King, Esq. did at the 11/14/12
    Disciplinary Hearing in NG12-0204. While I was peacefully using a urinal in the
    restroom, a lecherous, leering Bar Counsel King sauntered right up to the very next
    urinal beside mine and stated "pretty good grub, huh, Zach?" He said this as we both
    had our penises in our hands. Needless to say it was entirely inappropriate,
    unwelcomed, and requiring Mr. King's immediate removal from this matter, in addition
    to a multitude of other basis for such an action that I have previously set forth.
    Beyond that, Mr. King continues in his lame "push me pull me" thing were he
    alternatively bemoans me not coming into the Bar's Office to meet and allegedly have
    an opportunity to review the materials submitted in connection with the always murkily
    attributed grievances only to threaten some abuse of process in a manner similar to
    Laura Peters has done should I appear... (that's the nice thing about scanning and
    OCR'ing the entire "big box" he only had delivered on 11/8/12...it shows so much
    about King's approach, so very much...which, when combined with King's practice of
    gleefully announcing that SCR 106 has given him a license to lie, cheat, and commit
    other transgressions...its a wonder why the other attorney's in the Office of Bar
    Counsel even bother trying to keep up the fine work they have done for so very long to
    make the image of the State Bar of Nevada what it is...
    000189
    Sincerely,
    `
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
    11 14 12 email dda young and 0204 panel regarding skau and update dispatch discovery.htm
    11 8 12 city attorney skau and homer email with 3 motion to ex parte quash attachments.htm
    11 8 12 emails to dogan, kandaras and skau 0204.htm
    11 8 12 homer and 11 9 12 skau reno city attorney's office emails 063341.htm
    11 9 12 email from skau 063341 purporting that Judge authorized service of notice of hearing by email.htm
    Download all

    000190
    RE: does Richard Hill have standing to file a grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/18/12 8:48 AM
    To: davidc@nvbar.org (davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com)
    Mr. King admits in his email below that he is departing from the SBN's stated policy of according every
    grievance received a case number. Further, Justice Hardesty made some comments about a Constitutional
    requirement in Nevada at a luncheon earlier this year respecting the fact that the Nevada Supreme Court must
    review every grievance received...which would be hard to do given Mr. King, the filter/attack dog for the rich,
    powerful, and influential in Northern Nevada/Social Climber Extraordinaire. Further, Mr. King was sued by a
    close personal friend of mine, Geof Giles, Esq., and, aside from King's overt love of big banking and obvious
    hatred of homeowners (which is notated on the record in hearings before the legislature and elsewhere) it is
    inappropriate for King to have remained on my disciplinary matter...and I informed you of this long ago...
    Now, this situation is a disaster for all involved in some respects. I am worried about Pat. I think we need
    to get him some help. Being Bar Counsel is a tough deal, all that power can really go to one's head, and I
    would like to be part of the intervention (what? No, I won't lead the damn thing, I couldn't possibly do that...I
    don't have the training or time or inclin...Oh, alright! Fine, I'll do it) so we can get our Patty back. I know for a
    fact his spouse is on board, and I have arranged for a bag to be packed for him and a plane ticket to
    Biloxi...there's a great facility there, and when Pat comes back and its the old Patty Ice we all know and love, he
    will be just as welcome as the flowers in May. Who's with me? Otherwise, you are left in the rather
    untenable situation of trying to explain why Pat is violating SCR 121 with the Eastman in CV11-00820 prior to
    the filing of any Petition, why he is feeding Judge Nash Holmes the "clear and convincing evidence" ethical
    violation standard of proof language and instructions that she should improperly transmogrify a traffic citation
    trial into some newfangled "summary disciplinary hearing" scenario (and she can't even cite to the right
    statute when she wants to splash out with a criminal contempt conviction or, in her terms "the misdemeanor of
    criminal contempt" (we all know being a prosecutor isn't exactly the best training ground for building up one's
    aptitude for specificity or factual support, now, is it?).
    It just hurts to see Pat like this...He's such a great guy "when he's right", you know? But when Dave's not
    there, its like "Risky Business" up here...Patty gets out the Bob Seager out, takes them old records off the
    shelf... and the dress shirt/boxer shorts/white tube socks/dark lensed Ray-Bans come out too, and the next
    thing you know he's got some sort of dog-horse hybrid crapping all over the floors of the Northern Office of the
    State Bar of Nevada, he's wearin' cargo pants to Disciplinary Hearings, he's booking Judge Linda Gardner's
    courtroom deputy for the same hearing that involves Judge L. Gardner's ghost grievance in NG12-0435, he
    booking the same court reporting firm (Sunshine and Pam Longoni, and Senator Grassley would find that dba so
    rich, would he not?) that hung up on the phone on Coughlin and got his appeal dismissed for lack of a transcript
    cited to in the matter that resulted in the SCR 111(6) Petition that is the basis for the current temporary
    suspension of Coughlin's law license. It one thing to run this hustle on some sad 25 year old...But, why would
    you want to get in a throwin' stars competition with a ninja? You wouldn't. He's failing to send out Laura's
    000191
    10/9/12 Affidavit, despite it being file-stamped. He's making the SBN look like lying clowns considering the
    announcing of the applicable SCR 105(4) procedural rules by "Clerk of Court Peters" on 9/11/12 (vis a vis
    deadlines not running for materials requiring service by certified mailing until the signature tag is signed by the
    recipient, and barring that, a remailing of such a certified mailing, and failing the requisition of a signed
    signature tag there, the certified mailing of a Notice of Intent to Take Default (and King and Peters, by
    admission on their own certificate of mailing to the file stamped 10/9/12 NOITD only sent it by certified mail, ie,
    they departed from their stated and established procedural practice of sending everything two different ways
    (ie, certified and first class)...regardless, HERES THE KICKER...that 10/9/12 certified mailing of the NOITD was
    returned to the SBN and signed for by the SBN on 11/8/12, and the envelope (a large manila one with the SBN's
    in house red Pitney Bowes postage printing affixed to it indicating an under postage was mistakenly applied
    given te large manila envelope with a certified mail certificate and return receipt requested card (at least $5.50
    in postage) had only $1.25 in postage affixed to it, which Tim, a 20 year employee of the Downtown Reno (I
    might have previously said Vassar, for some reason my brain was stuck on that...but it was definitely, definitely
    the Downtown Reno 89505 postal station) where upon a previous attempt to collect the certified mailing Tim
    failed to find it (who knows why, might be due to my handing him an Official Change of Address on October
    5th, 2012 for my PO Box 3961 89505 address..from which I forward mail to my current 1471 E. 9th St. 89512
    address) or due to his looking in "the small box" whereas that mailing was in an 8.5 x 11 inch envelope...but
    when I returned again on a later date, the same counter attendant, Tim, did find the 10/9/12 certified mailing
    of the NOITD (and Chair Echeverria doesn't seem to get this...I didn't get the NOITD until November 8th, 2012,
    and I only got it then in the bate stamped form is come in with the other thousands of pages of documents in
    the Sierra Document Processing "big box" that Chair Echeverria's 10/30/12 Order required the SBN to provide
    me as a consolation, apparently, to actually following the rule in SCR 105(2)(c) and allowing me inspect the
    materials "up to 3 days prior" to the 11/14/12 Hearing (that is a huge deal, for a variety of reasons, not least of
    which is the act that King continued to attempt to Supplement the Designation of Witnesses and Summary of
    Evidence as late as 11/7/12 (and the certified mailing signature card for that Supplemental was only signed for
    today, 11/16/12, and you know if Joe Garin is going to pull the old "actual notice of is not a substitute for
    technical compliance with service rules" card on me in 60302, that I am going there with the SBN), to wit, from
    SBN Ethics Committee member Joe Garin's 10/22/12 Respondent's Brief in 60302 (where Coughlin sued Washoe
    Legal Services, and involving NNDB member Kathleen Breckenridge, whose mess Coughlin cleaned up quite
    nicely on the i-864 Affidavit of Support for battered immigrant spouse issue (Breckenridge got the $3K award of
    attorney's fees...I clean up what she failed to spot, and am fired shortly thereafter....). So, really, given the
    return receipt card was only signed for the Notice of Hearing on 10/27/12 (and the earliest it was in my box,
    according to USPS track and confirm was 10/22/12, despite a certificate of mailing by Peters indicating she
    sent it out 10/12/12...which is odd given the USPS Track & Confirm shows it was first scanned into USPS custody
    on 10/16/12...not so odd when you consider that upon my arriving at the SBN's Northern Office on 10/31/12 at
    about 4:45 pm I spoke with Peters and noticed that in the "outbox" at the front desk were a lot of letters
    with the green certified mail/return receipt requested placards affixed to them...and I queried Peters about
    them. She admitted the mail had been picked up that day at the SBN already, so those items would not go
    out that day, despite what the certifcate of mailing attached thereto might swear to under penalty of perjury
    (you are playing with people's livelihood's and Fourteenth Amendment property rights, here...)...So, it would
    appear that Peters signed the certificate of mailing for the Notice of Hearing (and I believe a Designation of
    Witnesses and Summary of Evidence requires its own file stamping and its own certificate of mailing...and the
    bate stamped version of the "Disciplinary File for Zach Coughlin" indicates, in the 10/12/12 certifcate of mailing,
    that only a Notice of Hearing was sent out (ie, not a DoWSoE along with it...regardless, SCR 105(2)(c) requires
    000192
    the Panel send it out and serve it in compliance with SCR 109 (as altered by SCR 105(4), which includes Peter's
    attestations of 9/11/12...). None of that was done correctly. Rather, King persisted in his established
    practice of going back on the SBN's word to cheat and gain an advantage, and in his habit of taking on the roles
    of the Panel or the Clerk of Court (or the Municipal Court Judge where he tells Judge Nash Holmes to be sure to
    put the "I find by clear and convincing evidence violations of (insert copy and pasting with zero specificity as to
    any factual support for such a summary ethical violation order incident to a "simple traffic citation matter" (do
    you get the picture, here? Its amateur hour, and he's doing it with your good name, or what's left of it by
    now...) various Rules of Professional Conduct so Pat can ignore Claiborne some more and rest on his laurels
    and SCR 111(5)....which Chair Echeverria likes himself quite a bit...only problem is that they both like to go with
    a lot of Richard HIll testimony about pajamas and slippers and livin' in the former home law office after eviction
    and "breaking and entering" some crawlspace/glorified basement under the house that never had a lock at any
    time...not to much SCR 111(5), not relevant, puffing going on there, though, huh, Pat? Chair Echeverria?
    SCR 105(2)(c) a/k/a that which Patrick O. King and Chair Echeverria used as a guide for "things to make sure we
    avoid providing to Respondent Coughlin so our hit piece goes off smoothly and we both get a bunch of attaboys
    by the McGeorge Mafia and other power brokers..." along with the ol' Bar Counsel as debt collector for Richard
    G. Hill,Esq. and Casey Baker, Esq. meme of "if the Panel won't sign on to my ridiculous disbarment of Coughlin
    request, then please be sure to require Coughlin to pay Richard G. Hill, Esq. the attorney's fees award that
    Coughlin's former co-worker Judge Flanagan entered against Coughlin after refusing to recuse himself, and
    shortly after Pat King's 3/23/12 email to Coughlin attempting to mislead Coughlin about the Department 3
    "Clerk of Court' throwing a sewing circle of gossip :
    "...(c) Time to conduct hearing; notice of hearing; discovery of evidence against attorney. The hearing panel
    shall conduct a hearing within 45 days of assignment and give the attorney at least 30 days' written notice of
    its time and place. The notice shall be served in the same manner as the complaint, and shall inform the
    attorney that he or she is entitled to be represented by counsel, to cross-examine witnesses, and to present
    evidence. The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the
    attorney, and the names of the witnesses bar counsel intends to call for other than impeachment, together with
    a brief statement of the facts to which each will testify, all of which may be inspected up to 3 days prior to the
    hearing. Witnesses or evidence, other than for impeachment, which became known to bar counsel thereafter,
    and which bar counsel intends to use at the hearing, shall be promptly disclosed to the attorney. For good cause
    shown, the chair may allow additional time, not to exceed 90 days, to conduct the hearing."

    The thing is, since the Panel was not even created or named by NNDB Chairman Susich until October
    Here's Joe "Joey Detroit" Garin's take on why the SBN did a very bad think in pushing through with that
    Disciplinary Hearing on 11/14/12, by analogy to 60302, of course:
    "b. The District Court properly dismissed Torvinen, Breckenridge, and Sabo from the case because Plaintiff failed
    to provide them proper process.
    A claim of insufficiency of process is a challenge to the content and form of a summons and complaint. See e.g.,
    Musgrave v. Squaw Creek Coal Co., 964 N.E.2d 891 (Ind. Ct. App. 2012). A defendant has an absolute right to
    000193
    demand that process be issued in a manner prescribed by law. See MJS Enterprises, Inc. v. Superior Court, 153
    Cal.App.3d 555,557,200 Cal.Rptr. 286 (1984). Additionally, Nevada Rule of Civil Procedure 4( d) provides,plaintiff
    furnish person making copies necessary.
    "The summons and complaint shall be served together. The shall the service with such as are Service shall be
    made by delivering a f!2J2l!. of the summons attached to a f!2J2l!. of the complaint ... " (Emphasis added). In
    this case, Plaintiff failed to effectuate proper process against Torvinen, Sabo, and Breckenridge because process
    did not comply with NRCP 4(d). With respect to Torvinen, on October 27, 2011, Plaintiff served Torvinen with 35
    pages worth of documents related to the case. (Record Vol. II, 201-248). Nearly every page comprised of 9
    pages scaled onto one page. Id. Accordingly, on November 15, 2011 Torvinen filed a Motion to Dismiss on the
    grounds that Plaintiffs service of process was untimely and insufficient under NRCP 4. Id. Torvinen argued that a
    copy is a reproduction of an original and that Plaintiff provided modified versions of the original that were
    illegible and improper. Id. On November 30, 2011, Plaintiff responded with a three sentence Opposition that
    stated that service was sufficient and sidestepped the issue regarding process. (Record Vol. II, 394-396). The
    District Court subsequently dismissed Torvinen from the case for lack of service of process. (Record Vol. IV,
    1174-1160). The Court later clarified its order and found that Torvinen was dismissed for lack of process.
    (Record Vol. IV, 1475-1480). It adopted Torvinen's arguments that the papers provided were not a "copy" within
    the meaning of NRCP 4 and found Plaintiff did not effectuate proper process. Id. Likewise, Plaintiff served
    Breckenridge in a similar fashion. Breckenridge received a total of 89 pages worth of documents some of which
    related to the case and others which did not. (Record Vol. II, 286-387). The documents were also scaled down in
    size. Id. Some pages comprised of 9 pages to a page, while others fit 2 pages to a page. Id. On November 28,
    2011, Breckenridge filed a Motion to Dismiss based on non-service of process and insufficient process. Id. Much
    like
    Torvinen, Breckenridge argued that 89 pages of condensed documents did not
    constitute a "copy" of a summons and complaint within the meaning of NRCP 4.
    Id.
    In response, Plaintiff filed two perplexing oppositions presumably against her Motion, the latter of which was
    untimely. (Record Vol. II, 416-468; Vol. III 569-671). In the first opposition, Plaintiff dedicated two sentences to
    opposing Breckenridge's Motion. (Record Vol. II, 416-468). Per the first opposition's title-Opposition to all
    Defendant's Motions to Dismiss and all Defendant's Motions to Quash Service, Motion for Extension of Time to
    Respond/Continuance; Opposition to Motion to Tax Costs Simultaneously Seeking Extensions of Time or
    Continuance to Respond-Plaintiff sought to do various things in two sentences. Id. In reality, Plaintiff failed to
    do anything more than make a conclusory statement that he opposed the then filed motions to dismiss.
    Plaintiff's second opposition while more than two sentences in length, sought to raise tangential issues that
    were not before the Court. (Record Vol. III, 569-671). In effect, the District Court dismissed Breckenridge from
    the case. (Record Vol. III, 723-725).
    The District Court also dismissed Sabo from the case after she filed a motion to dismiss on the grounds of
    insufficient process. Id. Specifically, Plaintiff served Sabo with only a copy of the summons, once again ignoring
    NRCP 4's requirements. (Record Vol. II, 250-261).
    Based on all the above, it is clear that the District Court properly dismissed Torvinen, Breckenridge, and Sabo
    from this case. Plaintiff did not truly oppose the various motions to dismiss and failed to effectuate process on
    the parties.
    It was only after the District Court dismissed Torvinen, Breckenridge, and Sabo, that Plaintiff found a case, which
    he now relies on, to argue that the District Court erred in dismissing these parties (Record Vol III. 767-869).
    Plaintiff relies on the New York case, McKenzie v. Amtrak M of E, 777 F.Supp. 1119 (S.D.N.Y.
    000194
    forma
    1990). In McKenzie, a New York court denied a Motion to Dismiss for defects in process because they were
    attributable to court personnel. Id. at 112l. Specifically, the court acknowledged that generally there is a strong
    argument for ineffective service of process "unless a legible copy of both the summons and the Complaint are
    received by the defendant." Id. (citing Village of Wellsville v. At!. Richfield Co., 608 F.Supp. 497 (W.D.N.Y.1985);
    Parker v. Mack, 61 N.Y.2d 114, 472 N.Y.S.2d 882, 460 N.E.2d 1316 (Ct.App.1984)). The Court determined that
    because court personnel in this particular jurisdiction were required to make copies for in forma pauperis
    litigants, and a faint copy of the complaint was made and served on the defendants, dismissal was not
    warranted. Id.
    The McKenzie decision is not controlling and inapplicable to this case. In citing to the McKenzie decision,
    Plaintiff seeks to carve an exception into NRCP 4(a), which specifically places the responsibility to effectuate
    proper service of process on a plaintiff. Moreover, the circumstances in McKenzie were unique because that
    particular jurisdiction required court personnel to make copies for in
    pauperis litigants and serve such copies on their behalf. Plaintiff has failed
    to establish that court personnel in the Second Judicial District Court are required to makes copies of service
    papers for in form pauperis applicants. That is because there is no such requirement or practice and NRCP 4(d)
    specifically imputes that responsibility on a plaintiff. Furthermore, Plaintiff never argued that the modifications
    to the service papers were the fault of court personnel. Rather, the modifications were admittedly Plaintiff's
    own doing. (Record Vol. III, 816). Thus, McKenzie is not only a non-binding decision, but it is inapposite to the
    rules and
    overall circumstances of this case.
    Overall, the District Court did not abuse its discretion in dismissing Torvinen, Breckenridge, and Sabo from the
    case seeing as Plaintiff provided insufficient process."
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 17:57:26 +0000
    Dear Mr. Coughlin,

    Please come to see me and I will show you the letter and documents from the Court.

    000195
    Patrick King

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 10:39 AM
    To: Patrick King
    Subject: RE: does Richard Hill have standing to file a grievance

    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a
    grievance. Please provide any documentation or proof related to these apparent
    communications from judges that you are only now bringing up.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada
    Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 17:18:34 +0000
    Dear Mr. Coughlin,

    I have repeatedly expressed my interest in having a meeting with you to discuss the
    grievances against you. You claim to be too busy to meet with me, yet you have time to write lengthy e-mails and
    apparently to do legal research.

    You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
    standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I
    have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from different
    Courts. These grievances, and the evidence attached with them, rather clearly puts into question your competence to
    practice law. As I have explained to you, I will make the evidence and exhibits available to you when you come to
    inspect them at my office. I will not send you reports or document, especially since you claim your mail is being
    compromised.

    As for the grievances you have made, nothing that you have submitted appears to show an
    000196
    ethical violation that could be proved by clear and convincing evidence, which is the standard of proof required in
    disciplinary matters. As such, at this time we have not opened any files based on the information you have
    submitted.

    Sincerely,

    Patrick King

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 9:12 AM
    To: Patrick King; cdbaker@richardhillaw.com
    Subject: does Richard Hill have standing to file a grievance

    American Jurisprudence Trials


    Database updated April 2011
    Defending Lawyers in Disciplinary Proceedings
    31 Am. Jur. Trials 633 (Originally published in 1984)
    III Attorney-Client Grievances
    10 In general
    11 Sources of complaints and grievances; checklist
    12 Former criminal clients
    13 Particular problem clients
    14 Fee disputes; checklist of factors of reasonableness
    15 Arbitration; forms
    16 Fee dispute committee hearings; illustrative testimony

    Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining


    professional
    misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
    misrepresentation
    000197
    and engaging in conduct prejudicial to administration of justice, where attorney, acting in
    bad faith,
    filed documents which he or someone in his office generated to falsely certify debtors'
    completion of
    required credit counseling course and which he knew, or should have known, that debtors
    did not
    sign or otherwise adopt, and also certified documents as being completed by debtors. 11
    U.S.C.A.
    109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
    2010).

    Mr. King, could you please update me on that status and progress of the various grievances
    I filed recently in addition to providing a detailed summary of the content of all of your
    correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
    anyone with his office. Further, please state whether Casey Baker is part of the grievance,
    as Hill asserts he is filing it on Mr. Baker's behalf.

    Sincerely,

    Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
    work" for opposing counsel?
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    new Discovery finally produced by Reno City attorney on 1/12/12
    Jaywalking arrest in SCR 105 Complaint
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 11/14/12 6:46 AM
    To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
    (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
    (fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
    (complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
    (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (eifert.nta@att.net)
    (eifert.nta@att.net); (consult@laketahoelaw.com) (rhrc@laketahoelaw.com); (stuttle@washoecounty.us)
    (stuttle@washoecounty.us); (kadlicj@reno.gov) (kadlicj@reno.gov); (wongd@reno.gov)
    000198
    (wongd@reno.gov); (schornsby@nvdetr.org) (schornsby@nvdetr.org)
    Dear Panel and Bar Counsel,
    Please find the attach additional discovery the Reno City Attorney's Office gave me
    today related to the custodial jaywalking arrest of 1/12/12, at which time Richard Hill
    applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD
    Officer Look took a special trip to the jail to attempt to serve the TPO for Hill).
    Please see attached the video of the arrest and interactions prior thereto, and consider
    the lack of accuracy in Hill and Baker's Second Motion to Show Cause, Judge
    Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause
    Hearing (which WCSO Deputy Machen, the same one who filed a false affidavit
    incident to the summary eviction order posting and lockout on 11/1/11 in the Richard
    Hill eviction cases rev2011-001708 served on Coughlin, by way of violating the
    "courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
    case Coughlin did not require personal service anyways...this was hazing by Hill and
    the RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11
    TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD
    Sargent Tarter telling Coughlin to leave Hill's office upon going there after being
    released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12
    resulting in a wrongful arrest for criminal trespass of Coughlin by RPD Officer Chris
    Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer
    Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee
    Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
    report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for
    "misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage
    the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable
    cause basis for doing so. Further, both Hill and Officer Leedy substantially
    misrepresent what Officer Hollingsworth said. Additionally, should Officer
    Hollingsworth had indeed told Coughlin that what he was doing was legal but that the
    Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve
    cooperation, that would violate Soldal v. Cook County, which is essentially what RPD
    Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which
    les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes
    a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky
    associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-
    way believing RPD Officer Carter's statement on 11/15/11 that "Richard G. Hill pays
    me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's
    000199
    merely attributing the statement that RPD Carter said to Carter is not misconduct.
    Hill's making up things about a "crack pipe and bag of weed" and "large quantity of
    pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see
    that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that
    mentions this "large quantity of pills"). If you knew all the Thursday nights I spent
    since 2003 with Coe, and now deceased Judge Bob, and so many others, you would
    realize how infinitely tacky Hill's conduct is.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
    1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
    7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204
    25 page discovery northwind ncs krebs reduced size.pdf
    1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-
    000018 0204 Leed.pdf
    SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
    1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
    4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
    11 9 12 61901 amendment to opposition.pdf
    11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder
    ptthoa 0204.pdf
    10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
    bifurcate atty client severe hearing trialotjl.pdf
    bifurcate atty client severe hearing trial.pdf
    CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
    NG12-0204 BF.pdf
    Download all

    000200
    City Attorney Skau, updated discovery in iPhone case, dispatch
    recordings, don't seem to reveal basis for "a possible fight" assertions in
    office testimony and prosecutors's filings and argument
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 11/14/12 2:09 AM
    To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com
    (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
    (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com
    (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org
    (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com);
    cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com
    (consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us); kadlicj@reno.gov
    (kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov); schornsby@nvdetr.org
    (schornsby@nvdetr.org); jleslie@washoecounty.us (jleslie@washoecounty.us);
    jgoodnight@washoecounty.us (jgoodnight@washoecounty.us); jbosler@washoecounty.us
    (jbosler@washoecounty.us)
    Dear DDA Young and Bar Counsel and Panel Members,
    The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what
    started all this off (by "all this" I mean the 46 days in jail, the 10 different trips to jail,
    the five to six different evictions, all summary, the competency evaluations, and all the
    associated grievances. This arrest and prosecution have largely been based on and
    the office and prosecutor have cited to, their contention that the information from
    ECOMM or dispatch told the RPD Officers (and the arresting Officer Nick Duralde is
    married to a dispatcher working that night and perhaps whose voice is on these files,
    finally given to me only today, by Reno City Attorney's Office Creighton Skau, after he
    secured my attendance at a hearing that I do not believe was noticed in a legal since by
    sending me an email saying Judge Sferrazza authorized service of the notice of the
    hearing by email...which Judge Sferrazza denies (in fairness to Mr. Skau...its possible
    the Judge did say that...Mr. Young could maybe shed some light on that, as apparently
    their was a sort of group meeting with he, the Reno City Attorney and the WCPD on or
    about November 8th, 2012 in rCR2012-063342, that I was not noticed on and, of
    course did not attend).
    Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch
    reported a "possible fight" and how that somehow justified the rash approach taken
    by Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand
    Larceny (7 days in jail, the eviction notice in the Richard Hills summary eviction from
    000201
    my former home law office was served during the interim in RJC Rev2011-001708) for
    a three year old iphone that the alleged owner, Cory Goble, testified was worth about
    $80 at the time....(and the overcharging of a felony enabled Officer Duralde to conduct
    a search incident to arrest for a misdemeanor not committed in his presence, after 7
    pm...which Nevada law prohibits, particularly where, as here, there was no citizen's
    arrest (Coughlin himself called 911 and there is a video of the time prior to arrest
    where Coughlin is heard imploring the skater youths to stay peaceful and wait for law
    enforcement to arrive so a civil resolution of the dispute could be garnered).
    I am writing now and providing this new production of ECOMM/911 dispatch
    recordings that would seem to be the State's last hope of proving that the Officers were
    told of, by dispatch, "a possible fight" and therein provide some factual basis for that
    which Officer Duralde and DDA Young have testified to, and filed pleadings in that
    matter arguing that reports of "a possible fight" justified the subsequent terry stop
    weapons check pat down, and search incident to arrest (remember, Officer Duralde
    announced 20 seconds into arriving on scene that he was going to arrest Coughlin and
    do a search of Coughlin's pockets prior to conducting any of the pretexutal
    "investigation" that he later testified to...its just that Officer Duralde did not realize he
    was being recorded when he said that....no matter how he "remixed" things in his
    Supplementary Declaration (filed within 48 hours of arrest) or his Narrative (by all
    indications, the Narrative was only filed some three months after the arrest and
    apparently after the RPD and City Attorneys Office became aware that the video of the
    arrest was publicly available).
    I have listened closely to these dispatch recordings and hear nothing about "a possible
    fight". Does that make the Officer's Testimony perjury and DDA Young's conduct
    misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the SBN's
    Office on Double R. Blvd. I ask that you attend and explain these matters as this
    arrest is pled in Bar Counsel Kings SCR 105 Complaint.
    Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to
    subpoena the dispatch recordings until October 3, 2012 (despite the Trial occuring on
    May 7th, 2012 (in violation of NRS 178.405, no less), and again on July 16th,
    2012....and, again on August 29th, and September 5th, 2012....and then please explain
    why you feigned inability to personally serve subpoenas as a basis for failing to get
    Nicole Watson (easily found and or served via a certified mailing under NRS 174.345,
    at the addresses your investigator refused to turn over to me until November 2012 upon
    000202
    a court order (you guys are supposed to help defend the accused, not the County or
    local law enforcement against their potential civil liability for ego driven foolish
    arrests) as a student at McQueen High School along with Lucy Byington, both
    percipient witnesses, and where Watson was captured on tape admitting to the "man
    with a six-pack" holding the phone aloft and offering it up, and announcing, very
    loudly, that he woud "throw it in the river" if it was not immediately claimed (therein
    presenting yet another claim of right defense and further vitiating the legitimacy of
    DDA Young's retaliatory, deficiently pled, amending of the Complaint on December
    5th, 2012 to included "possessing or receiving stolen property from another".
    I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City
    Attorney's gained an advantage and prejudiced my ability to defend in both NG12-
    0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I will
    note that at least Joe Goodnight gathered the three 911 calls.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 66 files to share with you on SkyDrive. To view them, click the links below.
    PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 1.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-49 PM Source_ID = 31.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-00 PM Source_ID = 36.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-06 PM Source_ID = 38.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21.wav
    000203
    Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17.wav
    PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.wav
    PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
    Download all

    SBN and or Panel will be breaking the law by holding a hearing
    tomorrow in violation of SCR 105(2)(c) proof attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/13/12 3:22 PM
    To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
    nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org);
    fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org);
    complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net
    (eifert.nta@att.net); rosec@nvbar.org (rosec@nvbar.org)
    You will be criminals as of tomorrow if you hold that hearing.
    SCR 105(2)(c), SBN"s Index for Hearing is holding out certificates of mailing and or
    proofs of service on the most materials documents incident to a due process analysis
    (10 9 12 Notice of Intent to Take Default was recieved as returned due to insufficient
    postage by the SBN on 11 8 12, I declare under penalty of perjury...nrs 53.045...further,
    SBN only sent one envelope of that document, that returned for insufficient postage
    certified mail mailing on 10 9 12.
    Additionally, SBN is holding out 10 12 2012 certified mailing of Notice of Hearing and
    Designation of Witnesses and Summary of Evidence as having a date of 10/12/12 for a
    constructive notice analysis, despite the USPS proof indicating the first scan in a USPS
    system occurred on 10/16/12.
    Additionaly, the SBN and Peters formally declared that the 8/23/12 mailing was
    000204
    returned to the SBN and that another certified mailing of the Complaint would
    immediately be sent out, and that the 8/23/12 certified mailing would never be offered
    to prove proof of service under SCR 109 or in any other manner offered as proof of
    service of the Complaint. Yet that is just what King has done by his Index putting
    that forward.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    11 13 14 attachment proving 0204 sbn and panel fraud scr 105(2)(c).pdf
    From: zachcoughlin@hotmail.com
    To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org;
    fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
    cvellis@bhfs.com
    Subject: FW:
    Date: Sun, 11 Nov 2012 07:50:13 -0800
    Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR
    116 appeal rights...
    Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN
    Laura Peters signed a waiver of service or similar
    and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law
    (Response)

    Date: Mon, 13 Aug 2012 11:28:12 -0700


    From: silverman@silverman-decaria.com
    To: zachcoughlin@hotmail.com
    Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
    I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final
    000205
    judgment in the crim case and point out that your temporary suspension is akin to a permanent death of your
    practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now
    have access to your meds and are ok. I can't think this pleading is going to help you much...it is too long,
    repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't make
    your case in 3-5 pp, you can't make your case in 35. You do seem to be a good lawyer, however. At bottom, Steve
    Harris took hundreds of thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF.
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com

    SCR Rule 104(3) Complaint filed against Bar Counsel King and Clerk
    of Court Peters
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/12/12 9:51 PM
    To: Frank Flaherty (fflaherty@dyerlawrence.com); rosec@nvbar.org (rosec@nvbar.org);
    schornsby@nvdetr.org (schornsby@nvdetr.org); glennm@nvbar.org (glennm@nvbar.org)
    President Flaherty,
    I have filed my SCR 104(3) Complaint with you already. I reserve my right to supplement it at a later date, but
    it is filed. Whether you choose to abide by the duties of your Office is not something I can control. However,
    I do understand that there is a Constitutional requirement that the Nevada Supreme Court review your
    determination. Please provide me the case number for this Complaint, and the case numbers for every grievance
    I have filed this year. Just want my file stamp and case number, Sir. I understand you may feel my Complaint
    is jibberish...but I don't believe Clerk's of Court, under NRCP 5(e) are permitted to refuse to file Complaints (or
    anything for that matter, so...please just stamp it in and give 'er a case number.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: FFlaherty@dyerlawrence.com
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org; PatrickK@nvbar.org; KimberlyF@nvbar.org
    Subject: RE: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
    Date: Wed, 31 Oct 2012 21:02:36 +0000
    000206
    Mr. Coughlin:

    Regarding your numerous complaints and allegations below, I have no case


    numbers, I have no authority over attorneys who are not employees of the
    Office of Bar Counsel, and I certainly have no authority over judges.

    If you think you really need to file a complaint against an attorney in the
    Office of Bar Counsel, please review SCR 104(3) and send me a succinct and
    organized written document, along with only relevant exhibits, setting forth
    your allegations that said attorney has violated the Nevada Rules of
    Professional Conduct.

    Thank you.

    Francis C. Flaherty
    Dyer-Lawrence
    2805 Mountain Street
    Carson City, Nevada 89703
    (775) 885-1896
    FAX: (775) 885-8728

    This e-mail may contain legally privileged and/or confidential information. If you are not the intended
    recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you
    are hereby notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited.
    If you have received this message in error, please immediately notify the sender and delete this message from
    your computer.

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]


    Sent: Wednesday, October 31, 2012 12:57 PM
    To: Frank Flaherty
    Subject: FW: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman

    000207
    Dear President Flaherty,

    Can I get a case number for this matter, I have not heard anything about it in forever. I also, I would like to
    file a grievance or Complaint against Bar Counsel Pat King and NNDB Chairman Susich for failing to follow the
    June 7th, 2012 Order of the Nevada Supreme Court and SCR 111(7)-(8), in addition to SCR 102(4)(d). Under
    the Ching or Chang decision, the SBN is the "complainant" and wit respect to these matters, wherein I allege
    misconduct by Peter Christiansen, Character and Fitness Chairman Kevin Kelly, Esq. and others, the SBN has not
    known about these matters for more than 4 years. Further, King refuses to undertake any investigation
    against Richard G. Hill, Esq., Judge Nash Holmes, Casey Baker, any of the RMC "court appointed defenders" (like
    Loomis, Puentes, Taitel, Sotelo) or WCPD's Leslie, Goodnight, Dogan, or Bosler. Now, King is trying to jam me
    into a combo hearing on November 14th, 2012 in his ng12-0205 ng12-0434, and ng12-0434 scr 105 complaint,
    which impermissilby seeks to skirt scr 111(7)-(8) vis a vis King's SCR 111 petition in 60838 (please see my filings
    in that regard).


    Furhter, the "courthouse sanctuary" rule makes the RMC Marshal Harley's conduct in personally serving me
    notice of an Order to Show Cause Hearing in the appeal of the eviction matter in cv11-03628 (Richard HIll got
    me evicted from my former home law office) on behalf of WCSO Deputy Machen (whom HIll hired to serve it
    despit the Caplow decision making clear that is not even required...basically, its wrong to have the RMC Marshal
    barge in to my plea bargaining session with city attorney ormaas on february 27th, 2012 incident to the traffic
    citations in 11 tr 26800 that the rpd gave me at hill's office when I went to get my wallet, key's, drivers license,
    and client's files from hill after being released from a fraudulent custodial arrest for criminal trespass at my
    former home law office in a criminal complaint signed by hill, judge nash holmes held that 11 tr 26800 trial later
    that day, despite her apparent admission that she was made aware by the wcpd and or wcpd biray dogan that
    an order for competency evaluation had been entered respecting me on 2/27/12 at 1:31 pm and nrs 178.405
    and nrs 5.010 shoudl have prevented judge nash holmes from holding that trial, and In re Oliver (us supreme
    court case requiring sixth amendment right to council in cases like 11 tr 26800 where Judge Nash Holmes
    convicted me of "summary criminal contempt" despite her order resting upon alleged conduct outside her
    presence, in a bathroom stall that she alleged in her 3/ 12/12 hearing in that matter an RMC Marshall
    witnessed by peering through a bathroom stall I was in where "dissassemblign a smartphone" or some
    nonsense like that peeping tom crap...RMC Harley was serving an Order to Show Cause on behalf of WCSO
    Deputy Machen (who didn't want to wait around to serve me it....just like on 11/1/11 when machen didn't want
    to follow the law in serving me the eviction order, and instead filed a false affidavit attesting to personal service,
    then conducted a lockout using a stale or invalid eviction order when I was not present, only to attest to having
    "personally served" me..

    This is a mess, the SBN doesn't have jack on me (give me my hearing under the court's 6/7/12 order for the
    "sole purpose" of determingin my punishment over the "walmart candy bar" petty larceny conviction, which I
    000208
    completely showed to lack due process (dismissing appeals for failure to cite to a transcript where the rmc is
    breaking the law in not preparing the transcript? i proved perjury by all the city's witnesses, and prosecutorial
    misconduct, clearly)....then the criminal trespass conviction is so flawed its unbelievably. the judge was the
    brother of the family court judge garnder who got me fired from washoe legal services, and the brother passed
    her sanction order to judge nash holmes who passes it to the sbn, and it becomes ng12-0435, but sbn king
    doesn't want to admit that that is how he got it? and the brother judge gardner refuses to recuse himself
    from that criminal trespass case rmc 11 cr 26405, despit my filing mandamus against his sister's order in 54844
    and despite his sister's order being a bar grievance against me, submitted by judge holmes, on behalf of the
    brother judge gardner and all the other rmc judges? and the rmc "loses" my n otice of appeal an it gets
    dismissed in cr12-1262 by the same judge elliot of d10 whom put me in jail between 4/19 and 4/26/12
    impermissibly based upon lies by the competency evaluators and a motion by dda young that violated nrs
    178.405's mandatory stay? and during that incarceration richard hill's $40k attorneys fees motion against me
    in the eviction cv11-03628 is filed, which flanagan ultimately awarded?

    the sbn is gambling a large chunk of yours and its reputation on a bunch of asinine arrest by the rpd, and
    extremely suspect co-signing of richard hill's bullshit this year by people who should know better.


    Sincerely,


    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Subject: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
    Date: Fri, 16 Mar 2012 13:48:17 -0700
    000209
    Dear Bar Counsel,
    I write respectfully asking an inquiry be conducted into whether Kevin Kelly indicated
    at my June 2002 hearing that 3 pro bono attorney's name would be provided to me, but
    that only one was, Peter S. Christiansen, and that, despite Christiansen saying he was
    doing my case on a pro bono basis, he was paid at least $5,000, and pretty much the
    only work he or his office did was attend the June 2002 hearing, and that Christiansen
    and Kelly are very, very close, and that they sent me to a psychologist who specializes
    in gambling addictions (I have never really even gambled) who cost approximately
    another $2,000....Then Ms. Eichman failed to submit my application for admission or
    my Request For Reconsideration (sent to her and Christiansen's office on September
    15th, 2003, as confirmed by my fax records, in additional to being mailed to them) to
    the Nevada Supreme Court. There are numerous other issues that deserve a grievance
    there, including whether Christiansen supervised the newly licensed Sanft in any way,
    whether a writing wherein I addressed alcoholism was forward to the Bar despite the
    express dictate that it not be, whether second Consent Agreement sent to the
    Christiasens on 9/27/04 was ever forwarded to the Bar. Additionally, Mike Rowe
    wrote very stern letters to me basically telling me not to follow up on things, whereupon
    my attorney's and Ms. Eichman failed to follow up on things, essentially tying my hands
    in the matter. I intend to supplement this grievance with additional matters soon, but
    wish it to begin now.
    Sincerely,
    Zach Coughlin
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    LITIGATION HOLD NOTICE PLEASE RETAIN ALL EVIDENCE
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/12/12 6:52 AM
    To: schornsby@nvdetr.org (schornsby@nvdetr.org); patrick@nvbar.org (patrick@nvbar.org);
    davidc@nvbar.org (davidc@nvbar.org); skent@skentlaw.com (skent@skentlaw.com);
    mike@tahoelawyer.com (mike@tahoelawyer.com); cvellis@bhfs.com (cvellis@bhfs.com);
    je@eloreno.com (je@eloreno.com); tsusich@nvdetr.org (tsusich@nvdetr.org); nevtelassn@sbcglobal.net
    000210
    (nevtelassn@sbcglobal.net)
    RELATED TO THE MAILING OF, THE CERTIFIED MAILING NUMBER OF,
    AND THE ENVELOPE AND DOCUMENTS RETURNED TO THE STATE BAR OF
    NEVADA, ESPECIALY THE ONLY COPY OF THE NOTICE OF INTENT TO
    TAKE DEFAULT THAT COUGHLIN EVER RECEIVED UNTIL GETTING A
    COPY OF THE FILE ON 11 7 12 FINALLY DELIVERED TO HIS PHYSICAL
    ADDRESS AT 1471 E. 9TH, ST. Simply put, the SBN only mailed a certified
    version of the Notice of Intent To Take Default. That 10/9/12 mailing was not given
    to Coughlin by "Tim" at the Vassar Station due to the postage thereon being
    insufficient. However, the copy of the file provided to Coughlin lacks any indication
    of what the certified mail track and confirm number is for that Notice of Intent to take
    default.
    Coughlin requests that the SBN notify the panel of its error, the fact that Coughlin's
    Notice of Hearing and DowSoE was not even scanned into the USPS certified mail
    until 10/16/12, despite the certificate of mailing indicating 10/12/12, and that that
    mailing, with purports to have included the DowSoE, was not even available to
    Coughlin until 10/22/12, at the po box Coughlin then utilized (3961
    Its more than inaccurate for Mr. King to suggest I have dodged service. See my
    email to Reno Carson below...I know I called and left at least once voice mail there,
    etc. Plus, despite still being afraid of local law enforcement and others, and just
    getting used to my new place (and I have already received threats), against my better
    judgment and preferences, on October 23rd, 2012, I alerted the sbn of my new physical
    adderss.
    The Disciplinary File provided to Coughlin lacks a return of or proof of service of the
    Complaint and for the Notice of Intent to take Default. Please proof of service
    thereof of proof of attempts at service, including the certified mailing numbers. Give
    the primacy of such documents to the due process of these matters, it would seem
    holding the 11/14/12 Hearing would be reversible error and imprudent.
    "The Rhino" is Johnno Lazetich, http://www.facebook.com/public/Johnno-Lazetich-the-Rhino
    000211
    we were on the Reno High School basketball team together in 1994-=95... Johnno ran the ball for Kansas State.

    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    9 24 12 10 3 12 10 23 12 physical address service issues ex 0204 rhino.pdf
    "From: zachcoughlin@hotmail.com
    To: process@renocarson.com
    Subject: checking in
    Date: Wed, 3 Oct 2012 23:09:50 -0700
    Dear Reno Carson,

    Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me
    know what I can do for you.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com"
    my new address
    000212
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 10/23/12 11:29 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; complaints@nvbar.org
    Dear Bar Counsel,
    I am still very afraid of retaliation by local law enforcement, and due to my status as a domestic violence victim. In
    the past, I have offered to assistn you in getting me served appropriately, but have received no follow up. Further,
    the SBN, via Investigator/Clerk Peters and otherwise have made representations that I have relied upon to the extent
    that another certified mail SCR 105 Complaint would be sent out shortly after my communications with Peters on
    September 11th, 2012 or so where she admitted to receiving in the mail the one she said she sent on August 23rd,
    2012. Whatever the SCR 109 implications, the SBN's promises made by Peters are binding in that regard...
    Nonetheless, I now feel forced to provide you my address and expose myself to even greater danger, particularly
    where, some might say, the SBN has a vested interest in discrediting me now, a motive, a bias, some might say (I take
    no position in that regard at the current time). Please note my new phone number as well. While Mr. King has
    referred to some upcoming SCR 105 hearing (a "combo hearing" akin to the one's, including a Trial that DDA Young
    and his crew of Washoe County Public Defenders have been trying to run on me this year, including attempting to
    hold a Trial on May 7th, 2012 in RCR2011-0063341 where the Order finding me competent and remanding
    jurisdiction to the Justice Court in CR12-0376 was only signed, entered, and file stamped on May 9th, 2012...A big no-
    no under NRS 178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for given his
    communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and 12 CR 12420. This could be
    your Waterloo, so I hope you will investigate this properly. Especially considering the Order granting Loomis'
    withdraw in the criminal trespass case Mr. King just filed an SCR 111 petition in occurred during the pendency of such
    an evaluation on May 8th, 2011 (lots going on between May 7th-May 9th, 2012, here!) and the fact that Loomis and
    or the RMC ramrodded a Trial setting of June 18th, 2012 on May 8th, 2012 as well, well before Coughlin's
    competency was determined...and to the extent King indicates NG12-0204 and NG12-0435 rely on "Orders" entered
    or rendered during periods in which NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no
    good. Please don't make my address public yet or disseminate it in any way.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, 89512
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000213
    "From: zachcoughlin@hotmail.com
    To: process@renocarson.com
    Subject: checking in
    Date: Wed, 3 Oct 2012 23:09:50 -0700
    Dear Reno Carson,

    Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me
    know what I can do for you.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com"
    my physical address
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/03/12 9:31 AM
    To: patrickk@nvbar.org; laurap@nvbar.org
    Dear Bar Counsel King and Court Clerk Peters,

    I would prefer not to give my physical address given that I am a victim of domestic violence and
    have also been subject to quite a few attacks by law enforcement this year. I will provide it if
    you write back demanding it, as I want to cooperate, but could we arrange for me to accept
    service by certified mail of anything you wish to serve me? Or I could meet your process server
    somewhere?
    Zach Coughlin
    000214
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    citation to legal authority?
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 9/24/12 5:13 PM
    To: patrickk@nvbar.org
    Mr. King, this is the first I have heard of you wanting a physical address for me. Can you indicate, in writing, when, if
    ever the SBN has requested as much and whether it was in writing or verbal? Do you have an legal citation for
    your contentions.

    Thanks,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000215
    Tribal Police not allowed to arrest for misdemeanors FW: Case No.
    RCR2011-063341
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/11/12 8:40 AM
    To: homerj@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-
    stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov);
    kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org
    (patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); wongd@reno.gov (wongd@reno.gov);
    ormaasa@reno.gov (ormaasa@reno.gov); bonyr@reno.gov (bonyr@reno.gov); skauc@reno.gov
    (skauc@reno.gov); davidc@nvbar.org (davidc@nvbar.org); drakej@reno.gov (drakej@reno.gov);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); skent@skentlaw.com
    (skent@skentlaw.com)
    How exactly is it that both City Attorney Pamela Roberts, Esq. and Chris Hazlett-
    Stevens, Esq. did not violate RPC 3.8 or otherwise prosecute for arrests that were not
    lawful
    in RMC 11 CR 22176 (Indian Tribe police custodial arrest for misdemeanor? Not
    lawful under NRS 171.1255, and even if they were RPD, which they are not, its not like
    they charge Coughlin with something other than petty larceny a la NRS 171.136(2)...
    Further, can you provide me an indication of how it was lawful for RSIC Officer's
    Kameron Crawford or Donnie Braunworth to arrest me on 9/9/11 (and Wal-Mart's
    Thomas Frontino made explicitly clear in his testimony at trial on 11/30/11 that neither
    he nor any of Wal-Mart's staff in any way effected a custodial arrest of Coughlin on that
    date) for a misdemeanor given the following:
    NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
    1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
    employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
    her, or may, without a warrant, arrest a person:
    (a) For a public offense committed or attempted in the officer or agents presence.
    (b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
    s presence.
    (c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause
    for believing the person arrested to have committed it.
    (d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
    000216
    person arrested.
    (e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
    offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
    described.
    (f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
    upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
    2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
    (a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
    or colony; or
    (b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
    person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
    reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
    the presence of the officer or agent.
    For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
    (Added to NRS by 1985, 452)
    While Ormaas made sure to get judicial notice taken of jurisdiction in 11 TR 26800, it doesn't seem Pamela
    Roberts, Esq. did in the Indian Colony Wal-Mart matter...Why is that, Pam? Tribal land? Never determined
    if Coughlin had even an ounce of tribal blood? RSIC Officers not entitled to make custodial arrests for
    misdemeanors, even, apparently, one's committed right in their presence? So, even if Coughlin did refuse to
    provide his driver's license (which has been proven to be a lie, and perjury suborned by Pam Roberts as to the
    testimony of Wal-Mart's Frontino and the RSIC Officer's Crawford and Braunworth via police reports, dispatch
    recordings (AND PLEASE BE ADIVSED, AS ITS WITHIN THE 2 YEARS, THAT THE CITY OF RENO, THE
    SOUTH DISPATCH CENTER FOR ECOMM OR WASHOE COUNTY, OR WHOEVER IT IS THAT
    HANDLES THE RSIC DISPATCH CALLS, IT ON A LITIGATION HOLD NOTICE. COUGHLIN
    DEMANDS (AND THE DISPATCH/ECOMM SOUTH DISPATCH CENTER WILL GET ITS NRS 174.345
    SUBPOENA IN THE MAIL FOR A MISDEMEANOR SOON ENOUGH) THAT THE CUSTODIAN OF
    RECORDS MAINTAIN ANY AND ALL RECORDINGS, LOGS, OR OTHER DOCUMENTATION OR
    MEDIA IN ANY WAY CONNECTED TO ZACHARY B. COUGHLIN IN ANY WAY WHATSOEVER,
    ESPECIALLY WITH REGARD TO THE ARREST OF 9/9/11 AT THE RSIC WAL-MART IN RENO
    NEVADA NEAR GLENDALE AND W. 2ND ST.
    So, all these arrests by the RSIC police of alleged shoplifters at Wal-Mart...Sling Bla...er, Officer Braunworth
    testified that there was lots of them (sounds like Wal-Mart and the RSIC have the whole "find a way to get a
    search incident to arrest" thing down part, while avoiding any wrongful arrest liability against the deep pocket
    tenant Wal-Mart by avoiding any "shopkeeper's privilege" type citizen's arrests (or trying to use just as much
    intimidation and coercion as Frontino and the gang can muster, while seeking to claim not to have effected a
    citizen's arrest later in court, given setting the RSIC up to handle those types of lawsuits is arguably a better long
    term loss mitigation approach for these long term business partners, Wal-Mart and their partner/landlord the RSIC.
    So, please enlighten me. How is it these RSIC Officers are making all these custodial arrests for simple
    misdemeanors? And just where in the audio transcript of the Trial (you might want to have RMC house
    000217
    transcriptionist Pam Longoni finally get around to making a transcript and providing it to Coughlin, as the
    handouts the RMC itself provides defendants baring Longoni's and the RMC's "down payment"/transcript hostage
    rules are tantamount to extortion in violation of NRS 189.030. Then there is the bit about the RMC and or other
    discovering over $700K was "missing", and the attempts to chalk it up to "data entry" errors. Please get that
    transcript to me right away, and transcripts of every other hearing I have ever had in the RMC, including the one
    on or around February 2nd, 2012 or so where RMC court appointed defender Roberto Puentes successfully argued
    for an Order Granting His Withdrawal (five Withdrawals by court appointed counsel of Coughlin, four via an
    Order Granting a duly filed Motion (though these guy's Motions wouldn't pass my 7th grade English Class's bi-
    weekly writing assignment in my days at Swope Middle School) and Hon. W. Gardner starts to divulge, only after
    Coughlin's prompting, bit by bit some of the patent conflicts that should have prevented him from ever ruling on a
    single motion in that case 11 CR 26405. With such lack of vigor from the RMC's court appointed defense
    counsel, could a class action lawsuit agains them, the RMC, and or the City of Reno be a possibility someday?
    Certainly is a nice lil side gig $7K a month those guys get...and all these prosecutions and trips to jail this year
    certainly have afforded an opportunity to see the "operation" up close.
    Also, you know, as to lots of these arrests, like say the July 3rd, 2012 arrest by RPD Officer Alan Weaver and
    now Sargent Brian Dye in 12 CR 12420 (wherein two RMC court appointed counsel have already sought and
    obtained Orders Granting Their Withdrawal, one, by Keith Loomis, one by Henry Sotelo, the latter in violation of
    the stay in NRS 178.405) the legitimacy of effecting a custodial arrest is completely suspect considering:
    ARREST: BY WHOM AND HOW MADE
    NRS 171.124 Arrest by peace officer or officer of Drug Enforcement Administration.
    1. Except as otherwise provided in subsection 3 and NRS 33.070 and 33.320, a peace officer or an officer of the
    Drug Enforcement Administration designated by the Attorney General of the United States for that purpose may
    make an arrest in obedience to a warrant delivered to him or her, or may, without a warrant, arrest a person:
    (a) For a public offense committed or attempted in the officers presence.
    (b) When a person arrested has committed a felony or gross misdemeanor, although not in the officers
    presence.
    (c) When a felony or gross misdemeanor has in fact been committed, and the officer has reasonable cause for
    believing the person arrested to have committed it.
    (d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
    person arrested.
    (e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
    offense, and the officer has reasonable cause to believe that the person arrested is the person so named or
    described.
    2. A peace officer or an officer of the Drug Enforcement Administration designated by the Attorney General of the
    United States for that purpose may also, at night, without a warrant, arrest any person whom the officer has
    reasonable cause for believing to have committed a felony or gross misdemeanor, and is justified in making the
    arrest, though it afterward appears that a felony or gross misdemeanor has not been committed.

    000218
    So back to the Wal-Mart RSIC arrest...the charge sheet doesn't say Coughlin was arrested for anything other than
    petty larceny....but:
    NRS 171.136 When arrest may be made.
    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of
    day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
    (1) There is a warrant of arrest against the person; and
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain
    or arrest the person for another alleged violation or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest
    immediately after the offense is committed;
    (e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and the arrest
    is made in the manner provided in NRS 171.137;
    (f) When the offense charged is a violation of a temporary or extended order for protection against domestic
    violence issued pursuant to NRS 33.017 to 33.100, inclusive;
    (g) When the person is already in custody as a result of another lawful arrest; or
    (h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
    So, on exactly what basis was the July 3rd, 2012 arrest made by the RPD? The police report says the arrest was
    made for "disturbing the peace", yet the only allegation of anything remotely in the "officer's presence" relates to
    the minor traffic citation the City of Reno is clinging to in attempts to mitigate the Sec. 1983 damages here.
    However, the RPD admits at least one vehicle was between their's and Coughlin's and Sooudi et al (besides
    making an incomprehensibly stupid decision to briefly file an amended complaint for trespassing where even the
    RPD was smart enough to realize that was a poor choice given Coughlin still had lease at Northwind, and thus a
    pat claim of right defense to any trespass allegation absent something like the manufactured protection order that
    RPD Officer Weaver coerced Milan Krebs into obtaining, just like Weaver attempted to get Superior Storage's
    Matt Grant to do, shortly after Weaver, in full view of Welch, Sargent Miller, and other RPD Officer's, on
    September 21st, 2012, threatened to come up with yet another fraudulent "failure to secure a load on one's vehicle"
    arrest of Coughlin). So, even though Weaver and Dye are stuck with their statements in the written reports,
    wherein they allege to have arrest Coughlin for "disturbing the peace" only to then tack on "citations" for the two
    traffic offenses (and the "proof of insurance" citation, even after Officer Weaver admits to being provided a high
    000219
    definition pdf picture on a 5 inch smart phone screen with a policy number, etc., only to be amplified by the July
    5th, 2012 bail hearing racket tearing (a tennis reference for Jill Drake, Esq.,... for shame, really Jill, really, really
    unimpressed).
    Please remit a certified check for $450,000 in satisfaction of these torts committed upon Coughlin, under color of
    law.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: homerj@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov;
    fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
    Subject: RE: Case No. RCR2011-063341
    Date: Thu, 8 Nov 2012 20:36:27 -0800
    couldn't open them, and I don't accept service of anything form you... See Allison
    Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
    the RMC Rules to the extent there is not difference technologically anymore between
    an email and a fax:
    Rule 5: Motions/Pleadings by Facsimile
    A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
    facsimile, except as otherwise specified in this rule.
    B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
    C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
    and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
    D. Each transmitted page shall bear sequential numbers in the transmission.
    E. All persons are eligible to use motion/pleading-by-facsimile procedures.
    F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address,
    fax number and telephone number.
    G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
    telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
    H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
    the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
    motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
    I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
    J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
    Rule 6: Continuances
    000220
    No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
    state the reason therefore and whether or not any continuance has previously been sought or granted.
    Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
    continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
    and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
    vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
    then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
    an blaming it on the Court.
    Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
    other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
    who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
    'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
    becuase he has lied numerous times, on the record about not being served where he has been. Take, for
    instance
    Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405,
    failed to follow RMC Rules in withdrawing from representation:
    Rule 3: Authorization to Represent
    A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
    with the Court.
    B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
    may rule on the motion or set a hearing.
    Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

    Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
    case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
    NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
    of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
    otherwise.
    Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
    provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    000221
    Inbox x
    utbound fax report
    Voxox noreply@voxox.com Jun 27
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    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 08:54:28 PM on 2012-06-27.
    xoxo,
    The Voxox Team
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    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 09:16:58 PM on 2012-06-27.
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    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 08:13:34 AM on 2012-06-28.
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    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 09:04:24 AM on 2012-06-28.
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    Hi zachcoughlin,
    Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
    Your Fax was delivered @ 09:05:24 AM on 2012-06-28.
    000222
    000223
    Print Close
    FW:
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/11/12 7:50 AM
    To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
    nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org);
    fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org);
    complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
    3 attachments
    10 31 12 0204 Pre Hearing Motion to Dismiss and for Summary Judgement and Memorandum of
    Law (Responsive Pleading).pdf (10.4 MB) , 10 31 12 subpoena on peters and waiver of service.pdf
    (541.5 KB) , ex x harris silverman coughlin garin 0204 11 11 12.pdf (9.8 MB)
    Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR
    116 appeal rights...
    Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN
    Laura Peters signed a waiver of service or similar
    and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law
    (Response)

    Date: Mon, 13 Aug 2012 11:28:12 -0700


    From: silverman@silverman-decaria.com
    To: zachcoughlin@hotmail.com
    Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
    I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final
    judgment in the crim case and point out that your temporary suspension is akin to a permanent death of your
    practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now
    have access to your meds and are ok. I can't think this pleading is going to help you much...it is too long,
    repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't make
    your case in 3-5 pp, you can't make your case in 35. You do seem to be a good lawyer, however. At bottom, Steve
    Harris took hundreds of thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF.
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com

    000224
    Emergency Ex Parte Motion NG12-0204, 0434,0435
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/11/12 4:13 AM
    To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
    (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
    (fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
    (complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
    (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
    from:
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    tel and fax 949 667 7402
    I do not consent to service or notice of anything electronically in this proceeding, but I do appreciate being
    copied on such things via email and fax)
    Emergency Ex Parte Motion NG12-0204, 0434,0435
    please find attached 88 page Emergency Ex Parte Motion to Dismiss or Quash or Otherwise Challenge
    Sufficiency of Service
    and of Process, of Complaint and Notice of Intent to Take Default and DoWSoE; and Preserving for Appeal
    Objection to All other Due Process Violations; and UNDER PROTEST...RESPONSE TO COMPLAINT
    submitted for filing with the State Bar of Nevada on November 9th, 2012
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    11 9 12 response under protest 0204 and various motions and notices 0204 etc.pdf

    RE: Case No. RCR2011-063341
    000225
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/08/12 8:36 PM
    To: HomerJ@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-
    stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov);
    kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org
    (patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org)
    couldn't open them, and I don't accept service of anything form you... See Allison
    Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
    the RMC Rules to the extent there is not difference technologically anymore between
    an email and a fax:
    Rule 5: Motions/Pleadings by Facsimile
    A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
    facsimile, except as otherwise specified in this rule.
    B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
    C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
    and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
    D. Each transmitted page shall bear sequential numbers in the transmission.
    E. All persons are eligible to use motion/pleading-by-facsimile procedures.
    F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address,
    fax number and telephone number.
    G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
    telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
    H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
    the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
    motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
    I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
    J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
    Rule 6: Continuances
    No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
    state the reason therefore and whether or not any continuance has previously been sought or granted.
    Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
    continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
    and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
    vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
    then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
    an blaming it on the Court.
    Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
    other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
    who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
    'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
    000226
    becuase he has lied numerous times, on the record about not being served where he has been. Take, for
    instance
    Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405,
    failed to follow RMC Rules in withdrawing from representation:
    Rule 3: Authorization to Represent
    A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
    with the Court.
    B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
    may rule on the motion or set a hearing.
    Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

    Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
    case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
    NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
    of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
    otherwise.
    Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
    provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Inbox x
    utbound fax report
    Voxox noreply@voxox.com Jun 27
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    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 08:54:28 PM on 2012-06-27.
    xoxo,
    The Voxox Team
    This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox?
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    000227
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    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 09:16:58 PM on 2012-06-27.
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    to me
    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 08:13:34 AM on 2012-06-28.
    Voxox noreply@voxox.com Jun 28
    to me
    Hi zachcoughlin,
    Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
    Your Fax was delivered @ 09:04:24 AM on 2012-06-28.
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    to me
    Hi zachcoughlin,
    Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
    Your Fax was delivered @ 09:05:24 AM on 2012-06-28.
    Date: Thu, 8 Nov 2012 14:48:18 -0800
    From: HomerJ@reno.gov
    To: zachcoughlin@hotmail.com
    Subject: Case No. RCR2011-063341
    Please see attached documents from Creig Skau, Deputy City Attorney:

    1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1 & 2)

    2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9:00a.m.)

    Thank you.

    Jeannie Homer
    Legal Secretary
    1 East First Street, 3rd Floor
    Reno, Nevada 89505
    000228
    (775)334-2050
    (775)334-2420/fax
    homerj@reno.gov

    ATTORNEY-CLIENT PRIVILEGE

    This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and
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    "investigator" Peters putting the blindfold on herselfFW:


    Undeliverable:
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 8:25 PM
    To: complaints@nvbar.org (complaints@nvbar.org); davidc@nvbar.org (davidc@nvbar.org);
    patrickk@nvbar.org (patrickk@nvbar.org)
    This is ridiculous that Clerk of Court/Investigator Peters has admitted to adding me to her blocked senders list.
    Why doesn't she add herself to the "blocked paycheck" list? Please forward this on to her. Plus, she added
    me to that least WAY too late to excuse the lack of investigation and due diligence her, considering all the
    materials I can proved she and the SBN received.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: postmaster@nvbar.org
    To: zachcoughlin@hotmail.com
    Date: Tue, 6 Nov 2012 19:45:32 -0800
    Subject: Undeliverable:
    Delivery has failed to these recipients or groups:
    laurap@nvbar.org (laurap@nvbar.org)
    This message was rejected by the recipient e-mail system. Please check the recipient's e-mail address and try resending this
    message, or contact the recipient directly.
    000229
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    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: "laurap@nvbar.org" <laurap@nvbar.org>, "patrickk@nvbar.org"
    <patrickk@nvbar.org>
    Subject:
    Date: Tue, 6 Nov 2012 19:44:50 -0800
    Importance: Normal
    x-skydrive-mailtype: SkyMail
    x-skydrive-id: 43084638F32F5F28!4610
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    x-doc-filename1: 11 6 12 0202 Objection and Notice.pdf
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    x-doc-filename2: supplemental to Coughlin's designation fo witnesses and
    summary and production of evidence and notice of objection 0204 CORRECTED
    CAPTION.pdf
    x-doc3:
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    x-doc-filename3: 0204 notice of non service of purported notice of intent to
    take default.pdf
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    x-doc-filename5: 0204 subpoena all.pdf
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    --Forwarded Message Attachment--
    From: zachcoughlin@hotmail.com
    To: laurap@nvbar.org; patrickk@nvbar.org
    Subject:
    Date: Tue, 6 Nov 2012 19:44:50 -0800
    Dear Bar Counsel King and Clerk of Court/Investigator Peters and Chairman
    000230
    Echeverria,
    There is a big problem with respect to when the State Bar of Nevada actually sent the
    Respondent, Coughlin the Designation of Witnesses and Summary of Evidence
    (DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE.
    Further, Coughlin has never received any Notice of Intent to Take Default
    (NoITD) from the SBN. As such, the notice and other procedural safeguards
    attendant to the Hearing set for 11/14/12 are severely deficient. This is just the 13th
    chime of the clock, and I have had as many "get right with Jesus" (or any other number
    of nondenominational Saviors) talks with Bar Counsel King and Clerk Peters as anyone
    deserves. Add to that this new thing where first Bar Counsel says, as required by
    SCR 105(2)(c)'s:
    "The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the names of the
    witnesses bar counsel intends to call for other than impeachment, together with a brief statement of the facts to which each will testify, all of
    which may be inspected up to 3 days prior to the hearing. "
    See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from under
    Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to allow inspection of others (even where the SCR
    105 Complaint specifically invokes such non copied materials), and then cut short the time up to which Respondnet may inspect. Let's say
    Bar Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows Coughlin to go to the SBN and
    inspect "up to 3 days prior"...so Coughlin may go to the SBN tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is
    a violation of SCR 105, right? Please advise in writing.
    Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel and the
    Panel's failure to follow these rules "may result in contempt of the appropriate disciplinary board or
    hearing panel having jurisdiction..." Please note there has already been a Motion for Order to Show Cause
    filed against Bar Counsel and or the Board or Panel in 60838 and 61426. Additionally, please be aware that
    SCR 119(3) holds: 3. Other rules of procedure. Except as otherwise provided in these rules, the
    Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
    In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for procedural safeguards
    in that it was issued prior to the expiration of five judicials days from the constructive service upon Coughlin,
    under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used do to a
    recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the SBN outgoing mail box two
    certified letter to myself that Clerk of Court Peters admitted would not be picked up that day by the regular
    postal carrier to the SBN, despite what they certificates of mailing therein might state. It is particularly
    troubling to me that the Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence
    included with it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it
    from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up with less than
    the required notice (and jam the Panel up to for the matter, though there has been little indication so far that
    000231
    the Panel cares or has much an intent to do anything more than let Bar Counsel King lead them down the same
    primrose path that Clerk Peters can tell you about...). It is a path that Richard G. Hill, Esq. often takes people
    down too...
    I would be very interest to know who was on the screening Panel...which Bar Counsel King promised to tell me,
    though, like most all of Pat's promises, he has broken...could it have been David Hamilton, Esq.? Richard G.
    Hill's best friend, David Hamilton? Was it WCDA Mary Kandaras? The one included in the correspondences
    about my smartphone and micro sd data card being searched and or seized illegally and or outside any lawful
    search incident to arrest given the hand of an booking it into Coughlin's property on 2/27/12, only for the RMC
    Marshals to return on 2/28/12 (at the soonest) to take it back to Judge Nash Holmes? What's next, Judges
    showing up in our bedrooms reading our diaries out of the blue?
    It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas and granted
    me indigent status as to witness fees...if this is not within the power of Bar Counsel or is otherwise against the
    Orders of the Panel or Board, please let me know very soon. Please See SCR 110 and in that regard, I am
    requesting a prehearing conference for the purpose of gathering admissions from Bar Counsel and narrowing
    the issues, and in that regard, I recently sent Bar Counsel and at least Panel Chair Echeverria materials related
    to what I see as a frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John
    Gessin.

    Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have voiced to
    President of the State Bar of Nevada Flaherty, in that light:
    Rule120. Costs; bar counsel conflict or disqualification
    2.If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of governors shall
    appoint an attorney, ad hoc, to act in the place of bar counsel.
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
    11 6 12 0202 Objection and Notice.pdf
    supplemental to Coughlin's designation fo witnesses and summary and production of evidence and notice of objection
    0204 CORRECTED CAPTION.pdf
    0204 notice of non service of purported notice of intent to take default.pdf
    0204 SUBPOENA WITH DISCLAIMER.pdf
    0204 subpoena all.pdf
    000232
    Download all

    (No Subject)
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 7:44 PM
    To: laurap@nvbar.org (laurap@nvbar.org); patrickk@nvbar.org (patrickk@nvbar.org)
    Dear Bar Counsel King and Clerk of Court/Investigator Peters and Chairman
    Echeverria,
    There is a big problem with respect to when the State Bar of Nevada actually sent the
    Respondent, Coughlin the Designation of Witnesses and Summary of Evidence
    (DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE.
    Further, Coughlin has never received any Notice of Intent to Take Default
    (NoITD) from the SBN. As such, the notice and other procedural safeguards
    attendant to the Hearing set for 11/14/12 are severely deficient. This is just the 13th
    chime of the clock, and I have had as many "get right with Jesus" (or any other number
    of nondenominational Saviors) talks with Bar Counsel King and Clerk Peters as anyone
    deserves. Add to that this new thing where first Bar Counsel says, as required by
    SCR 105(2)(c)'s:
    "The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the names of the
    witnesses bar counsel intends to call for other than impeachment, together with a brief statement of the facts to which each will testify, all of
    which may be inspected up to 3 days prior to the hearing. "
    See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from under
    Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to allow inspection of others (even where the SCR
    105 Complaint specifically invokes such non copied materials), and then cut short the time up to which Respondnet may inspect. Let's say
    Bar Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows Coughlin to go to the SBN and
    inspect "up to 3 days prior"...so Coughlin may go to the SBN tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is
    a violation of SCR 105, right? Please advise in writing.
    Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel and the
    Panel's failure to follow these rules "may result in contempt of the appropriate disciplinary board or
    hearing panel having jurisdiction..." Please note there has already been a Motion for Order to Show Cause
    filed against Bar Counsel and or the Board or Panel in 60838 and 61426. Additionally, please be aware that
    SCR 119(3) holds: 3. Other rules of procedure. Except as otherwise provided in these rules, the
    000233
    Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
    In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for procedural safeguards
    in that it was issued prior to the expiration of five judicials days from the constructive service upon Coughlin,
    under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used do to a
    recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the SBN outgoing mail box two
    certified letter to myself that Clerk of Court Peters admitted would not be picked up that day by the regular
    postal carrier to the SBN, despite what they certificates of mailing therein might state. It is particularly
    troubling to me that the Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence
    included with it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it
    from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up with less than
    the required notice (and jam the Panel up to for the matter, though there has been little indication so far that
    the Panel cares or has much an intent to do anything more than let Bar Counsel King lead them down the same
    primrose path that Clerk Peters can tell you about...). It is a path that Richard G. Hill, Esq. often takes people
    down too...
    I would be very interest to know who was on the screening Panel...which Bar Counsel King promised to tell me,
    though, like most all of Pat's promises, he has broken...could it have been David Hamilton, Esq.? Richard G.
    Hill's best friend, David Hamilton? Was it WCDA Mary Kandaras? The one included in the correspondences
    about my smartphone and micro sd data card being searched and or seized illegally and or outside any lawful
    search incident to arrest given the hand of an booking it into Coughlin's property on 2/27/12, only for the RMC
    Marshals to return on 2/28/12 (at the soonest) to take it back to Judge Nash Holmes? What's next, Judges
    showing up in our bedrooms reading our diaries out of the blue?
    It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas and granted
    me indigent status as to witness fees...if this is not within the power of Bar Counsel or is otherwise against the
    Orders of the Panel or Board, please let me know very soon. Please See SCR 110 and in that regard, I am
    requesting a prehearing conference for the purpose of gathering admissions from Bar Counsel and narrowing
    the issues, and in that regard, I recently sent Bar Counsel and at least Panel Chair Echeverria materials related
    to what I see as a frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John
    Gessin.

    Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have voiced to
    President of the State Bar of Nevada Flaherty, in that light:
    Rule120. Costs; bar counsel conflict or disqualification
    2.If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of governors shall
    appoint an attorney, ad hoc, to act in the place of bar counsel.
    Zach Coughlin
    1471 E. 9th St.
    000234
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
    11 6 12 0202 Objection and Notice.pdf
    supplemental to Coughlin's designation fo witnesses and summary and production of evidence and notice of objection
    0204 CORRECTED CAPTION.pdf
    0204 notice of non service of purported notice of intent to take default.pdf
    0204 SUBPOENA WITH DISCLAIMER.pdf
    0204 subpoena all.pdf
    Download all

    (No Subject)
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 9:46 AM
    To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
    (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
    (fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
    (complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
    (je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Zach has a file to share with you on SkyDrive. To view it, click the link below.
    11 5 12 SUPPLMENTSAL TO 0204.pdf

    000235
    Print Close
    Zach Coughlin has shared a folder with you
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 9:46 AM
    To: patrickk@nvbar.org
    Exhibit 1 to 11 3 12
    Supplement to
    Coughlin's List of
    View photos
    You are invited to view Zach's album. This album has
    147 files.
    031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
    0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
    122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
    from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
    071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
    082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
    082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    Share your files with
    000236
    Zach Coughlin has shared a folder with you
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 9:46 AM
    To: davidc@nvbar.org
    Exhibit 1 to 11 3 12
    Supplement to
    Coughlin's List of
    View photos
    You are invited to view Zach's album. This album has
    147 files.
    031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
    0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
    122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
    from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
    071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
    082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
    082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    Share your files with
    Zach Coughlin has shared a folder with you
    000237
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 11/06/12 9:46 AM
    To: complaints@nvbar.org
    Exhibit 1 to 11 3 12
    Supplement to
    Coughlin's List of
    View photos
    You are invited to view Zach's album. This album has
    147 files.
    031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
    0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
    0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
    122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
    from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
    071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
    082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
    082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
    082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
    090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
    Share your files with
    FW: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena Duces
    Tecum: CV10-01341
    000238
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/05/12 3:31 AM
    To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com)
    5 attachments
    12 8 11 email to eflex regarding Gessin's efiler status and withdrawals 0204.htm (12.7 KB) , 11 25 11 email to John Gessin
    jd.gman@yahoo.com explaining ghostwriting taboos and Notice of Appearance 0204.htm (12.7 KB) , 9 6 11 11-05078 Gessin 0204
    26405 1708 03628 proof that Coughlin was commercial tenant 40.253 prohibits summary evict no cause.pdf (39.5 KB) , 9 6 11 11-
    05078 NVB Gessin Coughlin not ghostwriting 0204.pdf (558.4 KB) , 9 7 11 Adversary Proceeding 11-05077-btb rissone gessin
    0204.pdf (36.2 KB)
    Dear Mr. King and Chairman Echeverria,
    Is this ghostwriting allegation by Hill in 0204 still an issue? I am pretty sure Gessin paid for his own
    electronic filing account at about the time we parted ways...and that Hill, Baker, and I were all listed as his
    attorney at that time....Shelly O'Neill, Esq. (of the NNDB) is now or recently was Gessin's attorney in various
    matters...Can we narrow down what is at issue in the hearing? I didn't do any ghostwriting and in fact kind of
    went out of my way to prevent anything of the sort...I think I was halfway concerned about the appearance of
    ghostwriting when I sent Gessin the 11/25/11 email and filing Notices of Appearances were, to some extent (not
    soley) done to guard against anything like that... In the eflex notification below...I did not filed such a Subpoena
    Duces Tecum and I am almost sure I didn't have anything to do with a subpoena and Gessin during the entire
    time I worked on his matters. I believe I filed a few documents in the NVB on an "unbundled services" type
    of arrangement, from which I learned that it is not really possible to do so, to the extent that one will still need
    get an Order granting their Withdrawal as "counsel of record", even if the attorney notates "unbundled services"
    on the information above the caption....
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Date: Fri, 9 Dec 2011 10:22:05 -0800
    From: eflex@washoecourts.us
    To: zachcoughlin@hotmail.com
    Subject: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena Duces Tecum: CV10-01341
    ****** IMPORTANT NOTICE - READ THIS INFORMATION *****
    PROOF OF SERVICE OF ELECTRONIC FILING
    A filing has been submitted to the court RE: CV10-01341
    Judge: PATRICK FLANAGAN
    Official File Stamp: 12-09-2011:09:26:55
    Clerk Accepted: 12-09-2011:10:17:49
    Court: Second Judicial District Court - State of Nevada
    Case Title: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB)
    Document(s) Submitted: Subpoena Duces Tecum
    000239
    - **Continuation
    Filed By: JOHN GESSIN
    You may review this filing by clicking on the following link to take you to your cases.
    This notice was automatically generated by the courts auto-notification system.
    If service is not required for this document (e.g., Minutes), please disregard the below language.
    The following people were served electronically:
    RICHARD HILL, ESQ. for JOHN GESSIN
    ZACHARY COUGHLIN, ESQ. for JOHN GESSIN
    CASEY BAKER, ESQ. for JOHN GESSIN
    The following people have not been served electronically and must be served by traditional means (see Nevada electronic filing rules):
    GLADE HALL, ESQ.
    --Forwarded Message Attachment--
    Print Close
    John Gessin wishing to be able to file without rejections
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 12/08/11 3:08 PM
    To: eflex@washoecourts.us; filing@washoecourts.us; cfranden@mail.co.washoe.nv.us; courttech@washoecourts.us
    3 attachments
    alternatively errate withdraw etc CV09-00710 - ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , alternatively
    errate withdraw etc ARB09-00710 - ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , ERRATA TO NOTICE OF
    APPEARANCE OR ALTERNATIVELY MTN TO WITHDRAWCV10-01341 - STACEY RISSONE VS. JOHN DAVID GESSIN (ARB) notice of
    appearance hill baker.pdf (81.0 KB)
    I am writing (I just filed the attached motions as well) due to exigent circumstances. Basically, John
    Gessin (jd.gman@yahoo.com 775 376 3650), who is apparently an efiler pro se, wishes to be able to file things, but
    is being told my attorney of record status is preventing that. In order to attempt to avoid prejudicing Mr.
    Gessin's interests, I am writing to ask that you allow him to file what he wants, on his own behalf right
    away, given that time may be of the essence.

    Sincerely,
    Zach Coughlin, Esq.
    817 N. Virginia St. #2
    Reno, NV 89501
    tel: 775 338 8118
    fax: 949 667 7402
    Licensed in Nevada and USPTO
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
    confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
    are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
    information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney
    work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
    distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
    message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    --Forwarded Message Attachment--
    000240
    Print Close
    NOTICES OF APPEARANCES
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/25/11 12:24 AM
    To: jd.gman@yahoo.com
    4 attachments
    CV10-01341 RISSONE ARB BAKER HILL NOTICE OF APPEARANCE.pdf (60.4 KB) , CV09-00710 TAITANO MOORE STP NOTICE OF
    APPEARANCE.pdf (60.6 KB) , CV10-03675 STACEY RISSONE ET VS JOHN DAVID GESSIN ET (D3) NOTICE OF APPEARANCE.pdf (60.4 KB) ,
    ARB09-00710 taitano moore arb notice of appearance.pdf (61.1 KB)
    John, Let me know whats going on, i got a new temporary address and phone number. theres is some
    ghostwriting taboos, so...if you want me to withdraw thats fine, whatever, its all good
    Zach Coughlin, Esq.
    817 N. Virginia st. #2
    Reno, NV 89501
    775 229 6737
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
    confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
    are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
    information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney
    work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
    distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
    message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    RE: convicting attorney of summary criminal contempt during pendency of Order for
    Competency Evaluation
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/04/12 12:34 AM
    To: togninim@reno.gov (togninim@reno.gov); joey.hastings@washoecounty.us (joey.hastings@washoecounty.us);
    joey.orduna@washoecounty.us (joey.orduna@washoecounty.us); david.hardy@washoecounty.us (david.hardy@washoecounty.us);
    patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
    Dear SBN,
    I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me
    in response to your antiquated email system having any sort of file size limitations resulting in a rejection of a
    transmission that pretty much an old free gmail or hotmail account could accept. So, your on notice of that
    and your apparent purposeful Luddite stance (reminds me of "Investigator" Peters mentioning how reluctant she
    is to investigate anything) is not something I will be receiving any notice of so you might want to adjust your
    email system accordingly.
    I have an idea, how about you implement a "salary size limitation" on your paychecks until you cease pursuing
    outdated and dubious plausible deniability constructs?
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    000241
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
    skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org;
    je@eloreno.com; cvellis@bhfs.com
    Subject: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
    Date: Sat, 3 Nov 2012 03:13:58 -0700
    togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
    skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
    tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    RE: Mr. King's assertion in his 3/16/12 letter
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sun 11/04/12 12:33 AM
    To: patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org)
    Dear SBN,
    I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me
    in response to your antiquated email system having any sort of file size limitations resulting in a rejection of a
    transmission that pretty much an old free gmail or hotmail account could accept. So, your on notice of that
    and your apparent purposeful Luddite stance (reminds me of "Investigator" Peters mentioning how reluctant she
    is to investigate anything) is not something I will be receiving any notice of so you might want to adjust your
    email system accordingly.
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
    skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org;
    je@eloreno.com; cvellis@bhfs.com
    Subject: FW: Mr. King's assertion in his 3/16/12 letter
    Date: Sat, 3 Nov 2012 03:00:11 -0700
    Dear Judge Hardy, Chairman Susich, Clerk of Court Orduna Hastings, Bar Counsel, and Ms. Tognini, and Members of the Panel,

    It is plain from my interactions with Patrick King that the irony of Richard G. Hill, Esq's allegations of my "ghostwriting" are
    richest when considering the apparent "ghost-grievancing" going on here, especially with respect to the genesis of NG12-0435,
    the grievance consisting of Family Court Judge Linda Gardner's April 2009 Order sanctioning a domestic violence attorney
    $1,000, personally, where failed to follow Judge Linda Gardner's orders to seek to intimidate his battered spouse immigrant client
    into accepting the marital settlement agreement offer of one John Springgate, Esq. (a chimera of sorts where Mr. Springgate's
    client would agree to be responsilbe for a collection of third party credit card debt for which he was the sole signatory and for
    which even under and extremely unlikely "doctrine of the neccessaires, assuing my client lost on a "waste of marital assets",
    approach, my client, Ms. Joshi, would be very unlikely to ever face judgment or execution in connection with such third party
    credits card debts. I failed to cave to Judge Linda Gardner's bullying demands, and even where she yelled at me and my client
    000242
    in the impromptu "settlement conference" she decided to hold 10 minutes before the Trial (Judge Linda Gardner yelled at me to
    "shut up" in front of my client, then proceeded to tell Ms. Joshi "don't listen to your attorney!" in an angry, hostile, and
    belligerent tone), and instead cited to an ALR article that presents the position I took as the majority viewpoint in American
    jurisprudence with respect to the duty of a domestic obligation not being permissibly set off with a mere debt, particularly a third
    party unsecured credit card debt, such as those for which Mr. Joshi was the sole signatory. Apparently Judge Gardner agreed
    with John Springgate's whining about how he "needed to be able to know how much to charge for his time" or something along
    those lines (Mr. Springgate indicated that Coughlin's failing to immediately accept Springgate's settlement offer was screwing up
    Springgate's whole profit margin, and therefore contrary to the orderly administration of justice, or something along those lines,
    at which point Springgate moved for sanctions (despite not having served a 21 day safe harbor filing ready NRCP 11 motion),
    which, in John's words was tantamount to "sending a shot across your bow", a bloodsport sort of analogy one might expect from
    a semi-professional fencer like Mr. Springgate. I was fired from Washoe Legal Services and told by its Executive Director
    that the decision was based solely on Judge Linda Gardner's Order....which was odd given she and Master Edmondson and at
    least one other judge had given Elcano positive reviews of my work less than two months prior to that. Elcano, though, did,
    at the time of reporting those positive reviews mention that he goes "way back" with Linda Gardner, and that "she owes" him
    because "he did her a big favor a long time ago", etc., etc.

    Anyways, Bar Counsel King has recently indicated that he was completely unaware that Linda Gardner is the sister of the RMC
    Judge William Gardner who refused to recuse himself from the criminal trespass conviction I sustained incident to a custodial
    arrest at my former home law office, wherein the opposing counsel Richard G. Hill, Esq., has been caught lying on tape
    regarding whether any warning was given to me to leave, and whether the RPD identified themselves as law enforcement and
    issued a lawful order to leave the premises prior to the landlord kicking down a door to a "basement" that was, according to Hill's
    associate, not even a part of the property (or included in the part of the property contained within any exterior doors to the
    premises.

    Despite the statements of RMC Judge Gardner in the audio cds that King himself finally admitted to me to possessing and
    receiving from RMC Judge Nash Holmes (after several instances of King lying about his willingness to allowing me to review
    the materials Judge Nash Holmes and others slipped to the SBN, King finally was forced to turn over at least a few of those
    items. Included amongst them were the hearings before Judge William Gardner on 4/10/12 and 5/8/12 wherein RMC Judge
    William Gardner admits that his sister is none other than Family Court Judge Linda Gardner, and that his sister passed him her
    April 2009 Order sanctioning Coughlin (which Coughlin filed a Petition for Writ of Mandamus challenging in 54844,):
    http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746

    Washoe Legal Services fired Coughlin, citing Judge Linda Gardner's Order sanctioning Coughlin as the sole reason for its doign
    so. Couglin sued WLS for wrongful termination, and Judge Elliot dismissed Coughlin's lawsuit without reaching the merits of
    the Complaint, but then decided to sanction Coughlin for his lawsuit allegedly lacking "merit" anyways...go figure. Judge
    Elliot also incarcerated Coughlin from April 19th, 2012-April 26th, 2012 based upon some fraudulent letter by Lake's Crossing,
    and some Motion for Revocation of Bail made by DDA Zach Young at a time when NRS 178.405 forbid his making any motions
    given that all proceedings must be stayed during the pendency of an Order for Competency Evaluation. Amazingly, in her
    3/16/12 letter to the SBN, Judge Nash Holmes is still mentioning how she and the RMC are furiosly trying to set for Trial the
    case stemming from teh custodial "jaywalking" arrest of Coughlin on January 12th, 2012 incidnet to the lies by Richard G. Hill,
    Esq. to the RPD on that date. It is curious that that matter 11 CR 00696 was all of the sudden transferred to Judge Nash
    Holmes on February 27th, 2012, the same day Judge Nash Holmes was purportedly made aware of the 2/27/12 Order for
    Competency Evaluation of Coughlin in RCR2011-063341 (relative, at the very least, to the communications between Tognini and
    the WCPD, at the very least). Additionally, Second Judicial District Chief Appeals Clerk denied Coughlin's 2/27/12 filing of
    a Motion for Extension of Time to effectuate service in the wrongful termination lawsuit by Coughlin against Elcano (whom
    Judge Linda Garnder "owes a big favor", according to Elcano) in CV11-01955 (before Judge Elliot).

    Further, to the extent Judge Elliot's remanding Coughlin into custody to coerce his consent to divulging extremely private
    medical information is somehow a contempt Order, then the "letter" or "evaluation under seal" of 4/18/12 by Lakes Crossing Dr.
    Bill Davis and Dr. Sally Farmer must be in the form of an affidavit. It was not. Further, Coughlin called Dr. Davis from the
    booking room at the jail and Dr. Davis attempted to weasel out of the consequences of his professional misconduct, done under
    color of law, by alleging that he "didn't write the 4/18/12 letter filed with the Court" but merely signed it and was not responsible
    for it being filed with the court. To the extent the assertions in that 4/18/12 letter are outright lies (they are...the letter
    indicates Coughlin outright refused to provide basic medical information, which is not true, Coughlin indicated he would "need
    to check his records" in response to one initial question, and then mentioned that some professional, particularly physicians, face
    an inability to obtain malpractice insurance if word gets out that they take anti-depressants. Somehow Dr. Davis and Dr.
    Farmer interpreted such a statement to allow themselves to file a letter with the Court alleging that Coughlin "threatened one of
    the evaluators with legal action". No wonder Lake's Crossing insists on doing a Terry Stop style "pat down" search on each
    and everyone forced to go there by the Courts to get a Competency Evaluation (the RJC and WCPD have it set up so that one
    000243
    must utilize the services of Lake's Crossing for any such evaluation) and maintain a strick ban on any sort of smart phones or
    cellular phones within their evaluation rooms (how difficult it would be for Dr. Davis and Dr. Farmer to lie with seeming
    impunity, as they did in their 4/18/12 "evaluation" filed with the Court in CR12-0376, should their subjects be readily able to
    reveal the dishonesty of these evaluators via some recording impeachign their credibility. To the extent Judge Elliot found
    Coughlin in contempt of court (which he apparently did in response to Coughlin inquiring into the scope and extent of such a
    Competency Evaluation rather than submitting to a blank check inquest into his mental health and medical records incident to a
    retaliatory Motion for Competency Evaluation on 2/27/12 by a public defender upset that Coughlin had criticized his failing to
    show up to a court date even after that attorney, Biray Dogan had filed a Notice of Appearance and met with the client to discuss
    the case RCR2012-065630, for over an hour and a half just one week previous to that missed court appearance, and where DDA
    Young was clearly retaliating against Coughlin for Coughlin filing a Motion for Sanctions against Young just days previous to
    that in a different case.

    Regardkess. Marilyn Tognini is now being listed as a witness Coughlin intends to call at his November 14th, 2012 NNDB
    hearing at the State Bar of Nevada Offices at 9 am, and any other person whom Judge Nash Holmes may be referring to in her
    attached grievance against Coughlin (wherein she manages to allude to some hearsay about Coughlin living in his car despite the
    fact that Coughlin was clearly still living at 1422 E. 9th St. at the time Judge Nash Holmes letter to the SBN was written,
    3/14/12, even where Judge Nash Holmes feigns an inability to readily make contact with Coughlin, depsite neither she nor the
    RMC calling, emailing or faxing Coughlin, or managing to mail the 2/28/12 Order to the address all other RMC Departments
    then had for Coughlin. Regardless, that 3/14/12 grievance goes on to demonstrate Judge Nash Holmes profound lack of respect
    for or knowledge of the dictates of NRS 178.405, or the legal principles, in general, related to refraining from proceeding with
    prosecutions where the competency of the accused is in doubt in the mind of the trier of fact. Further, the SBN's Bar Counsel
    Patrick King (whom, again, managed to just in the last couple weeks indicate that he was unaware that Judge William Gardner
    and Judge Linda Gardner are brother and sister, or even related, despite King receiving from the RMC's Judge Nash Holmes a
    box of materials that included multiple hearings in the criminal trespass proseuction of Coughlin that Judge William Gardner
    (then RMC Administrative Judge, whom admitted to "at least one meeting" wherein he and the other RMC Judges discussed
    Coughlin, along with Chief Marshal Roper, only for Judge Gardner to then attempt to say with a straight face that he "was not
    sure whether he was" aware of this or that, or had any knowledge of the grievance Judge Nash Holmes filed against Coughlin
    with the SBN (despite that 3/14/12 letter to the SBN by Judge Nash Holmes expressly purporting to be written on behalf of
    herself and ALL the other RMC Judges, whose "full cooperation" she assures she can deliver to the SBN in seeking to discredit
    Coughlin and in so doing assist the City of Reno in addressing the multiple wrongful arrests of Coughlin in the preceding
    months.

    Regardless, the communications between the Washoe County Public Defender and the RMC, including Ms. Tongini and Judge
    Nash Holmes, and what exactly Judge William Gardner was made aware of, and what he passed from his sister, Judge Linda
    Gardner, on to Judge Nash Holmes, and what Judge Nash Holmes passed onto Bar Counsel King is now of material relevance,
    and brings into play the issue of the level of candor with opposing counsel King exhibits in his 4/19/12 correspondenc with
    Coughlin when he purports to only have recieved Judge Linda Gardner's April 2009 Order for Sanctions on 3/15/12 (and that
    "5" in the "15" looks shaky, Pat), wherin King wrote: "It was sent to me by the clerk of the court at my request, pursuant to my
    investigation." Which Clerk of Court, Mr. King? Clerk of Court Orduna Hastings? Then there is Judge Elliot dismissing Coughlin's
    lawsuit against Washoe Legal Services, then incarcerating Coughlin between April 19th and April 26th, 2012 (during which time Richard G. Hill
    and Casey Baker filed their Motion for Attorney's Fees of $40,050 incident to the appeal of a summary eviction in CV11-03628, which
    Coughlin's former co-worker Judge Flanagan awarded Baker and Hill, after Judge Flanagan refused to recuse himself even where Coughlin
    pointed out the necessity of his so doing. Then Judge Elliot denied Coughlin's appeal of RMC Judge Howard's conviction of Coughlin for
    "petty larceny of a candy bar and some cough drops" in 11 CR 22176 (the sole basis for the current temporary suspension of Coughlin's law
    license, incident to a trial where the Reno City Attorney Pamela Roberts offered perjured testimony from Wal-Mart's Thomas Frontino and
    RSIC Officer Kameron Crawford that Crawford was justified in conducting a custodial arrest and search incident thereto for an alleged
    misdemeanor offense, occurring after 7 pm, outside the presence of the officer, in light of Coughlin failure to provide the officer his driver's
    license. City Attorney Roberts had been provided by the RSIC a video tape showing Coughlin providing Crawford his driver's license, and
    Coughlin's booking inventory sheet lists his drivers license (despite Officer Crawfords sworn testimony that Coughlin did not have one on his
    person at the time, even where Wal-Mart's video shows Crawford copying down Coughlin's information off the driver's license Coughlin
    provided to Offier Crawford, and where Wal-Mart admits that it did not effect a citizen's arrest of Coughlin, and therefore NRS 178.1255
    required an application of the exclusionary rule to any partial package of "cough drops" found in Coughlin's pockets upon a search incident to
    arrest (and even that is not all that necessary to prove Coughlin's innocence given that the RSIC Officer and Wal-Mart's Frontino testified
    incorrectly that the receipt for the $83.82 worth of groceries that Coughlin selected and paid after his allegely consuming a "candy bar and
    some cough drops" while shopping, did, in fact have an entry for that exact UPC of Duract Cough Melts ("cough drops"), contrary to the sworn
    testimony of both Wal-Mart's Frontino and the RSIC's Crawford). But none ofthat mattered much to Judge Elliot, as he denied Coughlin's
    appeal based on some civil statute related to a litigant being required to pay for a transcript up front, even where, in criminal matters, the
    000244
    RMC is required to transmit the record on appeal and order the production fo the transcripts within 10 days of the filing of a Notice of Appeal,
    pursuant to NRS 189.010-030, regardless of whether the criminal defendant pays for the transcript up front. See CR12-1018 for other
    instances of teh RMC and its "exclusive trancriptionist" Pam Longoni perpetuating a fraud on the public (the RMC indicates Longoni is the only
    transcriptionist they will allow, and demand that she be paid up front....Longoni hung up on Coughlin multiple times and otherwise prejudiced
    Coughlin's appeal by refusing to prepare his transcript even where Coughlin would pay up front for the transcripts, in CR11-2064. Judge Elliot
    then dismissed Coughlin's appeal of the criminal trespass conviction by Judge William Gardner in CR12-1262 where the RMC and Lisa Wagner
    failed to file the 6/28/12 Notice of Appeal Coughlin has confirmation that the RMC and City Attorney Hazlett-Stevens recieved, though both
    maintain a dubious position counter to such irrefutable proof.

    Additionally, one of the aspects of Richard G. Hill's grievance with the SBN against Coughlin, memorialized in NG12-0204 (one of the three greivances forming
    Mr. Kings SCR 105 SBN v. Couglin Petition) alleges some sort of "ghostwriting" on Coughlin's part for a former client of Coughlin's John Gessin. This is
    plainly not true, though some confusion may have arisen given the fact that at about the time Gessin and Couglin parted ways, Gessin apparently paid for and
    signed up for an E-flex account (apparently non-attorneys may do so?). Hill's allegations respecting Gessin are baseless and ironic given the fact that
    Coughlin filed Notice of Appearance as Gessin's attorney in various matters, and even sent Gessin a correspondence wherein he warns Gessin that he will not
    tolerate any appearance of ghostwriting (what can an attorney do when a client pays him money, drafts of NRCP 60(b) Motions are worked up extensively over a
    period of time, then the client decides he wants to part ways, and takes with him those drafts? File a Notice of Appearance so there is at least some paper
    trial?). It would be helpful to addressing Hill's allegations vis a vis "ghostwriting" for Gessin if the Second Judicial District Court would present or allow for
    inspection anything it may have tending to shed light on such allegations.


    Here is one correspondence Coughlin sent then client John Gessin refuting the allegations that Hill made to the SBN in his attached 1/14/12 grievance against
    Coughlin (attached to the SBN King's 2/14/12 letter to Coughlin):

    "Subject: NOTICES OF APPEARANCES

    John, Let me know whats going on, i got a new temporary address and phone number. theres is some
    ghostwriting taboos, so...if you want me to withdraw thats fine, whatever, its all good
    Zach Coughlin, Esq."


    Further, in her 10 4 12 order in 11 TR 26800, Judge Nash Holmes continues to refuse to allow Coughlin to appeal a final appealable order convicting
    him of "summary criminal contempt", even though Judge Holme's Order specifically relies upon alleged conduct, and an essential element thereof, not
    occuring in here "immediate presence", and where there is no Affidavit by her Marshal (Judge Nash Holmes states on the record in 11 TR 26800 that an
    RMC Marshal (apparently Marshal Harley) followed Coughlin into the restroom during a break in the Trial Judge Nash Holmes begrudingly granted
    Coughlin (though she ordered him to leave his yellow note pad in the courtroom?) whereupon Marshal Harley played Peeping Tom through a bathroom
    stall and alleges to have spied Coughlin "dissassembling a smartphone", which Judge Nash Holmes took as an opportunity to find "by clear and
    convicing" evidence that Coughlin "lied" "under oath" in response to her impromptu, sua sponte, interrogation of Coughlin immediately following that
    bathroom break (and soon after RMC Marshal Harley (who violated the "courthouse sanctuary" dictates against serving Coughlin Judge Flanagan's
    Order to Show Cause for a 3/23/12 Hearing on Richard G. Hill's Motion in the eviction appeal in CV11-03628 while Coughlin and City Attorney Ormaas
    where haggling over plea details immediately prior to the traffic citation trial in 11 TR 26800 (incident to Coughlin being told to leave Hill's office
    upon arriving their to retrieve his keys, wallet, and driver's license, and client's file upon being released from three days in jail incident to a criminal
    trespass complaint Hill signed against Coughlin, which the RPD committed misconduct in subjecting Coughlin to a custodial arrest for, especially in
    light of the video taped admission of Sargent Lopez and the matrials presented in Coughlin's recent filings in 61901 and 11 CR 26405). RMC Marshal
    Harley took it upon himself to aid WCSO Deputy Machen in filing a false Affidavit of Service in Harley's handing Coughlin, on behalf of Hill, a
    document Hill paid the WCSO to serve on Coughlin (an how unseemly and bullying to attempt to serve it at the traffic citation trial, appearance of
    impartiality and impropriety be damned, Caplow, regardless.). And City Attorney Ormaas may have been whispering in Harley's ears given her
    apparent concern or her responses to Coughlin asking her, shortly before the trial commenced, if she planned to follow up on or in any way document
    the admissions to accepting bribes from Richard Hill made by the officer effecting the custodial criminal trespass arrest, RPD Officer Chris Carter, Jr.
    (whom will apparently attest that he was jesting, though its not clear what is funny about arresting an attorney for trespass at his former home law
    office where the WCSO admits it lied in filing an Affidavit of Service attesting to having "personally served" Coughlin such an Eviction Order.


    I appreciate this opportunity to clarify my subpoena.

    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    000245

    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: Mr. King's assertion in his 3/16/12 letter
    Date: Thu, 19 Apr 2012 21:29:10 +0000
    April 19, 2012

    Zach Coughlin

    Dear Mr. Coughlin,

    A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the grievances filed
    against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be preparing a formal Complaint.

    I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at Wal-Mart and
    that you should not have been found in contempt of Court. However, it must concern you that you were found in contempt of Court by more than one
    Judge in two different trials. You wanted to know how I learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009.
    It was sent to me by the clerk of the court at my request, pursuant to my investigation.

    It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were
    held in contempt of Court. You may be well served to explain what remedial measures you are taking to make sure you do not repeat the conduct
    complained about. I cannot give you legal advice. However I can suggest you cooperate with Bar counsels investigation and that you respond
    specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the office of Bar Counsel.


    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 5:41 PM
    To: Patrick King; David Clark; Glenn Machado
    Subject: Mr. King's assertion in his 3/16/12 letter

    Dear Bar Counsel,


    One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months worth of my portion of our rent from
    me (our arrangement was I would give her the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed a great deal
    and paid lots of her tuition, and she broke up with me and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her
    graduation from UNR. I did not know about her stealing my portion of the rent or failing to pay her own portion until August 2011, as the landlord was on an
    extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the eviction in RJC REV2011-001708 from my former home
    law office ensued within less than a week of his communicating this deficiency. He and his counsel, Richard G. Hill, Esq. and Casey Baker pursued a No Cause
    Notice of Eviction because there was a wealth of support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in addition to
    personal property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such, indicated it would "be the path
    of least resistance" to simply seek a No Cause Eviction. The only problem in their attempt to circumvent the law (even though they still threatened to seek
    back rent in another forum after getting their No Cause, summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a
    commercial law office there, and NRS 40.253 makes impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice,
    000246
    which, of course Baker and Hill chose not to do....and it was about the time that Hill started to understand that his "wrong site surgery" for his neurosurgeon
    landlord client might subject Hill and his firm to some malpractice liability, that Hill started writing letters to bar counsel attempting to start some grievance on
    behalf of Gessin (whom Hill did not find so objectionable when Gessin was Hill's client and Hill was milking over $20K from Gessin) for "ghostwriting" even though
    I was listed as Attorney of Record on several different Gessin cases, etc., etc.
    Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has filed a grievance or complaint and also with
    respect to any criminal charge against me, including that which resulted in a conviction in 11 CR 22176, which, I think will ultimately reveal was replete with
    prosecutorial misconduct, lying by the Wal-Mart loss prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other
    errors by Judge Howard.
    I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on that 3/16/12 letter from Assistant
    Bar Counsel King (please see attached picture of the letter and envelope) indicates it was mailed 3/16/12, and the letter indicates it was not faxed to me (despite
    my numerous written requests that such a practice be done in consideration of the problems I have encountered in the USPS violations of the Federal Torts
    Claims Act and incident to the domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which included interference with my mail).
    I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden Valley USPS Station and the
    Downtown Reno Post Office in and attempt to make every diligent effort to receive my mail. I have been threatened by and lied to by the supervisors of the
    Golden Valley Station USPS Station. I had a hearing related to a landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12
    letter that I was living in my car at that time rather suspect, given my home law office was located at the property which was the subject of that hearing and
    which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no attribution for such hearsay in her extremely reckless assertion) in RJC
    REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked even a law license to litigate on her behalf, or on that of the HOA which
    Kern has now decided to appear for, despite her being listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in
    RJC Rev2012-000374.
    My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to respond to it. Additionally, I note
    that Mr. King, in that 3/16/12 letter, writes "I am enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order from
    District court....I will make available for your review and inspection the supporting documents and audio recordings."
    However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting documents and audio recordings". I wish
    to have a copy of all such "supporting documents and audio recordings", and failing a copy being provided, I wish to be allowed the access to conduct a "review
    and inspection" of "the supporting documents and audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such
    access. In addition, Mr. King now informs me that he has opened a grievance on behalf of Judge Linda M. Gardner, incident to a Order for Sanctions she entered
    in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or otherwise provided it to Bar Counsel as a Complaint or Grievance
    or otherwise. I believe someone necessarily must file the complaint or grievance. Further, I believe I am entitled to know whom that is, and when such was
    filed. Additionally, Mr. King has, so failed to provide a copy or any access to any purported complaint by the City of Reno Marshal's division incident to my
    accessing justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
    I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord tenant hearing set for March 15th,
    2012, and further, in response to hostility, retaliation, lies, and threats made by the USPS Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms."
    Passot. Some mail, like Mr. King's 3/16/12 letter to me, was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the
    other, on it by the USPS), however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me, but rather, apparently, returned to
    the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for Judge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what
    Judge Nash Holmes is referring to when she describes difficulty contacting me (the attempts by Judge Nash Holmes and the RMC apparently did not included
    either email or fax or a phone call, however....).
    There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the RMC dated 3/14/12) and which
    mailings it ultimately forwarded on to me (at my then PO BOX 60952, please note, I have a new PO BOX, that I intened to keep for a substantial period of time, it
    is PO BOX 3961, Reno 89505...), such as a 3/13/12 mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope
    has 3 yellow stickers stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then next sticker indicating a hold, and the
    final sticker atop the stack indicating a forwarding date of 3/28/12....).
    I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former home law office, and there was
    difficulties in filing a Change of Address incident to that given that the Address being changed from was permanently assigned to a business, a motor lodge.
    Further, some problem cause Bank of America to temporarily deny my attempts to change my address on file online, and rather require that I mail Bank of
    America a signed letter requesting as much, all the way to Florida. That resulted in delays in filing an online Change of Address with the USPS, given the USPS
    demands the online changes be made with one's own debit card, and that they debit card bare the same billing address as the location one is filing a change of
    address from, or else, the USPS, will process such a request, but it will add 7-10 days to tohe processing time. I chose that option given mailign a letter to
    Bank of America in Florida would have taken just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and the
    supervisor, beyond calling me a "squatter" in advance of the hearing in RJC REv2011-000374 (and refusing to divulge whom had been providing information to
    them resulting in such a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my Change of Address to my then PO Box
    60952 was being processed, my mail would be held at the Golden Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the
    following days, a supervisor named Buck Hyde literally assaulted me, and he and two other supervisors there, Terri James and "Ms. Passot" informed me they
    were "Feds" and didn't have to put up with any crap from an attorney related to state laws like NRS 118A.190, though they couldn't cite specifically to any section
    of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former home law office at 1422 E. 9th St. #2.
    Sincerely,
    000247
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    convicting attorney of summary criminal contempt during pendency of Order for
    Competency Evaluation
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 11/03/12 3:14 AM
    To: togninim@reno.gov (togninim@reno.gov); joey.hastings@washoecounty.us (joey.hastings@washoecounty.us);
    joey.orduna@washoecounty.us (joey.orduna@washoecounty.us); david.hardy@washoecounty.us (david.hardy@washoecounty.us);
    patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
    5 attachments
    11TR26800 RMC 031412_20120312-1033_01cd003b8f0851d0.wmv (10.3 MB) , 10 25 12 61901 opposition (1) FILESTAMPED
    61901 SCR 111(4) In Re Coughlin.pdf (225.1 KB) , 61901 10 29 12 amendedemmental.pdf (230.2 KB) , Patrick King sbn grievance
    letter of 3 16 12 and Judge Nash Holmes greivance of 3 14 12 rmc 11 TR 26800.pdf (575.8 KB) , exhibit 1 with cover page part 1 of
    3 61901 10 25 12 filing.pdf (8.0 MB)
    togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
    skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
    tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    FW: Mr. King's assertion in his 3/16/12 letter
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 11/03/12 3:00 AM
    To: togninim@reno.gov (togninim@reno.gov); joey.hastings@washoecounty.us (joey.hastings@washoecounty.us);
    joey.orduna@washoecounty.us (joey.orduna@washoecounty.us); david.hardy@washoecounty.us (david.hardy@washoecounty.us);
    patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com
    (mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
    je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
    4 attachments
    11cr26405 puentes 041012_20120410-0903_01cd16f8c3aa49b0.mp3 (5.1 MB) , 11CR26405 050812 Loomis_20120508-
    1104_01cd2d0a627f5f90.mp3 (15.1 MB) , 5 11 09 wls elcano washoe legal services dismissal letter citing Judge Linda Gardner's
    Order sole cause 26405 26800 00696.pdf (902.5 KB) , 5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302
    26800 60317 54844 dd.pdf (15.3 KB)
    Dear Judge Hardy, Chairman Susich, Clerk of Court Orduna Hastings, Bar Counsel, and Ms. Tognini, and Members of the Panel,

    It is plain from my interactions with Patrick King that the irony of Richard G. Hill, Esq's allegations of my "ghostwriting" are
    richest when considering the apparent "ghost-grievancing" going on here, especially with respect to the genesis of NG12-0435,
    the grievance consisting of Family Court Judge Linda Gardner's April 2009 Order sanctioning a domestic violence attorney
    $1,000, personally, where failed to follow Judge Linda Gardner's orders to seek to intimidate his battered spouse immigrant client
    into accepting the marital settlement agreement offer of one John Springgate, Esq. (a chimera of sorts where Mr. Springgate's
    client would agree to be responsilbe for a collection of third party credit card debt for which he was the sole signatory and for
    which even under and extremely unlikely "doctrine of the neccessaires, assuing my client lost on a "waste of marital assets",
    approach, my client, Ms. Joshi, would be very unlikely to ever face judgment or execution in connection with such third party
    credits card debts. I failed to cave to Judge Linda Gardner's bullying demands, and even where she yelled at me and my client
    in the impromptu "settlement conference" she decided to hold 10 minutes before the Trial (Judge Linda Gardner yelled at me to
    000248
    "shut up" in front of my client, then proceeded to tell Ms. Joshi "don't listen to your attorney!" in an angry, hostile, and
    belligerent tone), and instead cited to an ALR article that presents the position I took as the majority viewpoint in American
    jurisprudence with respect to the duty of a domestic obligation not being permissibly set off with a mere debt, particularly a third
    party unsecured credit card debt, such as those for which Mr. Joshi was the sole signatory. Apparently Judge Gardner agreed
    with John Springgate's whining about how he "needed to be able to know how much to charge for his time" or something along
    those lines (Mr. Springgate indicated that Coughlin's failing to immediately accept Springgate's settlement offer was screwing up
    Springgate's whole profit margin, and therefore contrary to the orderly administration of justice, or something along those lines,
    at which point Springgate moved for sanctions (despite not having served a 21 day safe harbor filing ready NRCP 11 motion),
    which, in John's words was tantamount to "sending a shot across your bow", a bloodsport sort of analogy one might expect from
    a semi-professional fencer like Mr. Springgate. I was fired from Washoe Legal Services and told by its Executive Director
    that the decision was based solely on Judge Linda Gardner's Order....which was odd given she and Master Edmondson and at
    least one other judge had given Elcano positive reviews of my work less than two months prior to that. Elcano, though, did,
    at the time of reporting those positive reviews mention that he goes "way back" with Linda Gardner, and that "she owes" him
    because "he did her a big favor a long time ago", etc., etc.

    Anyways, Bar Counsel King has recently indicated that he was completely unaware that Linda Gardner is the sister of the RMC
    Judge William Gardner who refused to recuse himself from the criminal trespass conviction I sustained incident to a custodial
    arrest at my former home law office, wherein the opposing counsel Richard G. Hill, Esq., has been caught lying on tape
    regarding whether any warning was given to me to leave, and whether the RPD identified themselves as law enforcement and
    issued a lawful order to leave the premises prior to the landlord kicking down a door to a "basement" that was, according to Hill's
    associate, not even a part of the property (or included in the part of the property contained within any exterior doors to the
    premises.

    Despite the statements of RMC Judge Gardner in the audio cds that King himself finally admitted to me to possessing and
    receiving from RMC Judge Nash Holmes (after several instances of King lying about his willingness to allowing me to review
    the materials Judge Nash Holmes and others slipped to the SBN, King finally was forced to turn over at least a few of those
    items. Included amongst them were the hearings before Judge William Gardner on 4/10/12 and 5/8/12 wherein RMC Judge
    William Gardner admits that his sister is none other than Family Court Judge Linda Gardner, and that his sister passed him her
    April 2009 Order sanctioning Coughlin (which Coughlin filed a Petition for Writ of Mandamus challenging in 54844,):
    http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746

    Washoe Legal Services fired Coughlin, citing Judge Linda Gardner's Order sanctioning Coughlin as the sole reason for its doign
    so. Couglin sued WLS for wrongful termination, and Judge Elliot dismissed Coughlin's lawsuit without reaching the merits of
    the Complaint, but then decided to sanction Coughlin for his lawsuit allegedly lacking "merit" anyways...go figure. Judge
    Elliot also incarcerated Coughlin from April 19th, 2012-April 26th, 2012 based upon some fraudulent letter by Lake's Crossing,
    and some Motion for Revocation of Bail made by DDA Zach Young at a time when NRS 178.405 forbid his making any motions
    given that all proceedings must be stayed during the pendency of an Order for Competency Evaluation. Amazingly, in her
    3/16/12 letter to the SBN, Judge Nash Holmes is still mentioning how she and the RMC are furiosly trying to set for Trial the
    case stemming from teh custodial "jaywalking" arrest of Coughlin on January 12th, 2012 incidnet to the lies by Richard G. Hill,
    Esq. to the RPD on that date. It is curious that that matter 11 CR 00696 was all of the sudden transferred to Judge Nash
    Holmes on February 27th, 2012, the same day Judge Nash Holmes was purportedly made aware of the 2/27/12 Order for
    Competency Evaluation of Coughlin in RCR2011-063341 (relative, at the very least, to the communications between Tognini and
    the WCPD, at the very least). Additionally, Second Judicial District Chief Appeals Clerk denied Coughlin's 2/27/12 filing of
    a Motion for Extension of Time to effectuate service in the wrongful termination lawsuit by Coughlin against Elcano (whom
    Judge Linda Garnder "owes a big favor", according to Elcano) in CV11-01955 (before Judge Elliot).

    Further, to the extent Judge Elliot's remanding Coughlin into custody to coerce his consent to divulging extremely private
    medical information is somehow a contempt Order, then the "letter" or "evaluation under seal" of 4/18/12 by Lakes Crossing Dr.
    Bill Davis and Dr. Sally Farmer must be in the form of an affidavit. It was not. Further, Coughlin called Dr. Davis from the
    booking room at the jail and Dr. Davis attempted to weasel out of the consequences of his professional misconduct, done under
    color of law, by alleging that he "didn't write the 4/18/12 letter filed with the Court" but merely signed it and was not responsible
    for it being filed with the court. To the extent the assertions in that 4/18/12 letter are outright lies (they are...the letter
    indicates Coughlin outright refused to provide basic medical information, which is not true, Coughlin indicated he would "need
    to check his records" in response to one initial question, and then mentioned that some professional, particularly physicians, face
    an inability to obtain malpractice insurance if word gets out that they take anti-depressants. Somehow Dr. Davis and Dr.
    Farmer interpreted such a statement to allow themselves to file a letter with the Court alleging that Coughlin "threatened one of
    the evaluators with legal action". No wonder Lake's Crossing insists on doing a Terry Stop style "pat down" search on each
    and everyone forced to go there by the Courts to get a Competency Evaluation (the RJC and WCPD have it set up so that one
    must utilize the services of Lake's Crossing for any such evaluation) and maintain a strick ban on any sort of smart phones or
    000249
    cellular phones within their evaluation rooms (how difficult it would be for Dr. Davis and Dr. Farmer to lie with seeming
    impunity, as they did in their 4/18/12 "evaluation" filed with the Court in CR12-0376, should their subjects be readily able to
    reveal the dishonesty of these evaluators via some recording impeachign their credibility. To the extent Judge Elliot found
    Coughlin in contempt of court (which he apparently did in response to Coughlin inquiring into the scope and extent of such a
    Competency Evaluation rather than submitting to a blank check inquest into his mental health and medical records incident to a
    retaliatory Motion for Competency Evaluation on 2/27/12 by a public defender upset that Coughlin had criticized his failing to
    show up to a court date even after that attorney, Biray Dogan had filed a Notice of Appearance and met with the client to discuss
    the case RCR2012-065630, for over an hour and a half just one week previous to that missed court appearance, and where DDA
    Young was clearly retaliating against Coughlin for Coughlin filing a Motion for Sanctions against Young just days previous to
    that in a different case.

    Regardkess. Marilyn Tognini is now being listed as a witness Coughlin intends to call at his November 14th, 2012 NNDB
    hearing at the State Bar of Nevada Offices at 9 am, and any other person whom Judge Nash Holmes may be referring to in her
    attached grievance against Coughlin (wherein she manages to allude to some hearsay about Coughlin living in his car despite the
    fact that Coughlin was clearly still living at 1422 E. 9th St. at the time Judge Nash Holmes letter to the SBN was written,
    3/14/12, even where Judge Nash Holmes feigns an inability to readily make contact with Coughlin, depsite neither she nor the
    RMC calling, emailing or faxing Coughlin, or managing to mail the 2/28/12 Order to the address all other RMC Departments
    then had for Coughlin. Regardless, that 3/14/12 grievance goes on to demonstrate Judge Nash Holmes profound lack of respect
    for or knowledge of the dictates of NRS 178.405, or the legal principles, in general, related to refraining from proceeding with
    prosecutions where the competency of the accused is in doubt in the mind of the trier of fact. Further, the SBN's Bar Counsel
    Patrick King (whom, again, managed to just in the last couple weeks indicate that he was unaware that Judge William Gardner
    and Judge Linda Gardner are brother and sister, or even related, despite King receiving from the RMC's Judge Nash Holmes a
    box of materials that included multiple hearings in the criminal trespass proseuction of Coughlin that Judge William Gardner
    (then RMC Administrative Judge, whom admitted to "at least one meeting" wherein he and the other RMC Judges discussed
    Coughlin, along with Chief Marshal Roper, only for Judge Gardner to then attempt to say with a straight face that he "was not
    sure whether he was" aware of this or that, or had any knowledge of the grievance Judge Nash Holmes filed against Coughlin
    with the SBN (despite that 3/14/12 letter to the SBN by Judge Nash Holmes expressly purporting to be written on behalf of
    herself and ALL the other RMC Judges, whose "full cooperation" she assures she can deliver to the SBN in seeking to discredit
    Coughlin and in so doing assist the City of Reno in addressing the multiple wrongful arrests of Coughlin in the preceding
    months.

    Regardless, the communications between the Washoe County Public Defender and the RMC, including Ms. Tongini and Judge
    Nash Holmes, and what exactly Judge William Gardner was made aware of, and what he passed from his sister, Judge Linda
    Gardner, on to Judge Nash Holmes, and what Judge Nash Holmes passed onto Bar Counsel King is now of material relevance,
    and brings into play the issue of the level of candor with opposing counsel King exhibits in his 4/19/12 correspondenc with
    Coughlin when he purports to only have recieved Judge Linda Gardner's April 2009 Order for Sanctions on 3/15/12 (and that
    "5" in the "15" looks shaky, Pat), wherin King wrote: "It was sent to me by the clerk of the court at my request, pursuant to my
    investigation." Which Clerk of Court, Mr. King? Clerk of Court Orduna Hastings? Then there is Judge Elliot dismissing Coughlin's
    lawsuit against Washoe Legal Services, then incarcerating Coughlin between April 19th and April 26th, 2012 (during which time Richard G. Hill
    and Casey Baker filed their Motion for Attorney's Fees of $40,050 incident to the appeal of a summary eviction in CV11-03628, which
    Coughlin's former co-worker Judge Flanagan awarded Baker and Hill, after Judge Flanagan refused to recuse himself even where Coughlin
    pointed out the necessity of his so doing. Then Judge Elliot denied Coughlin's appeal of RMC Judge Howard's conviction of Coughlin for
    "petty larceny of a candy bar and some cough drops" in 11 CR 22176 (the sole basis for the current temporary suspension of Coughlin's law
    license, incident to a trial where the Reno City Attorney Pamela Roberts offered perjured testimony from Wal-Mart's Thomas Frontino and
    RSIC Officer Kameron Crawford that Crawford was justified in conducting a custodial arrest and search incident thereto for an alleged
    misdemeanor offense, occurring after 7 pm, outside the presence of the officer, in light of Coughlin failure to provide the officer his driver's
    license. City Attorney Roberts had been provided by the RSIC a video tape showing Coughlin providing Crawford his driver's license, and
    Coughlin's booking inventory sheet lists his drivers license (despite Officer Crawfords sworn testimony that Coughlin did not have one on his
    person at the time, even where Wal-Mart's video shows Crawford copying down Coughlin's information off the driver's license Coughlin
    provided to Offier Crawford, and where Wal-Mart admits that it did not effect a citizen's arrest of Coughlin, and therefore NRS 178.1255
    required an application of the exclusionary rule to any partial package of "cough drops" found in Coughlin's pockets upon a search incident to
    arrest (and even that is not all that necessary to prove Coughlin's innocence given that the RSIC Officer and Wal-Mart's Frontino testified
    incorrectly that the receipt for the $83.82 worth of groceries that Coughlin selected and paid after his allegely consuming a "candy bar and
    some cough drops" while shopping, did, in fact have an entry for that exact UPC of Duract Cough Melts ("cough drops"), contrary to the sworn
    testimony of both Wal-Mart's Frontino and the RSIC's Crawford). But none ofthat mattered much to Judge Elliot, as he denied Coughlin's
    appeal based on some civil statute related to a litigant being required to pay for a transcript up front, even where, in criminal matters, the
    RMC is required to transmit the record on appeal and order the production fo the transcripts within 10 days of the filing of a Notice of Appeal,
    000250
    pursuant to NRS 189.010-030, regardless of whether the criminal defendant pays for the transcript up front. See CR12-1018 for other
    instances of teh RMC and its "exclusive trancriptionist" Pam Longoni perpetuating a fraud on the public (the RMC indicates Longoni is the only
    transcriptionist they will allow, and demand that she be paid up front....Longoni hung up on Coughlin multiple times and otherwise prejudiced
    Coughlin's appeal by refusing to prepare his transcript even where Coughlin would pay up front for the transcripts, in CR11-2064. Judge Elliot
    then dismissed Coughlin's appeal of the criminal trespass conviction by Judge William Gardner in CR12-1262 where the RMC and Lisa Wagner
    failed to file the 6/28/12 Notice of Appeal Coughlin has confirmation that the RMC and City Attorney Hazlett-Stevens recieved, though both
    maintain a dubious position counter to such irrefutable proof.

    Additionally, one of the aspects of Richard G. Hill's grievance with the SBN against Coughlin, memorialized in NG12-0204 (one of the three greivances forming
    Mr. Kings SCR 105 SBN v. Couglin Petition) alleges some sort of "ghostwriting" on Coughlin's part for a former client of Coughlin's John Gessin. This is
    plainly not true, though some confusion may have arisen given the fact that at about the time Gessin and Couglin parted ways, Gessin apparently paid for and
    signed up for an E-flex account (apparently non-attorneys may do so?). Hill's allegations respecting Gessin are baseless and ironic given the fact that
    Coughlin filed Notice of Appearance as Gessin's attorney in various matters, and even sent Gessin a correspondence wherein he warns Gessin that he will not
    tolerate any appearance of ghostwriting (what can an attorney do when a client pays him money, drafts of NRCP 60(b) Motions are worked up extensively over a
    period of time, then the client decides he wants to part ways, and takes with him those drafts? File a Notice of Appearance so there is at least some paper
    trial?). It would be helpful to addressing Hill's allegations vis a vis "ghostwriting" for Gessin if the Second Judicial District Court would present or allow for
    inspection anything it may have tending to shed light on such allegations.


    Here is one correspondence Coughlin sent then client John Gessin refuting the allegations that Hill made to the SBN in his attached 1/14/12 grievance against
    Coughlin (attached to the SBN King's 2/14/12 letter to Coughlin):

    "Subject: NOTICES OF APPEARANCES

    John, Let me know whats going on, i got a new temporary address and phone number. theres is some
    ghostwriting taboos, so...if you want me to withdraw thats fine, whatever, its all good
    Zach Coughlin, Esq."


    Further, in her 10 4 12 order in 11 TR 26800, Judge Nash Holmes continues to refuse to allow Coughlin to appeal a final appealable order convicting
    him of "summary criminal contempt", even though Judge Holme's Order specifically relies upon alleged conduct, and an essential element thereof, not
    occuring in here "immediate presence", and where there is no Affidavit by her Marshal (Judge Nash Holmes states on the record in 11 TR 26800 that an
    RMC Marshal (apparently Marshal Harley) followed Coughlin into the restroom during a break in the Trial Judge Nash Holmes begrudingly granted
    Coughlin (though she ordered him to leave his yellow note pad in the courtroom?) whereupon Marshal Harley played Peeping Tom through a bathroom
    stall and alleges to have spied Coughlin "dissassembling a smartphone", which Judge Nash Holmes took as an opportunity to find "by clear and
    convicing" evidence that Coughlin "lied" "under oath" in response to her impromptu, sua sponte, interrogation of Coughlin immediately following that
    bathroom break (and soon after RMC Marshal Harley (who violated the "courthouse sanctuary" dictates against serving Coughlin Judge Flanagan's
    Order to Show Cause for a 3/23/12 Hearing on Richard G. Hill's Motion in the eviction appeal in CV11-03628 while Coughlin and City Attorney Ormaas
    where haggling over plea details immediately prior to the traffic citation trial in 11 TR 26800 (incident to Coughlin being told to leave Hill's office
    upon arriving their to retrieve his keys, wallet, and driver's license, and client's file upon being released from three days in jail incident to a criminal
    trespass complaint Hill signed against Coughlin, which the RPD committed misconduct in subjecting Coughlin to a custodial arrest for, especially in
    light of the video taped admission of Sargent Lopez and the matrials presented in Coughlin's recent filings in 61901 and 11 CR 26405). RMC Marshal
    Harley took it upon himself to aid WCSO Deputy Machen in filing a false Affidavit of Service in Harley's handing Coughlin, on behalf of Hill, a
    document Hill paid the WCSO to serve on Coughlin (an how unseemly and bullying to attempt to serve it at the traffic citation trial, appearance of
    impartiality and impropriety be damned, Caplow, regardless.). And City Attorney Ormaas may have been whispering in Harley's ears given her
    apparent concern or her responses to Coughlin asking her, shortly before the trial commenced, if she planned to follow up on or in any way document
    the admissions to accepting bribes from Richard Hill made by the officer effecting the custodial criminal trespass arrest, RPD Officer Chris Carter, Jr.
    (whom will apparently attest that he was jesting, though its not clear what is funny about arresting an attorney for trespass at his former home law
    office where the WCSO admits it lied in filing an Affidavit of Service attesting to having "personally served" Coughlin such an Eviction Order.


    I appreciate this opportunity to clarify my subpoena.

    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com

    000251
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: Mr. King's assertion in his 3/16/12 letter
    Date: Thu, 19 Apr 2012 21:29:10 +0000
    April 19, 2012

    Zach Coughlin

    Dear Mr. Coughlin,

    A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the grievances filed
    against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be preparing a formal Complaint.

    I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at Wal-Mart and
    that you should not have been found in contempt of Court. However, it must concern you that you were found in contempt of Court by more than one
    Judge in two different trials. You wanted to know how I learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009.
    It was sent to me by the clerk of the court at my request, pursuant to my investigation.

    It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were
    held in contempt of Court. You may be well served to explain what remedial measures you are taking to make sure you do not repeat the conduct
    complained about. I cannot give you legal advice. However I can suggest you cooperate with Bar counsels investigation and that you respond
    specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the office of Bar Counsel.


    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 5:41 PM
    To: Patrick King; David Clark; Glenn Machado
    Subject: Mr. King's assertion in his 3/16/12 letter

    Dear Bar Counsel,


    One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months worth of my portion of our rent from
    me (our arrangement was I would give her the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed a great deal
    and paid lots of her tuition, and she broke up with me and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her
    graduation from UNR. I did not know about her stealing my portion of the rent or failing to pay her own portion until August 2011, as the landlord was on an
    extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the eviction in RJC REV2011-001708 from my former home
    law office ensued within less than a week of his communicating this deficiency. He and his counsel, Richard G. Hill, Esq. and Casey Baker pursued a No Cause
    Notice of Eviction because there was a wealth of support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in addition to
    personal property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such, indicated it would "be the path
    of least resistance" to simply seek a No Cause Eviction. The only problem in their attempt to circumvent the law (even though they still threatened to seek
    back rent in another forum after getting their No Cause, summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a
    commercial law office there, and NRS 40.253 makes impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice,
    which, of course Baker and Hill chose not to do....and it was about the time that Hill started to understand that his "wrong site surgery" for his neurosurgeon
    landlord client might subject Hill and his firm to some malpractice liability, that Hill started writing letters to bar counsel attempting to start some grievance on
    000252
    behalf of Gessin (whom Hill did not find so objectionable when Gessin was Hill's client and Hill was milking over $20K from Gessin) for "ghostwriting" even though
    I was listed as Attorney of Record on several different Gessin cases, etc., etc.
    Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has filed a grievance or complaint and also with
    respect to any criminal charge against me, including that which resulted in a conviction in 11 CR 22176, which, I think will ultimately reveal was replete with
    prosecutorial misconduct, lying by the Wal-Mart loss prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other
    errors by Judge Howard.
    I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on that 3/16/12 letter from Assistant
    Bar Counsel King (please see attached picture of the letter and envelope) indicates it was mailed 3/16/12, and the letter indicates it was not faxed to me (despite
    my numerous written requests that such a practice be done in consideration of the problems I have encountered in the USPS violations of the Federal Torts
    Claims Act and incident to the domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which included interference with my mail).
    I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden Valley USPS Station and the
    Downtown Reno Post Office in and attempt to make every diligent effort to receive my mail. I have been threatened by and lied to by the supervisors of the
    Golden Valley Station USPS Station. I had a hearing related to a landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12
    letter that I was living in my car at that time rather suspect, given my home law office was located at the property which was the subject of that hearing and
    which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no attribution for such hearsay in her extremely reckless assertion) in RJC
    REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked even a law license to litigate on her behalf, or on that of the HOA which
    Kern has now decided to appear for, despite her being listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in
    RJC Rev2012-000374.
    My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to respond to it. Additionally, I note
    that Mr. King, in that 3/16/12 letter, writes "I am enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order from
    District court....I will make available for your review and inspection the supporting documents and audio recordings."
    However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting documents and audio recordings". I wish
    to have a copy of all such "supporting documents and audio recordings", and failing a copy being provided, I wish to be allowed the access to conduct a "review
    and inspection" of "the supporting documents and audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such
    access. In addition, Mr. King now informs me that he has opened a grievance on behalf of Judge Linda M. Gardner, incident to a Order for Sanctions she entered
    in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or otherwise provided it to Bar Counsel as a Complaint or Grievance
    or otherwise. I believe someone necessarily must file the complaint or grievance. Further, I believe I am entitled to know whom that is, and when such was
    filed. Additionally, Mr. King has, so failed to provide a copy or any access to any purported complaint by the City of Reno Marshal's division incident to my
    accessing justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
    I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord tenant hearing set for March 15th,
    2012, and further, in response to hostility, retaliation, lies, and threats made by the USPS Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms."
    Passot. Some mail, like Mr. King's 3/16/12 letter to me, was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the
    other, on it by the USPS), however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me, but rather, apparently, returned to
    the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for Judge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what
    Judge Nash Holmes is referring to when she describes difficulty contacting me (the attempts by Judge Nash Holmes and the RMC apparently did not included
    either email or fax or a phone call, however....).
    There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the RMC dated 3/14/12) and which
    mailings it ultimately forwarded on to me (at my then PO BOX 60952, please note, I have a new PO BOX, that I intened to keep for a substantial period of time, it
    is PO BOX 3961, Reno 89505...), such as a 3/13/12 mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope
    has 3 yellow stickers stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then next sticker indicating a hold, and the
    final sticker atop the stack indicating a forwarding date of 3/28/12....).
    I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former home law office, and there was
    difficulties in filing a Change of Address incident to that given that the Address being changed from was permanently assigned to a business, a motor lodge.
    Further, some problem cause Bank of America to temporarily deny my attempts to change my address on file online, and rather require that I mail Bank of
    America a signed letter requesting as much, all the way to Florida. That resulted in delays in filing an online Change of Address with the USPS, given the USPS
    demands the online changes be made with one's own debit card, and that they debit card bare the same billing address as the location one is filing a change of
    address from, or else, the USPS, will process such a request, but it will add 7-10 days to tohe processing time. I chose that option given mailign a letter to
    Bank of America in Florida would have taken just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and the
    supervisor, beyond calling me a "squatter" in advance of the hearing in RJC REv2011-000374 (and refusing to divulge whom had been providing information to
    them resulting in such a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my Change of Address to my then PO Box
    60952 was being processed, my mail would be held at the Golden Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the
    following days, a supervisor named Buck Hyde literally assaulted me, and he and two other supervisors there, Terri James and "Ms. Passot" informed me they
    were "Feds" and didn't have to put up with any crap from an attorney related to state laws like NRS 118A.190, though they couldn't cite specifically to any section
    of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former home law office at 1422 E. 9th St. #2.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000253
    RE: SBN still has not provided Coughlin access to the materials he is entitled to to prepare
    for 11/14/12 Hearing
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/02/12 11:45 PM
    To: patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org)
    From: zachcoughlin@hotmail.com
    To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
    tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
    Subject: SBN still has not provided Coughlin access to the materials he is entitled to to prepare for 11/14/12 Hearing
    Date: Fri, 2 Nov 2012 22:36:46 -0700
    Dear Panel Members and Bar Counsel,

    I called Mr. King (he directed me to call Panel Chair Echeverria) today to seek clarification regarding an earlier approval he
    relayed to me from Chief Bar Counsel David Clark, wherein Mr. Clark advised me that I, even though I am a temporarily
    suspended attorney, have been given permission by the Office of Bar Counsel to issue subpoenas in connection with this
    disciplinary matter (ng12-0204, ng12-0434, ng12-0435...odd, can't recall a single other "case" in all my legal research that had
    three case numbers....especially where an Order Denying a Motion to Bifurcate was issued, even before the 5 days for me to file
    a Reply to the Opposition (given NRCP is expressly applicable to these matters under the SCR's)...Am I going to find out that
    my filings are "too long" under a view that assumes this is "one case" even though there are "three grievance case numbers" in
    the caption, and where each "grievance" is fairly rambling? And where the SBN's King purports this hearing to involve
    that which the N. S. Ct. Ordered to occur in response to its temporary suspension Order incident to the SCR 111 Petition for the
    petty larceny of a "candy bar and some cough drops" (ie, the Court order that matter, 60838, referred to the Board for a "hearing
    at which the sole issue to be determined" would be my punishment for that which was noticed and adjudicated in the 60838 SCR
    111 Petition. I believe you are all now violating Nevada Law in persisting in your denial of my right to such a hearing wherein
    the "sole issue" is such, but rather trying to jam me up with this "combo hearing" that seeks to encompass a great deal of
    disparate claims (many of which are pending criminal charges, and therefore, entirely outside of your jursisiction at this point,
    and your deigning to address them interferes with the orderly administration of justice in those pending criminal prosecutions, as
    evinced by Judge Sferrazza's refusal to testify at the November 14th, 2012 Hearing...which is problematic considering Judge
    Sferrazza presided over the civil summary eviction matter in RJC Rev2011-001708 that is intimately connect to ALL THREE of
    the grievances included in King's reckless, negligent, compromised SCR 105 "Complaint". For instance:
    NG12-0204: Richard G. Hill's January 14th, 2012 letter to Bar Counsel King (whom he had just worked on the Milsner v.
    Carstarphen matter with (http://law.justia.com/cases/nevada/supreme-court/2012/51631.html )

    Today, King admitted to being unaware of who Casey Baker, Esq. is. King also admitted to not having read any of my
    filings in any of these connected matters, only to then suggest an analogy along the lines of if a woman is raped a lot, she is
    probably a whore and deserves it or wanted it, given the sheer mathematical improbability of any one woman getting raped over
    and over, and how King just doesn't get paid enough to stick his nose into some gangbang, what with the chances of getting
    himself involved in doing the right thing where it is just so much easier to sit back and pretend that the Claiborne decision
    (explicated extensively in my attached August 13th, 2012 Petition) does not permit Bar Counsel to just throw its hands up and
    suggest that a Muni Court conviction (even, in RMC 11 CR 26405, presided over by the brother of the judge whose sanctions
    Orders is before you in NG12-0435, and where the brother refused to recuse himself from that criminal trespass conviction
    incident to the lies and or attempts to mislead a tribunal by Casey Baker, Esq. and Richard G. Hill at the June 18th, 2012
    criminal trespass trial incident to the civil eviction from Coughlin's former law office in RJC Rev2011-001708. Asst. Bar
    Counsel King also admitted that he had failed to even view the video taped admission by RPD Sargent Lopez that she, Hill,
    Merliss, and RPD Officer Carter lied in order to effectuate the wrongful arrest leading to Couglin's conviction by the brother of
    the sister whose 2009 sanctions Order against Coughlin only became a grievance on March 14th, 2012 (apparently King adopts
    Ching as to whom can be an SCR 105 complainant, and therefore within the statute of limitations, when it comes to
    Gardner's April 2009 Order, but not when it involves misconduct by a Chairman of the Character and Fitness Committee of the
    SBN, Spearmint Rhino owner Kevin Kelly, Esq., whom also owns a Las Vegas Strip Club that gives cabbies $10 million dollars
    a year to funnel tourists to it's doors from the airport, and the misconduct of Peter Christiansen, Jr. and Mike Sanft, and others
    incident to Coughlin's application for admission in Nevada, including that of then Director of Admissions Patrice Eichmann,
    000254
    made all the more feasible by the conduct of Mike Smiley Rowe, Esq. and the fraudulent conduct of Mark Tratos and Mary
    LaFrance) when RMC Judge Nash Holmes (in response to prompting by the SBN) passed that three year old Order (attorneys
    get sanctioned all the time, such orders do not become grievances as a matter of course, and the SBN has admitted it keeps no
    central record of any such grievances) on to Bar Counsel after receiving it from her co-RMC Judge, and the brother of the family
    court judge issuing the sanction order...at right about the time that Coughlin filed that March 7th, 2012 Notice of Appeal (and
    there is plenty of case law to establish that a "summary criminal conviction" is a final appealable Order, and the RMC is
    fraudulently conspiring with transcriptionist Pam Longoni to violate NRS 189.010-030 by demanding payment up front for such
    transcripts by indigent criminal defendants, and Longoni and the RMC's fraud in that regard resulted in Judge Elliot denying
    Coughlin's appeal of the Wal-Mart candy bar petty larceny conviction in cr11-2064, wherein Judge Elliot actually cites to a civil
    statute related to transcript preparation to justify the RMC's fraud, seen elsewhere in CR12-1018, further the RMC "lost'
    Coughlin's Notice of Appeal of the 11 cr26405 criminal trespass conviction appeal (despite Coughlin having digitial confirmation
    of the receipt of that fax by the RMC, and where RMC Rules allows service thereof via that means upon both the Court and the
    City Attorney (and Hazlett-Stevens lied about that as well, in addition to the lies he told respecting whether the City Attorney
    had received anything from the RSIC following Coughlin's Wal-Mart arrest) in the "summary criminal contempt" Order
    stemming from the traffic citation (California roll) trial connected to Coughlin reporting the admissions of bribery by Richard
    Hill (RPD Officer Carter stated as much during the November 13th, 2011 criminal trespass arrest, now part of the SCR 105
    Complaint, incorporated by reference, one must suppose, by Hill's NG12-0204 grievance) to the Sargent who retaliated against
    Coughlin by issuing three traffic citations, for Coughlin so reporting such admissions by the arresting officer in the trespass
    matter to the Sargent who issued the traffic citations to Coughlin incident to Coughlin going to Hill's office to retrieve his keys,
    wallet, client's files, and goverment issued identification after being release from 3 days in jail incident to the wrongful criminal
    trespass arrest.

    Mr. King is beyond incorrect is stating that he will be able to simply point to a criminal conviction and declare that no inquiry
    into the legitimacy of that conviction may be made. There is a wealth of case law and precedent that holds otherwise, and Mr.
    King has previously been made aware of that. This is true especially where the convictions at issue completely fail to evince
    even baseline level of regard for traditional notions of due process. Simply put, some might say the members of this Panel
    ought think rather hard before tying their reputations to the mast that is the extremely low bar required to get a conviction in the
    Reno Municipal Court these days....and further, the Panel would be well advised to avoid letting Mr. King lead it down that
    primrose path wherein one believes they will be entitled to merely accept a municipal court conviction as conclusive proof of
    misconduct or otherwise rule irrelevant any inquiry into the circumstances attendant to such a matter. This will be
    particularly true where Mr. King seeks to, in his SCR 105 Complaint, allege matters not even charged in that Municipal Court
    criminal trespass proseuction. How Mr. King will be able to allege his RPC 3.8 violating allegations respecting "breaking and
    entering" or "broken locks" are relevant or admissible where Coughlin's dissection of the illegitimacy of the Walmart candy bar
    petty larceny conviction (supposedly part of the SCR 105 Compalint....and mentioned in Hill's NG12-0204 grievance...which
    brings to mind the question...what of matters not mentioned in any of the three grievance numbers? How are they eligible for
    inclusion in some SCR 105 "Complaint' that lacks a unique case number of its own?) Regardless, it is November 2nd, 2012
    and my defense has been irreversibly prejudiced by the refusal of Bar Counsel to allow me to access the materials at the SBN
    that are my right to under the SCR, thus bringing the legitimacy of the entire November 14th, 2012 hearing into doubt, to which
    any argument that I should be made to fit the bill for Bar Counsel's bungling and fraudulent failure to follow the rules applicable
    to this matter, in addition to its own written attestations, is entirely unsupportable.

    Regardless, Richard G. Hill, Esq.'s hench man, Casey Baker, Esq., now that the heat is on and he and Hill's avarice driven
    misdeeds are finally facing the oversight they deserve, has now suddenly fled back to Kentucky:
    http://www.nvbar.org/lawyer-detail/11271

    It was Baker whom Hill used to file the November 21st, 2011 and January 20th, 2012 filings in RJC Rev2011-001708 and the appeal thereof in CV11-03628 to
    make the allegatons that Hill himself knew unwise to make in his own regard within a sworn Declaration...So, despite Hill, not Baker, having the eye witness
    knowledge of such events (like whether the RPD identified themselves as law enforcement and issued to Coughlin a lawful warning to leave at the risk of a
    criminal trespass citation or arrest prior to the landlord kicking down the door to a quasi "basement" under the property that Baker's own testimony at the June
    18th, 2012 trespass trail admits lacked any sort of exterior lock, and thus would require no "breaking of any sort" of the type both Susich and King suddenly felt
    the need to allege when considering how terribly compromised their 60975 Petiton and the instant SCR 105 "combo-grievances" (kind of like a "due process
    value meal" that Pat King is serving up, and asking this Board to co-sign...which, apparently the Chairman finds fitting....what's next, are you going to have lawyers
    dress up in Hot Dog on a Stick employee uniforms (you know, rainbow colors, the spinning thing atop the hat, etc.) too? Is that how little the property right of
    a law license (case law declares it as much under the Fourteenth Amendment, and any willful deprivation thereof by this Board, including a deprivation of the due
    process required to impinge thereupon, can subject the members of this Board the 42 USC Sec. 1983 liability, especially where, as her, what appears to be a
    coordinated effort to obstruct justice and proceed impermissibly under color of law for the self interested aims of those leveraging such positions is apparent.
    RICO.


    I am writing to request confirmation of what I believe Mr. Clark has previously rule, ie, that I, as an indigent respondent herein, am not required to pay witnesses
    any sort of "witness fee" in issuing and or serving subpoenas and subpoens duces tecums upon them in connection with the November 14th, 2011 Hearing in
    this matter. I feel Hill's then associate Casey Baker, Esq's testimony will be particular necessary to this hearing (especially where Hill admits himself that he was
    not present at the purported November 1st, 2011 "lockout" in the eviction matter (and the service of an receipt by the WCSO with respect to any such lockout
    000255
    Order is of material relevance, as NRS 40.253 requires such an Order be carried out "within 24 hours of receipt" thereof...and Baker's testimony at the June 18th,
    2012 criminal trespass trial, in combination with previous statements by the Washoe County Sheriff's Office (and please add these individuals and matters to my
    designation fo witnesses and summary of evidence to be presented) Supervisor Liz Stuchell, Roxy Silve, Deputy Machen, and administrators, supervisors, and
    clerks at the Reno Justice Court (RJC) add up to the fact that it was Hill, Baker, and the WCSO, and RPD that were trespassing, not Coughlin, at Coughlin's former
    home law office. Attached it the video taped admission by RPD Sargent Lopez respecting the lies by her, RPD Officer Carter, Hill, Merliss, and Baker leading
    to Coughlin's arrest and conviction for criminal trespass. Keith Loomis will need to answer for his failure to fulfill the Sixth Amendment in that regard, in
    addition to the content of the unapproved and impermissible "meeting" with RMC Judge Gardner and City of Reno Prosecutor wherein, upon information and
    belief, an "approach" to handling the criminal trespass trial of Coughlin was "developed" shortly before the April 10th, 2012 Trial date in that criminal trespass
    matter (a Trial date which violated Nevada law, anyways, in that it was set and held during the pendency of an Order for Competency Evaluation of Coughlin in
    violation of NRS 178.405 and NRS 5.010). Any trier of fact that wishes to attempt to pull the wool over Coughlin's eyes, make incongruous and patently
    compromised, often sua sponte relevancy rulings, or otherwise cook up a due process value meal may wish to ask RMC Judge Gardner how the recent filings by
    Coughlin in 61901 and the RMC 11 CR 26405 are tasting right about now. Or get Judge Howard's inpute with respect to the analysis of his work in 60838.
    And Judge Nash Holmes may be able to provide some insight as to how that approach served her, particularly where her "criminal summary contempt" order
    was made during the pendency of an Order for Competency Evaluation, and cites to alleged conduct committed outside her immediate presence (and that's the
    thing about "summary adjudications"....the are so arbitary and devoid of due process that the requirements attendant thereto must be stricly adhered to....so when
    Judge Nash Holmes in here Orders in 11 TR 26800 of 2/28/12 and 3/12 3/13, and 3/13/12 refers to some RMC Marshal allegedly peering, Peeping Tom style,
    through a bathroom stall wherein Coughlin was during a restroom break within that trial, her Order fails to adhere to the dictate that each element of any
    conduct she deigns to summarily rule upon be committed in her "immediate presence"...otherwise, someone would have to sign an Affidavit like a grown up, and
    Coughlin would be entitled to a hearing, and likely appointed counsel under the Sixth Amendment before some Bar Counsel like King could attempt to prop up
    any such "conviction" in an attempt to lend it an air of respectiability, especially where that Marshal Harley (whom King conveniently has failed to subpoena) had
    his own self interested reasons for seeking to discredit Coughlin (RMC Marshal Harley violated the "courthouse sanctuary" rule and contributed to an appearance
    of impropriety where he served Coughlin an Order to Show Cause incident to one of Hill's fraudulent Motions seeking to abuse process in hopes of remaining
    competitive with an actual attorney like Coughlin (rather than a known hack like HIll whom inherited a law practice from his father and who legion of local
    attorneys accuse of unneccesarily running up fees on his clients by purposefully overcomplicating litigations and engendering an adversarial stance amongst
    litigants designed to line Hill's pockets, and those of, apparently, even his legal assistans, whom drive $130,000 Mercedes v12 SL-600 sport coupe convertibles to
    crack inspections of law offices incident to impermissible summary evictions of commercial tenants where Hill chose to proceed under a No Cause Eviction Notice
    (along with Baker) rather than a Non Payment Notice, and therein committed a "wrong site surgery" (in a litigation sense, to borrow some of the parlance of the
    landlord, Dr. Merliss's field, wherein he is a Neurosurgeon/Neurologist in Chico, CA, apparently armed with enough money to choose to run up $60,000, as of
    April 2012 in fees ot HIll and Baker in these matters rather than settle with Coughlin for the $1,500 Coughlin offered him).

    Please add to the witness list all the individuals mentioned in the various filings I have provided you, including, but not limited to RPD Officers Duralde, Rosa,
    Alaksa, Weaver, Look, Travis Warren, and Leedy, RPD Sargent Tarter,Lopez, Sifre, Oliver Miller, Dye, and Bradshaw, Hill's Associate Casey Baker, Sheri Hill, and
    to be deterimined members of HIll's staff (particulary those with knowledge of any matters connected to the receipt of either of the Eviction Orders by the WCSO
    in the eviction matter, WCPD Jim Leslie, Biray Dogan, Joe Goodnight, Walmart Thomas Frontino and ASM John Ellis, and a yet to be determined AP Associate
    whom, along with Ellis, made express threats to retaliate against Coughlin with abuse of process similar to the petty larceny candy bar conviction in 60838 that
    currently forms the only basis for the suspension of Coughlin's law license and for which this Panel and the SBN are violating Nevada law in persisting in refusing
    to follow the dicates of both the Supreme Court Rules of Nevada and the Court's June 7th, 2012 Order in 60838, but rather, like Clerk/"reluctant" Investigator
    Peters, are allowing themselves to be led down that primrose path that Pat King finds to pleasurable to take the unwitting along in his social climbing and life of
    ease and comfort, devoid of honor or intergrity, approach to life...Also, to the extent then Panel considers a pending criminal prosecution up for inquiry in a
    disciplinary proceeding, included in potential witness call may call are Nicole Watson, Lucy Byington, Nate Zarate, Cory Goble, the individual whose phone
    number is 7753786673, Colton Templeton, Robert Dawson, Nick Duralde, Ron Rosa, Thomas Alaksa, Savannah Montgomery, Linda Gray, Kelly Odom, Kariann
    Beechlker, RPD Officer Schaur and any others present at arrest of 1/14/12 for "misuse of emergency communications", and of the 5-6 officers whom, along with
    RPD Duralde pulled Coughlin over upon his release from jail on 1/13/12 for the 1/12/12 "jaywalking" arrest made upon the fraudulent assertions of Richard HIll,
    RJC Judge Jack Schroeder (whom evicted Coughlin from Park Terrace and granted Hill the protection order incident to the jaywalking arrest and who yelled "do
    you want to go to jail" at Coughlin at the extension hearing when Coughlin broached the topic of Hill's abuse of process, and whom wrongfully granted the
    6/27/12 Eviction Order in RJC Rev2012-001048 despite the deficient 5 day notice listing the wrong court to file a tenan'ts affidavit (a requirement under NRS
    40.253, and despite Coughlin's numerous calls and 6/26/12 email to the RJC, SJC, RPD and WCSO, also Jeff Nichols and Peter Eastman and Paul Freitag, Esq.
    (involved in SBN King's impermissilbe disclosures and slanderous statements concerning Coughlin and the NVB (which King also made to his boss in front of
    Coughlin, David Clark, and which have proven to be baseless, despite King ticking such off amongst the top 2 reasons for the SCR 105 Complaint he alleged he
    would hurriedly throw together upon Coughlin serving King, the SBN, Clark and Peters the August 13th, 2012 filing in 60838 and 61426, now before the N. S. Ct.).
    Also, Richard Cornell, Tom Hall, Geof Giles, and Michael Lehrners, Judge Joe Van Walraven and others all whom have indicated, to one degree or another, that
    Hill's conduct incident to this eviction matter and concomitant appeal is deplorable and entirely consistent with the way Hill has comported himself throughout
    his 33 year career, which began with is inheriting a large scale law practice from his father, and continued on with Hill effecting the manner of a 10 year old boy
    entrusted with flying a 747 full of people, to this day. Add to the witness List Paul Elcano of WLS, Judge Steven Elliot, Judge Patrick Flanagan, Hale
    Lane/Holland and Hart's Anthony Hall and Tim Lukas, Richard Elmore, Judge Scott Pearson, Judge Peter J. Sferrazza (though he indicated on 10/22/12 that he
    declined the SBN's request that he testify, citing his sitting on the pending criminal prosecution in RCR2011-063341), the RJC's Bonnie Cooper and "Nevi", Chief
    Bailiff Michael Sexton, RMC Chief Marshal Roper and Marshal Deighton, Marshal Thompson, Marshal Coppa, WCDC Van der Wal, Beatson, Hoekstra, Cheung,
    unnamed deputies. Further, please add Western Nevada Management's Sue King, Jared Scalise, and Park Terrace Townhomes Association attorney Gayle Kern,
    Esq., Roberto Puentes, Lew Taitel, the RMC's Matthew Fisk and Cassandra Jackson, Donna Ballard, Judge Howards past legal assistant, Judge Nash Holmess legal
    and administrative assistant, Martin Crowley or Martin Weiner or whichever attorney is was Judge Nash Holmes was sued for wiretapping in the past, the RMC
    counter clerk "Daniel" and "Thom", WDC Chief Appeals Clerk Matheus, Joey Orduna Hastings, Chief Judge David Hardy, Justice Hardesty (whom was one of only
    three Justices signing the June 7th, 2012 temporary suspension Order, but whom recused himself from 60302 and 60317, the wrongful termination suit against
    Washoe Legal Services (see attached letters from WLS's Executive Director citing Judge Linda Gardner's April 2009 Order sanctioning Coughlin as the "sole
    reason" for Coughlin's firing (her brother, RMC Judge William Gardner refused to recuse himself from the criminal trespass conviction mentioned in in King's SCR
    105 Complaint, and King admitted two weeks ago that he was unaware that the two Judge Gardners were brother and sister or related whatsoever, or that Judge
    Nash Holmes was a prison warden or something similar for ten years, and a lifelong prosecutor besides that (in addition to all other RMC Judges and all RMC
    court appointed defenders).


    Also, I never received any Notice of Intent to Take Default from the SBN, and herein lodge my objection to any Order by this Panel that cites thereto.
    Additionally, SBN's Peters has indicated no other respondents have ever been made to pay witness subpoena fees, and further Peters and the SBN have
    repeatedly failed to adhere to agreements they have made with Coughlin (including the failure of the SBN to resend a certified mail copy of the SCR 105
    Complaint incident to the agreement between Peters and Coughlin on or about September 11th, 2012.

    000256



    Sincerely,




    Sincerley,
    skent@skentlaw.com, mike@tahoelawyer.com, nevtelassn@sbcglobal.net, patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org;
    complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
    Subject: RE: Records
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
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    000260
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    000261
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    RE: release of information to my attorney
    From:Goodnight, Joseph W (JGoodnight@washoecounty.us)This sender is in your safe list.
    Sent: Wed 5/02/12 4:45 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin,
    MHC has received your referral and diagnosis from Ascent NBI. The MHC coordinator indicated that your case will be added to Friday's staffing and your
    application "looks fine." I take that to indicate that you'll likely be accepted. I have a call in to DDA Young to re-open negotiations. This is what I intend to
    present for a global resolution:

    Parties will agree to transfer jurisdiction of RCR11-063341 (RJC Misdemeanors) to MHC. DDA Young will defer prosecution of RCR12-065630 (misuse of
    911) and upon successful completion of MHC, will dismiss with prejudice. City prosecutor in Reno Municipal Court case (Trespass) will defer prosecution
    and upon successful completion of MHC, will dismiss with prejudice (your attorney, Mr. Loomis, should advise you regarding this case).

    Is that acceptable to you? If not, please let me know immediately.
    Sincerely,
    Joe Goodnight


    **********************************************************
    Joseph W. Goodnight
    Deputy Public Defender
    (775) 337-4839
    jgoodnight@washoecounty.us
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
    confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
    000262
    are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
    information is strictly prohibited.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, May 02, 2012 2:28 PM
    To: Goodnight, Joseph W
    Subject: FW: release of information to my attorney
    Joe,

    Here is Yassars assistants update. I am in favor of a global resolution. regarding mental health court, do they attemt to
    take over ones medical care or second guess ones doctor on health care matters? what is the worst case scenario with mental
    health court? lets say one does not do well in it, does that defendnat then get tried in justice court as they would have
    before entering mental health court? can the mental health court sentence one to jail?

    thanks,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

    > From: megan@ascentreno.com
    > To: ZachCoughlin@hotmail.com
    > Subject: RE: release of information to my attorney
    > Date: Wed, 2 May 2012 14:22:06 -0700
    >
    > Zach,
    > I have not had time to type up the letter due to the high volume of patients and calls in the office. I will get to the letter as soon as I get a chance . The
    attorneys office did call prior to you showing up in the office and due to that I did not have a release to talk with them regarding your diagnosis or
    treatment I told them I would have to get that first.
    >
    > Megan Sredy
    >
    > Megan Sredy
    > Patient Coordinator
    > Ascent NBI & TMS Center
    > 540 West Plumb Lane, Suite 1A
    > Reno, NV 89509
    > Phone (775) 322-4666; Fax (775) 322-4747
    >
    >
    > IMPORTANT:
    > This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for
    the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately, and delete
    the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other
    than the intended recipient is prohibited.
    >
    >
    >
    > -----Original Message-----
    > From: zach coughlin [mailto:ZachCoughlin@hotmail.com]
    > Sent: Wednesday, May 02, 2012 2:06 PM
    > To: ecek@ascentreno.com; megan@ascentreno.com
    > Subject: release of information to my attorney
    >
    > From: zach coughlin <ZachCoughlin@hotmail.com>
    > Subject: release of information to my attorney
    > Phone: 7753388118
    >
    > Message Body:
    > ----------------------
    >
    > My attorney sent me the following earlier today
    >
    > > Mr. Coughlin,
    > > I have not received anything from Dr. Yassar's office. I called again and left a message with them to contact me regarding the release. I'd like
    confirmation of the diagnosis today so I can submit your MHC application (again, due on Wednesday for staffing/acceptance meeting on Friday). Would you
    like me to try submitting your application without the diagnosis? Perhaps this would achieve a conditional acceptance pending receipt of the diagnosis. Let
    me know.
    > > Sincerely,
    > > Joe Goodnight
    > >
    > > PS - I don't know about your second question regarding RMC contact.
    > >
    000263
    > > **********************************************************
    > > Joseph W. Goodnight
    > > Deputy Public Defender
    > > (775) 337-4839
    > > jgoodnight@washoecounty.us
    >
    >
    >
    >
    >
    > Note, above is Joe Goodnights telephone number and email.
    >
    >
    >
    > --
    > This mail is sent via quick contact form on Ascent Reno Psychiatry http://ascentrenopsychiatry.com
    >
    --Forwarded Message Attachment--
    Print
    RE: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Mon 2/27/12 3:27 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Mr. Coughlin:

    E-mail works well for me.

    Keith Loomis

    Close
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, February 27, 2012 7:56 AM
    To: keithloomis@earthlink.net
    Subject: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?

    hi, i guess Mr. Loomis was appointed as my 3rd defense attorney in RMC case 11 cr 26405. I have not heard anything about this case, and
    the RMC indicated they had nothing scheduled. Please communicate with me only via email or fax please, having issues with my mail
    incident to domestic violence committed against me my fax is 949 667 7402. thanks,
    Zach Coughlin
    court date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Mon 3/05/12 4:09 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Mr. Coughlin:

    I have requested that court set your trespass case for trial in about 30 days. I will let you know the date and time as soon as I know.

    Keith Loomis
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)
    000264
    Sent: Wed 3/07/12 4:36 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin:

    On what grounds, other than those already set forth in your existing motion, do you believe a motion to dismiss should be filed?

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 07, 2012 12:45 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date

    Mr. Loomis,
    Please copy me on any and all correspondences, filing, or other documentation or verbal requests,
    correspondences, etc. that you submit to the Court, including the one you reference below.
    Please do not follow Taitel's tact of agreeing to requests or failing to oppose motions without
    even attempting to obtain my permission to in advance thereof.
    I would like for you to draft a Motion to Dismiss in this case for me review.
    Thanks,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: court date
    Date: Mon, 5 Mar 2012 16:09:19 -0800
    Mr. Coughlin:

    I have requested that court set your trespass case for trial in about 30 days. I will let you know the date and time as soon as I know.

    Keith Loomis
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Fri 3/09/12 10:14 AM
    To: zachcoughlin@hotmail.com
    No worries. Made me laugh.
    000265

    Couple of questions:

    Did you file an appeal from Justice of the Peace Sferrazzas eviction order?
    If yes, has it been resolved?

    Did Sferrazza announce at the close of the hearing on the 25
    th
    that he was granting the eviction and ask Hill/Baker to provide a written order?

    Did you ever see the eviction order posted by WCSO
    If yes, when?

    What is relevance of personnel files of Carter or Lopez?

    How is Dr. Merliss testimony material to the defense of this case?

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 08, 2012 12:46 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date

    Dear Mr. Loomis,


    I apologize Sir for what I am sure comes across as rudeness on my part. You seem like a good
    guy, and you have great hair. I simply don't have time, money or energy to do any of this the
    polite way given the "uniqueness" of this situation....Please just know I mean you no disrespect.
    Would you please file a request or Motion for the Personnel File of RPD Officer Chris Carter and
    Sargent Monica Lopez as well as supboena from the RPD all the volumns of crap Richard Hill has
    given them on this in addition to noticing the court and City Atty as to Richard HIll being a
    witness, subpoena him (though the earlier continuance would appear to imply he already is) AND
    SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO CAN GET HIS OUT DOWN HERE FOR
    THE TRIAL AND A DEPOSITION PRIOR THERETO, ETSPECIALLY CONSIDERING THAT THE VARIOUS
    POLICE REPORTS AND MOTIONS FOR ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE
    WAS AT THE PROPERTY IN THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY
    PUENTES GOT YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT
    CLEARLY). iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON
    ME, THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT.
    000266
    ALSO PLEASE FILE A MOTION TO dismiss based upon denial of right to a speedy trial, spoliation of
    evidence, etc....
    PEACE
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

    Trial Date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Fri 3/09/12 10:44 AM
    To: zachcoughlin@hotmail.com
    1 attachment
    Coughlin Trial Setting.pdf (771.8 KB)
    See attached
    RE: Trial Date
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Mon 3/12/12 9:26 AM
    To: zachcoughlin@hotmail.com
    I can do that if there is a good reason to vacate the date. What is the reason?

    Keith
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 6:28 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Please file something with the court seeking to vacate that trial date and explaining that you failed
    to even once consult with your client prior to setting it.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: Trial Date
    Date: Fri, 9 Mar 2012 10:44:17 -0800
    See attached
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Mon 3/12/12 10:02 AM
    To: zachcoughlin@hotmail.com
    000267
    This e-mail is sent to address the grounds you identified as forming the basis of a motion to dismiss. As you know there is both a constitutional right and
    a statutory right to a speedy trial. This case is nowhere close to a violation of the constitutional right to a speedy trial. The statute does provide for a
    right to trial within 60 days of arraignment in municipal court. NRS 178.556(2). In this circumstance the court may dismiss the complaint. The
    statute requires, however, that the trial not have been postponed at the request of the defendant. It is my understanding that the January 10, 2012, trial
    date, was postponed at your request. If that is true then there are not grounds to dismiss on the basis of a violation of a right to speedy trial.

    Dismissal based on spoliation is a civil concept. It has not been applied to criminal cases in Nevada as of yet. See Higgs v. State, 126 Nev. Adv. Opn 1
    (2010). Rather defendants in criminal cases are protected from the loss of evidence in the hands of the prosecution by the doctrine of due process.
    Consequently you might have a basis to request dismissal if the City Attorneys Office lost evidence, in its possession material to the case. In such case
    if the City acted in bad faith or with connivance or if you were prejudiced by the loss then there may be grounds on which to base a dismissal. Please advise
    as to what evidence was lost and how it was lost.

    You have not identified any other grounds as a basis for dismissal. If you believe there are other grounds, let me know.

    Thanks

    Keith Loomis









    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 08, 2012 12:46 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date

    Dear Mr. Loomis,


    I apologize Sir for what I am sure comes across as rudeness on my part. You seem like a good
    guy, and you have great hair. I simply don't have time, money or energy to do any of this the
    polite way given the "uniqueness" of this situation....Please just know I mean you no disrespect.
    Would you please file a request or Motion for the Personnel File of RPD Officer Chris Carter and
    Sargent Monica Lopez as well as supboena from the RPD all the volumns of crap Richard Hill has
    given them on this in addition to noticing the court and City Atty as to Richard HIll being a
    witness, subpoena him (though the earlier continuance would appear to imply he already is) AND
    SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO CAN GET HIS OUT DOWN HERE FOR
    THE TRIAL AND A DEPOSITION PRIOR THERETO, ETSPECIALLY CONSIDERING THAT THE VARIOUS
    000268
    POLICE REPORTS AND MOTIONS FOR ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE
    WAS AT THE PROPERTY IN THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY
    PUENTES GOT YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT
    CLEARLY). iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON
    ME, THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT.
    ALSO PLEASE FILE A MOTION TO dismiss based upon denial of right to a speedy trial, spoliation of
    evidence, etc....
    PEACE
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

    RE: Trial Date


    From:Keith Loomis (keithloomis@earthlink.net)You moved this message to its current location.
    Sent: Wed 3/14/12 2:35 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    My obligation under Nevada Rule of Professional Conduct 1.2 is to abide by a clients decision concerning the objectives of representation and, as
    required by Rule 1.4 to consult with the client as to the means by which the objectives of representation are to be pursued. In a criminal case the lawyer
    shall abide by the clients decision, after consultation with the lawyer, as to plea to be entered, whether to waive jury trial whether the client will testify.

    Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any relevant limitations on the lawyers conduct when the lawyer knows that the client
    expects assistance not permitted by the Rules of Professional Conduct or other law.

    Under Rule 2.1. In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In
    rendering advice, a lawyer may refer not only to law but to other considerations such as moral economic, social and political factors, that may be relevant
    to the clients situation.

    Under Rule 3.1. A lawyer shall not 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 frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for a
    defendant in a criminal proceeding that could result in incarceration, may nevertheless so defend the proceeding as to require that every element of the case
    be established.

    Under Rule 3.2(a) and (b). A lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.
    The duty stated in paragraph (a) does not preclude a lawyer from granting a reasonable request from opposing counsel for an accommodation, such as an
    extension of time, or from disagreeing with a clients wishes on administrative and tactical matters, such as scheduling depositions, the number of
    depositions to be taken, and the frequency and use of written discovery requests.

    Under Rule 8.4(d) It is misconduct for a lawyer to engage in conduct which is prejudicial to the administration of justice.

    000269
    These, and others, are the professional rules I operate under in providing legal representation to you in case number 11 CR 26405, a case in which you are
    charged with the crime of trespass. It is my understanding that your objective in this criminal case is that you be acquitted of the crime of trespass. That
    is my purpose in representing you. I am happy to work towards that outcome to the best of my ability. It is my opinion, however, that much of what you
    ask to be done is not in compliance with the above rules. Accordingly, I will not be filing a motion to dismiss based upon NRCP 6(a) and (b), I see that
    argument as frivolous. I will not be proceeding with the summoning of an out-of-state witness (Merliss) unless you can establish his materiality to the
    defense. Nor will I be subpoenaing the personnel records of law enforcement personnel unless you can establish to my satisfaction why they are relevant to
    this case. I have no intention at this time of conducting any depositions in the case or sending requests for production of documents or interrogatories in
    the case. I see these actions as unduly burdensome on the judicial system, and unwarranted by anything you have provided to this point. I also see them
    as frivolous and an attempt to utilize the criminal justice system to accomplish objectives not relevant to my purpose in representing you.

    If you are dissatisfied with the limitations I perceive to exist regarding my representation of you, you are welcome to terminate my representation of you.
    You may then ask the Court to appoint a new lawyer to represent you.

    It is my understanding that Deputy Machem will be testifying in the case along with Richard Hill and Casey Baker.

    I do think that there are some interesting angles to the case upon which a defense can be based and I will be pursuing those angles. I have asked you in
    previous e-mails to provide information which I believe will be helpful to the defense of your case.

    I advise you that the City has offered to recommend time-served as a sentence if you enter a no-contest plea to trespass. It is also my understanding that
    you have other criminal cases pending in both Reno Justice Court and in the Second Judicial District Court of the State of Nevada. It is my understanding
    further that all of the criminal cases can be resolved in a single plea to a misdemeanor offense if you will obtain psychological counseling. It is my
    obligation to inform you of the availability of these resolutions to the present criminal case in which I provide representation. I will, of course, abide by your
    decision as to whether to accept these resolutions or not.

    I note that there is a psychiatric evaluation scheduled for you in 2
    nd
    Judicial District Court Case No. CR12-0376 on April 3, 2012. The outcome of that
    evaluation could have an important impact on this case. I am asking that you authorize a release of the information contained in the evaluation to me so
    that I may determine what impact it could have on your behalf in this case.

    I remain prepared to represent you in the trespass case. I think that a trial of the case will be interesting. My representation, however, is circumscribed by
    the Nevada Rules of Professional Conduct.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, March 13, 2012 4:29 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Dear Mr. Loomis,

    In your motion to dismiss, I would like you to really focus on and set forth to the court the fact that the eviction
    order needed to be served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules of practice. The provisions of NRS,
    Nevada Rules of Civil Procedure and Nevada Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent
    with the provisions of NRS 40.220 to 40.420, inclusive, apply to the proceedings mentioned in those sections.

    The language about "removing the tenant with in 24 hours of receipt of the order" is only applicable to those situations where the tenant does
    not file a Tenant's Answer or Tenant's Affidavit. I did file such a Tenan'ts Affidavit, and litigated the matter thoroughly. In those
    situations, NRS 40.400 requires NRCP to apply, specifically NRCP 6(a) and 6(e), and clearly WCSO Machem (please subpoena and identify
    as witnesses Mary Kandaras, Esq. of the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO Civil Division supervisor Liz Stuchell
    for the trial in this matter, and further send out a request for production and subpoena duces tecum to the WCDA and the WCSO askign them
    000270
    to specify, in writing and in detail, the exact procedures and policies in place with respect to the service and conducting of such lockouts (ie,
    not default lockouts where there is not a summary eviction hearing, but one's like the present one, where there was a Tenant's Answer and
    hearing held, etc....). Be sure to ask whether the are aware of what "personally served" means, and whether they mail the Orders on top of
    merely posting them to the door. Further, I have been told that the WCSO has a policy or penatly system in place whereby the deputies
    must get these lockouts performed "within 24 hours of receipt of the order" the receipt being the WCSO's receipt, and not the tenant's
    receipt. I don't ncessarily read the statute that way, but....the WCSO policy and punishment system would be at least some indication of
    what the legislature meant (I guess, but I dont' really think so, though, you will note that Hill was left with nothing but citing to the "usual and
    customary practice of the WCSO" in serving the Eviction ORders and performign lockouts, I believe, because the law does not contain much
    to support Hill's contention and therefore he wishes to see the WCSO "customary practices" being given the weight of law.

    Please see some specific selections attached from the eviction matter. I know, I know, you want to curtail the scope of your representation
    to an immaculate degree....but Hill can clearly be seen in his various Motion to Show Cause, State Bar Grievances, Temproary Protection
    Order Applications, etc., etc., to be a punk who doesn't much like competing on an even playing field, like any good private schooler, he
    would rather sick an attack dog on somebody than get in the octogon and go toe to toe mentally. Regardless, Hill shows a continual desire
    to subvert NRCP 6(e), which applies to service of documents filed elecronically in the Second Judicial District Court. He would rather
    withhold opposing counsels computers, laptops, client files, driver's license, etc. The last thing he wants is to go argument for argument,
    research for research, writing for writing. Private school and daddy's pleading bank. Hill files a Motion to Show caue allegeing Coughlin
    subvreted an Order that was filed on January 11th, 2012 with Couglin's action of January 12th, 2012. Under NRCP 6(e), the Order Denying
    the TRO had not even been served yet, and there has been no indidcation that Hill gave the Order at the town dump to anyone other than an
    RPD Officer.

    Further, it is not all that clear why Hills Motion for ORder to Show Cause deserves a full blown hearing when D7 does not indicate a hearing
    will be accorded to the appeal. This is particularly suspect given that Anvui sets forth that appeals in summary eviction matters are done on
    a trial de novo basis.
    There are a number, but how about your complete lack of communication with me prior to so setting that date.
    How about Mr. Taitel and Mr. Puentes's failure in this matter and the prejudice to my case so created? How
    about your failing to identify yourself as the public defender to a room full of defendants in jail at the arraignment?
    There are other reasons as well, including, but not limited to, your resistance to subpoena the materials I have and
    am requesting.

    I wish for you to subpoena the personnel files of both RPD Sargent Monica Lopez and Officer Chris Carter. I wish
    for you to list Dr. Merliss as a witness and subpoena his appearance and appropriately notice the City of Reno in
    that regard, same goes for Richard Hill and Casey Baker (Baker, by letter dated November 10th, 2011 demands the
    full rental value for the property as "storage" under NRS 40.253, while also asserting he will go after moving and
    inventory costs, in addition to Hill's contractor Phil Stewarts later ridiculous charges and perjury. Please subpoena
    Stewart as well.

    Most importantly subpoena Washoe County Sheriff's Office Deputy Machem to testify and serve a subpoena
    dueces tecum, requests for production, and interrogatories seeking records and responses from the WCSO as set
    forth in the letter I sent Liz Stuchell (see attached) on or about February 10th, 2012. You see, the WCSO and
    Deputy Machem may be committing a fraud upon the public by repeatedly filing affidavits of service that attest to
    personal service where Liz Stuchell, of the WCSO admits that they clearly do not know, or choose to "remix" the
    legal meaning of "personally serve".

    Further, please inform the City of Reno and appropriately notice the same as to the existence and intent to offer
    into evidence a video of Richard Hill, Esq., admitting that he and his firm, on behalf of Dr. Merliss, were withholding
    the accused personal property, in addition to the client's files from the former commercial lease home law office
    of the accused and asserting a lien, under NRS 40.253 for "storage", however, as the video tape shows, Hill admits
    to charging the undersigned the same $900 per month rent as was charged for the "full use and occupancy" of the
    premises at 121 River Rock St., Reno, NV 89512. Hill further demands that property be removed in a certain
    order, regardless of whether his articifically inflated lien was paid or not. Additionally, Hill committed fraud upon
    the court in a number of instances and filed false police reports wherein he alleges that he agreed to or otherwise
    made available to the accused items such as the accused's clients files (and for a time wallet and state issued
    driver's license) where, clearly, without requiring any payment by the accused, however, clearly, the facts show that
    Hill never actually lived up to those assertions and repeatedly failed to show provide such items absent payment of
    his artifically inflated lien.

    Further, I wish for you to divulge and provide notice that it is available for pickup and that we intent to introduce
    into evidence a video of RPD Sargent Monica Lopez admitting that she and RPD Officer Carter did not identify
    000271
    themselves as police officers or otherwise ask the accused to leave 121 River Rock St. on the date of the arrest prior
    to Merliss opening the door to the basement. This is apparently in direct contradiction to the sworn filings made
    by Richard Hill, Esq. in his affidavits attached to his various Motions to Show Cause, the Reply to Opposition
    thereto, Opposition to TRO, etc., etc. (in RJC Rev2011-001708 and the appeal in CV11-03628). For that reason
    alone Merliss' presence is required. He was a precipient witness and you are asking me why he should be there?
    You have a duty to zealously advocate on my behalf, Mr. Loomis. You are paid, by the public, to do so.
    Please divulge any prior associations you have with anyone employed by or workign as an independent contractor
    with the RMC and or the Reno City Attorney, including anyone you went to law school with or attended the same
    law school as, within a 5 year period.

    Further, I wish for you to file a motion seeking a mistrial or otherwise requiring the recusal of the RMC and further
    disclosing why it is that Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth
    recuse Judge Dilworth?) in one case, without detailing why exactly, while Judge Gardner apparently is intent on
    remaining on in 11 CR 26405, despite the fact that an apparent conflict exists, one which he only disclosed upon
    prompting from the accused, with respect to Judge Gardner's very recent employment with the Reno City
    Attorney's office and the existing and or brewing litigation (or, at least, possible litigation) between the accused and
    the City of Reno, Reno City Attorney, and possibly, the RMC.

    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473

    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: RE: Trial Date
    Date: Mon, 12 Mar 2012 09:26:35 -0700
    I can do that if there is a good reason to vacate the date. What is the reason?

    Keith
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 6:28 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Please file something with the court seeking to vacate that trial date and explaining that you failed
    to even once consult with your client prior to setting it.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: Trial Date
    Date: Fri, 9 Mar 2012 10:44:17 -0800
    000272
    See attached
    RE: i was evicted 3 15 12, i need a continuance
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Wed 3/28/12 2:03 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    This message is sent to address issues raised in the e-mail you sent on 3-26-12.

    1. Please note that you are free to send the communications you send to me, to anyone else you desire. You should be aware that
    sending your communications to other parties will cause your communications to me to lose their attorney-client confidentiality.
    2. For what specific purposes do you need a continuance? A continuance purely for the purpose of delay is not a proper reason for a
    continuance.
    3. Whether you are entitled to e-mail the Reno Municipal Court is not my concern. That is a problem to be addressed between you and
    the Court.
    4. Ms. Drake is no longer the attorney handling your case for the Reno City Attorneys Office. Your case is now being handled by
    Christopher Hazlett-Stevens, Esq.
    5. In response to your question regarding the weaknesses of the trespassing case I offer the following:
    a. The complaint is deficient in that if fails to set forth the elements of the crime of trespass. It fails to identify whether your
    presence on the premises was for the purpose to vex or annoy the owner or occupant of the premises or whether it was an entry onto
    the premises after a warning not to so trespass. This is probably easily remedied by an amendment at the time of trial.
    Nevertheless these are alternative theories on which a trespass case can be pursued and the defendant is entitled to know on which
    theory or theories a case is being prosecuted in advance of showing up for trial.
    b. You filed an appeal on October 19, 2011, apparently, of the order made by Justice of the Peace Sferrazza on October 13, 2011.
    That order denied your request for a continuance and granted summary eviction unless you filed a deposit with the court. Typically
    the courts lose jurisdiction to rule on other matters in the case once an appeal is taken. It is clear from the court records that this
    appeal was pending before the Second Judicial District Court at the time the court held a hearing on the unlawful detainer on October
    25, 2011. It may well be that the Justice Court lost jurisdiction to hold the eviction hearing while the appeal was pending.
    c. I am working on some other thoughts.
    6. If you are dissatisfied with the way I am representing you, you remain free to seek a new attorney.
    7. Another chuckle regarding my ownership of strip clubs. I dont own or have any ownership interest in any strip clubs, brothels,
    adult book stores or movie houses. I guess that leaves me free to moralize.
    8. I still dont see the importance of Dr. Merliss. The request for payment of an amount equal to rent, was for storage of your
    personal property. You are entitled to contest the amount of the storage fee, which you did. There is no credible evidence anywhere which
    suggests that anyone intended to reopen or create a new tenancy allowing you to retain possession of the premises.
    9. Dr. Merliss is an out of state witness. In order to compel his appearance, his testimony must be material. NRS 174.425(1). It does not
    appear that his testimony is material under the information you have provided Further, under NRS 174.425(2) he is entitled to be paid his
    subsistence and travel expenses incurred in coming to Nevada. Are you prepared to pay those expenses in advance of his coming to Nevada?
    10. I dont intend to fax or e-mail to you, your full file in this case. You already have everything with the exception of a couple of items
    which I mailed to your old address. I will send them again to your new address. If you want to review the file you are welcome to do so at
    my office. If you want copies of anything in the file you may mark the items. After giving you a cost estimate, for which I require payment in
    advance, we will provide you with copies of the marked items.

    Keith Loomis
    000273


    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 10:33 PM
    To: keithloomis@earthlink.net; stermitz@sbcglobal.net; jmd@randazza.com; jboles@callatg.com; kristiemanning@yahoo.com;
    kadlicj@reno.gov
    Subject: i was evicted 3 15 12, i need a continuance

    Dear Mr. Loomis,


    I was wrongfully evicted on 3 15 12, and I need a continuance in the criminal trespass matter that
    you set overly quickly against my express wishes anyway. My ability to collect evidence
    necessary to my defense and otherwise prepare has been adversely affected. Additionally, I don't
    feel as though you are performing in an appropriate manner as defense counsel, but rather you
    seem stuck in your prosecutorial ways, too quick to look for any excuse whatsoever to bury one's
    case, so I think you have forced a split here, which further prejudices my case and augers towards
    a continuance. Please move for one immediately and copy me on my entire file by email and
    fax please. Additionally, please seek clarification from the RMC as to whether I am allowed to
    ever send an email to renomunicrecords@reno.gov. Please note, today, Judge Flanagan denied
    Richard Hill's latest frivolous motion.
    Did you know that Kevin Kelly, of the State Bar of Nevada's Character and Fitness Committee for at
    least the last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
    http://www.reviewjournal.com/lvrj_home/2002/Mar-06-Wed-2002/news/18241452.html
    I know I always like my three hour tours of heavy handed moralizing from someone who runs a
    monolithic strip club in Las Vegas.
    You are on the State Bar of Nevada's fee dispute committee, aren't you Mr. Loomis? Do you
    own any strip clubs?
    Mr. Loomis, which of the elements of the trespass charge RMC 8.10.040 do you feel are weakest
    for Deputy City Attorney Jill Drake, whom I informed about the admission by Reno PD Officer
    Chris Carter that Richard G. Hill, Esq. bribes him, but for which Ms. Drake indicated a complete
    lack of interest and expressed that she would not be following up on that report of bribery of a
    RPD Officer. Mr. Kadlic, please place a copy of this correspondence in Jill Drake's personnel
    file. Additionally please place one in Allison Ormaa's personnel and employment file too, in
    addition to Deputy City Attorney Dan Wong's employment file, as all three of those Deputy City
    Attorney's were provided that report and all three indicated they did not care and had no
    intention of following up or otherwise investigating the admission by RPD Officer Chris Carter that
    Richard G. Hill, Esq. bribed him. I think the failure to follow up by any of these 3 Deputy City
    Attorney's relates to any future negligent hiring, training, and supervision claims that the Reno
    City Attorney may need to defend against when representing the Reno PD like it did in the Eeof
    v. Pitsnogle case:
    http://www.lvrj.com/news/reno-official-accused-of-witness-tampering-116586528.html
    000274
    You know, Deputy City Attorney Ormaas's decision to push on for that $70
    traffic ticket is looking more and more interesting. \\
    Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his
    understanding of the extent to which his attorney, Richard G. Hill, Esq. had
    effectively rescinded any eviction Order by sending a bill for the same
    amount as full use and occupany of the location at 121 River Rock St. goes to
    the substance of the elements found in RMC 8.10.040 as well as the
    credibility of both Merliss and Hill.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: i was evicted 3 15 12, i need a continuance
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Thu 3/29/12 4:59 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin:

    I previously sent you the setting slip for your trial in this matter by e-mail on March 9, 2012. That setting slip set your trial for April 10, 2012 at 8:00
    a.m. in Dept 2 of the Reno Municipal Court.

    I am available to meet. Best times for me next week are Monday afternoon, Thursday afternoon or Friday morning. Let me know which is best for
    you and I will set aside time for an appointment.

    No I am not going to send you my case plan in writing with reference to citations and copies of legal research etc. (You might take cognizance of the
    fact you sent my last discussion of your case to the Reno City Attorneys Office-notoriously poor strategic and tactical move on your part).

    No skin in the game.

    Keith Loomis


    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 12:04 PM
    000275
    To: keithloomis@earthlink.net
    Subject: RE: i was evicted 3 15 12, i need a continuance

    Mr. Loomis,
    Can you please indicate to me, via email, if there is a Trial Date or any other court date set in this
    matter, and, if so, provide the Date and Time. I would like to meet with you, when are you
    available to do so? Also, please indicate in writing what your plan is for this case and what you
    have done to zealously advocate on my behalf, including specifics regarding any legal research
    you have culled (and please provide citations and copies of the research gathered to me,
    preferably by email). In your duties on the State Bar of Nevada's Fee Dispute Committee, have
    you ever had a fee dispute from a client of a public defender? Do public defenders have any
    skin in the game?
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC
    seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing
    RPD on bribery and retaliation
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Thu 3/29/12 5:05 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    There has not been, as of yet, a trial as to which a mistrial could be declared in this case. A motion for mistrial is consequently premature.

    I am only representing you as to your trespass case over which Judge Gardner is presiding. I am not representing you in regards to any other criminal
    case over which any other Reno Municipal Court Judge is presiding. If you believe there are grounds to seek the recusal of Judge Gardner in regards
    to your trespass case, please identify what those grounds might be.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 2:44 PM
    To: keithloomis@earthlink.net
    Subject: FW: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court
    after cross examing RPD on bribery and retaliation
    Importance: Low

    Dear Mr. Loomis,


    Please file a motion for a mistrial and a motion to conflict out any RMC Judge from hearing any criminal case where I am a defendant.
    Thanks,
    000276
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: dgentile@gordonandsilver.com; renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com;
    defense@freeman-law.com; ed@npri.org; mkandaras@da.washoecounty.us; mark@markmausertlaw.com
    Subject: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after
    cross examing RPD on bribery and retaliation
    Date: Thu, 29 Mar 2012 14:39:17 -0700
    Dear City of Reno,
    Please place a copy of this in Marshal Coppa's and the other Marshal who transported me to jail
    on 2/27/12's employment/personnel file as he was the one who went into a backroom of the "Sally
    Bay" at the jail after whispering in the WCSO Deputy Cheung's ear. Please ask him about the bag
    with the micro sd card, the various contradictory statements made by RMC staff, Reno Marshals,
    and WCSO staff with respect to the chain of custody of the seized property, with particular
    attention focused on Marshal Harley's statements concerning any micro sd card, Debi Campbell's
    assertions in that regard, what Pam Willmore heard WCSO Deputy Hodge admit with respect to
    the WCSO retention of the micro sd and other property, comparing that with any recordigns of
    that conversation that may exist, and further referencing the statements of Ms. Campbell,
    Cummings, and Beckman, while also reviewing any recordings made of telephone conversations
    with WCSO Detention Facility Staff shortly after Coughlin was released from jail on
    Please find new attachments herein including the emailed responses of WCSO agents
    Cummings, Debi Campbell, and Trish Beckman.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com
    Subject: City of Reno Marshal Division hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing
    RPD on bribery and retaliation
    Date: Thu, 29 Mar 2012 14:05:54 -0700
    Dear City of Reno and Mr. Jeanney,
    I was told by the Washoe County Sheriff's Office to call the City of Reno Marshal's division to
    inquire about the return of the personal property that was seized from me incident to a 2/27/12
    arrest for summar contempt during the traffic trial in 11 tr 26800 before Judge Nash Holmes. I
    called the number held out as the Marshals Division contact number http://reno.gov/index.aspx?page=223
    And a "Bill" answered the phone, was evasive, indicated he did not work for the Marshal's division,
    would not give me any contact information for a Marshal, any Marshal, told me he wasn't going to
    answer me stupid questions, and hung up on me.
    I called back and I believe it was Marshal Harley who answered (though I am not sure) and he
    answere the phone in an unprofessional manner, guessing as to my identity in some show of
    menace. Rather than tjust answer the phone like a professional and provide me the number
    for Marshal Dayton, as I was requesting, this individual refused to provide the number, answered
    the phone on a "gotcha" type way where there was nothing to "gotcha", then hung up the phone
    000277
    on purpose after declaring that he would not give me Marshal Dayton's number or take a
    message. Please place a copy of this correspondence/complaints in "Bill" of court security for the
    Reno Munic Court, and Marshal Harley's file and follow up this grievance. I am available to
    comment on this unprofessional conduct further. Please also find attached other recent
    complaints I have submitted regarding the Marshal Division and place them in the individual's
    complained of employment/personnel files. There will be no ability to allege a lack of
    knowledge of this conduct in any future negligent hiring, training, and supervision lawsuit incident
    to any misconduct alleged. I a requesting that a full scale investigation/inquiry be conducted
    pursuant to the various conflicting, and inconsistent statement made with respect to the seized
    personal property (inlcuding my phones, etc.). You might want to consider whether any Washoe
    County Sheriff's Deputies have made statements that will conflict with anything the City of Reno
    may say from hear on out. Given problems associated with my recently being adjudge a victim
    of domestic violence (my vulnerability in that regard made moreso by Judge Nash Holmes seizing
    my cell phones and attempt to have my incomed reduced through jeopardizing my law license,
    etc.) please correspond with my in writing only and only by email and or fax.
    Sincerely,
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    --Forwarded Message Attachment--
    Name JAMES MENZEL
    Position
    Marshal
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost of retirement benefits is
    included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $60,609.42
    Detail page for JAMES MENZEL
    Overtime and
    Callback $622.67
    Collected
    Total Pay $63,750.96
    Benefits
    $22,425.49
    Accumulated
    Total Pay &
    $86,176.45
    Benefits
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    000278
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JOEL HARLEY
    Name JOEL HARLEY
    7821 - Marshal
    Position
    Reno
    Year 2010
    Base Pay $85,323.07
    Overtime and
    $6,755.56
    Callback Collected
    Other Pay $478.65
    Total Pay $92,557.28
    Benefits Accumulated N/A
    Total Pay & Benefits $124,126.82
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JUSTIN ROPER
    Name JUSTIN ROPER
    Position
    7819 Marshal Commander
    Reno
    Year 2010
    Base Pay $107,914.00
    000279
    Overtime and
    $0.00
    Callback Collected
    Other Pay ($2,697.89)
    Total Pay $105,216.11
    Benefits Accumulated N/A
    Total Pay & Benefits $145,144.36
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Name JAMES MENZEL
    Position
    Marshal
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost of retirement benefits is
    included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $60,609.42
    Detail page for JAMES MENZEL
    Overtime and
    Callback $622.67
    Collected
    Total Pay $63,750.96
    Benefits
    $22,425.49
    Accumulated
    Total Pay &
    $86,176.45
    Benefits
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    000280
    --Forwarded Message Attachment--
    Detail page for JOEL HARLEY
    Name JOEL HARLEY
    7821 - Marshal
    Position
    Reno
    Year 2010
    Base Pay $85,323.07
    Overtime and
    $6,755.56
    Callback Collected
    Other Pay $478.65
    Total Pay $92,557.28
    Benefits Accumulated N/A
    Total Pay & Benefits $124,126.82
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JUSTIN ROPER
    Name JUSTIN ROPER
    Position
    7819 Marshal Commander
    Reno
    Year 2010
    Base Pay $107,914.00
    Overtime and
    Callback Collected
    $0.00
    Other Pay ($2,697.89)
    Total Pay $105,216.11
    000281
    Benefits Accumulated N/A
    Total Pay & Benefits $145,144.36
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    RE: request for a pre trial motion and bail motion
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Tue 8/07/12 9:55 AM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Zach

    Why dont you move to represent yourself. That way you will be completely satisfied with the services you provide yourself and can do all of the
    things you believe are necessary.

    If you want me to continue to represent you, what I asked you to provide to me was a description of the events which lead to the charge of disturbing
    the peace. I still need that description.

    Keith Loomis















    000282

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, August 06, 2012 3:54 PM
    To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
    Subject: request for a pre trial motion and bail motion

    Dear Mr. Loomis and City Attorney Kadlic and Deputy City Attorney Drake,

    I am writing to request that you file some motion to alter, amend, reconsider, set aside, or modify my bail in the case stemming from my JUly 3, 2012 arrest
    for distrubing the peace, failure to provide proof of insurance, and failure to secure a load. I am writing to request that you file a pre trial motion (Motion to
    Dismiss, request for a pre trial motion and bail motion, and motion to supress police report based upon the DTP arrest occuring for alleged conduct outside the
    officer's presence). If you will not file these motion (and please provide me a draft of such motions for my review prior to filing them as well as prior to
    making any communication on my behalf to either the RMC or the City of Reno Prosecutor), please provide me a written indication of your rationale for so
    refusing, and then please file a Motion to Withdrawal as soon as practicable. I ask this respectfully.

    The police showed up to the hearing, yet I was not noticed of that fact in advance, or of the hearing itself. Further, Judge Gardner explicilty indicated he
    was basing his decision to raise the bail based upon "public safety" and "concern for the defendant's safety", which are impermissible rationale for so increasin
    one's bail.

    NRS
    178.498. Many courts use a bail schedule to determine the amount, but note the
    initial amount can be increased if good cause is shown. NRS 178.499. Additionally, in
    determining the amount of bail, the judge should look at the following factors (NRS
    178.498):
    The nature and circumstances of the offense charged
    The defendants financial ability to post bail
    The defendants character; and
    The factors listed in NRS 178.4853.
    Bail can not be excessive. U.S. Const. Amend. VIII. It should be limited to a
    reasonable amount designed to ensure the defendants presence in court. It should not
    be a corrective or preventative detention device.

    NRS 178.484. The Court should take care in imposing any restrictions on a defendants constitutional rights (i.e.,
    search and seizure) and only imply such restrictions if warranted by the underlying facts
    of the alleged crime. Section 11 of NRS 178.484 describes the document that must
    be signed by the defendant before he/she can be released on bail.

    My bail hearing contained what seems to be an impermissible coercive attempt to condition my release or the possibility thereof upon my providing
    confidential medical records (Lake's Crossing etc) to the Reno Municipal Court, even where the same judge presiding over the bail hearing found me
    competent enough to face a criminal trepass trial less than two weeks before teh bail hearing in 11 CR 26405.

    The friend of mine who posted my bail, Jared Swanson, has a serious form of cancer and a one year old baby. I request a reduction of the bail for his
    benefit and for the proof of insurance charge to be dismissed, as (and I am trying to avoid this in any way I can), if I am rearrested, such a proof of insurance
    charge may present another basis for imposing an unduly burdensome bail upon me, as it did on July 5th, 2012 where, despite my having produced a legible
    pdf copy of my proof of insurance card on my large screened zoomable smart phone, Officers Weaver and Dye still charged me with that violation, and the
    bail was subsequently increase. Further, none of the events or accusations forming the basis of the distrubing the police charge occurred in the officer's
    000283
    presence, and the police report contains no indication whatsoever that the arrest was made based upon NRS 171.1771. I provided Officer Weaver my
    driver's license prior to the arrest. I did not
    refuses to give a written promise to appear in court as provided in NRS 171.1773.

    When a person is believed to have committed a misdemeanor offense, the peace officer has the discretion to
    either issue a citation or arrest and detain the person. NRS 171.1771 states that a person can be arrested if
    his identity is questionable or if the peace officer does not believe the person will appear in court. A person
    can also be arrested for a misdemeanor offense if a warrant has been issued.

    Additionally, I am requesting that you file a Motion to Dismiss the Disturbing the Peace charge based upon a lack of evidence and or insufficiency of pleading
    in that the allegations do not amount to a prima facie case of a DTP violation. Further, please subpoena and or collect the Protection Order application filed
    by Milan Krebs on July 5th, 2012, and interview Krebs as to why he mentions Coughlin often carrying around a large knife in a menacing manner in that
    protection order application, yet completely failed to mention that in his July 3rd, 2012 police report. Additionally, please determine why Kreb's TPO
    appliication has a different style of handwriting on the caption compared to the descriptive sections, indicating someone pushed the filing of the TPO on Krebs,
    perhaps his employer, Northwind Apartments or the RPD, which has in the days preceding the arrest threatend to arrest Coughlin for criminal trespass if he
    returned to any part of the premises of Northwind Apartments, in consideration of Coughlin's eviction from unit 29, despite the fact Coughlin still had a valid
    right to go to his other two rentals, units 45 and 71, in addition to the fact that Northwinds essentially withdrew or rescinded its June 28th, 2012 eviction of
    Coughlin by posting an Amended 5 Day Unlawful Detainer Notice on unit 29 on June 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada
    Courts Services that the July 14th, 2012 5 Day notice was not "personally served" (NCS's R. Wray lied about effecting personal service, as he could not
    possibly have verified someone of "suitable age and discretion" was within the windowless room with a metal door closed and locked and where no Wray
    admits that he received no verbal response from the unit or anyone therein upon his knocking on the door and or attempting to break into the unit, please see
    Soldal v. Cook County in that regard, a US S. Ct case) and therefore Coughlin would have had until at least noon on July 28th, 2012 to file a Tenant's Answer,
    whereas the eviction/lockout/arrest of June 28th, 2012 took place two hours before noon at 10 am).

    Additionally, RPD Officer Weaver had previously attempted to break into one of my rentals at Northwind at a time when he lacked a warrant and or an exigent
    rationale for doing so, much less an eviction Order. I just want this case to be dismissed and to try to move on in life, and difuse the tensions incident to
    this case.

    I did not disturb the peace at Northwinds as alleged, nor did I make the threats Kreb's accuses me of or stalk him or follow him in a threatening manner at
    any time. Additionaly, I never broke into nor did I ever attempt to break into Krebs' truck, and in fact, I filed a police report in June 2012 reporting
    extortionate threats by another maintenance man at Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne Jakob, wherein they
    threatened to make such a spurious allegation, but subsuquently refrained from doign so when it apparently occurred to them that I may have excuplatory
    video evidence disproving such an allegation as well as capturing their baseless and extortionate threats and accusations. Additionally, please subpoene the
    police reports I filed with the RPD and any emails I sent to any officers (including Weaver, Barnes, Sargent MIiller, LIeutenant Brown) and any reports of or
    recording of phone conversations I had with any of those RPD personnel. Further, please see the attached june 26th, 2012 email to the RPD, WCSO, RJC,
    Sparks Justice Court and others pointing out the insufficiency of the 5 day Notice drafted and posted by non-lawyers Nevada Court Services, in that under
    NRS 40.253 it listed the wrong forum for the tenant to file a Tenant's Answer, and under the Aiken decision of the Nevada Supreme Court and NRCP 60(b)(4),
    any lockout order stemming therefrom is void for lack of jurisdiction.

    NRS 171.136 When arrest may be made.

    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:...
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation
    or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;...
    (g) When the person is already in custody as a result of another lawful arrest; or

    000284
    6/08/12
    Krebs did not immediately arrest me under NRS 171.136(2)(d), nor was the DTP arrest for an offense alleged to have occurred in the officer's presence.

    the attached videos are of the incident on June 5th, 2012, not from July 3rd, 2012, but they support my contentions and the relevancy of subpoening the
    police incident reports and other documentation should this case not be dismissed, nolle prosequi, de minimis, etc....

    I will forward to you my emails to the RPD et all from June 26th, and July 2nd, 2012. I realize their tone was not a smart one to take or appropriate and am
    only sending them in hopes of having this matter dismissed. I do not have any interest in pursuing anything like Wheeler v Cross 344 Fed Apps 420 (
    (2008.

    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
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    000285
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    Sent: Mon 6/11/12 4:10 PM
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    1 attachment
    000286
    6/11/12
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    RE: request for a pre trial motion and bail motion
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Tue 8/07/12 4:25 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    You have already had two bail hearings. You are out on bail now. I decline to file a new request for a bail hearing.
    I will be out of town on vacation from Friday August 10 and will return on Monday Aug. 20. That makes attendance at a bail hearing problematic and
    unlikely to be heard before your trial.
    I do think the complaint fails to allege the charge of disturbing the peace. I will make the motion to dismiss it at the time of trial.
    000287
    The fact that the officer did not observe you committing a misdemeanor means he was not entitled to arrest you. You have a civil claim
    against RPD and the officer. That does not mean the charge of DTP is subject to dismissal.
    I will review the case involving Mr. Krebs and his request for a temporary protective order.
    I need your description of what happened on the 3
    rd
    of July. Will you provide it?

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, August 07, 2012 3:38 PM
    To: Keith Loomis
    Subject: RE: request for a pre trial motion and bail motion

    Are you refusing to file the motions o requested?


    -----Original Message-----
    From: Keith Loomis
    Sent: 7 Aug 2012 16:55:44 GMT
    To: 'Zach Coughlin'
    Subject: RE: request for a pre trial motion and bail motion
    Zach

    Why dont you move to represent yourself. That way you will be completely satisfied with the services you provide yourself and can do all of the
    things you believe are necessary.

    If you want me to continue to represent you, what I asked you to provide to me was a description of the events which lead to the charge of disturbing
    the peace. I still need that description.

    Keith Loomis












    000288




    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, August 06, 2012 3:54 PM
    To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
    Subject: request for a pre trial motion and bail motion

    Dear Mr. Loomis and City Attorney Kadlic and Deputy City Attorney Drake,

    I am writing to request that you file some motion to alter, amend, reconsider, set aside, or modify my bail in the case stemming from my JUly 3, 2012 arrest
    for distrubing the peace, failure to provide proof of insurance, and failure to secure a load. I am writing to request that you file a pre trial motion (Motion to
    Dismiss, request for a pre trial motion and bail motion, and motion to supress police report based upon the DTP arrest occuring for alleged conduct outside the
    officer's presence). If you will not file these motion (and please provide me a draft of such motions for my review prior to filing them as well as prior to
    making any communication on my behalf to either the RMC or the City of Reno Prosecutor), please provide me a written indication of your rationale for so
    refusing, and then please file a Motion to Withdrawal as soon as practicable. I ask this respectfully.

    The police showed up to the hearing, yet I was not noticed of that fact in advance, or of the hearing itself. Further, Judge Gardner explicilty indicated he
    was basing his decision to raise the bail based upon "public safety" and "concern for the defendant's safety", which are impermissible rationale for so increasin
    one's bail.

    NRS
    178.498. Many courts use a bail schedule to determine the amount, but note the
    initial amount can be increased if good cause is shown. NRS 178.499. Additionally, in
    determining the amount of bail, the judge should look at the following factors (NRS
    178.498):
    The nature and circumstances of the offense charged
    The defendants financial ability to post bail
    The defendants character; and
    The factors listed in NRS 178.4853.
    Bail can not be excessive. U.S. Const. Amend. VIII. It should be limited to a
    reasonable amount designed to ensure the defendants presence in court. It should not
    be a corrective or preventative detention device.

    NRS 178.484. The Court should take care in imposing any restrictions on a defendants constitutional rights (i.e.,
    search and seizure) and only imply such restrictions if warranted by the underlying facts
    of the alleged crime. Section 11 of NRS 178.484 describes the document that must
    be signed by the defendant before he/she can be released on bail.

    My bail hearing contained what seems to be an impermissible coercive attempt to condition my release or the possibility thereof upon my providing
    confidential medical records (Lake's Crossing etc) to the Reno Municipal Court, even where the same judge presiding over the bail hearing found me
    competent enough to face a criminal trepass trial less than two weeks before teh bail hearing in 11 CR 26405.
    000289

    The friend of mine who posted my bail, Jared Swanson, has a serious form of cancer and a one year old baby. I request a reduction of the bail for his
    benefit and for the proof of insurance charge to be dismissed, as (and I am trying to avoid this in any way I can), if I am rearrested, such a proof of insurance
    charge may present another basis for imposing an unduly burdensome bail upon me, as it did on July 5th, 2012 where, despite my having produced a legible
    pdf copy of my proof of insurance card on my large screened zoomable smart phone, Officers Weaver and Dye still charged me with that violation, and the
    bail was subsequently increase. Further, none of the events or accusations forming the basis of the distrubing the police charge occurred in the officer's
    presence, and the police report contains no indication whatsoever that the arrest was made based upon NRS 171.1771. I provided Officer Weaver my
    driver's license prior to the arrest. I did not
    refuses to give a written promise to appear in court as provided in NRS 171.1773.

    When a person is believed to have committed a misdemeanor offense, the peace officer has the discretion to
    either issue a citation or arrest and detain the person. NRS 171.1771 states that a person can be arrested if
    his identity is questionable or if the peace officer does not believe the person will appear in court. A person
    can also be arrested for a misdemeanor offense if a warrant has been issued.

    Additionally, I am requesting that you file a Motion to Dismiss the Disturbing the Peace charge based upon a lack of evidence and or insufficiency of pleading
    in that the allegations do not amount to a prima facie case of a DTP violation. Further, please subpoena and or collect the Protection Order application filed
    by Milan Krebs on July 5th, 2012, and interview Krebs as to why he mentions Coughlin often carrying around a large knife in a menacing manner in that
    protection order application, yet completely failed to mention that in his July 3rd, 2012 police report. Additionally, please determine why Kreb's TPO
    appliication has a different style of handwriting on the caption compared to the descriptive sections, indicating someone pushed the filing of the TPO on Krebs,
    perhaps his employer, Northwind Apartments or the RPD, which has in the days preceding the arrest threatend to arrest Coughlin for criminal trespass if he
    returned to any part of the premises of Northwind Apartments, in consideration of Coughlin's eviction from unit 29, despite the fact Coughlin still had a valid
    right to go to his other two rentals, units 45 and 71, in addition to the fact that Northwinds essentially withdrew or rescinded its June 28th, 2012 eviction of
    Coughlin by posting an Amended 5 Day Unlawful Detainer Notice on unit 29 on June 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada
    Courts Services that the July 14th, 2012 5 Day notice was not "personally served" (NCS's R. Wray lied about effecting personal service, as he could not
    possibly have verified someone of "suitable age and discretion" was within the windowless room with a metal door closed and locked and where no Wray
    admits that he received no verbal response from the unit or anyone therein upon his knocking on the door and or attempting to break into the unit, please see
    Soldal v. Cook County in that regard, a US S. Ct case) and therefore Coughlin would have had until at least noon on July 28th, 2012 to file a Tenant's Answer,
    whereas the eviction/lockout/arrest of June 28th, 2012 took place two hours before noon at 10 am).

    Additionally, RPD Officer Weaver had previously attempted to break into one of my rentals at Northwind at a time when he lacked a warrant and or an exigent
    rationale for doing so, much less an eviction Order. I just want this case to be dismissed and to try to move on in life, and difuse the tensions incident to
    this case.

    I did not disturb the peace at Northwinds as alleged, nor did I make the threats Kreb's accuses me of or stalk him or follow him in a threatening manner at
    any time. Additionaly, I never broke into nor did I ever attempt to break into Krebs' truck, and in fact, I filed a police report in June 2012 reporting
    extortionate threats by another maintenance man at Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne Jakob, wherein they
    threatened to make such a spurious allegation, but subsuquently refrained from doign so when it apparently occurred to them that I may have excuplatory
    video evidence disproving such an allegation as well as capturing their baseless and extortionate threats and accusations. Additionally, please subpoene the
    police reports I filed with the RPD and any emails I sent to any officers (including Weaver, Barnes, Sargent MIiller, LIeutenant Brown) and any reports of or
    recording of phone conversations I had with any of those RPD personnel. Further, please see the attached june 26th, 2012 email to the RPD, WCSO, RJC,
    Sparks Justice Court and others pointing out the insufficiency of the 5 day Notice drafted and posted by non-lawyers Nevada Court Services, in that under
    NRS 40.253 it listed the wrong forum for the tenant to file a Tenant's Answer, and under the Aiken decision of the Nevada Supreme Court and NRCP 60(b)(4),
    any lockout order stemming therefrom is void for lack of jurisdiction.

    NRS 171.136 When arrest may be made.

    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:...
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation
    or offense;
    000290
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;...
    (g) When the person is already in custody as a result of another lawful arrest; or

    Krebs did not immediately arrest me under NRS 171.136(2)(d), nor was the DTP arrest for an offense alleged to have occurred in the officer's presence.

    the attached videos are of the incident on June 5th, 2012, not from July 3rd, 2012, but they support my contentions and the relevancy of subpoening the
    police incident reports and other documentation should this case not be dismissed, nolle prosequi, de minimis, etc....

    I will forward to you my emails to the RPD et all from June 26th, and July 2nd, 2012. I realize their tone was not a smart one to take or appropriate and am
    only sending them in hopes of having this matter dismissed. I do not have any interest in pursuing anything like Wheeler v Cross 344 Fed Apps 420 (
    (2008.

    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
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    6/08/12
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    NvRenoPd@coplogic.com
    Sent: Fri 6/08/12 4:39 PM
    To: zachcoughlin@hotmail.com
    ****DO NOT RESPOND TO THIS E-MAIL****
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    000293
    6/11/12
    NvRenoPd@coplogic.com
    To zachcoughlin@hotmail.com
    From:
    NvRenoPd@coplogic.com
    Sent: Mon 6/11/12 4:10 PM
    To: zachcoughlin@hotmail.com
    1 attachment
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    000294
    6/11/12
    Your Online Police Report 120103420 Has Been Approved
    NvRenoPd@coplogic.com
    To zachcoughlin@hotmail.com
    From:
    NvRenoPd@coplogic.com
    Sent: Mon 6/11/12 4:11 PM
    To: zachcoughlin@hotmail.com
    1 attachment
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    Reno Police Department
    RE: respectfully submitted
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Wed 8/08/12 2:43 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Zach:
    I reviewed the file in the Krebs protective order application. It is interesting in that there is not one reference by Mr. Krebs to a belief that you were
    trying to provoke him to engage in violence or a violation of law. Those appear to be solely the words of Office Weaver.
    000295
    I subsequently received your 100 page e-mail and do not intend to review it at length as most of the material appears irrelevant. What I
    gather from it is that you are once again not happy with my representation and want me to withdraw. I think there is merit to that request. It
    appears that our relationship has broken down and that you are asking me to engage in conduct that will result in violations of the rules of professional
    conduct. Those include Rules 3.1, 3.2 , 4.4 and possibly others. I also fundamentally disagree with some of your requested actions in that so far you
    have refused to provide your description of what happened on July 3, 2012 with Mr. Krebs. It also appears that your repeated demands are making
    my representation unreasonably difficult. It would be helpful; if I can represent in the motion to withdraw that you are willing to waive the 60 day
    rule for trial, so that a new attorney can be appointed to represent you and have enough time to prepare your case. Please respond whether you will
    agree to that waiver. If not I will simply file the motion without the representation and hope for the best.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, August 07, 2012 11:01 PM
    To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
    Subject: FW: respectfully submitted

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: weavera@reno.gov; barnesm@reno.gov
    Subject: respectfully submitted
    Date: Fri, 8 Jun 2012 16:41:49 -0700
    Dear Officer Weaver and Officer Barnes,
    I am respectfully submitting this supplementary material to the police report I submitted to you in
    person on June 6, 2012 regarding the assault I was the victim of at the hands of maintenance staff
    member Luke of Northwind Apartments on June 5th, 2012, and the attempts at unlawful entry
    committed by Northwind Manager Dwayne Jakob on or about June 4, 2012.
    I am attaching an article you may find of interest regarding the intersection of landlord tenant law
    and police work, vis a vis criminal/civil matters and the fine distinctions that sometimes arise. I
    didn't see anything in there on Officer Weavers fine hypothetical regarding entry without
    permission when a burglary may be occurring. That situation probably does not come up that
    often because hardly anybody but the police would be brave enough to enter such a dangerous
    situation.
    000296
    I appreciate the brave service both of you provide. I am attaching this materials just because
    they are interesting to me and may be to you and in no way wish for so attachign these to be
    interpreted as a criticism of either of your police work.
    Sincerely,
    Zach Coughlin
    Motion to Withdraw
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Fri 8/10/12 11:07 AM
    To: Zach Coughlin (ZachCoughlin@hotmail.com)
    1 attachment
    SKMBT_C35312081011000.pdf (164.4 KB)
    Motion to Withdraw is attached

    Keith Loomis

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    State Bar of Nevada 600 E. Charleston Blvd Las Vegas, NV 89104 702-382-2200
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    Back to top
    --Forwarded Message Attachment--
    Print Close
    RE: motion for continuance
    From:Pamela Roberts (robertsp@reno.gov)
    Sent: Wed 11/16/11 5:12 PM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for reciprocal discovery. You just need to call
    ahead at 334-2050 and arrange to pick it up. You are entitled to copies of all the reports and witness statements and video we may have on this case.
    Since I am not calling any additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send you an additional list of
    witnesses. I am also not obligated to do any further investigation or interviews. Pam Roberts.
    -----Original Message-----
    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: <robertsp@reno.gov>
    Date: Wed, 16 Nov 2011 15:35:48 -0800
    Subject: RE: motion for continuance
    Ms. Roberts,
    Thanks for your reply. Please ascertain from Walmart whether any Walmart employees had, previous to
    this incident, made any threats respecting maliciously having the accused banned from Walmart's incident
    to a disagreement over Walmart staff and managers curious practice of "forgetting" their return policy,
    despite some individuals having worked there over 10 years....Further, I believe it relevant and part of your
    duty to provide exculpatory information to ascertain whether the RSIC police officer made statements
    wherein he attempted to coerce a consent to an impermissible search and further buttressed his probable
    cause finding to conduct a search incident to arrest, expressly, in words, to the accused, upon the accused's
    failure to consent to such a search.

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

    Date: Mon, 14 Nov 2011 10:36:45 -0800
    From: robertsp@reno.gov
    To: zachcoughlin@hotmail.com
    Subject: Re: motion for continuance
    000304
    Mr. Coughlin, we were closed on Friday and I have just read your email. If you have not received confirmation from the Court that your trial date has
    been continued, you will need to appear this afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that
    time and if we are unable to resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
    decision to grant your motion to continue.

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

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

    -----Original Message-----
    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: <robertsp@reno.gov>
    Date: Fri, 11 Nov 2011 01:40:53 -0800
    Subject: motion for continuance
    Dear Counselor Roberts,
    I believe you are the prosecutor for the case against me, State v. Coughlin, which I believe is still set for
    trial on November 14th, I think at 1pm. I am not totally sure that there is a duty to serve you on such a
    thing, but I filed a Motion for Continuance and a Motion for Appointment of Counsel sometime within
    about the last 10 days, I would say. I believe I attempted to copy you on it, but have recently been
    evicted and its been a very difficult time in terms of coordinating paperwork, etc., etc. I apologize for
    any inconvenience this may have cause you. I am unsure of whether the November 14th trial is still set
    to take place. I believe fairness dictates that it be continued to a later date. I have request counsel but
    have yet to receive any, or wait, I was denied a request to receive counsel because Judge Howard said
    there is not a 6th amendment right to counsel where, even though jail time is technically a possibility, the
    state does not anticipate seeking jail time...or something like that, however, I found some cases that say I
    should still get counsel appointed, especially where I show I am indigent, and I believe I qualify as
    indigent rather easily. Can and would you agree to a continuance? I believe I tried to contact about
    this prior to filing my Request for a Continuance. I maintain my innocence in this case and feel any sort
    of conviction, especially one involving any sort of theft based charge, would work a terrible injustice and
    greatly damage my reputation and employment prospects. I want a jury trial, too.
    Sincerely,
    Zach Coughlin
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
    confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient,
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    in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.

    --Forwarded Message Attachment--
    Print Close
    000305
    WLS
    From:Paul Elcano (pelcano@washoelegalservices.org)You moved this message to its current location.
    Sent: Wed 5/06/09 9:38 AM
    To: zachcoughlin@hotmail.com
    Dear Zach,

    You are correct about the letter being delivered on April 20


    th
    , I misread my timeline. My decision is limited to the hearing conduct.
    You have proffered nothing that indicates that the way you acted in court is in any way related to any outside event. Your 50 page motion for reconsideration
    before Judge Gardner has not linked your conduct in any way to an outside event. You have refused to give me a time and date to meet once again, and I
    will issue my determination tomorrow morning at 9:00 am.

    Access to your computer materials, will be made at a convenient time and place with our office manager, executive director or
    designee and our computer specialist present. This is a business computer, and without further research I will not give you access to it privately. You have
    been given a tape of the two Joshi hearings. To date, you have not agreed to meet at any time and place to discuss these hearings; and you have not
    specifically requested any identified items, documents etc. that were related to your conduct in this hearing. Your series of questions about the Board is
    irrelevant. The Board delegated this matter to me to handle as a personnel matter.

    -Paul
    SBN still has not provided Coughlin access to the materials he is entitled to to prepare for
    11/14/12 Hearing
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 11/02/12 10:36 PM
    To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
    (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
    (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com
    (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
    33 attachments
    all emails to loomis 26405 12420 26800 00696 065630 063341.pdf (779.8 KB) , 2 28 12 Contempt Order Nash 26800 26405 065630
    00696 063341 bf size reduced.pdf (449.9 KB) , 11cr26405 puentes 041012_20120410-0903_01cd16f8c3aa49b0.mp3 (5.1 MB) ,
    NvRenoPd@coplogic.com rpd police reports by coughlin 063341 duralde carter lopez sifre 1708 26405 26800.htm (145.0 KB) , rpd
    carter police report 11 cr 26405 puentes loomis 1708 merliss rmc gardner cr12-0376 mh12-0032 650630 063341 rpd lopez carter
    police report 11 13 12-2.pdf (6.3 MB) , 3 3 12 attached to loomis email and filed in rmc final motion to dismiss 11 cr 26405 26800
    065630 063341.pdf (442.6 KB) , goodnight jgoodnight@washoecounty.us 5 2 12 email regarding hazlett loomis mhc 178.405 063341
    26405.htm (16.3 KB) , all emails from keith loomis keithloomis@earthlink.net between 2 27 12 and 8 10 12 26405 26800 00696
    063341 065630.htm (322.8 KB) , 3 7 12 rmc 11 cr 26405 loomis gardner 178.405 Coughlin Trial Setting 26800 00696 063341
    065630.pdf (321.4 KB) , 8 9 12 Loomis second Motion to withdraw 12 cr 12420 rmc see also 26405.pdf (229.2 KB) , State Bar Of
    Nevada nvbar casey baker 1708 26405.htm (42.7 KB) , 5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302
    26800 60317 54844 dd.pdf (15.3 KB) , 11 16 2011 email from reno city attorney roberts.htm (16.3 KB) , WCSO Beckman, Debi
    Campbell, Cummings, Hodge Statements on property sezied from Reno Attorney by Reno Munic Court Judge Nash Holmes.pdf
    (150.3 KB) , ZachCoughlin@hotmail.com emails to puentes@aol.com.pdf (222.1 KB) , pam roberts on her duty.pdf (812.0 KB) ,
    Patrick King sbn grievance letter of 3 16 12 and Judge Nash Holmes greivance of 3 14 12 rmc 11 TR 26800.pdf (575.8 KB) , proof
    of clandestine status conference on 2 27 12 dogan young nash holmes schroeder rcr2012-065630 rjc rmc rpd wcso wcpd wcda -
    Copy.pdf (1644.4 KB) , proof of faxing notice of appeal to both rmc gardner and reno city attorney hazlett-stevens.pdf (14.5 KB) ,
    proof picture of personally delivering notice of appeal to city of reno hazlett 6 27 12 in cr12-1262 11 cr 26405.pdf (43.9 KB) ,
    records request and subpoena to RSIC.pdf (71.2 KB) , records request to rsic police.pdf (65.8 KB) , rmc 12 cr 12420 Loomis motion
    to withdraw as counsel 8 9 12 City of Reno v Coughlin.pdf (926.9 KB) , Motion for Continuance to Reno City Atty Roberts RMC.pdf
    (448.9 KB) , ORDER RELEASING PROPERTY 11 TR 26800 3 30 12 nash rmc rjc rpd wcso king clark marked as recd back by rmc
    4 13 12 return to sender pthoa hy.pdf (287.1 KB) , letter to bar counsel regarding rmc and reno city attorney complaints with loomis
    emails.pdf (329.3 KB) , ex 1 to motion to set aside dismissal cr12-1262.pdf (2.5 MB) , CR12-1262-3093668 (Opposition to Mtn
    ...).pdf (92.5 KB) , CR12-1262-3117150 (Ord Dismiss Appeal Remand).pdf (73.9 KB) , CR12-1262-3119416 (Exhibit 1).pdf (2.7
    MB) , 6 28 12 email to hazlett stevens showing what was served notice of appeal 11 cr 26405 cr12-1262.pdf (12.8 KB) , 12 14 11 fax
    to Puentes re WCSO Affidavit of Service REV2011-001708.pdf (24.9 KB) , 5 6 09 email from elcano wls stating his decision is
    limited to hearing conduct before judge linda gardner rmc 26405 26800 60302.htm (10.3 KB)
    Dear Panel Members and Bar Counsel,
    000306

    I called Mr. King (he directed me to call Panel Chair Echeverria) today to seek clarification regarding an earlier approval he
    relayed to me from Chief Bar Counsel David Clark, wherein Mr. Clark advised me that I, even though I am a temporarily
    suspended attorney, have been given permission by the Office of Bar Counsel to issue subpoenas in connection with this
    disciplinary matter (ng12-0204, ng12-0434, ng12-0435...odd, can't recall a single other "case" in all my legal research that had
    three case numbers....especially where an Order Denying a Motion to Bifurcate was issued, even before the 5 days for me to file
    a Reply to the Opposition (given NRCP is expressly applicable to these matters under the SCR's)...Am I going to find out that
    my filings are "too long" under a view that assumes this is "one case" even though there are "three grievance case numbers" in
    the caption, and where each "grievance" is fairly rambling? And where the SBN's King purports this hearing to involve
    that which the N. S. Ct. Ordered to occur in response to its temporary suspension Order incident to the SCR 111 Petition for the
    petty larceny of a "candy bar and some cough drops" (ie, the Court order that matter, 60838, referred to the Board for a "hearing
    at which the sole issue to be determined" would be my punishment for that which was noticed and adjudicated in the 60838 SCR
    111 Petition. I believe you are all now violating Nevada Law in persisting in your denial of my right to such a hearing wherein
    the "sole issue" is such, but rather trying to jam me up with this "combo hearing" that seeks to encompass a great deal of
    disparate claims (many of which are pending criminal charges, and therefore, entirely outside of your jursisiction at this point,
    and your deigning to address them interferes with the orderly administration of justice in those pending criminal prosecutions, as
    evinced by Judge Sferrazza's refusal to testify at the November 14th, 2012 Hearing...which is problematic considering Judge
    Sferrazza presided over the civil summary eviction matter in RJC Rev2011-001708 that is intimately connect to ALL THREE of
    the grievances included in King's reckless, negligent, compromised SCR 105 "Complaint". For instance:
    NG12-0204: Richard G. Hill's January 14th, 2012 letter to Bar Counsel King (whom he had just worked on the Milsner v.
    Carstarphen matter with (http://law.justia.com/cases/nevada/supreme-court/2012/51631.html )

    Today, King admitted to being unaware of who Casey Baker, Esq. is. King also admitted to not having read any of my
    filings in any of these connected matters, only to then suggest an analogy along the lines of if a woman is raped a lot, she is
    probably a whore and deserves it or wanted it, given the sheer mathematical improbability of any one woman getting raped over
    and over, and how King just doesn't get paid enough to stick his nose into some gangbang, what with the chances of getting
    himself involved in doing the right thing where it is just so much easier to sit back and pretend that the Claiborne decision
    (explicated extensively in my attached August 13th, 2012 Petition) does not permit Bar Counsel to just throw its hands up and
    suggest that a Muni Court conviction (even, in RMC 11 CR 26405, presided over by the brother of the judge whose sanctions
    Orders is before you in NG12-0435, and where the brother refused to recuse himself from that criminal trespass conviction
    incident to the lies and or attempts to mislead a tribunal by Casey Baker, Esq. and Richard G. Hill at the June 18th, 2012
    criminal trespass trial incident to the civil eviction from Coughlin's former law office in RJC Rev2011-001708. Asst. Bar
    Counsel King also admitted that he had failed to even view the video taped admission by RPD Sargent Lopez that she, Hill,
    Merliss, and RPD Officer Carter lied in order to effectuate the wrongful arrest leading to Couglin's conviction by the brother of
    the sister whose 2009 sanctions Order against Coughlin only became a grievance on March 14th, 2012 (apparently King adopts
    Ching as to whom can be an SCR 105 complainant, and therefore within the statute of limitations, when it comes to
    Gardner's April 2009 Order, but not when it involves misconduct by a Chairman of the Character and Fitness Committee of the
    SBN, Spearmint Rhino owner Kevin Kelly, Esq., whom also owns a Las Vegas Strip Club that gives cabbies $10 million dollars
    a year to funnel tourists to it's doors from the airport, and the misconduct of Peter Christiansen, Jr. and Mike Sanft, and others
    incident to Coughlin's application for admission in Nevada, including that of then Director of Admissions Patrice Eichmann,
    made all the more feasible by the conduct of Mike Smiley Rowe, Esq. and the fraudulent conduct of Mark Tratos and Mary
    LaFrance) when RMC Judge Nash Holmes (in response to prompting by the SBN) passed that three year old Order (attorneys
    get sanctioned all the time, such orders do not become grievances as a matter of course, and the SBN has admitted it keeps no
    central record of any such grievances) on to Bar Counsel after receiving it from her co-RMC Judge, and the brother of the family
    court judge issuing the sanction order...at right about the time that Coughlin filed that March 7th, 2012 Notice of Appeal (and
    there is plenty of case law to establish that a "summary criminal conviction" is a final appealable Order, and the RMC is
    fraudulently conspiring with transcriptionist Pam Longoni to violate NRS 189.010-030 by demanding payment up front for such
    transcripts by indigent criminal defendants, and Longoni and the RMC's fraud in that regard resulted in Judge Elliot denying
    Coughlin's appeal of the Wal-Mart candy bar petty larceny conviction in cr11-2064, wherein Judge Elliot actually cites to a civil
    statute related to transcript preparation to justify the RMC's fraud, seen elsewhere in CR12-1018, further the RMC "lost'
    Coughlin's Notice of Appeal of the 11 cr26405 criminal trespass conviction appeal (despite Coughlin having digitial confirmation
    of the receipt of that fax by the RMC, and where RMC Rules allows service thereof via that means upon both the Court and the
    City Attorney (and Hazlett-Stevens lied about that as well, in addition to the lies he told respecting whether the City Attorney
    had received anything from the RSIC following Coughlin's Wal-Mart arrest) in the "summary criminal contempt" Order
    stemming from the traffic citation (California roll) trial connected to Coughlin reporting the admissions of bribery by Richard
    Hill (RPD Officer Carter stated as much during the November 13th, 2011 criminal trespass arrest, now part of the SCR 105
    Complaint, incorporated by reference, one must suppose, by Hill's NG12-0204 grievance) to the Sargent who retaliated against
    Coughlin by issuing three traffic citations, for Coughlin so reporting such admissions by the arresting officer in the trespass
    000307
    matter to the Sargent who issued the traffic citations to Coughlin incident to Coughlin going to Hill's office to retrieve his keys,
    wallet, client's files, and goverment issued identification after being release from 3 days in jail incident to the wrongful criminal
    trespass arrest.

    Mr. King is beyond incorrect is stating that he will be able to simply point to a criminal conviction and declare that no inquiry
    into the legitimacy of that conviction may be made. There is a wealth of case law and precedent that holds otherwise, and Mr.
    King has previously been made aware of that. This is true especially where the convictions at issue completely fail to evince
    even baseline level of regard for traditional notions of due process. Simply put, some might say the members of this Panel
    ought think rather hard before tying their reputations to the mast that is the extremely low bar required to get a conviction in the
    Reno Municipal Court these days....and further, the Panel would be well advised to avoid letting Mr. King lead it down that
    primrose path wherein one believes they will be entitled to merely accept a municipal court conviction as conclusive proof of
    misconduct or otherwise rule irrelevant any inquiry into the circumstances attendant to such a matter. This will be
    particularly true where Mr. King seeks to, in his SCR 105 Complaint, allege matters not even charged in that Municipal Court
    criminal trespass proseuction. How Mr. King will be able to allege his RPC 3.8 violating allegations respecting "breaking and
    entering" or "broken locks" are relevant or admissible where Coughlin's dissection of the illegitimacy of the Walmart candy bar
    petty larceny conviction (supposedly part of the SCR 105 Compalint....and mentioned in Hill's NG12-0204 grievance...which
    brings to mind the question...what of matters not mentioned in any of the three grievance numbers? How are they eligible for
    inclusion in some SCR 105 "Complaint' that lacks a unique case number of its own?) Regardless, it is November 2nd, 2012
    and my defense has been irreversibly prejudiced by the refusal of Bar Counsel to allow me to access the materials at the SBN
    that are my right to under the SCR, thus bringing the legitimacy of the entire November 14th, 2012 hearing into doubt, to which
    any argument that I should be made to fit the bill for Bar Counsel's bungling and fraudulent failure to follow the rules applicable
    to this matter, in addition to its own written attestations, is entirely unsupportable.

    Regardless, Richard G. Hill, Esq.'s hench man, Casey Baker, Esq., now that the heat is on and he and Hill's avarice driven
    misdeeds are finally facing the oversight they deserve, has now suddenly fled back to Kentucky:
    http://www.nvbar.org/lawyer-detail/11271

    It was Baker whom Hill used to file the November 21st, 2011 and January 20th, 2012 filings in RJC Rev2011-001708 and the appeal thereof in CV11-03628 to
    make the allegatons that Hill himself knew unwise to make in his own regard within a sworn Declaration...So, despite Hill, not Baker, having the eye witness
    knowledge of such events (like whether the RPD identified themselves as law enforcement and issued to Coughlin a lawful warning to leave at the risk of a
    criminal trespass citation or arrest prior to the landlord kicking down the door to a quasi "basement" under the property that Baker's own testimony at the June
    18th, 2012 trespass trail admits lacked any sort of exterior lock, and thus would require no "breaking of any sort" of the type both Susich and King suddenly felt
    the need to allege when considering how terribly compromised their 60975 Petiton and the instant SCR 105 "combo-grievances" (kind of like a "due process
    value meal" that Pat King is serving up, and asking this Board to co-sign...which, apparently the Chairman finds fitting....what's next, are you going to have lawyers
    dress up in Hot Dog on a Stick employee uniforms (you know, rainbow colors, the spinning thing atop the hat, etc.) too? Is that how little the property right of
    a law license (case law declares it as much under the Fourteenth Amendment, and any willful deprivation thereof by this Board, including a deprivation of the due
    process required to impinge thereupon, can subject the members of this Board the 42 USC Sec. 1983 liability, especially where, as her, what appears to be a
    coordinated effort to obstruct justice and proceed impermissibly under color of law for the self interested aims of those leveraging such positions is apparent.
    RICO.


    I am writing to request confirmation of what I believe Mr. Clark has previously rule, ie, that I, as an indigent respondent herein, am not required to pay witnesses
    any sort of "witness fee" in issuing and or serving subpoenas and subpoens duces tecums upon them in connection with the November 14th, 2011 Hearing in
    this matter. I feel Hill's then associate Casey Baker, Esq's testimony will be particular necessary to this hearing (especially where Hill admits himself that he was
    not present at the purported November 1st, 2011 "lockout" in the eviction matter (and the service of an receipt by the WCSO with respect to any such lockout
    Order is of material relevance, as NRS 40.253 requires such an Order be carried out "within 24 hours of receipt" thereof...and Baker's testimony at the June 18th,
    2012 criminal trespass trial, in combination with previous statements by the Washoe County Sheriff's Office (and please add these individuals and matters to my
    designation fo witnesses and summary of evidence to be presented) Supervisor Liz Stuchell, Roxy Silve, Deputy Machen, and administrators, supervisors, and
    clerks at the Reno Justice Court (RJC) add up to the fact that it was Hill, Baker, and the WCSO, and RPD that were trespassing, not Coughlin, at Coughlin's former
    home law office. Attached it the video taped admission by RPD Sargent Lopez respecting the lies by her, RPD Officer Carter, Hill, Merliss, and Baker leading
    to Coughlin's arrest and conviction for criminal trespass. Keith Loomis will need to answer for his failure to fulfill the Sixth Amendment in that regard, in
    addition to the content of the unapproved and impermissible "meeting" with RMC Judge Gardner and City of Reno Prosecutor wherein, upon information and
    belief, an "approach" to handling the criminal trespass trial of Coughlin was "developed" shortly before the April 10th, 2012 Trial date in that criminal trespass
    matter (a Trial date which violated Nevada law, anyways, in that it was set and held during the pendency of an Order for Competency Evaluation of Coughlin in
    violation of NRS 178.405 and NRS 5.010). Any trier of fact that wishes to attempt to pull the wool over Coughlin's eyes, make incongruous and patently
    compromised, often sua sponte relevancy rulings, or otherwise cook up a due process value meal may wish to ask RMC Judge Gardner how the recent filings by
    Coughlin in 61901 and the RMC 11 CR 26405 are tasting right about now. Or get Judge Howard's inpute with respect to the analysis of his work in 60838.
    And Judge Nash Holmes may be able to provide some insight as to how that approach served her, particularly where her "criminal summary contempt" order
    was made during the pendency of an Order for Competency Evaluation, and cites to alleged conduct committed outside her immediate presence (and that's the
    thing about "summary adjudications"....the are so arbitary and devoid of due process that the requirements attendant thereto must be stricly adhered to....so when
    Judge Nash Holmes in here Orders in 11 TR 26800 of 2/28/12 and 3/12 3/13, and 3/13/12 refers to some RMC Marshal allegedly peering, Peeping Tom style,
    through a bathroom stall wherein Coughlin was during a restroom break within that trial, her Order fails to adhere to the dictate that each element of any
    conduct she deigns to summarily rule upon be committed in her "immediate presence"...otherwise, someone would have to sign an Affidavit like a grown up, and
    Coughlin would be entitled to a hearing, and likely appointed counsel under the Sixth Amendment before some Bar Counsel like King could attempt to prop up
    any such "conviction" in an attempt to lend it an air of respectiability, especially where that Marshal Harley (whom King conveniently has failed to subpoena) had
    his own self interested reasons for seeking to discredit Coughlin (RMC Marshal Harley violated the "courthouse sanctuary" rule and contributed to an appearance
    of impropriety where he served Coughlin an Order to Show Cause incident to one of Hill's fraudulent Motions seeking to abuse process in hopes of remaining
    competitive with an actual attorney like Coughlin (rather than a known hack like HIll whom inherited a law practice from his father and who legion of local
    attorneys accuse of unneccesarily running up fees on his clients by purposefully overcomplicating litigations and engendering an adversarial stance amongst
    000308
    litigants designed to line Hill's pockets, and those of, apparently, even his legal assistans, whom drive $130,000 Mercedes v12 SL-600 sport coupe convertibles to
    crack inspections of law offices incident to impermissible summary evictions of commercial tenants where Hill chose to proceed under a No Cause Eviction Notice
    (along with Baker) rather than a Non Payment Notice, and therein committed a "wrong site surgery" (in a litigation sense, to borrow some of the parlance of the
    landlord, Dr. Merliss's field, wherein he is a Neurosurgeon/Neurologist in Chico, CA, apparently armed with enough money to choose to run up $60,000, as of
    April 2012 in fees ot HIll and Baker in these matters rather than settle with Coughlin for the $1,500 Coughlin offered him).

    Please add to the witness list all the individuals mentioned in the various filings I have provided you, including, but not limited to RPD Officers Duralde, Rosa,
    Alaksa, Weaver, Look, Travis Warren, and Leedy, RPD Sargent Tarter,Lopez, Sifre, Oliver Miller, Dye, and Bradshaw, Hill's Associate Casey Baker, Sheri Hill, and
    to be deterimined members of HIll's staff (particulary those with knowledge of any matters connected to the receipt of either of the Eviction Orders by the WCSO
    in the eviction matter, WCPD Jim Leslie, Biray Dogan, Joe Goodnight, Walmart Thomas Frontino and ASM John Ellis, and a yet to be determined AP Associate
    whom, along with Ellis, made express threats to retaliate against Coughlin with abuse of process similar to the petty larceny candy bar conviction in 60838 that
    currently forms the only basis for the suspension of Coughlin's law license and for which this Panel and the SBN are violating Nevada law in persisting in refusing
    to follow the dicates of both the Supreme Court Rules of Nevada and the Court's June 7th, 2012 Order in 60838, but rather, like Clerk/"reluctant" Investigator
    Peters, are allowing themselves to be led down that primrose path that Pat King finds to pleasurable to take the unwitting along in his social climbing and life of
    ease and comfort, devoid of honor or intergrity, approach to life...Also, to the extent then Panel considers a pending criminal prosecution up for inquiry in a
    disciplinary proceeding, included in potential witness call may call are Nicole Watson, Lucy Byington, Nate Zarate, Cory Goble, the individual whose phone
    number is 7753786673, Colton Templeton, Robert Dawson, Nick Duralde, Ron Rosa, Thomas Alaksa, Savannah Montgomery, Linda Gray, Kelly Odom, Kariann
    Beechlker, RPD Officer Schaur and any others present at arrest of 1/14/12 for "misuse of emergency communications", and of the 5-6 officers whom, along with
    RPD Duralde pulled Coughlin over upon his release from jail on 1/13/12 for the 1/12/12 "jaywalking" arrest made upon the fraudulent assertions of Richard HIll,
    RJC Judge Jack Schroeder (whom evicted Coughlin from Park Terrace and granted Hill the protection order incident to the jaywalking arrest and who yelled "do
    you want to go to jail" at Coughlin at the extension hearing when Coughlin broached the topic of Hill's abuse of process, and whom wrongfully granted the
    6/27/12 Eviction Order in RJC Rev2012-001048 despite the deficient 5 day notice listing the wrong court to file a tenan'ts affidavit (a requirement under NRS
    40.253, and despite Coughlin's numerous calls and 6/26/12 email to the RJC, SJC, RPD and WCSO, also Jeff Nichols and Peter Eastman and Paul Freitag, Esq.
    (involved in SBN King's impermissilbe disclosures and slanderous statements concerning Coughlin and the NVB (which King also made to his boss in front of
    Coughlin, David Clark, and which have proven to be baseless, despite King ticking such off amongst the top 2 reasons for the SCR 105 Complaint he alleged he
    would hurriedly throw together upon Coughlin serving King, the SBN, Clark and Peters the August 13th, 2012 filing in 60838 and 61426, now before the N. S. Ct.).
    Also, Richard Cornell, Tom Hall, Geof Giles, and Michael Lehrners, Judge Joe Van Walraven and others all whom have indicated, to one degree or another, that
    Hill's conduct incident to this eviction matter and concomitant appeal is deplorable and entirely consistent with the way Hill has comported himself throughout
    his 33 year career, which began with is inheriting a large scale law practice from his father, and continued on with Hill effecting the manner of a 10 year old boy
    entrusted with flying a 747 full of people, to this day. Add to the witness List Paul Elcano of WLS, Judge Steven Elliot, Judge Patrick Flanagan, Hale
    Lane/Holland and Hart's Anthony Hall and Tim Lukas, Richard Elmore, Judge Scott Pearson, Judge Peter J. Sferrazza (though he indicated on 10/22/12 that he
    declined the SBN's request that he testify, citing his sitting on the pending criminal prosecution in RCR2011-063341), the RJC's Bonnie Cooper and "Nevi", Chief
    Bailiff Michael Sexton, RMC Chief Marshal Roper and Marshal Deighton, Marshal Thompson, Marshal Coppa, WCDC Van der Wal, Beatson, Hoekstra, Cheung,
    unnamed deputies. Further, please add Western Nevada Management's Sue King, Jared Scalise, and Park Terrace Townhomes Association attorney Gayle Kern,
    Esq., Roberto Puentes, Lew Taitel, the RMC's Matthew Fisk and Cassandra Jackson, Donna Ballard, Judge Howards past legal assistant, Judge Nash Holmess legal
    and administrative assistant, Martin Crowley or Martin Weiner or whichever attorney is was Judge Nash Holmes was sued for wiretapping in the past, the RMC
    counter clerk "Daniel" and "Thom", WDC Chief Appeals Clerk Matheus, Joey Orduna Hastings, Chief Judge David Hardy, Justice Hardesty (whom was one of only
    three Justices signing the June 7th, 2012 temporary suspension Order, but whom recused himself from 60302 and 60317, the wrongful termination suit against
    Washoe Legal Services (see attached letters from WLS's Executive Director citing Judge Linda Gardner's April 2009 Order sanctioning Coughlin as the "sole
    reason" for Coughlin's firing (her brother, RMC Judge William Gardner refused to recuse himself from the criminal trespass conviction mentioned in in King's SCR
    105 Complaint, and King admitted two weeks ago that he was unaware that the two Judge Gardners were brother and sister or related whatsoever, or that Judge
    Nash Holmes was a prison warden or something similar for ten years, and a lifelong prosecutor besides that (in addition to all other RMC Judges and all RMC
    court appointed defenders).


    Also, I never received any Notice of Intent to Take Default from the SBN, and herein lodge my objection to any Order by this Panel that cites thereto.
    Additionally, SBN's Peters has indicated no other respondents have ever been made to pay witness subpoena fees, and further Peters and the SBN have
    repeatedly failed to adhere to agreements they have made with Coughlin (including the failure of the SBN to resend a certified mail copy of the SCR 105
    Complaint incident to the agreement between Peters and Coughlin on or about September 11th, 2012.




    Sincerely,




    Sincerley,
    skent@skentlaw.com, mike@tahoelawyer.com, nevtelassn@sbcglobal.net, patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org;
    complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
    Subject: RE: Records
    Zach Coughlin
    1471 E. 9th St.
    Reno, NV 89512
    Tel and Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    --Forwarded Message Attachment--
    000309
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    Your Online Police Report T11005956 Has Been Submitted
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    000314
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    --Forwarded Message Attachment--
    Print Close
    RE: release of information to my attorney
    From:Goodnight, Joseph W (JGoodnight@washoecounty.us)This sender is in your safe list.
    Sent: Wed 5/02/12 4:45 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin,
    MHC has received your referral and diagnosis from Ascent NBI. The MHC coordinator indicated that your case will be added to Friday's staffing and your
    application "looks fine." I take that to indicate that you'll likely be accepted. I have a call in to DDA Young to re-open negotiations. This is what I intend to
    present for a global resolution:

    Parties will agree to transfer jurisdiction of RCR11-063341 (RJC Misdemeanors) to MHC. DDA Young will defer prosecution of RCR12-065630 (misuse of
    911) and upon successful completion of MHC, will dismiss with prejudice. City prosecutor in Reno Municipal Court case (Trespass) will defer prosecution
    and upon successful completion of MHC, will dismiss with prejudice (your attorney, Mr. Loomis, should advise you regarding this case).

    Is that acceptable to you? If not, please let me know immediately.
    Sincerely,
    Joe Goodnight


    **********************************************************
    Joseph W. Goodnight
    Deputy Public Defender
    (775) 337-4839
    jgoodnight@washoecounty.us
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
    confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
    are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
    information is strictly prohibited.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, May 02, 2012 2:28 PM
    To: Goodnight, Joseph W
    Subject: FW: release of information to my attorney
    Joe,

    Here is Yassars assistants update. I am in favor of a global resolution. regarding mental health court, do they attemt to
    take over ones medical care or second guess ones doctor on health care matters? what is the worst case scenario with mental
    health court? lets say one does not do well in it, does that defendnat then get tried in justice court as they would have
    before entering mental health court? can the mental health court sentence one to jail?

    thanks,
    000315
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

    > From: megan@ascentreno.com
    > To: ZachCoughlin@hotmail.com
    > Subject: RE: release of information to my attorney
    > Date: Wed, 2 May 2012 14:22:06 -0700
    >
    > Zach,
    > I have not had time to type up the letter due to the high volume of patients and calls in the office. I will get to the letter as soon as I get a chance . The
    attorneys office did call prior to you showing up in the office and due to that I did not have a release to talk with them regarding your diagnosis or
    treatment I told them I would have to get that first.
    >
    > Megan Sredy
    >
    > Megan Sredy
    > Patient Coordinator
    > Ascent NBI & TMS Center
    > 540 West Plumb Lane, Suite 1A
    > Reno, NV 89509
    > Phone (775) 322-4666; Fax (775) 322-4747
    >
    >
    > IMPORTANT:
    > This message (including any attachments) may contain confidential, proprietary, privileged and/or private information. The information is intended to be for
    the use of the individual or entity designated above. If you are not the intended recipient of this message, please notify the sender immediately, and delete
    the message and any attachments. Any disclosure, reproduction, distribution or other use of this message or any attachments by an individual or entity other
    than the intended recipient is prohibited.
    >
    >
    >
    > -----Original Message-----
    > From: zach coughlin [mailto:ZachCoughlin@hotmail.com]
    > Sent: Wednesday, May 02, 2012 2:06 PM
    > To: ecek@ascentreno.com; megan@ascentreno.com
    > Subject: release of information to my attorney
    >
    > From: zach coughlin <ZachCoughlin@hotmail.com>
    > Subject: release of information to my attorney
    > Phone: 7753388118
    >
    > Message Body:
    > ----------------------
    >
    > My attorney sent me the following earlier today
    >
    > > Mr. Coughlin,
    > > I have not received anything from Dr. Yassar's office. I called again and left a message with them to contact me regarding the release. I'd like
    confirmation of the diagnosis today so I can submit your MHC application (again, due on Wednesday for staffing/acceptance meeting on Friday). Would you
    like me to try submitting your application without the diagnosis? Perhaps this would achieve a conditional acceptance pending receipt of the diagnosis. Let
    me know.
    > > Sincerely,
    > > Joe Goodnight
    > >
    > > PS - I don't know about your second question regarding RMC contact.
    > >
    > > **********************************************************
    > > Joseph W. Goodnight
    > > Deputy Public Defender
    > > (775) 337-4839
    > > jgoodnight@washoecounty.us
    >
    >
    >
    >
    >
    > Note, above is Joe Goodnights telephone number and email.
    >
    >
    >
    > --
    > This mail is sent via quick contact form on Ascent Reno Psychiatry http://ascentrenopsychiatry.com
    >
    --Forwarded Message Attachment--
    000316
    Print Close
    RE: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Mon 2/27/12 3:27 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Mr. Coughlin:

    E-mail works well for me.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, February 27, 2012 7:56 AM
    To: keithloomis@earthlink.net
    Subject: rmc 11 cr 26405 you are appointed counsel? for puentes ne taitel?

    hi, i guess Mr. Loomis was appointed as my 3rd defense attorney in RMC case 11 cr 26405. I have not heard anything about this case, and
    the RMC indicated they had nothing scheduled. Please communicate with me only via email or fax please, having issues with my mail
    incident to domestic violence committed against me my fax is 949 667 7402. thanks,
    Zach Coughlin
    court date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Mon 3/05/12 4:09 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Mr. Coughlin:

    I have requested that court set your trespass case for trial in about 30 days. I will let you know the date and time as soon as I know.

    Keith Loomis
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Wed 3/07/12 4:36 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin:

    On what grounds, other than those already set forth in your existing motion, do you believe a motion to dismiss should be filed?

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 07, 2012 12:45 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date
    000317

    Mr. Loomis,
    Please copy me on any and all correspondences, filing, or other documentation or verbal requests,
    correspondences, etc. that you submit to the Court, including the one you reference below.
    Please do not follow Taitel's tact of agreeing to requests or failing to oppose motions without
    even attempting to obtain my permission to in advance thereof.
    I would like for you to draft a Motion to Dismiss in this case for me review.
    Thanks,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: court date
    Date: Mon, 5 Mar 2012 16:09:19 -0800
    Mr. Coughlin:

    I have requested that court set your trespass case for trial in about 30 days. I will let you know the date and time as soon as I know.

    Keith Loomis
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Fri 3/09/12 10:14 AM
    To: zachcoughlin@hotmail.com
    No worries. Made me laugh.

    Couple of questions:

    Did you file an appeal from Justice of the Peace Sferrazzas eviction order?
    If yes, has it been resolved?

    Did Sferrazza announce at the close of the hearing on the 25
    th
    that he was granting the eviction and ask Hill/Baker to provide a written order?

    Did you ever see the eviction order posted by WCSO
    If yes, when?
    000318

    What is relevance of personnel files of Carter or Lopez?

    How is Dr. Merliss testimony material to the defense of this case?

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 08, 2012 12:46 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date

    Dear Mr. Loomis,


    I apologize Sir for what I am sure comes across as rudeness on my part. You seem like a good
    guy, and you have great hair. I simply don't have time, money or energy to do any of this the
    polite way given the "uniqueness" of this situation....Please just know I mean you no disrespect.
    Would you please file a request or Motion for the Personnel File of RPD Officer Chris Carter and
    Sargent Monica Lopez as well as supboena from the RPD all the volumns of crap Richard Hill has
    given them on this in addition to noticing the court and City Atty as to Richard HIll being a
    witness, subpoena him (though the earlier continuance would appear to imply he already is) AND
    SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO CAN GET HIS OUT DOWN HERE FOR
    THE TRIAL AND A DEPOSITION PRIOR THERETO, ETSPECIALLY CONSIDERING THAT THE VARIOUS
    POLICE REPORTS AND MOTIONS FOR ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE
    WAS AT THE PROPERTY IN THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY
    PUENTES GOT YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT
    CLEARLY). iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON
    ME, THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT.
    ALSO PLEASE FILE A MOTION TO dismiss based upon denial of right to a speedy trial, spoliation of
    evidence, etc....
    PEACE
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473

    Trial Date
    From:Keith Loomis (keithloomis@earthlink.net)
    Sent: Fri 3/09/12 10:44 AM
    To: zachcoughlin@hotmail.com
    1 attachment
    000319
    Coughlin Trial Setting.pdf (771.8 KB)
    See attached
    RE: Trial Date
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Mon 3/12/12 9:26 AM
    To: zachcoughlin@hotmail.com
    I can do that if there is a good reason to vacate the date. What is the reason?

    Keith
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 6:28 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Please file something with the court seeking to vacate that trial date and explaining that you failed
    to even once consult with your client prior to setting it.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: Trial Date
    Date: Fri, 9 Mar 2012 10:44:17 -0800
    See attached
    RE: court date
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Mon 3/12/12 10:02 AM
    To: zachcoughlin@hotmail.com
    This e-mail is sent to address the grounds you identified as forming the basis of a motion to dismiss. As you know there is both a constitutional right and
    a statutory right to a speedy trial. This case is nowhere close to a violation of the constitutional right to a speedy trial. The statute does provide for a
    right to trial within 60 days of arraignment in municipal court. NRS 178.556(2). In this circumstance the court may dismiss the complaint. The
    statute requires, however, that the trial not have been postponed at the request of the defendant. It is my understanding that the January 10, 2012, trial
    date, was postponed at your request. If that is true then there are not grounds to dismiss on the basis of a violation of a right to speedy trial.

    Dismissal based on spoliation is a civil concept. It has not been applied to criminal cases in Nevada as of yet. See Higgs v. State, 126 Nev. Adv. Opn 1
    (2010). Rather defendants in criminal cases are protected from the loss of evidence in the hands of the prosecution by the doctrine of due process.
    Consequently you might have a basis to request dismissal if the City Attorneys Office lost evidence, in its possession material to the case. In such case
    if the City acted in bad faith or with connivance or if you were prejudiced by the loss then there may be grounds on which to base a dismissal. Please advise
    as to what evidence was lost and how it was lost.

    You have not identified any other grounds as a basis for dismissal. If you believe there are other grounds, let me know.

    000320
    Thanks

    Keith Loomis









    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 08, 2012 12:46 AM
    To: keithloomis@earthlink.net
    Subject: RE: court date

    Dear Mr. Loomis,


    I apologize Sir for what I am sure comes across as rudeness on my part. You seem like a good
    guy, and you have great hair. I simply don't have time, money or energy to do any of this the
    polite way given the "uniqueness" of this situation....Please just know I mean you no disrespect.
    Would you please file a request or Motion for the Personnel File of RPD Officer Chris Carter and
    Sargent Monica Lopez as well as supboena from the RPD all the volumns of crap Richard Hill has
    given them on this in addition to noticing the court and City Atty as to Richard HIll being a
    witness, subpoena him (though the earlier continuance would appear to imply he already is) AND
    SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO CAN GET HIS OUT DOWN HERE FOR
    THE TRIAL AND A DEPOSITION PRIOR THERETO, ETSPECIALLY CONSIDERING THAT THE VARIOUS
    POLICE REPORTS AND MOTIONS FOR ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE
    WAS AT THE PROPERTY IN THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY
    PUENTES GOT YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT
    CLEARLY). iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON
    ME, THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT.
    ALSO PLEASE FILE A MOTION TO dismiss based upon denial of right to a speedy trial, spoliation of
    evidence, etc....
    PEACE
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000321

    RE: Trial Date


    From:Keith Loomis (keithloomis@earthlink.net)You moved this message to its current location.
    Sent: Wed 3/14/12 2:35 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    My obligation under Nevada Rule of Professional Conduct 1.2 is to abide by a clients decision concerning the objectives of representation and, as
    required by Rule 1.4 to consult with the client as to the means by which the objectives of representation are to be pursued. In a criminal case the lawyer
    shall abide by the clients decision, after consultation with the lawyer, as to plea to be entered, whether to waive jury trial whether the client will testify.

    Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any relevant limitations on the lawyers conduct when the lawyer knows that the client
    expects assistance not permitted by the Rules of Professional Conduct or other law.

    Under Rule 2.1. In representing a client, a lawyer shall exercise independent professional judgment and render candid advice. In
    rendering advice, a lawyer may refer not only to law but to other considerations such as moral economic, social and political factors, that may be relevant
    to the clients situation.

    Under Rule 3.1. A lawyer shall not 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 frivolous, which includes a good faith argument for an extension, modification or reversal of existing law. A lawyer for a
    defendant in a criminal proceeding that could result in incarceration, may nevertheless so defend the proceeding as to require that every element of the case
    be established.

    Under Rule 3.2(a) and (b). A lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.
    The duty stated in paragraph (a) does not preclude a lawyer from granting a reasonable request from opposing counsel for an accommodation, such as an
    extension of time, or from disagreeing with a clients wishes on administrative and tactical matters, such as scheduling depositions, the number of
    depositions to be taken, and the frequency and use of written discovery requests.

    Under Rule 8.4(d) It is misconduct for a lawyer to engage in conduct which is prejudicial to the administration of justice.

    These, and others, are the professional rules I operate under in providing legal representation to you in case number 11 CR 26405, a case in which you are
    charged with the crime of trespass. It is my understanding that your objective in this criminal case is that you be acquitted of the crime of trespass. That
    is my purpose in representing you. I am happy to work towards that outcome to the best of my ability. It is my opinion, however, that much of what you
    ask to be done is not in compliance with the above rules. Accordingly, I will not be filing a motion to dismiss based upon NRCP 6(a) and (b), I see that
    argument as frivolous. I will not be proceeding with the summoning of an out-of-state witness (Merliss) unless you can establish his materiality to the
    defense. Nor will I be subpoenaing the personnel records of law enforcement personnel unless you can establish to my satisfaction why they are relevant to
    this case. I have no intention at this time of conducting any depositions in the case or sending requests for production of documents or interrogatories in
    the case. I see these actions as unduly burdensome on the judicial system, and unwarranted by anything you have provided to this point. I also see them
    as frivolous and an attempt to utilize the criminal justice system to accomplish objectives not relevant to my purpose in representing you.

    If you are dissatisfied with the limitations I perceive to exist regarding my representation of you, you are welcome to terminate my representation of you.
    You may then ask the Court to appoint a new lawyer to represent you.

    It is my understanding that Deputy Machem will be testifying in the case along with Richard Hill and Casey Baker.

    000322
    I do think that there are some interesting angles to the case upon which a defense can be based and I will be pursuing those angles. I have asked you in
    previous e-mails to provide information which I believe will be helpful to the defense of your case.

    I advise you that the City has offered to recommend time-served as a sentence if you enter a no-contest plea to trespass. It is also my understanding that
    you have other criminal cases pending in both Reno Justice Court and in the Second Judicial District Court of the State of Nevada. It is my understanding
    further that all of the criminal cases can be resolved in a single plea to a misdemeanor offense if you will obtain psychological counseling. It is my
    obligation to inform you of the availability of these resolutions to the present criminal case in which I provide representation. I will, of course, abide by your
    decision as to whether to accept these resolutions or not.

    I note that there is a psychiatric evaluation scheduled for you in 2
    nd
    Judicial District Court Case No. CR12-0376 on April 3, 2012. The outcome of that
    evaluation could have an important impact on this case. I am asking that you authorize a release of the information contained in the evaluation to me so
    that I may determine what impact it could have on your behalf in this case.

    I remain prepared to represent you in the trespass case. I think that a trial of the case will be interesting. My representation, however, is circumscribed by
    the Nevada Rules of Professional Conduct.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, March 13, 2012 4:29 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Dear Mr. Loomis,

    In your motion to dismiss, I would like you to really focus on and set forth to the court the fact that the eviction
    order needed to be served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules of practice. The provisions of NRS,
    Nevada Rules of Civil Procedure and Nevada Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent
    with the provisions of NRS 40.220 to 40.420, inclusive, apply to the proceedings mentioned in those sections.

    The language about "removing the tenant with in 24 hours of receipt of the order" is only applicable to those situations where the tenant does
    not file a Tenant's Answer or Tenant's Affidavit. I did file such a Tenan'ts Affidavit, and litigated the matter thoroughly. In those
    situations, NRS 40.400 requires NRCP to apply, specifically NRCP 6(a) and 6(e), and clearly WCSO Machem (please subpoena and identify
    as witnesses Mary Kandaras, Esq. of the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO Civil Division supervisor Liz Stuchell
    for the trial in this matter, and further send out a request for production and subpoena duces tecum to the WCDA and the WCSO askign them
    to specify, in writing and in detail, the exact procedures and policies in place with respect to the service and conducting of such lockouts (ie,
    not default lockouts where there is not a summary eviction hearing, but one's like the present one, where there was a Tenant's Answer and
    hearing held, etc....). Be sure to ask whether the are aware of what "personally served" means, and whether they mail the Orders on top of
    merely posting them to the door. Further, I have been told that the WCSO has a policy or penatly system in place whereby the deputies
    must get these lockouts performed "within 24 hours of receipt of the order" the receipt being the WCSO's receipt, and not the tenant's
    receipt. I don't ncessarily read the statute that way, but....the WCSO policy and punishment system would be at least some indication of
    what the legislature meant (I guess, but I dont' really think so, though, you will note that Hill was left with nothing but citing to the "usual and
    customary practice of the WCSO" in serving the Eviction ORders and performign lockouts, I believe, because the law does not contain much
    to support Hill's contention and therefore he wishes to see the WCSO "customary practices" being given the weight of law.

    Please see some specific selections attached from the eviction matter. I know, I know, you want to curtail the scope of your representation
    to an immaculate degree....but Hill can clearly be seen in his various Motion to Show Cause, State Bar Grievances, Temproary Protection
    Order Applications, etc., etc., to be a punk who doesn't much like competing on an even playing field, like any good private schooler, he
    would rather sick an attack dog on somebody than get in the octogon and go toe to toe mentally. Regardless, Hill shows a continual desire
    to subvert NRCP 6(e), which applies to service of documents filed elecronically in the Second Judicial District Court. He would rather
    withhold opposing counsels computers, laptops, client files, driver's license, etc. The last thing he wants is to go argument for argument,
    research for research, writing for writing. Private school and daddy's pleading bank. Hill files a Motion to Show caue allegeing Coughlin
    subvreted an Order that was filed on January 11th, 2012 with Couglin's action of January 12th, 2012. Under NRCP 6(e), the Order Denying
    the TRO had not even been served yet, and there has been no indidcation that Hill gave the Order at the town dump to anyone other than an
    RPD Officer.
    000323

    Further, it is not all that clear why Hills Motion for ORder to Show Cause deserves a full blown hearing when D7 does not indicate a hearing
    will be accorded to the appeal. This is particularly suspect given that Anvui sets forth that appeals in summary eviction matters are done on
    a trial de novo basis.
    There are a number, but how about your complete lack of communication with me prior to so setting that date.
    How about Mr. Taitel and Mr. Puentes's failure in this matter and the prejudice to my case so created? How
    about your failing to identify yourself as the public defender to a room full of defendants in jail at the arraignment?
    There are other reasons as well, including, but not limited to, your resistance to subpoena the materials I have and
    am requesting.

    I wish for you to subpoena the personnel files of both RPD Sargent Monica Lopez and Officer Chris Carter. I wish
    for you to list Dr. Merliss as a witness and subpoena his appearance and appropriately notice the City of Reno in
    that regard, same goes for Richard Hill and Casey Baker (Baker, by letter dated November 10th, 2011 demands the
    full rental value for the property as "storage" under NRS 40.253, while also asserting he will go after moving and
    inventory costs, in addition to Hill's contractor Phil Stewarts later ridiculous charges and perjury. Please subpoena
    Stewart as well.

    Most importantly subpoena Washoe County Sheriff's Office Deputy Machem to testify and serve a subpoena
    dueces tecum, requests for production, and interrogatories seeking records and responses from the WCSO as set
    forth in the letter I sent Liz Stuchell (see attached) on or about February 10th, 2012. You see, the WCSO and
    Deputy Machem may be committing a fraud upon the public by repeatedly filing affidavits of service that attest to
    personal service where Liz Stuchell, of the WCSO admits that they clearly do not know, or choose to "remix" the
    legal meaning of "personally serve".

    Further, please inform the City of Reno and appropriately notice the same as to the existence and intent to offer
    into evidence a video of Richard Hill, Esq., admitting that he and his firm, on behalf of Dr. Merliss, were withholding
    the accused personal property, in addition to the client's files from the former commercial lease home law office
    of the accused and asserting a lien, under NRS 40.253 for "storage", however, as the video tape shows, Hill admits
    to charging the undersigned the same $900 per month rent as was charged for the "full use and occupancy" of the
    premises at 121 River Rock St., Reno, NV 89512. Hill further demands that property be removed in a certain
    order, regardless of whether his articifically inflated lien was paid or not. Additionally, Hill committed fraud upon
    the court in a number of instances and filed false police reports wherein he alleges that he agreed to or otherwise
    made available to the accused items such as the accused's clients files (and for a time wallet and state issued
    driver's license) where, clearly, without requiring any payment by the accused, however, clearly, the facts show that
    Hill never actually lived up to those assertions and repeatedly failed to show provide such items absent payment of
    his artifically inflated lien.

    Further, I wish for you to divulge and provide notice that it is available for pickup and that we intent to introduce
    into evidence a video of RPD Sargent Monica Lopez admitting that she and RPD Officer Carter did not identify
    themselves as police officers or otherwise ask the accused to leave 121 River Rock St. on the date of the arrest prior
    to Merliss opening the door to the basement. This is apparently in direct contradiction to the sworn filings made
    by Richard Hill, Esq. in his affidavits attached to his various Motions to Show Cause, the Reply to Opposition
    thereto, Opposition to TRO, etc., etc. (in RJC Rev2011-001708 and the appeal in CV11-03628). For that reason
    alone Merliss' presence is required. He was a precipient witness and you are asking me why he should be there?
    You have a duty to zealously advocate on my behalf, Mr. Loomis. You are paid, by the public, to do so.
    Please divulge any prior associations you have with anyone employed by or workign as an independent contractor
    with the RMC and or the Reno City Attorney, including anyone you went to law school with or attended the same
    law school as, within a 5 year period.

    Further, I wish for you to file a motion seeking a mistrial or otherwise requiring the recusal of the RMC and further
    disclosing why it is that Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth
    recuse Judge Dilworth?) in one case, without detailing why exactly, while Judge Gardner apparently is intent on
    remaining on in 11 CR 26405, despite the fact that an apparent conflict exists, one which he only disclosed upon
    prompting from the accused, with respect to Judge Gardner's very recent employment with the Reno City
    Attorney's office and the existing and or brewing litigation (or, at least, possible litigation) between the accused and
    000324
    the City of Reno, Reno City Attorney, and possibly, the RMC.

    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473

    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: RE: Trial Date
    Date: Mon, 12 Mar 2012 09:26:35 -0700
    I can do that if there is a good reason to vacate the date. What is the reason?

    Keith
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 6:28 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date

    Please file something with the court seeking to vacate that trial date and explaining that you failed
    to even once consult with your client prior to setting it.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: Trial Date
    Date: Fri, 9 Mar 2012 10:44:17 -0800
    See attached
    RE: i was evicted 3 15 12, i need a continuance
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Wed 3/28/12 2:03 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    This message is sent to address issues raised in the e-mail you sent on 3-26-12.

    1. Please note that you are free to send the communications you send to me, to anyone else you desire. You should be aware that
    sending your communications to other parties will cause your communications to me to lose their attorney-client confidentiality.
    000325
    2. For what specific purposes do you need a continuance? A continuance purely for the purpose of delay is not a proper reason for a
    continuance.
    3. Whether you are entitled to e-mail the Reno Municipal Court is not my concern. That is a problem to be addressed between you and
    the Court.
    4. Ms. Drake is no longer the attorney handling your case for the Reno City Attorneys Office. Your case is now being handled by
    Christopher Hazlett-Stevens, Esq.
    5. In response to your question regarding the weaknesses of the trespassing case I offer the following:
    a. The complaint is deficient in that if fails to set forth the elements of the crime of trespass. It fails to identify whether your
    presence on the premises was for the purpose to vex or annoy the owner or occupant of the premises or whether it was an entry onto
    the premises after a warning not to so trespass. This is probably easily remedied by an amendment at the time of trial.
    Nevertheless these are alternative theories on which a trespass case can be pursued and the defendant is entitled to know on which
    theory or theories a case is being prosecuted in advance of showing up for trial.
    b. You filed an appeal on October 19, 2011, apparently, of the order made by Justice of the Peace Sferrazza on October 13, 2011.
    That order denied your request for a continuance and granted summary eviction unless you filed a deposit with the court. Typically
    the courts lose jurisdiction to rule on other matters in the case once an appeal is taken. It is clear from the court records that this
    appeal was pending before the Second Judicial District Court at the time the court held a hearing on the unlawful detainer on October
    25, 2011. It may well be that the Justice Court lost jurisdiction to hold the eviction hearing while the appeal was pending.
    c. I am working on some other thoughts.
    6. If you are dissatisfied with the way I am representing you, you remain free to seek a new attorney.
    7. Another chuckle regarding my ownership of strip clubs. I dont own or have any ownership interest in any strip clubs, brothels,
    adult book stores or movie houses. I guess that leaves me free to moralize.
    8. I still dont see the importance of Dr. Merliss. The request for payment of an amount equal to rent, was for storage of your
    personal property. You are entitled to contest the amount of the storage fee, which you did. There is no credible evidence anywhere which
    suggests that anyone intended to reopen or create a new tenancy allowing you to retain possession of the premises.
    9. Dr. Merliss is an out of state witness. In order to compel his appearance, his testimony must be material. NRS 174.425(1). It does not
    appear that his testimony is material under the information you have provided Further, under NRS 174.425(2) he is entitled to be paid his
    subsistence and travel expenses incurred in coming to Nevada. Are you prepared to pay those expenses in advance of his coming to Nevada?
    10. I dont intend to fax or e-mail to you, your full file in this case. You already have everything with the exception of a couple of items
    which I mailed to your old address. I will send them again to your new address. If you want to review the file you are welcome to do so at
    my office. If you want copies of anything in the file you may mark the items. After giving you a cost estimate, for which I require payment in
    advance, we will provide you with copies of the marked items.

    Keith Loomis


    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 10:33 PM
    To: keithloomis@earthlink.net; stermitz@sbcglobal.net; jmd@randazza.com; jboles@callatg.com; kristiemanning@yahoo.com;
    kadlicj@reno.gov
    Subject: i was evicted 3 15 12, i need a continuance

    Dear Mr. Loomis,


    I was wrongfully evicted on 3 15 12, and I need a continuance in the criminal trespass matter that
    you set overly quickly against my express wishes anyway. My ability to collect evidence
    necessary to my defense and otherwise prepare has been adversely affected. Additionally, I don't
    000326
    feel as though you are performing in an appropriate manner as defense counsel, but rather you
    seem stuck in your prosecutorial ways, too quick to look for any excuse whatsoever to bury one's
    case, so I think you have forced a split here, which further prejudices my case and augers towards
    a continuance. Please move for one immediately and copy me on my entire file by email and
    fax please. Additionally, please seek clarification from the RMC as to whether I am allowed to
    ever send an email to renomunicrecords@reno.gov. Please note, today, Judge Flanagan denied
    Richard Hill's latest frivolous motion.
    Did you know that Kevin Kelly, of the State Bar of Nevada's Character and Fitness Committee for at
    least the last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
    http://www.reviewjournal.com/lvrj_home/2002/Mar-06-Wed-2002/news/18241452.html
    I know I always like my three hour tours of heavy handed moralizing from someone who runs a
    monolithic strip club in Las Vegas.
    You are on the State Bar of Nevada's fee dispute committee, aren't you Mr. Loomis? Do you
    own any strip clubs?
    Mr. Loomis, which of the elements of the trespass charge RMC 8.10.040 do you feel are weakest
    for Deputy City Attorney Jill Drake, whom I informed about the admission by Reno PD Officer
    Chris Carter that Richard G. Hill, Esq. bribes him, but for which Ms. Drake indicated a complete
    lack of interest and expressed that she would not be following up on that report of bribery of a
    RPD Officer. Mr. Kadlic, please place a copy of this correspondence in Jill Drake's personnel
    file. Additionally please place one in Allison Ormaa's personnel and employment file too, in
    addition to Deputy City Attorney Dan Wong's employment file, as all three of those Deputy City
    Attorney's were provided that report and all three indicated they did not care and had no
    intention of following up or otherwise investigating the admission by RPD Officer Chris Carter that
    Richard G. Hill, Esq. bribed him. I think the failure to follow up by any of these 3 Deputy City
    Attorney's relates to any future negligent hiring, training, and supervision claims that the Reno
    City Attorney may need to defend against when representing the Reno PD like it did in the Eeof
    v. Pitsnogle case:
    http://www.lvrj.com/news/reno-official-accused-of-witness-tampering-116586528.html
    You know, Deputy City Attorney Ormaas's decision to push on for that $70
    traffic ticket is looking more and more interesting. \\
    Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his
    understanding of the extent to which his attorney, Richard G. Hill, Esq. had
    effectively rescinded any eviction Order by sending a bill for the same
    amount as full use and occupany of the location at 121 River Rock St. goes to
    the substance of the elements found in RMC 8.10.040 as well as the
    credibility of both Merliss and Hill.
    000327
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: i was evicted 3 15 12, i need a continuance
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Thu 3/29/12 4:59 PM
    To: zachcoughlin@hotmail.com
    Mr. Coughlin:

    I previously sent you the setting slip for your trial in this matter by e-mail on March 9, 2012. That setting slip set your trial for April 10, 2012 at 8:00
    a.m. in Dept 2 of the Reno Municipal Court.

    I am available to meet. Best times for me next week are Monday afternoon, Thursday afternoon or Friday morning. Let me know which is best for
    you and I will set aside time for an appointment.

    No I am not going to send you my case plan in writing with reference to citations and copies of legal research etc. (You might take cognizance of the
    fact you sent my last discussion of your case to the Reno City Attorneys Office-notoriously poor strategic and tactical move on your part).

    No skin in the game.

    Keith Loomis


    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 12:04 PM
    To: keithloomis@earthlink.net
    Subject: RE: i was evicted 3 15 12, i need a continuance

    Mr. Loomis,
    Can you please indicate to me, via email, if there is a Trial Date or any other court date set in this
    matter, and, if so, provide the Date and Time. I would like to meet with you, when are you
    available to do so? Also, please indicate in writing what your plan is for this case and what you
    have done to zealously advocate on my behalf, including specifics regarding any legal research
    you have culled (and please provide citations and copies of the research gathered to me,
    preferably by email). In your duties on the State Bar of Nevada's Fee Dispute Committee, have
    you ever had a fee dispute from a client of a public defender? Do public defenders have any
    skin in the game?
    Sincerely,
    000328
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC
    seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing
    RPD on bribery and retaliation
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Thu 3/29/12 5:05 PM
    To: zachcoughlin@hotmail.com
    Dear Mr. Coughlin:

    There has not been, as of yet, a trial as to which a mistrial could be declared in this case. A motion for mistrial is consequently premature.

    I am only representing you as to your trespass case over which Judge Gardner is presiding. I am not representing you in regards to any other criminal
    case over which any other Reno Municipal Court Judge is presiding. If you believe there are grounds to seek the recusal of Judge Gardner in regards
    to your trespass case, please identify what those grounds might be.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 2:44 PM
    To: keithloomis@earthlink.net
    Subject: FW: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court
    after cross examing RPD on bribery and retaliation
    Importance: Low

    Dear Mr. Loomis,


    Please file a motion for a mistrial and a motion to conflict out any RMC Judge from hearing any criminal case where I am a defendant.
    Thanks,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: dgentile@gordonandsilver.com; renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com;
    defense@freeman-law.com; ed@npri.org; mkandaras@da.washoecounty.us; mark@markmausertlaw.com
    Subject: City of Reno Marshal Division Harrassment, hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after
    cross examing RPD on bribery and retaliation
    Date: Thu, 29 Mar 2012 14:39:17 -0700
    Dear City of Reno,
    Please place a copy of this in Marshal Coppa's and the other Marshal who transported me to jail
    on 2/27/12's employment/personnel file as he was the one who went into a backroom of the "Sally
    Bay" at the jail after whispering in the WCSO Deputy Cheung's ear. Please ask him about the bag
    with the micro sd card, the various contradictory statements made by RMC staff, Reno Marshals,
    and WCSO staff with respect to the chain of custody of the seized property, with particular
    000329
    attention focused on Marshal Harley's statements concerning any micro sd card, Debi Campbell's
    assertions in that regard, what Pam Willmore heard WCSO Deputy Hodge admit with respect to
    the WCSO retention of the micro sd and other property, comparing that with any recordigns of
    that conversation that may exist, and further referencing the statements of Ms. Campbell,
    Cummings, and Beckman, while also reviewing any recordings made of telephone conversations
    with WCSO Detention Facility Staff shortly after Coughlin was released from jail on
    Please find new attachments herein including the emailed responses of WCSO agents
    Cummings, Debi Campbell, and Trish Beckman.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: renodirect@reno.gov; kadlicj@reno.gov; rcornlaw@150.reno.nv.us; stermitz@sbcglobal.net; office@bdjlaw.com; defense@freeman-law.com
    Subject: City of Reno Marshal Division hanging up phone on me, RMC seizing Reno Attorney's smart phone and cell phone etc. in court after cross examing
    RPD on bribery and retaliation
    Date: Thu, 29 Mar 2012 14:05:54 -0700
    Dear City of Reno and Mr. Jeanney,
    I was told by the Washoe County Sheriff's Office to call the City of Reno Marshal's division to
    inquire about the return of the personal property that was seized from me incident to a 2/27/12
    arrest for summar contempt during the traffic trial in 11 tr 26800 before Judge Nash Holmes. I
    called the number held out as the Marshals Division contact number http://reno.gov/index.aspx?page=223
    And a "Bill" answered the phone, was evasive, indicated he did not work for the Marshal's division,
    would not give me any contact information for a Marshal, any Marshal, told me he wasn't going to
    answer me stupid questions, and hung up on me.
    I called back and I believe it was Marshal Harley who answered (though I am not sure) and he
    answere the phone in an unprofessional manner, guessing as to my identity in some show of
    menace. Rather than tjust answer the phone like a professional and provide me the number
    for Marshal Dayton, as I was requesting, this individual refused to provide the number, answered
    the phone on a "gotcha" type way where there was nothing to "gotcha", then hung up the phone
    on purpose after declaring that he would not give me Marshal Dayton's number or take a
    message. Please place a copy of this correspondence/complaints in "Bill" of court security for the
    Reno Munic Court, and Marshal Harley's file and follow up this grievance. I am available to
    comment on this unprofessional conduct further. Please also find attached other recent
    complaints I have submitted regarding the Marshal Division and place them in the individual's
    complained of employment/personnel files. There will be no ability to allege a lack of
    knowledge of this conduct in any future negligent hiring, training, and supervision lawsuit incident
    to any misconduct alleged. I a requesting that a full scale investigation/inquiry be conducted
    pursuant to the various conflicting, and inconsistent statement made with respect to the seized
    personal property (inlcuding my phones, etc.). You might want to consider whether any Washoe
    County Sheriff's Deputies have made statements that will conflict with anything the City of Reno
    may say from hear on out. Given problems associated with my recently being adjudge a victim
    of domestic violence (my vulnerability in that regard made moreso by Judge Nash Holmes seizing
    my cell phones and attempt to have my incomed reduced through jeopardizing my law license,
    etc.) please correspond with my in writing only and only by email and or fax.
    000330
    Sincerely,
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    --Forwarded Message Attachment--
    Name JAMES MENZEL
    Position
    Marshal
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost of retirement benefits is
    included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $60,609.42
    Overtime and
    Callback $622.67
    Collected
    Total Pay $63,750.96
    Benefits
    Accumulated
    $22,425.49
    Total Pay &
    Benefits
    $86,176.45
    Detail page for JAMES MENZEL
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JOEL HARLEY
    Name JOEL HARLEY
    7821 - Marshal
    Position
    Reno
    000331
    Year 2010
    Base Pay $85,323.07
    Overtime and
    Callback Collected
    $6,755.56
    Other Pay $478.65
    Total Pay $92,557.28
    Benefits Accumulated N/A
    Total Pay & Benefits $124,126.82
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JUSTIN ROPER
    Name JUSTIN ROPER
    Position
    7819 Marshal Commander
    Reno
    Year 2010
    Base Pay $107,914.00
    Overtime and
    Callback Collected
    $0.00
    Other Pay ($2,697.89)
    Total Pay $105,216.11
    Benefits Accumulated N/A
    Total Pay & Benefits $145,144.36
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    000332
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Name JAMES MENZEL
    Position
    Marshal
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost of retirement benefits is
    included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $60,609.42
    Detail page for JAMES MENZEL
    Overtime and
    Callback $622.67
    Collected
    Total Pay $63,750.96
    Benefits
    $22,425.49
    Accumulated
    Total Pay &
    $86,176.45
    Benefits
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JOEL HARLEY
    Name JOEL HARLEY
    7821 - Marshal
    Position
    Reno
    Year 2010
    Base Pay $85,323.07
    Overtime and
    $6,755.56
    Callback Collected
    000333
    Other Pay $478.65
    Total Pay $92,557.28
    Benefits Accumulated N/A
    Total Pay & Benefits $124,126.82
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Detail page for JUSTIN ROPER
    Name JUSTIN ROPER
    Position
    7819 Marshal Commander
    Reno
    Year 2010
    Base Pay $107,914.00
    Overtime and
    Callback Collected
    $0.00
    Other Pay ($2,697.89)
    Total Pay $105,216.11
    Benefits Accumulated N/A
    Total Pay & Benefits $145,144.36
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    RE: request for a pre trial motion and bail motion
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Tue 8/07/12 9:55 AM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Zach
    000334

    Why dont you move to represent yourself. That way you will be completely satisfied with the services you provide yourself and can do all of the
    things you believe are necessary.

    If you want me to continue to represent you, what I asked you to provide to me was a description of the events which lead to the charge of disturbing
    the peace. I still need that description.

    Keith Loomis
















    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, August 06, 2012 3:54 PM
    To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
    Subject: request for a pre trial motion and bail motion

    Dear Mr. Loomis and City Attorney Kadlic and Deputy City Attorney Drake,

    I am writing to request that you file some motion to alter, amend, reconsider, set aside, or modify my bail in the case stemming from my JUly 3, 2012 arrest
    for distrubing the peace, failure to provide proof of insurance, and failure to secure a load. I am writing to request that you file a pre trial motion (Motion to
    Dismiss, request for a pre trial motion and bail motion, and motion to supress police report based upon the DTP arrest occuring for alleged conduct outside the
    officer's presence). If you will not file these motion (and please provide me a draft of such motions for my review prior to filing them as well as prior to
    making any communication on my behalf to either the RMC or the City of Reno Prosecutor), please provide me a written indication of your rationale for so
    refusing, and then please file a Motion to Withdrawal as soon as practicable. I ask this respectfully.

    The police showed up to the hearing, yet I was not noticed of that fact in advance, or of the hearing itself. Further, Judge Gardner explicilty indicated he
    000335
    was basing his decision to raise the bail based upon "public safety" and "concern for the defendant's safety", which are impermissible rationale for so increasin
    one's bail.

    NRS
    178.498. Many courts use a bail schedule to determine the amount, but note the
    initial amount can be increased if good cause is shown. NRS 178.499. Additionally, in
    determining the amount of bail, the judge should look at the following factors (NRS
    178.498):
    The nature and circumstances of the offense charged
    The defendants financial ability to post bail
    The defendants character; and
    The factors listed in NRS 178.4853.
    Bail can not be excessive. U.S. Const. Amend. VIII. It should be limited to a
    reasonable amount designed to ensure the defendants presence in court. It should not
    be a corrective or preventative detention device.

    NRS 178.484. The Court should take care in imposing any restrictions on a defendants constitutional rights (i.e.,
    search and seizure) and only imply such restrictions if warranted by the underlying facts
    of the alleged crime. Section 11 of NRS 178.484 describes the document that must
    be signed by the defendant before he/she can be released on bail.

    My bail hearing contained what seems to be an impermissible coercive attempt to condition my release or the possibility thereof upon my providing
    confidential medical records (Lake's Crossing etc) to the Reno Municipal Court, even where the same judge presiding over the bail hearing found me
    competent enough to face a criminal trepass trial less than two weeks before teh bail hearing in 11 CR 26405.

    The friend of mine who posted my bail, Jared Swanson, has a serious form of cancer and a one year old baby. I request a reduction of the bail for his
    benefit and for the proof of insurance charge to be dismissed, as (and I am trying to avoid this in any way I can), if I am rearrested, such a proof of insurance
    charge may present another basis for imposing an unduly burdensome bail upon me, as it did on July 5th, 2012 where, despite my having produced a legible
    pdf copy of my proof of insurance card on my large screened zoomable smart phone, Officers Weaver and Dye still charged me with that violation, and the
    bail was subsequently increase. Further, none of the events or accusations forming the basis of the distrubing the police charge occurred in the officer's
    presence, and the police report contains no indication whatsoever that the arrest was made based upon NRS 171.1771. I provided Officer Weaver my
    driver's license prior to the arrest. I did not
    refuses to give a written promise to appear in court as provided in NRS 171.1773.

    When a person is believed to have committed a misdemeanor offense, the peace officer has the discretion to
    either issue a citation or arrest and detain the person. NRS 171.1771 states that a person can be arrested if
    his identity is questionable or if the peace officer does not believe the person will appear in court. A person
    can also be arrested for a misdemeanor offense if a warrant has been issued.

    Additionally, I am requesting that you file a Motion to Dismiss the Disturbing the Peace charge based upon a lack of evidence and or insufficiency of pleading
    in that the allegations do not amount to a prima facie case of a DTP violation. Further, please subpoena and or collect the Protection Order application filed
    by Milan Krebs on July 5th, 2012, and interview Krebs as to why he mentions Coughlin often carrying around a large knife in a menacing manner in that
    protection order application, yet completely failed to mention that in his July 3rd, 2012 police report. Additionally, please determine why Kreb's TPO
    appliication has a different style of handwriting on the caption compared to the descriptive sections, indicating someone pushed the filing of the TPO on Krebs,
    perhaps his employer, Northwind Apartments or the RPD, which has in the days preceding the arrest threatend to arrest Coughlin for criminal trespass if he
    returned to any part of the premises of Northwind Apartments, in consideration of Coughlin's eviction from unit 29, despite the fact Coughlin still had a valid
    000336
    right to go to his other two rentals, units 45 and 71, in addition to the fact that Northwinds essentially withdrew or rescinded its June 28th, 2012 eviction of
    Coughlin by posting an Amended 5 Day Unlawful Detainer Notice on unit 29 on June 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada
    Courts Services that the July 14th, 2012 5 Day notice was not "personally served" (NCS's R. Wray lied about effecting personal service, as he could not
    possibly have verified someone of "suitable age and discretion" was within the windowless room with a metal door closed and locked and where no Wray
    admits that he received no verbal response from the unit or anyone therein upon his knocking on the door and or attempting to break into the unit, please see
    Soldal v. Cook County in that regard, a US S. Ct case) and therefore Coughlin would have had until at least noon on July 28th, 2012 to file a Tenant's Answer,
    whereas the eviction/lockout/arrest of June 28th, 2012 took place two hours before noon at 10 am).

    Additionally, RPD Officer Weaver had previously attempted to break into one of my rentals at Northwind at a time when he lacked a warrant and or an exigent
    rationale for doing so, much less an eviction Order. I just want this case to be dismissed and to try to move on in life, and difuse the tensions incident to
    this case.

    I did not disturb the peace at Northwinds as alleged, nor did I make the threats Kreb's accuses me of or stalk him or follow him in a threatening manner at
    any time. Additionaly, I never broke into nor did I ever attempt to break into Krebs' truck, and in fact, I filed a police report in June 2012 reporting
    extortionate threats by another maintenance man at Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne Jakob, wherein they
    threatened to make such a spurious allegation, but subsuquently refrained from doign so when it apparently occurred to them that I may have excuplatory
    video evidence disproving such an allegation as well as capturing their baseless and extortionate threats and accusations. Additionally, please subpoene the
    police reports I filed with the RPD and any emails I sent to any officers (including Weaver, Barnes, Sargent MIiller, LIeutenant Brown) and any reports of or
    recording of phone conversations I had with any of those RPD personnel. Further, please see the attached june 26th, 2012 email to the RPD, WCSO, RJC,
    Sparks Justice Court and others pointing out the insufficiency of the 5 day Notice drafted and posted by non-lawyers Nevada Court Services, in that under
    NRS 40.253 it listed the wrong forum for the tenant to file a Tenant's Answer, and under the Aiken decision of the Nevada Supreme Court and NRCP 60(b)(4),
    any lockout order stemming therefrom is void for lack of jurisdiction.

    NRS 171.136 When arrest may be made.

    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:...
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation
    or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;...
    (g) When the person is already in custody as a result of another lawful arrest; or

    Krebs did not immediately arrest me under NRS 171.136(2)(d), nor was the DTP arrest for an offense alleged to have occurred in the officer's presence.

    the attached videos are of the incident on June 5th, 2012, not from July 3rd, 2012, but they support my contentions and the relevancy of subpoening the
    police incident reports and other documentation should this case not be dismissed, nolle prosequi, de minimis, etc....

    I will forward to you my emails to the RPD et all from June 26th, and July 2nd, 2012. I realize their tone was not a smart one to take or appropriate and am
    only sending them in hopes of having this matter dismissed. I do not have any interest in pursuing anything like Wheeler v Cross 344 Fed Apps 420 (
    (2008.

    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    000337
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
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    From:NvRenoPd@coplogic.com
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    To: zachcoughlin@hotmail.com
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    000338
    6/11/12
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    000339
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    Your Online Police Report 120103420 Has Been Approved
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    RE: request for a pre trial motion and bail motion
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Tue 8/07/12 4:25 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    You have already had two bail hearings. You are out on bail now. I decline to file a new request for a bail hearing.
    I will be out of town on vacation from Friday August 10 and will return on Monday Aug. 20. That makes attendance at a bail hearing problematic and
    unlikely to be heard before your trial.
    I do think the complaint fails to allege the charge of disturbing the peace. I will make the motion to dismiss it at the time of trial.
    The fact that the officer did not observe you committing a misdemeanor means he was not entitled to arrest you. You have a civil claim
    against RPD and the officer. That does not mean the charge of DTP is subject to dismissal.
    I will review the case involving Mr. Krebs and his request for a temporary protective order.
    I need your description of what happened on the 3
    rd
    of July. Will you provide it?

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, August 07, 2012 3:38 PM
    To: Keith Loomis
    Subject: RE: request for a pre trial motion and bail motion

    Are you refusing to file the motions o requested?


    -----Original Message-----
    000340
    From: Keith Loomis
    Sent: 7 Aug 2012 16:55:44 GMT
    To: 'Zach Coughlin'
    Subject: RE: request for a pre trial motion and bail motion
    Zach

    Why dont you move to represent yourself. That way you will be completely satisfied with the services you provide yourself and can do all of the
    things you believe are necessary.

    If you want me to continue to represent you, what I asked you to provide to me was a description of the events which lead to the charge of disturbing
    the peace. I still need that description.

    Keith Loomis
















    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, August 06, 2012 3:54 PM
    To: keithloomis@earthlink.net; drakej@reno.gov; kadlicj@reno.gov
    Subject: request for a pre trial motion and bail motion

    Dear Mr. Loomis and City Attorney Kadlic and Deputy City Attorney Drake,

    I am writing to request that you file some motion to alter, amend, reconsider, set aside, or modify my bail in the case stemming from my JUly 3, 2012 arrest
    for distrubing the peace, failure to provide proof of insurance, and failure to secure a load. I am writing to request that you file a pre trial motion (Motion to
    Dismiss, request for a pre trial motion and bail motion, and motion to supress police report based upon the DTP arrest occuring for alleged conduct outside the
    000341
    officer's presence). If you will not file these motion (and please provide me a draft of such motions for my review prior to filing them as well as prior to
    making any communication on my behalf to either the RMC or the City of Reno Prosecutor), please provide me a written indication of your rationale for so
    refusing, and then please file a Motion to Withdrawal as soon as practicable. I ask this respectfully.

    The police showed up to the hearing, yet I was not noticed of that fact in advance, or of the hearing itself. Further, Judge Gardner explicilty indicated he
    was basing his decision to raise the bail based upon "public safety" and "concern for the defendant's safety", which are impermissible rationale for so increasin
    one's bail.

    NRS
    178.498. Many courts use a bail schedule to determine the amount, but note the
    initial amount can be increased if good cause is shown. NRS 178.499. Additionally, in
    determining the amount of bail, the judge should look at the following factors (NRS
    178.498):
    The nature and circumstances of the offense charged
    The defendants financial ability to post bail
    The defendants character; and
    The factors listed in NRS 178.4853.
    Bail can not be excessive. U.S. Const. Amend. VIII. It should be limited to a
    reasonable amount designed to ensure the defendants presence in court. It should not
    be a corrective or preventative detention device.

    NRS 178.484. The Court should take care in imposing any restrictions on a defendants constitutional rights (i.e.,
    search and seizure) and only imply such restrictions if warranted by the underlying facts
    of the alleged crime. Section 11 of NRS 178.484 describes the document that must
    be signed by the defendant before he/she can be released on bail.

    My bail hearing contained what seems to be an impermissible coercive attempt to condition my release or the possibility thereof upon my providing
    confidential medical records (Lake's Crossing etc) to the Reno Municipal Court, even where the same judge presiding over the bail hearing found me
    competent enough to face a criminal trepass trial less than two weeks before teh bail hearing in 11 CR 26405.

    The friend of mine who posted my bail, Jared Swanson, has a serious form of cancer and a one year old baby. I request a reduction of the bail for his
    benefit and for the proof of insurance charge to be dismissed, as (and I am trying to avoid this in any way I can), if I am rearrested, such a proof of insurance
    charge may present another basis for imposing an unduly burdensome bail upon me, as it did on July 5th, 2012 where, despite my having produced a legible
    pdf copy of my proof of insurance card on my large screened zoomable smart phone, Officers Weaver and Dye still charged me with that violation, and the
    bail was subsequently increase. Further, none of the events or accusations forming the basis of the distrubing the police charge occurred in the officer's
    presence, and the police report contains no indication whatsoever that the arrest was made based upon NRS 171.1771. I provided Officer Weaver my
    driver's license prior to the arrest. I did not
    refuses to give a written promise to appear in court as provided in NRS 171.1773.

    When a person is believed to have committed a misdemeanor offense, the peace officer has the discretion to
    either issue a citation or arrest and detain the person. NRS 171.1771 states that a person can be arrested if
    his identity is questionable or if the peace officer does not believe the person will appear in court. A person
    can also be arrested for a misdemeanor offense if a warrant has been issued.

    Additionally, I am requesting that you file a Motion to Dismiss the Disturbing the Peace charge based upon a lack of evidence and or insufficiency of pleading
    000342
    in that the allegations do not amount to a prima facie case of a DTP violation. Further, please subpoena and or collect the Protection Order application filed
    by Milan Krebs on July 5th, 2012, and interview Krebs as to why he mentions Coughlin often carrying around a large knife in a menacing manner in that
    protection order application, yet completely failed to mention that in his July 3rd, 2012 police report. Additionally, please determine why Kreb's TPO
    appliication has a different style of handwriting on the caption compared to the descriptive sections, indicating someone pushed the filing of the TPO on Krebs,
    perhaps his employer, Northwind Apartments or the RPD, which has in the days preceding the arrest threatend to arrest Coughlin for criminal trespass if he
    returned to any part of the premises of Northwind Apartments, in consideration of Coughlin's eviction from unit 29, despite the fact Coughlin still had a valid
    right to go to his other two rentals, units 45 and 71, in addition to the fact that Northwinds essentially withdrew or rescinded its June 28th, 2012 eviction of
    Coughlin by posting an Amended 5 Day Unlawful Detainer Notice on unit 29 on June 28th, 2012 shortly after Coughlin pointed out to Northwinds and Nevada
    Courts Services that the July 14th, 2012 5 Day notice was not "personally served" (NCS's R. Wray lied about effecting personal service, as he could not
    possibly have verified someone of "suitable age and discretion" was within the windowless room with a metal door closed and locked and where no Wray
    admits that he received no verbal response from the unit or anyone therein upon his knocking on the door and or attempting to break into the unit, please see
    Soldal v. Cook County in that regard, a US S. Ct case) and therefore Coughlin would have had until at least noon on July 28th, 2012 to file a Tenant's Answer,
    whereas the eviction/lockout/arrest of June 28th, 2012 took place two hours before noon at 10 am).

    Additionally, RPD Officer Weaver had previously attempted to break into one of my rentals at Northwind at a time when he lacked a warrant and or an exigent
    rationale for doing so, much less an eviction Order. I just want this case to be dismissed and to try to move on in life, and difuse the tensions incident to
    this case.

    I did not disturb the peace at Northwinds as alleged, nor did I make the threats Kreb's accuses me of or stalk him or follow him in a threatening manner at
    any time. Additionaly, I never broke into nor did I ever attempt to break into Krebs' truck, and in fact, I filed a police report in June 2012 reporting
    extortionate threats by another maintenance man at Northwinds ("Luke" is his name, I believe) and Northwind's Manage Dwayne Jakob, wherein they
    threatened to make such a spurious allegation, but subsuquently refrained from doign so when it apparently occurred to them that I may have excuplatory
    video evidence disproving such an allegation as well as capturing their baseless and extortionate threats and accusations. Additionally, please subpoene the
    police reports I filed with the RPD and any emails I sent to any officers (including Weaver, Barnes, Sargent MIiller, LIeutenant Brown) and any reports of or
    recording of phone conversations I had with any of those RPD personnel. Further, please see the attached june 26th, 2012 email to the RPD, WCSO, RJC,
    Sparks Justice Court and others pointing out the insufficiency of the 5 day Notice drafted and posted by non-lawyers Nevada Court Services, in that under
    NRS 40.253 it listed the wrong forum for the tenant to file a Tenant's Answer, and under the Aiken decision of the Nevada Supreme Court and NRCP 60(b)(4),
    any lockout order stemming therefrom is void for lack of jurisdiction.

    NRS 171.136 When arrest may be made.

    1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
    2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
    (a) Upon the direction of a magistrate, endorsed upon the warrant;
    (b) When the offense is committed in the presence of the arresting officer;
    (c) When the person is found and the arrest is made in a public place or a place that is open to the public and:...
    (2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another alleged violation
    or offense;
    (d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is committed;...
    (g) When the person is already in custody as a result of another lawful arrest; or

    Krebs did not immediately arrest me under NRS 171.136(2)(d), nor was the DTP arrest for an offense alleged to have occurred in the officer's presence.

    the attached videos are of the incident on June 5th, 2012, not from July 3rd, 2012, but they support my contentions and the relevancy of subpoening the
    police incident reports and other documentation should this case not be dismissed, nolle prosequi, de minimis, etc....

    I will forward to you my emails to the RPD et all from June 26th, and July 2nd, 2012. I realize their tone was not a smart one to take or appropriate and am
    only sending them in hopes of having this matter dismissed. I do not have any interest in pursuing anything like Wheeler v Cross 344 Fed Apps 420 (
    (2008.

    Sincerely,

    000343
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
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    000344
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    000345

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    To zachcoughlin@hotmail.com
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    Sent: Mon 6/11/12 4:10 PM
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    000346
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    To zachcoughlin@hotmail.com
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    Sent: Mon 6/11/12 4:11 PM
    000347
    To: zachcoughlin@hotmail.com
    1 attachment
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    RE: respectfully submitted
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Wed 8/08/12 2:43 PM
    To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
    Zach:
    I reviewed the file in the Krebs protective order application. It is interesting in that there is not one reference by Mr. Krebs to a belief that you were
    trying to provoke him to engage in violence or a violation of law. Those appear to be solely the words of Office Weaver.
    I subsequently received your 100 page e-mail and do not intend to review it at length as most of the material appears irrelevant. What I
    gather from it is that you are once again not happy with my representation and want me to withdraw. I think there is merit to that request. It
    appears that our relationship has broken down and that you are asking me to engage in conduct that will result in violations of the rules of professional
    conduct. Those include Rules 3.1, 3.2 , 4.4 and possibly others. I also fundamentally disagree with some of your requested actions in that so far you
    have refused to provide your description of what happened on July 3, 2012 with Mr. Krebs. It also appears that your repeated demands are making
    my representation unreasonably difficult. It would be helpful; if I can represent in the motion to withdraw that you are willing to waive the 60 day
    rule for trial, so that a new attorney can be appointed to represent you and have enough time to prepare your case. Please respond whether you will
    agree to that waiver. If not I will simply file the motion without the representation and hope for the best.

    Keith Loomis

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Tuesday, August 07, 2012 11:01 PM
    To: keithloomis@earthlink.net; jleslie@washoecounty.us; zyoung@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov
    Subject: FW: respectfully submitted

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    000348
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: weavera@reno.gov; barnesm@reno.gov
    Subject: respectfully submitted
    Date: Fri, 8 Jun 2012 16:41:49 -0700
    Dear Officer Weaver and Officer Barnes,
    I am respectfully submitting this supplementary material to the police report I submitted to you in
    person on June 6, 2012 regarding the assault I was the victim of at the hands of maintenance staff
    member Luke of Northwind Apartments on June 5th, 2012, and the attempts at unlawful entry
    committed by Northwind Manager Dwayne Jakob on or about June 4, 2012.
    I am attaching an article you may find of interest regarding the intersection of landlord tenant law
    and police work, vis a vis criminal/civil matters and the fine distinctions that sometimes arise. I
    didn't see anything in there on Officer Weavers fine hypothetical regarding entry without
    permission when a burglary may be occurring. That situation probably does not come up that
    often because hardly anybody but the police would be brave enough to enter such a dangerous
    situation.
    I appreciate the brave service both of you provide. I am attaching this materials just because
    they are interesting to me and may be to you and in no way wish for so attachign these to be
    interpreted as a criticism of either of your police work.
    Sincerely,
    Zach Coughlin
    Motion to Withdraw
    From:Keith Loomis (keithloomis@earthlink.net)This sender is in your safe list.
    Sent: Fri 8/10/12 11:07 AM
    To: Zach Coughlin (ZachCoughlin@hotmail.com)
    1 attachment
    SKMBT_C35312081011000.pdf (164.4 KB)
    Motion to Withdraw is attached

    Keith Loomis

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    Back to top
    000357
    --Forwarded Message Attachment--
    Print Close
    RE: motion for continuance
    From:Pamela Roberts (robertsp@reno.gov)
    Sent: Wed 11/16/11 5:12 PM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for reciprocal discovery. You just need to call
    ahead at 334-2050 and arrange to pick it up. You are entitled to copies of all the reports and witness statements and video we may have on this case.
    Since I am not calling any additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send you an additional list of
    witnesses. I am also not obligated to do any further investigation or interviews. Pam Roberts.
    -----Original Message-----
    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: <robertsp@reno.gov>
    Date: Wed, 16 Nov 2011 15:35:48 -0800
    Subject: RE: motion for continuance
    Ms. Roberts,
    Thanks for your reply. Please ascertain from Walmart whether any Walmart employees had, previous to
    this incident, made any threats respecting maliciously having the accused banned from Walmart's incident
    to a disagreement over Walmart staff and managers curious practice of "forgetting" their return policy,
    despite some individuals having worked there over 10 years....Further, I believe it relevant and part of your
    duty to provide exculpatory information to ascertain whether the RSIC police officer made statements
    wherein he attempted to coerce a consent to an impermissible search and further buttressed his probable
    cause finding to conduct a search incident to arrest, expressly, in words, to the accused, upon the accused's
    failure to consent to such a search.

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

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

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

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

    -----Original Message-----
    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: <robertsp@reno.gov>
    Date: Fri, 11 Nov 2011 01:40:53 -0800
    Subject: motion for continuance
    Dear Counselor Roberts,
    I believe you are the prosecutor for the case against me, State v. Coughlin, which I believe is still set for
    000358
    trial on November 14th, I think at 1pm. I am not totally sure that there is a duty to serve you on such a
    thing, but I filed a Motion for Continuance and a Motion for Appointment of Counsel sometime within
    about the last 10 days, I would say. I believe I attempted to copy you on it, but have recently been
    evicted and its been a very difficult time in terms of coordinating paperwork, etc., etc. I apologize for
    any inconvenience this may have cause you. I am unsure of whether the November 14th trial is still set
    to take place. I believe fairness dictates that it be continued to a later date. I have request counsel but
    have yet to receive any, or wait, I was denied a request to receive counsel because Judge Howard said
    there is not a 6th amendment right to counsel where, even though jail time is technically a possibility, the
    state does not anticipate seeking jail time...or something like that, however, I found some cases that say I
    should still get counsel appointed, especially where I show I am indigent, and I believe I qualify as
    indigent rather easily. Can and would you agree to a continuance? I believe I tried to contact about
    this prior to filing my Request for a Continuance. I maintain my innocence in this case and feel any sort
    of conviction, especially one involving any sort of theft based charge, would work a terrible injustice and
    greatly damage my reputation and employment prospects. I want a jury trial, too.
    Sincerely,
    Zach Coughlin
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
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    --Forwarded Message Attachment--
    Print Close
    WLS
    From:Paul Elcano (pelcano@washoelegalservices.org)You moved this message to its current location.
    Sent: Wed 5/06/09 9:38 AM
    To: zachcoughlin@hotmail.com
    Dear Zach,

    You are correct about the letter being delivered on April 20


    th
    , I misread my timeline. My decision is limited to the hearing conduct.
    You have proffered nothing that indicates that the way you acted in court is in any way related to any outside event. Your 50 page motion for reconsideration
    before Judge Gardner has not linked your conduct in any way to an outside event. You have refused to give me a time and date to meet once again, and I
    will issue my determination tomorrow morning at 9:00 am.

    Access to your computer materials, will be made at a convenient time and place with our office manager, executive director or
    designee and our computer specialist present. This is a business computer, and without further research I will not give you access to it privately. You have
    been given a tape of the two Joshi hearings. To date, you have not agreed to meet at any time and place to discuss these hearings; and you have not
    000359
    specifically requested any identified items, documents etc. that were related to your conduct in this hearing. Your series of questions about the Board is
    irrelevant. The Board delegated this matter to me to handle as a personnel matter.

    -Paul
    000360
    Print Close
    Why no Casey Baker, Esq., Allison Ormaas, Esq., WCSO
    Deputy Machen, or RMC Marshal Harley, WCPD Biray Dogan,
    DDA Zach Young
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/01/12 5:39 PM
    To: patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org);
    tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com);
    cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com);
    mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
    (nevtelassn@sbcglobal.net)
    Dear Mr. King,
    I am writing to formally complaint about your, once again, reneging on an offer you
    have made to allow me access to certain materials.
    Please explain your repeated misrepresentations to me regarding the "access" you will
    allow me to the materials I am entitled to view, and those you have made offers in
    writing to me to allow me to view and or review.
    I think you might find that the attached video of Sargent Lopez pretty much vitiates the
    criminal trespass conviction (and that conviction, and all of Judge Nash Holmes orders
    are void in light of there violation of NRS 178.405 vis a vis NRS 5.010 and the
    admission in Judge Nash Holmes March 14th, 2012 letter to the SBN, and beyond that
    In re Oliver and the fact that Judge Nash Holmes admits on the record to be basing her
    Order's upon conduct not committed in her "immediate presence" (an allegation of
    having a RMC Marshals look "Peeping Tom" style through a bathroom stall doesn't cut
    it)... Interesting that you have chosen to subpoena your former Attorney General's
    coworke Dan Wong rather than City Attorney Ormaas (given her presence at the
    2/27/12 11 TR26800 Trial from which the "summary criminal contempt" order stems,
    and the allegations of her and that RMC Marshal Harley (whom violated the
    "courthouse sanctuary" doctrine in one of the worst ways imaginable with his barging
    in on a plea bargain session to "personally serve" a Notice of Order to Show Cause on
    behalf of Richard G. Hill (and the 11 tr 26800 case involved traffic citations
    immediately after RPD Tarter told Coughlin to leave Hill's office, albeit without his
    000361
    wallet, keys, client's files, or state issued identification....) then to have the same
    WCSO Deputy Machen who lied about personally serving the lockout order on
    Coughlin (in the eviction involving Hill) again lie in his 3 7 2012 Affidavit attesting to
    have served the notice of the 3 23 12 ORder to Show Cause hearing (the one RMC
    Marshal Harley served for him, then got all jumpy and whispering in Ormaas's, and,
    apparently while Coughlin was in the restroom, made allegations to Judge Nash
    Holmes (and afterwards incident to the SITA) seeking to cover up his misconduct and
    that of Ormaas. Claiborne is not going to allow you to feign ignorance, Mr. King, nor
    is the proof of receipt of all my emails and writings and media. Have fun reviewing it
    all.
    Regardless, its not "summary contempt" if all essential elements of the allegation,
    under any iteration of NRS 22 are not alleged to have occurred in the "immediate
    presence" of the Judge...where, as here, that is not the case, those RMC Marshal are
    going to have to sign their names to affidavits like the big boys they strut around acting
    like they are, behaving in a menacing and intimidating manner that is wholly
    inconsistent with traditional notions of the type of comportment required of officers of
    the court.
    Again, today, you have reverted to your old tricks. I want everything, not just that
    which you or Clerk/Investigator Peters deem "related' to the SCR 105 "Complaint"
    (which has three case numbers on it ng12-0204, ng12-0434, and ng12-0435). Both you
    and Peters get real evasive when it comes times to answer for who submitted or filed
    the ng12-0435 grievance consisting of a three year old Order by Family Court Judge
    Linda Garnder, yet which bares a file stamp of March 15th, 2012 by the SBN...then
    there is Judge Linda Gardner's brother, RMC Judge William Gardner refusing to recuse
    himself from the criminal trespass case, resulting in a conviction. I would think the
    attached videos pretty much demonstrate perjury by Richard G. Hill considering the
    various Declarations and Application for a TPO, bar grievances, police reports, and
    Motions for Orders to Show Cause he filed or signed on to....Mr. King, is this what the
    SBN needs right now? A SCR 105 Complaint by you coyly including this January
    12th, 2012 "jaywalking" arrest, yet refusing to utter Hill's name in connection with it?
    Some selected past correspondences with Mr. King detailing his reneging on offers:
    Mr. King, one of of our recent discusson you promised to send me something in writing informing me as to who
    exactly was on the screening panel. You have failed to uphold that promise as well. Further, you and
    000362
    Clerk/Investigator Peters have remained evasive and contradictory respecting who filed NG12-0435, when, and
    under what circumstances it came to be a grievance. I think you will find that a review of the hearings you finally
    provided in 11 CR 26405 (April 10th and May 8th, 2012) will yield some really intersting statements on the
    record by Keith Loomis, Esq. (your Minden associate) and Judge William Gardner of the RMC (brother to Family
    Court Judge Linda Garnder, whose 2009 sanctions order was file stamped by the SBN on March 15th, 2012 and is
    now called NG12-0435, though neither you nor Peters will say anything all that sensible about the genesis of that
    grievance, etc. Judge Gardner makes some pretty curious statements respecting the competency analysis, the
    decision to plow ahead with a Trial Setting on March 7th, 2012 for April 10th, 2012 (interesting considering
    Coughlin filed the Notice of Appeal of the final, appealable "summary criminal contempt" conviction on that
    same date, March 7th, 2012 that now forms part of the asis for Judge Nash Holmes ng12-0434 "decompensating"
    grievance, incident to her March 14th, 2012 letter to the SBN....you might want to have Judge Gardner's
    statements on the record from 4/10/12 and 5/8/12 and Loomis's transcribed, as your possession of the audio
    thereof arguably puts a Claiborne-esque duty upon you to inquire as to the candor and veracity of some of those
    statements, especially vis a vis the "meetings" Gardners being the RMC's "Administrative Judge", etc., etc.
    Further, you have refused to allow me access to a number of materials that neither you nor Peters deem "part of
    the complaint" (the SCR SBN v Coughlin complaint...though to the extent one or more of ng12-0204, ng12-0434,
    0435 mention the RMC, arguably, I am entitled to anything at all related to me, whether submitted by the WCSO,
    RMC, City of Reno, City of Reno Marshals, etc.
    There are grievances against Dogan, Loomis, Young, Ormaas, Roberts, Hazlett, etc., etc., and given the
    SBN's and NNDB's known predilection against bifurcating hearings, why not have those individuals show
    up on November 14th, 2011 in the name of adminitrative economy? I am to financially strapped to
    arrange for all of their appearances, but I believe my requesting a waiver herein, or that the SBN or
    NNDB so arrange for these barristers to appear, combined with the duties attendant to Mr. King being
    a prosecutor (Brady Rule RPC 3.8, simple duty of fairness to opposing counsel, etc., etc.) might dictate
    that they so be obliged to appear. Certainly Dogan and Young could shed some light on the
    communications to the RMC and Judge Nash Holmes that made her holding the Trial on 2/27/12, hours
    after Dogan and Young successfully obtained an Order for Competency Evaluation of Coughlin in
    RCR2012-065630, appear to be plainly violative of NRS 178.405 and NRS 5.010 (as was Young's filing
    an Opposition later that day, baring a file stamp time over 90 minutes after that found on the Order
    for Competency Evaluation. As for WCSO Machen, why, he is practically indispensable here. You got
    him and Baker doing the November 1, 2011 eviction lockout, you got him with the phony Affidavit of
    Service he failed thereto on 11/7/11, you got Machen having RMC Marshal Harley serving the Notice of
    Order to Show Cause Hearing on Couglin on 2/27/12 while Coughlin and Ormaas haggled over the
    fines for the Richard Hill traffic citation trial before Judge Nash Holmes (I would think getting the audio
    of the other cases on Judge Holmes' docket at 1:00 pm on 2/27/12 will reveal what I heard her
    administrative assistant say...something along the lines of "I am going to start the record now so I
    don't forget to later...followed by a substantial period of no one being able to find Judge Nash Holmes,
    comments directed to how odd that was, etc., etc.) all occurring at the exact same time that Dogan
    and Young were holding their clandestine status conference on 2/27/12 at 1:30 pm...which didn't stop
    Judge Nash Holmes from continuing on to hold the 11 TR 26800 traffic citation trial, at which she
    suspended the proceedings at 4 pm or so, and had Coughlin cuffed and taken straight to a 5 day jail
    stay (and despite her protestations of concern for Coughlin's client's welfare, she gave the idea of a
    stay extremely short shrift, indeed). Funny how that Order immediatly follow Coughlin saying "RPD
    Sargent Tarter lied when...." BOOM. STOP. Summary criminal contempt conviction....5 day jail stay.
    Judge Nash Holmes even kept the $100 Coughlin's Mother paid to get him out a day early, despite the
    jail not releasing Coughlin. Wow, indeed.
    Patrick King (PatrickK@nvbar.org) Add to contacts 3/27/12 To: zachcoughlin@hotmail.com From: Patrick King
    (PatrickK@nvbar.org)This sender is in your safe list. Sent: Tue 3/27/12 9:24 AM To: zachcoughlin@hotmail.com
    000363
    (zachcoughlin@hotmail.com) March 27, 2012 Dear Mr. Coughlin, Perhaps you are not fully aware of your
    behavior. At our brief meeting yesterday I perceived you as very hostile and even threatening. Under those
    circumstances I felt it better to terminate the meeting. If it was not your intent to appear hostile or to attempt to
    intimidate me then you might consider how I perceived your conduct. I had intended to try to listen to you and
    determine how my office could best help you address the grievances that I have received. You said you did not
    have time and simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if you
    received the information I sent to you, I said I did not care how your received it, so long as you received it. I do
    care that you receive the information that I send to you. As I attempted to explain, I will be meeting with a panel
    to have them make a determination about the grievances that have been made against you by Mr. Hill and the
    Judge from Department 3 that you read at my office. I have asked for a written response to those grievances. In
    response I received many e-mails with attachments. I will soon be sharing the grievances with a disciplinary
    panel and will advise them of your responses to date. I will keep you advised of the panels determination.
    Sincerely, Patrick King Actions Zach Coughlin (zachcoughlin@hotmail.com) 3/26/12 To: patrickk@nvbar.org,
    glennm@nvbar.org, davidc@nvbar.org Dear Mr. King, This correspondence is sent to confirm that I visited the
    Double R Blvd. offices of the State Bar of Nevada today and attempted to be provided access the the various
    "other different judges" grievances that I, prior to last Friday, was completely unaware of. I have sent you several
    written correspondences detailing the tampering and other problems with my USPS mail incident to the two
    domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge
    Nash Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to
    identify the names of any other judges from whom you have received any other similar such materials and further
    refused to allow me to view and such items. I asked for a copy of the large box of documents, and other FOIA
    request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated
    that I did not have a right to review such complaint letters, grievances, or other materials, prior to being
    questioned by you and before any such meeting. I informed you that I am considering different attorneys to
    represent me right now, and indicated I need these materials to prepare for any future meeting with you. My
    records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via
    email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473 2012 Microsoft Terms Privacy Developers English (United
    States)
    From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Mon 4/02/12 3:57 PM To:
    zachcoughlin@hotmail.com Dear Mr. Coughlin, I have opened 3 disciplinary files against you. They are
    identified by number below: NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill NG12-0435
    Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes NG12-0434 Zachary B. Coughlin, Esq. Bar No.
    9473 (2005) Judge Gardner You have received the grievance from Mr. Hill and also the grievance from Judge
    Holmes. The Grievance from Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v Barti
    Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13. I have received
    certified copies of the contempt orders, a certified copy of the conviction at Wal-Mart, and an incident report
    from Marshals Thompson and Coppa regarding your conduct on March 22, 2012. I also have the recordings of the
    court proceedings at issue. At this time, I do not expect to be providing you with any additional information. If
    you have additional information that you want me to be made aware of in response to the grievances identified
    above please feel free to mail them to me. Sincerely, Patrick King, Assistant Bar Counsel
    \
    000364
    From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
    Sent: Thu 4/19/12 2:28 PM
    To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
    April 19, 2012
    Zach Coughlin
    Dear Mr. Coughlin,
    A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the
    grievances filed against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be
    preparing a formal Complaint.
    I understand from the e-mail below, that you do not believe you should have been found guilty of the theft
    at Wal-Mart and that you should not have been found in contempt of Court. However, it must concern you that you
    were found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of
    or obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court
    at my request, pursuant to my investigation.
    It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft
    and why you were held in contempt of Court. You may be well served to explain what remedial measures you are taking
    to make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest
    you cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge
    Holmes and Richard Hills grievance letters to the office of Bar Counsel.
    Patrick King
    Zach has 8 files to share with you on SkyDrive. To view them, click the links below.
    000365
    SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
    011412 RJC RCR2012-065630 RCR2011-063341 RCR2012-067980 Reno Police Department Sargent Paul Sifre arrests
    Reno Attorney for misuse of 911 second arr.3gp
    zach's arrest 009 26405 1708 26800 03628.flv
    zach's arrest 011 26405 1708 26800 03628.flv
    zach's arrest 010 26405 1708 26800 03628.flv
    10 4 12 ORDER STRIKING document filed in error on 10 2 12 and returning document 26800 0204 0434 nash 00696
    26405.pdf
    10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
    Download all
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: Records
    Date: Thu, 1 Nov 2012 16:04:21 +0000
    Good Morning Mr. Coughlin,
    Your disciplinary file is being sent to the printer to be copied. I am having the documents bate stamped and the
    printing company will mail them to you.
    Formal proceeding are taking place at the state bar office so you will not be permitted in the building.
    my new address
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 10/23/12 11:29 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; complaints@nvbar.org
    Dear Bar Counsel,
    000366
    I am still very afraid of retaliation by local law enforcement, and due to my status as a domestic
    violence victim. In the past, I have offered to assistn you in getting me served appropriately, but have
    received no follow up. Further, the SBN, via Investigator/Clerk Peters and otherwise have made
    representations that I have relied upon to the extent that another certified mail SCR 105 Complaint
    would be sent out shortly after my communications with Peters on September 11th, 2012 or so where
    she admitted to receiving in the mail the one she said she sent on August 23rd, 2012. Whatever the
    SCR 109 implications, the SBN's promises made by Peters are binding in that regard...
    Nonetheless, I now feel forced to provide you my address and expose myself to even greater danger,
    particularly where, some might say, the SBN has a vested interest in discrediting me now, a motive, a
    bias, some might say (I take no position in that regard at the current time). Please note my new phone
    number as well. While Mr. King has referred to some upcoming SCR 105 hearing (a "combo hearing"
    akin to the one's, including a Trial that DDA Young and his crew of Washoe County Public Defenders
    have been trying to run on me this year, including attempting to hold a Trial on May 7th, 2012 in
    RCR2011-0063341 where the Order finding me competent and remanding jurisdiction to the Justice
    Court in CR12-0376 was only signed, entered, and file stamped on May 9th, 2012...A big no-no under
    NRS 178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for given his
    communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and 12 CR 12420.
    This could be your Waterloo, so I hope you will investigate this properly. Especially considering the
    Order granting Loomis' withdraw in the criminal trespass case Mr. King just filed an SCR 111 petition in
    occurred during the pendency of such an evaluation on May 8th, 2011 (lots going on between May 7th-
    May 9th, 2012, here!) and the fact that Loomis and or the RMC ramrodded a Trial setting of June 18th,
    2012 on May 8th, 2012 as well, well before Coughlin's competency was determined...and to the extent
    King indicates NG12-0204 and NG12-0435 rely on "Orders" entered or rendered during periods in which
    NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no good. Please don't
    make my address public yet or disseminate it in any way.
    Sincerely,
    Zach Coughlin
    1471 E. 9th St.
    Reno, 89512
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    RE: Coughlin: Petit larceny case
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/01/12 1:10 PM
    To: Leslie, Jim (jleslie@washoecounty.us); odomk@reno.gov (odomk@reno.gov);
    complaints@nvbar.org (complaints@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com)
    Dear Jim,
    Have no idea what you mean about a "riding your butt" comment...Jim, you understand
    that files that are on a cd/dvd, are digital in nature, you get that, right? Please send me
    000367
    those files in accordance with Judge Sferrazza's October 22nd, 2012 Order, already.
    Also, Jim, you have a duty to maintain a copy of a former client's file, and here you
    admit to seeking to shirk that duty, I believe, for the even more impermissible purposes
    I have detailed previously.
    From: Jleslie@washoecounty.us
    To: zachcoughlin@hotmail.com
    Subject: Coughlin: Petit larceny case
    Date: Thu, 1 Nov 2012 19:38:03 +0000
    Mr. Coughlin:
    In response to your several argumentative phone calls today in which you stated at least once I am riding your butt and
    in which you keep demanding that we digitally transmit materials that are in hard form, if you have a dispute about the
    discovery/file materials or my conduct, set a hearing with the court and I will hand them to you in the presence of the
    judge since you are refusing to take receipt of them or sign an inventory.
    If you set a hearing, please note that I generally am not available Tuesday or Thursday mornings but will make all
    reasonable effort. Otherwise, I typically have RJC cases in the afternoons.
    I noticed you copied the State Bar on one or more of the emails. I wonder if you would prefer to have the Bar involved in
    monitoring the hand-off of materials?
    James B. Leslie, Esq.
    Chief Deputy Public Defender
    Washoe County Public Defenders Office
    350 South Center Street
    Fifth Floor
    Reno, NV 89509
    1-800-762-8031
    Direct Dial: 775-337-4828
    Fax: 775-337-4856
    000368
    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.
    RE: Records
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/01/12 4:43 PM
    To: Patrick King (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org);
    tsusich@nvdetr.org (tsusich@nvdetr.org); JE@ELORENO.com (je@eloreno.com);
    cvellis@bhfs.com (cvellis@bhfs.com)
    Dear Mr. King,
    I am writing to formally complaint about your, once again, reneging on an offer you
    have made to allow me access to certain materials.
    Please explain your repeated misrepresentations to me regarding the "access" you will
    allow me to the materials I am entitled to view, and those you have made offers in
    writing to me to allow me to view and or review.
    I think you might find that the attached video of Sargent Lopez pretty much vitiates the
    criminal trespass conviction (and that conviction, and all of Judge Nash Holmes orders
    are void in light of there violation of NRS 178.405 vis a vis NRS 5.010 and the
    admission in Judge Nash Holmes March 14th, 2012 letter to the SBN, and beyond that
    In re Oliver and the fact that Judge Nash Holmes admits on the record to be basing her
    Order's upon conduct not committed in her "immediate presence" (an allegation of
    having a RMC Marshals look "Peeping Tom" style through a bathroom stall doesn't cut
    it)... Interesting that you have chosen to subpoena your former Attorney General's
    coworke Dan Wong rather than City Attorney Ormaas (given her presence at the
    000369
    2/27/12 11 TR26800 Trial from which the "summary criminal contempt" order stems,
    and the allegations of her and that RMC Marshal Harley (whom violated the
    "courthouse sanctuary" doctrine in one of the worst ways imaginable with his barging
    in on a plea bargain session to "personally serve" a Notice of Order to Show Cause on
    behalf of Richard G. Hill (and the 11 tr 26800 case involved traffic citations
    immediately after RPD Tarter told Coughlin to leave Hill's office, albeit without his
    wallet, keys, client's files, or state issued identification....) then to have the same
    WCSO Deputy Machen who lied about personally serving the lockout order on
    Coughlin (in the eviction involving Hill) again lie in his 3 7 2012 Affidavit attesting to
    have served the notice of the 3 23 12 ORder to Show Cause hearing (the one RMC
    Marshal Harley served for him, then got all jumpy and whispering in Ormaas's, and,
    apparently while Coughlin was in the restroom, made allegations to Judge Nash
    Holmes (and afterwards incident to the SITA) seeking to cover up his misconduct and
    that of Ormaas. Claiborne is not going to allow you to feign ignorance, Mr. King, nor
    is the proof of receipt of all my emails and writings and media. Have fun reviewing it
    all.
    Regardless, its not "summary contempt" if all essential elements of the allegation,
    under any iteration of NRS 22 are not alleged to have occurred in the "immediate
    presence" of the Judge...where, as here, that is not the case, those RMC Marshal are
    going to have to sign their names to affidavits like the big boys they strut around acting
    like they are, behaving in a menacing and intimidating manner that is wholly
    inconsistent with traditional notions of the type of comportment required of officers of
    the court.
    Again, today, you have reverted to your old tricks. I want everything, not just that
    which you or Clerk/Investigator Peters deem "related' to the SCR 105 "Complaint"
    (which has three case numbers on it ng12-0204, ng12-0434, and ng12-0435). Both you
    and Peters get real evasive when it comes times to answer for who submitted or filed
    the ng12-0435 grievance consisting of a three year old Order by Family Court Judge
    Linda Garnder, yet which bares a file stamp of March 15th, 2012 by the SBN...then
    there is Judge Linda Gardner's brother, RMC Judge William Gardner refusing to recuse
    himself from the criminal trespass case, resulting in a conviction
    Mr. King, one of of our recent discusson you promised to send me something in writing informing me as to who
    exactly was on the screening panel. You have failed to uphold that promise as well. Further, you and
    Clerk/Investigator Peters have remained evasive and contradictory respecting who filed NG12-0435, when, and
    000370
    under what circumstances it came to be a grievance. I think you will find that a review of the hearings you finally
    provided in 11 CR 26405 (April 10th and May 8th, 2012) will yield some really intersting statements on the
    record by Keith Loomis, Esq. (your Minden associate) and Judge William Gardner of the RMC (brother to Family
    Court Judge Linda Garnder, whose 2009 sanctions order was file stamped by the SBN on March 15th, 2012 and is
    now called NG12-0435, though neither you nor Peters will say anything all that sensible about the genesis of that
    grievance, etc. Judge Gardner makes some pretty curious statements respecting the competency analysis, the
    decision to plow ahead with a Trial Setting on March 7th, 2012 for April 10th, 2012 (intersesting considering
    Coughlin filed the Notice of Appeal of the final, appealable "summary criminal contempt" conviction on that
    same date, March 7th, 2012 that now forms part of the asis for Judge Nash Holmes ng12-0434 "decompensating"
    grievance, incident to her March 14th, 2012 letter to the SBN....you might want to have Judge Gardner's
    statements on the record from 4/10/12 and 5/8/12 and Loomis's transcribed, as your possession of the audio
    thereof arguably puts a Claiborne-esque duty upon you to inquire as to the candor and veracity of some of those
    statements, especially vis a vis the "meetings" Gardners being the RMC's "Administrative Judge", etc., etc.
    Further, you have refused to allow me access to a number of materials that neither you nor Peters deem "part of
    the complaint" (the SCR SBN v Coughlin complaint...though to the extent one or more of ng12-0204, ng12-0434,
    0435 mention the RMC, arguably, I am entitled to anything at all related to me, whether submitted by the WCSO,
    RMC, City of Reno, City of Reno Marshals, etc.
    Patrick King (PatrickK@nvbar.org) Add to contacts 3/27/12 To: zachcoughlin@hotmail.com From: Patrick King
    (PatrickK@nvbar.org)This sender is in your safe list. Sent: Tue 3/27/12 9:24 AM To: zachcoughlin@hotmail.com
    (zachcoughlin@hotmail.com) March 27, 2012 Dear Mr. Coughlin, Perhaps you are not fully aware of your
    behavior. At our brief meeting yesterday I perceived you as very hostile and even threatening. Under those
    circumstances I felt it better to terminate the meeting. If it was not your intent to appear hostile or to attempt to
    intimidate me then you might consider how I perceived your conduct. I had intended to try to listen to you and
    determine how my office could best help you address the grievances that I have received. You said you did not
    have time and simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if you
    received the information I sent to you, I said I did not care how your received it, so long as you received it. I do
    care that you receive the information that I send to you. As I attempted to explain, I will be meeting with a panel
    to have them make a determination about the grievances that have been made against you by Mr. Hill and the
    Judge from Department 3 that you read at my office. I have asked for a written response to those grievances. In
    response I received many e-mails with attachments. I will soon be sharing the grievances with a disciplinary
    panel and will advise them of your responses to date. I will keep you advised of the panels determination.
    Sincerely, Patrick King Actions Zach Coughlin (zachcoughlin@hotmail.com) 3/26/12 To: patrickk@nvbar.org,
    glennm@nvbar.org, davidc@nvbar.org Dear Mr. King, This correspondence is sent to confirm that I visited the
    Double R Blvd. offices of the State Bar of Nevada today and attempted to be provided access the the various
    "other different judges" grievances that I, prior to last Friday, was completely unaware of. I have sent you several
    written correspondences detailing the tampering and other problems with my USPS mail incident to the two
    000371
    domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge
    Nash Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to
    identify the names of any other judges from whom you have received any other similar such materials and further
    refused to allow me to view and such items. I asked for a copy of the large box of documents, and other FOIA
    request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated
    that I did not have a right to review such complaint letters, grievances, or other materials, prior to being
    questioned by you and before any such meeting. I informed you that I am considering different attorneys to
    represent me right now, and indicated I need these materials to prepare for any future meeting with you. My
    records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via
    email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473 2012 Microsoft Terms Privacy Developers English (United
    States)
    From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Mon 4/02/12 3:57 PM To:
    zachcoughlin@hotmail.com Dear Mr. Coughlin, I have opened 3 disciplinary files against you. They are
    identified by number below: NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill NG12-0435
    Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes NG12-0434 Zachary B. Coughlin, Esq. Bar No.
    9473 (2005) Judge Gardner You have received the grievance from Mr. Hill and also the grievance from Judge
    Holmes. The Grievance from Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v Barti
    Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13. I have received
    certified copies of the contempt orders, a certified copy of the conviction at Wal-Mart, and an incident report
    from Marshals Thompson and Coppa regarding your conduct on March 22, 2012. I also have the recordings of the
    court proceedings at issue. At this time, I do not expect to be providing you with any additional information. If
    you have additional information that you want me to be made aware of in response to the grievances identified
    above please feel free to mail them to me. Sincerely, Patrick King, Assistant Bar Counsel
    \
    From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
    Sent: Thu 4/19/12 2:28 PM
    To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
    000372
    April 19, 2012
    Zach Coughlin
    Dear Mr. Coughlin,
    A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the
    grievances filed against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be
    preparing a formal Complaint.
    I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at
    Wal-Mart and that you should not have been found in contempt of Court. However, it must concern you that you were
    found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of or
    obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at
    my request, pursuant to my investigation.
    It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and
    why you were held in contempt of Court. You may be well served to explain what remedial measures you are taking to
    make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest you
    cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge
    Holmes and Richard Hills grievance letters to the office of Bar Counsel.
    Patrick King
    Zach has 16 files to share with you on SkyDrive. To view them, click the links below.
    EMAILS TO PATRICKK@NVBAR.ORG PATRICK KING BAR COUNSEL.pdf
    emails from ZachCoughlin@hotmail.com to Patrick King patrickk@nvbar.org since 3 23 12.pdf
    emails since 3 23 12 from patrickk@nvbar.org Patrick King Bar Counsel State Bar of Nevada.pdf
    5 4 09 attachment to wlc elcano email gardner 26405 01955 60302 ltrCoughlin2ndDraft.pdf
    5 7 09 termination letter from wls elcano linda gardner zachcoughlin040709.pdf
    000373
    5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844.pdf
    11TR26800 RMC 022712 031412_20120312-1033_01cd003b8f0851d0.mp3
    11CR26405 050812 Loomis_20120508-1104_01cd2d0a627f5f90.mp3
    11TR26800 RMC 022712 031412_20120227-1507_01ccf5618f76c460.mp3
    3 16 12 ng12-0434 SBN King letter containing RMC Judge Nash Homes 3 14 12 grievance against Coughlin and ng12-
    0435 linda gardner sanction from 4 10 09 26800 00696 54844.pdf
    2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH
    ME.pdf
    11cr26405 puentes 041012_20120410-0903_01cd16f8c3aa49b0.mp3
    rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv
    2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal harley.pdf
    rerevised exhibit 1 26405 61901 WITH BATES NUMBERING.pdf
    12-32685 10 15 12 scr 111(4) in re coughlin petition criminal trespass conviction 61901 26405 1708 26800 12420 hill
    sbn.pdf
    Download all
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: Records
    Date: Thu, 1 Nov 2012 16:04:21 +0000
    Good Morning Mr. Coughlin,
    Your disciplinary file is being sent to the printer to be copied. I am having the documents bate stamped and the
    printing company will mail them to you.
    Formal proceeding are taking place at the state bar office so you will not be permitted in the building.
    RE: Coughlin: Petit Larceny case -- Hand-Off Transmittal
    000374
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 11/01/12 3:14 AM
    To: Leslie, Jim (jleslie@washoecounty.us); davidc@nvbar.org (davidc@nvbar.org);
    patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
    complaints@nvbar.org (complaints@nvbar.org)
    1 attachment
    filed 10 18 12 MOtion and Memorandum in RCR2011-063341.pdf (1500.4 KB)
    Jim,
    I will give you an opportunity to retract or fully explain your statement in your last
    correspondence to me, wherein you wrote:
    "Given your past statements to me, I believe I should also warn you of the possibility of applicability of Nevada
    Rule of Professional Conduct 3.3. In that regard, please recall that during a meeting between you and I in one
    of the interview rooms at Reno Justice Court during trial on 9/5/12, you suggested to me that I alter the video
    recording of your interaction with the police officers in the petit larceny case. I told you I cannot do that. You
    became irate and argumentative and asked why I could not do it, and I told you it would be unethical. I raise
    this issue in this email transmittal to reiterate what I have had to tell you more than once in this case, that is, I
    cannot and will not assist you in alteration of evidence or other commission or attempted commission of fraud
    upon the court. Should I observe you attempting to do so during the resumed trial, currently set for November
    19, 2012, as noted above, I believe I would be required under Nevada Rule of Professional Conduct 3.3 to
    advise the Court."
    I don't know what is funnier, Jim, the accusation that I would somehow view you as tech savvy enough to whip
    up some video editing on the spot with "the county laptop" which "takes a little while to boot up", or the
    suggestion that I would be stupid and reckless enough to attempt to encourage you to commit some vague
    misconduct, you whom I cannot stand and whom clearly wants nothing but the worst for me. Sure, Jim, sure.
    I get it Jim, you have had a chance to read the Memorandum I submitted, which painstakingly dissects your
    misconduct, and you are panicking, doing damage control, reverting to your tried and true threatening of your
    indigent criminal client's routine....next, you will attempt to have a bailiff lean on your client with some
    intimidation tactics, probably have him threaten to "put my foot up your ass" as you did with Bailiff Reyes on
    October 8th, 2011 at the RJC.
    I consider your above writing to be an inappropriate threat, and beyond inaccurate. Jim, if there was a
    transcript of these conversations you refer to, and one compared them to your above statements, would your
    conduct be ethical or even legal? By "alter", what exactly do you mean, Jim? Are you referring to the "10
    minute break" where you need to "boot up the county laptop" 10 minutes before lunch, which Judge Sferrazza
    granted you so you could "do some trial prep" (mid-way through the trial, whereupon you were going to view,
    for the first time, apparently, the video of the arrest, especially given your early foul ups on the record wherein
    you failed to recognize the difference between the extortionate threats made by Officer Rosa from those made
    by Officer Duralde...then, during that "10 minute break" you proceed to do something other than what you told
    Judge Sferrazza the break was for...instead of reviewing the exculpatory video, you talked to the State Bar of
    Nevada on the phone and received confidential information related to Keith Loomis's representation or lack
    thereof of myself...I asked you whether you had any authority for your position that the videos of the arrest,
    000375
    and other investigatory videos I capture had to be submitted or presented to the court in their entirety (some
    of the videos are quite long...you wouldn't know Jim, because you have not viewed them....). You, of course,
    because you never have any citation for anything, instead proceeded to attempt to make some lame threat
    accusing me of some gibberish, in that classic Jim Leslie, CYA, faux sincere, hyperpretentious delivery of yours
    that is so very grating....
    Don't have time to go into all the misrepresentations you make in your email below. Jim, why don't you just
    email me the dispatch tapes, you know, as that is a very material issue in this matter. This is especially true
    where the RPD and DDA Young have seemingly come up with this "dispatch reported to the officers a possible
    fight" despite the fact that the dispatch logs mention only a "disturbance" at first, then
    Further, Duralde's Supplemental Declaration (the one he filed the day after the arrest, not the Narrative he filed
    3 months later when the RPD found out the arrest had been captured on tape by Coughlin...its a great video,
    Jim, you should watch it sometime....):
    "report of a larceny of a cell phone at that location. Dispatch relayed information that the victim had set his
    phone down and that he was now calling the phone and It was lighting up In the suspecfs pocket. The suspect
    was described as a white male adult, 35 years of age, 6'02",210 Iba, wearing a red Chicago hat and a white or
    yellow shirt and plaid shorts. Dispatch also relayed that the suspect was still on scene."
    Then, on page two of DDA Young Opposition to the Motion to Suppress (the one where you guys failed to
    preserve arguments related to the impermissiblity of a search incident to arrest based upon what remained of
    the facts should your suppression motion be granted as it related to the pat-down alone), DDA Young seems to
    come out of nowhere with this "report of a possible fight" stuff, which, conveniently, really helps in the whole
    "need for articulable facts supporting a reasonable suspicion/pat down or probable cause/search incident to
    arrest analysis...On page 5 of his Opposition, DDA Young drives the point home: "In the instant case, the pat-
    down search of the Defendant was proper under the totality of the circumstances. 3 Prior to arriving, Officer
    Duralde learned that the scene involved a loud disturbance with possible fight, thereby immediately raising the
    concern of weapons and the safety of all those present . This is just one factor for this Court to consider. Upon
    contacting the Defendant, he became uncooperative and challenged Officer Duralde that there was not enough
    information for a detention. This is just one factor for this Court to consider. Upon contacting the Defendant,
    he became uncooperative and challenged Officer Duralde that there was not enough information for a
    detention . Thereafter , in response to Officer Duralde's inquiry whether the Defendant had Mr. Goble's phone,
    the Defendant asked if he had the right not to answer the question. While the Defendant arguably can choose
    not to answer such a question, this response, along with his general attitude, demeanor, and reaction, certainly
    can be considered by this Court when addressing the reasonableness of Officer Duralde 1s concern for his and
    others l safety . It is important to note that there were multiple people on 2 scene, any of which could be
    subjected to injury or death if the 3 Defendant had a weapon . Upon arrival , the Defendant and a group of 4
    people (including Mr. Goble) were on scene, and with the allegation that the Defendant had stolen a phone
    belonging to a person of said 6 group, emotions were high and a physical fight could have erupted. Again, such
    factors should be considered by this Court when 8 determining the reasonableness of the pat-down search."
    But where is the support for this "a possible fight" suggestion? Its not in the discovery produced to me. So,
    how about those dispatch tapes, huh, Jim. Kelly Odom? Please email them to me, I don't want you trying to
    jam me up so close to trial with some non-sense about how some blank or scratched cd you gave me was the
    000376
    "only copy" your office had. I know you well, Jim. So, seeing as how you finally served a subpoena duces
    tecum on Kelly Odom/Ecomm/ 911 dispatchers, so we can finally hear the dispatch tapes, and see if any
    "possible fight" was mentioned, why don't you go ahead and email me those audio files (and audio files are
    mercifully small compared to video files, Jim, yet I have managed to send you reams of video files via email...).
    Also, I need the audio of the aborted Trial in this matter that was held on May 7th, 2012 (despite the fact that
    Judge Elliot did not sign the Order finding Coughlin Competent, and therefore ending the period in which "all
    proceedings must be stayed" required by NRS 178.405, until two days later, on May 9th, 2012. So you guys
    were going to jam me into a Trial while there was a pending Order for Competency Evaluation, just days after
    my getting out of jail, where my medication was wrongfully withheld from me (and some medications should
    not be ceased or started to abruptly), where I spent 8 days due to the lies of the Lakes Crossing evaluators and
    the misconduct and malpratice of your protege, Biray Dogan, whom proceeded to read my confidential medical
    information into the open, public record, in front of 40 or so members of the public....a transgression which Mr.
    Bosler saw no need to attempt to have stricken or corrected.
    BUT TO ME CLEAR, JIM...I know Goodnight orderd a copy of the May 7th, 2012 aborted Trial, that occurred
    during the pendency of an Order for Competency Evaluation. I do not have a copy of that JAVS audio, nor do I
    have a copy of my arraignment in rcr2011-063341. You guys don't even get billed for these and yet you have
    denied them to me, until you got wind of the fact that I went and got my own, then you come up with you faux
    offers to provide me copies....Very clever.
    Jim, the RJC severely limits my access to the files, so you are not entitled to make any assumptions that alleviate
    your duty to provide me copies of filings, access to my file, etc.
    Further, I see that Linda Gray filed a request for the audio of the October 22nd, 2012 Hearing, and I want a copy
    of it, so please email it to me, and also provide a hard copy. Its not rocket science copying a CD, Jim, and it
    doesn't take ages, either. You remember the October 22nd, 2012 Hearing, right, Jim...the one where you can
    be heard on the record telling me "you are going to fail" and "your're disintegrating" and making more of your
    threats about how I attempt to advocate on my own behalf the Judge will put me in jail, etc.,etc.? Yeah, I need
    a copy of the copy your office got of that hearing. With the bits where you tell the Judge "he (Coughlin)
    doesn't get to dip into our money, no one cent" in your explaining your refusal to subpoena material witnesses
    or send out subpoena duces tecums (odd, because the RPD doesn't seem to charge you guys for those....yet you
    never sent one to ECOMM until well over midway through the trial, why is that, Jim?).
    See, Jim, it was professional misconduct for you to spend your entire cross-examination of Cory Goble trying to
    establish a citizen's arrest was effectuated, and therefore help the police and the State overcome the fact that
    Officer Duralde cleary overcharged the crime as a felony in an attempt to game the system and get around the
    whole statutory dictate against officer's making custodial arrest (and therefore being permitted to conduct
    searches incident thereto) for misdemeanors, allegedly committed after 7 pm and outside the officer's presence
    (unless a citizen's arrest is immediately effected). Your cross was pretty good work for a prosecutor, but you
    get paid to fulfill the Sixth Amendment Jim, not throw retaliatory tizzy fits. Your failure to in any way utilize the
    911 call tapes and videos Coughlin took of the moments prior to arrest (where the youths admit they are trying
    to steal Coughlin's bike and his dog, to teach him a lesson...not to "detain" him or effect a "citizens arrest" (it
    almost seemed like DDA Young had you make the arguments he wanted to make, but knew would be unethical
    000377
    for him to make, or would expose other glaring weaknesses in his case, and in that way, you two really make
    beautiful music together, Jim). Then there is the fact that Coughlin himself called 911, and that Coughlin is
    heard on the video's prior to the police arriving encouraging the hostile gang of late teens, early twenties
    skateboarders to remain peaceful, and wait for the police to arrive, so the matter could be handled civily (and
    not lead to anyone dying, as Coughlin referenced the tragic death of a 25 year old man intervening in a purse
    snatching of that was in the news just months prior to the August 20th, 2011 arrest in this matter RCR2011-
    063341...really, Jim, you should join us at the November 14th,2 011 bar hearing in NG12-0204, as the SCR 105
    Complaint saw fit to make this pending criminal charge a basis for a professional misconduct hearing.
    In the meantime, why don't you send me the digital transmissions that Judge Sferrazza ordered, and not hide
    behind some "there's not enough time to make copies" non-sense. Right, Jim, you are really going to give me
    your only copies of things. Uh-huh. You? Jim, you? Jim, you spend all day covering your ass, so please.
    Besides, the Judge did not rule that I have to pick up some box of stuff, and sign some document while being
    harassed by you, attesting to the contents of long pieces of digital media (which I am sure you will object to me
    watching right there in your office). That is the beauty of the digital transmission, Jim. Maybe the WCPD will
    need to get itself a Skydrive, they are free, who knows? All I know is I have made far less money than you this
    year Jim, and done the lion's share of work on this case (with lots of extra work added by your misconduct), and
    I have found your work on this matter to be amongst the most distasteful I have ever seen by an attorney.
    So, now that I know that your office did subpoena Kelly Odom (she showed up to Trial, yet you kept that secret
    from me, in addition to the subpoena duces tecum you sent her, really late in the game, on October 3, 2012.
    Also, you do realize that RPD Officer Duralde's wife was on duty that night working as a dispatcher for ECOMM,
    right? Jessica Duralde, and what dispatch told the RPD that night has become a material issue in this case. Yet,
    the WCPD was satisfied with was the RPD gave them and didn't send a subpoena duces tecume out to ECOMM
    until after the Trial would have been over already, had it not been for how tenacious that Coughlin is.
    Finally, Jim, you might want to reconsider your analysis respecting your purported failure to subpoena witnesses
    after reviewing the attached, as you wrote:
    "I have not subpoenaed witnesses to the November 19, 2012, resumption of trial because (1) contrary to your
    assertions, no witnesses appear to have credible and persuasive prospective testimony to help your case, in fact
    most of the witnesses you have insisted on calling at trial appear to have prospective testimony harmful, not
    helpful, to your defense, (2) the witnesses you have demanded we subpoena and have testify appear to actually
    have prospective testimony contra to a finding of not-guilty, and (3) I already obtained several points through
    cross examination of Zurate, Duralde, and Goble that you requested and that are credible and potentially
    persuasive points in favor of your defense (please recall your comments to me during the first day of trial, I like
    where you are going with this . . . . )."
    From: Jleslie@washoecounty.us
    To: zachcoughlin@hotmail.com
    000378
    Subject: FW: Coughlin: Petit Larceny case -- Hand-Off Transmittal
    Date: Wed, 31 Oct 2012 23:56:26 +0000
    Mr. Coughlin:
    I understand from staff that you came in today demanding your documents. I also received your email asking for them
    and saying your email was now working again.
    Below is the original transmittal I tried to send Monday of this week.
    You have asked for proof of the transmittals bouncing back. I will print those, PDF them, and send them to you via email
    attachment tomorrow when I have time. In the meantime, now that you say your email is again working, I wanted to get
    the below transmittal to you today without further delay.
    Please note that, as noted in the below email, there are disks and photos as well. Please email me as to your availability
    to come in and take receipt of those.
    Thank you.
    James B. Leslie, Esq.
    Chief Deputy Public Defender
    Washoe County Public Defenders Office
    350 South Center Street
    Fifth Floor
    Reno, NV 89509
    1-800-762-8031
    Direct Dial: 775-337-4828
    Fax: 775-337-4856
    Email: jleslie@washoecounty.us
    000379
    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.
    From: Leslie, Jim
    Sent: Monday, October 29, 2012 2:17 PM
    To: zachcoughlin@hotmail.com
    Subject: Coughlin: Petit Larceny case -- Hand-Off Transmittal
    Importance: High
    Mr. Coughlin:
    This transmittal is protected by Attorney-Client Confidentiality. However, dissemination of any kind of the contents hereof
    or of any of the attachments hereto may effect a waiver of such Confidentiality, as you have been previously advised in prior
    emails and as you know from your legal training.
    Transmitted herewith as attachments are file materials which are transmitted as courtesy hand-off transmittal from us
    as assigned counsel of record to you as court-permitted self-representing defendant, for purpose of assisting you in your
    preparation for resumption of trial in the Petit Larceny case currently scheduled for November 19, 2012, at 8:30 a.m., and
    as to which date you have been previously advised via US Mail, email notice, verbal notice, and as you have previously
    acknowledged being advised of in prior proceedings in open Court.
    The attachments themselves shall serve as inventory of the materials transmitted herewith. Additionally, as courtesy and
    as memorialization of various issues, please note the following:
    Please note that there are also several computer discs/DVDs containing video and/or audio on them, as well as a set of
    color-printed photographs which we had prepared in response to your September 20, 2012, email to us, that we will
    produce in tangible form separate and apart and in addition to this email transmittal. You will need to pick those items
    up from our office and sign a receipt. A copy of that receipt is attached hereto as a PDF attachment, titled Receipt of
    Documents. Please email me whether you are available 10/29/12 or 10/30/12 for pick-up of the additional documents
    and I will arrange to be present with an executable receipt for your signature. Said receipt is necessary in part because
    the materials listed in the Receipt of Documents cannot be reproduced on short notice, in an effort to ensure you
    receive them well before the resumption of trial, and to avoid dispute as to what materials were handed over to you.
    000380
    I note that you and the Court confirmed at the last hearing that you have already directly received copies of the JAVS
    audio recordings of proceedings from the Court, so we are not producing those in duplicate.
    Included in the attached PDF transmittals are copies of clean, unredacted discovery materials from the State, copies of
    those materials with redactions, and our transmittal letter to you including redacted copies of the discovery materials
    dated December 1, 2011. We have also provided you via email other copies of those same discovery materials on prior
    occasions. Additionally, I recall personally trying to provide you additional courtesy copy of those materials on at least
    one occasion when you came to the office without an appointment and made loud verbal demands for another copy of
    your discovery because you had lost your previously provided copies, however, you then left the office when we tried
    to provide you that additional copy.
    Although we are hereby producing various pleadings as PDF attachments to this email, as listed herein, my understanding
    from you is that you already have copies of all filed pleadings, orders, etc., from your direct contacts with the Reno
    Justice Court. Nevertheless, the pleadings listed herein are produced as PDF attachments as a courtesy.
    We are not producing you copies of the voluminous emails and email attachments you have previously sent us, since by
    being the transmitting party of those emails and attachments you obviously have them yourself.
    Please also note that you are now operating as your own self-representing counsel, by way of the self-representation
    granted you by the Court on 10/22/12, in the petit larceny case. If you represent to anyone that you are operating in that
    case in conjunction with or as co-counsel with our office or any attorney therein, other than in our capacity as Stand-By
    Counsel, we will have to consider reporting you to the State Bar for fraudulent misrepresentation. Additionally, as you
    were warned by the Court on 10/22/12, you cannot use any of the materials we are transmitting or the information
    contained in those materials to harass any person or otherwise put the materials or information therein to any other
    improper use. These cautionary notes include but are not limited to information contained in the cell phone records of
    Mr. Goble and the addresses, phone numbers, and other contact information of any persons identified in the transmitted
    materials, including those attached to this email transmittal and those contained in the Receipt of Documents.
    Given your past statements to me, I believe I should also warn you of the possibility of applicability of Nevada Rule of
    Professional Conduct 3.3. In that regard, please recall that during a meeting between you and I in one of the interview
    rooms at Reno Justice Court during trial on 9/5/12, you suggested to me that I alter the video recording of your
    interaction with the police officers in the petit larceny case. I told you I cannot do that. You became irate and
    argumentative and asked why I could not do it, and I told you it would be unethical. I raise this issue in this email
    transmittal to reiterate what I have had to tell you more than once in this case, that is, I cannot and will not assist you in
    alteration of evidence or other commission or attempted commission of fraud upon the court. Should I observe you
    attempting to do so during the resumed trial, currently set for November 19, 2012, as noted above, I believe I would be
    required under Nevada Rule of Professional Conduct 3.3 to advise the Court.
    I have not subpoenaed witnesses to the November 19, 2012, resumption of trial because (1) contrary to your assertions,
    no witnesses appear to have credible and persuasive prospective testimony to help your case, in fact most of the
    000381
    witnesses you have insisted on calling at trial appear to have prospective testimony harmful, not helpful, to your defense,
    (2) the witnesses you have demanded we subpoena and have testify appear to actually have prospective testimony
    contra to a finding of not-guilty, and (3) I already obtained several points through cross examination of Zurate, Duralde,
    and Goble that you requested and that are credible and potentially persuasive points in favor of your defense (please
    recall your comments to me during the first day of trial, I like where you are going with this . . . . ). Additionally, the
    Court advised you on 10/22/12 that if you believe you require subpoenas, you may contact the Court directly and obtain
    subpoenas with waiver of fees.
    As directly by the Court on 10/22/12, I will be present at the trial on November 19, 2012, at 8:30 a.m. as Stand-By
    Counsel. If during the resumed trial you believe you are unable, after all, to adequately handle the trial proceedings
    yourself, I will be available to take over representation, at which point I would do my best to correct any errors or tactical
    mistakes you might have committed as well as otherwise try to win the case for you.
    Thank you,
    James B. Leslie, Esq.
    Chief Deputy Public Defender
    Washoe County Public Defenders Office
    350 South Center Street
    Fifth Floor
    Reno, NV 89509
    1-800-762-8031
    Direct Dial: 775-337-4828
    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.
    000382
    000383
    Print Close
    grievance against Keith Loomis, Esq. and Christopher
    Hazlett-Stevens, Esq., Lew Taitel, Esq., and Henry Sotelo,
    Esq., and WCPD Biray Dogan and Jim Leslie
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 10/22/12 12:33 AM
    To: complaints@nvbar.org; complaint@nvbar.org; rosec@nvbar.org; davidc@nvbar.org;
    patrickk@nvbar.org; glennm@nvbar.org
    Dear Bar Counsel,
    Please accept this filing of a formal grievance against the attorneys listed and mentioned
    herein. The basic import of this grievance is that these public defenders and
    prosecutors seek to leverage the benefits of Order for Comptency Evaluations (buy
    them some time to do research once they get cornered or exposed) while avoiding any
    of the dictates of NRS 178.405 and NRS 5.010 requiring "all proceedings" be stayed.
    There was an Order For Competency Evaluation by Judge Clifton in RCR2012-065630
    entered February 27th, 2012, and the Order in CR12--0376 adjudging Coughlin
    competent and remanding jurisdiction back to the lower court was not entered until May
    9th, 2012, yet Loomis and Hazlett-Stevens persisted in seeking to ramrod the criminal
    trespass case in RMC 11 CR 26405 through...and both were well aware of the February
    27th, 2012 Order for Competency Evaluation and the import of NRS 178.405, requiring
    the suspension of all proceedings during the pendency of such an Order. Further, the
    RMC failed to file the timely Notice of Appeal I submitted for filing on June 28th,
    2012, and which was served by delivering to the City Attorney's Office on June 27th,
    2012 (timely within 10 days under NRS 189.010) resulting in the dismissal of the
    appeal.
    Further, Loomis and Puentes deprived me of my right to supboena witnesses to defend myself in RMC 11 CR
    26405, a criminal trespass matter resulting in a criminal trespass conviction on June 18th, 2012, which I reported
    to Bar Counsel in compliance with SCR 111. SBN Bar Counsel King has the audio from two of the pre-trial
    hearings and I am attaching the audio of the trial or linking to it herein. It demonstrates the fact that Dr. Merliss
    was a percipient, material eye witness (in fact Dr. Merliss lied to the RPD in effectuating this wrongful arrest, and
    Sargent Marcia Lopez has admitted to me, contrary to RPD Officer Chris Carter's police report and Richard Hill's
    June 18th, 2012 sworn testimony and Casey Baker, Esq's (whom was not even there on November 13th, 2011)
    NRCP Rule 11 violating (given he possessed the video's taken by Dr. Merliss and his supervisory attorney,
    Richard G. Hill, Esq, which were propounded to the Reno City Attorney's Office and which both Loomis and
    Puentes had, which further demonstrate their culpability. There is a suggestion that these "contract" court
    000384
    appointed defenders put their own profit motive above their client's rights to subpoena witnesses and gather
    evidence to defende their cases (similar to the refusals by WCPD Jim Leslie, Loomis refused to procure and
    provide the audio of two extremely relevant court proceedings in the RJC, necessary to the defense of RMC case,
    which led to 18 days wrongful incarceration of me from July 3, 2012 to July 21st, 2012 in RMC 12 CR 12420.
    The two RJC matters are the Milan Krebs TPO hearing in RJC RCP2012-000287 (particularly necessary to the
    defense of that matter, in addition to the matter Leslie represent me on incident to a wrongful June 28th, 2012
    arrest by the WCSO in RCR2012-067980, incident to a fraudulently procurred Summary Eviction Order
    (stemming from the fraudulent Declaration of Personal Service by license process server Robert Wray for Nevada
    Court Services, which was committing the unauthorized practice of law (deeming themselves an "eviction
    consulting and process service company" in RJC rev2012-001048, where Wray lied about "personally serving" me
    a June 14th, 2012 5 day unlawful detainer notice (he tried to break and enter my rental #29, which had not
    windows and which had a locked front door at the time that he and Northwind Apartments Manager Duane Jakob
    attempted to break and enter and committ another trespass (as they had done previously, when they failed to get
    the City of Reno Code Enforcement to do their bidding in seeking to subvert the summary eviction process, and
    where the RPD, though making threats to arrest me for criminal trespass violative of Soldal v. Cook County, was
    taking too long to "help" Northwind out. WCPD Leslie failed to inform me or notify me in any way as to the fact
    that the WCDA filed, on August 23rd, 2012, a document listing Jakob as a witness it intends to call in its
    prosecution of me in RCR2012-067980. Further, WCPD Biray Dogan failed to inform me in any way of the fact
    that, on July 31st, 2012, DDA Young filed a Motion to Amend Criminal Complaint wherein he, lacking a RPC 3.8
    probable cause basis to do so, seeks to amend his charge in RCR2012-065630 to a charge that would invoke, upon
    a conviction, the reporting requirements of SCR 111(6), rather than maintain the difficult task of prosecuting one
    for "misue of 911" where 911 was allegedly utilized to report police misconduct, whereupon 911 operators
    purportedly efused to document such a complaint or report in any way. Additionally, Henry Sotelo, similar to
    Loomis, refused to procure and provide to his client, Coughlin (once Loomis received his second Order granting
    his withdrawal as court appointed counsel for Coughlin, once in RMC 11 CR 26405 (now a SCR 111(4) petition,
    filed by Bar Counsel against Coughlin on October 15th, 2012) and again in RMC 12 CR 12420 (Loomis also
    refused to send a request for discovery or subpoena duces tecum to the City of Reno or RPD for the various
    police reports Sargent Dye and Officer Weaver reference during an impermissible, unnotice, impromptu bail
    hearing (wherein Jill Drake, Esq. committed professional misconduct) on July 5th, 2012 (at which RMC Judge
    Gardner again failed to recuse himself despite the pending grievances filed on his behalf by Judge Nash Holmes,
    NG12-0434 and NG12-0435, the latter of which resulted from Judge W. Gardner's sister passing to him, her
    brother, her April 2009 Order After trial sanction Coughlin, to RMC Judge Nash Holmes, whom filed it on March
    14th, 2012 with Bar Counsel, along with her admission to to communications with the WCPD's Office, which the
    WCPD'S Office, including Bosler, Dogan, and Leslie, have refused to comment on to Coughlin in any way, aside
    from Leslie's dubious assertion that he is completely unaware of such.
    Regardless, given the import of NRS 178.405 and NRS 5.010, the June 18th, 2012 Trial in RMC 11 CR 26405
    should have never taken place, should have never been set on May 8th, 2012 (particularly where the 2/27/12 Order
    for Competency Evaluation in RCR2012-065630, to which Loomis admits to have been aware of, was not ruled
    upon by D10 ("Tiburon" prinout sua sponte gathered by Judge Gardner aside, where Loomis didn't manage to get
    one, though he did argue that an unofficial online "docket" was somehow capable of providing judicial notice of
    an Order Finding Coughlin competent on May 8th, 2012, which is clearly violative of NRS 178.405 and NRS
    5.010). Additionally, it is preposterous to find that Coughlin was able to make the decision to proceed without
    Loomis or other court appointed, Sixth Amendment satisfying representation, on May 8th, 2012, given the Order
    by D10 in CR12-0376 finding Coughlin competent did not get signed and entered until May 9th, 2012. This is
    reminiscent of DDA Young filing an Opposition to Coughlin's Motion to Appear as Co-Counsel in RCR2011-
    063341 after the entry of the 2/27/12 Order for Competency Evaluation by Judge Clifton in RCR2012-065630
    (though the docket lists Judge Schroeder as presiding over that "clandestine" status conference, so deemed in light
    of Coughlin being notice in writing that it had been vacated to March 29th, 2012, in light of the scheduling
    conflict presented by the RMC 11 TR 26800 traffic citation trial set for 1:00 pm on 2/27/12 before Judge Nash
    Holmes, which she held anyways, despite the dictates of NRS 178.405 and NRS 5.010 and the communicatiosn
    Judge Nash Holmes admits to in the March 14th, 2012 grievance she filed on behalf of all RMC Judges (including
    pro tempore ones) on March 14th, 2012, and for which Judge William Gardner admits to being aware of, as does
    City Attorney Hazlett-Stevens, whom makes ridiculously mincing arguments respecting the difference in being
    000385
    "competent" to practice law versus being "competent" to stand trial, even where he was aware of RCR2012-
    065630 and CR12-0376. Further, upon information and belief, Hazlett-Stevens demonstrates a lack of candor to
    tribunals where he argues he was not "served" documents that he recieved via email and or fax where the RMC
    Rules allow for such transmissions to constitute service upon "governmental attorneys". I reserve my right to
    supplement this grievance further at a later date. Additionally, Mr. Sotelo violated NRS 178.405 and NRS 5.010
    on September 30th, 2012 where he filed a Motion to Withdraw as Coughlin's Counsel of Record in 12 CR 12420
    during a period in which a September 5th, 2012 (though it might be file stamped September 7th, 2012) Order for
    Competency Evaluation of Coughlin in RCR2011-063341 was entered (and which the RMC, City Attorney
    Sooudi, and RMC defender Sotelo recognized as requiring a stay of a Motion Hearing in 12 CR 12420 on
    September 18th, 2012...). Sotelo compounds his misconduct by making spurious and vague allegations against his
    then client Coughlin in that Motion alluding to some "repugnant" course he alleges Coughlin wishes to maintain,
    though, predictably, Sotelo fails to provide any support for his egregiously prejudicial statement, damaging of his
    client's interests and defense, all while violating NRS 178.405 and NRS 5.010.
    Further, given the correspondences admitted to between Puentes and Loomis with the Washoe County Public
    Defender's Office, and in light of the fact that both Loomis and Puentes are employed by the RMC, the various
    Orders for Competency Evaluation filed since the first one of September 8th, 2011 regarding Coughlin, in
    RCR2011-063341, vitiate the import of all subsequently void Orders predicated upon any part of any proceeding
    not stayed during the pendency of such an Order for Competency Evaluation. That means, the conviction in RMC
    11 CR 22176 underpinning the SCR 111(6) petition in 60838 resulting in Coughlin's current temporary suspension
    of his law license, is necessarily void, particularly where the arraignment took place at a time (October 10th,
    2011) when Coughlin's competency was put into question, particularly where RMC defender Lew Taitel,
    appointed at Coughlin's court ordered defense counsel beginning on November 19th, 2011, was aware of the
    pending Order for Competency Evaluation in RJC RCR2011-063341 at the time of the November 30th, 2011 Trial
    in RMC 11 CR 22176. resulting in Coughlin's conviction for petty larceny. Please add Pamela Robert, Esq., City
    of Reno prosecutor on that matter to this grievance in that regard as well, in addition to her coworker Allison
    Ormaas, particularly where she appeared and offered argument both at the 2/27/12 Trial in 11 TR 26800 in the
    RMC, but as well as the February 12th, 2012 continuation of that Trial. In that regard, all of Judge Nash Holmes
    purported Orders, including those finding Coughlin "by clear and convincing evidence" to be guilty of "summary
    criminal contempt" and other violations of the Rules of Professional Conduct incident to the traffic citation trial in
    11 TR 26800 on 2/27/12 that Judge Nash Holmes, despite the mandates of NRS 178.405 and NRS 5.010,
    transmogrified into a disciplinary proceeding against a pro se attorney indigent criminal defendant denied his
    Sixth Amendment Right To Counsel in a proceeding wherein jail time was ultimately ordered, are also void, to the
    extent they are not already void given the divesting of her jurisdiction incident to Coughlin filing, on March 7th,
    2012, a Notice of Appeal of that summary contempt order as rendered (especially where the March 28th,2 2012
    written Order by Judge Nash Holmes was mailed to an address for Coughlin that the RMC knew was no longer
    good). Most recenlty, WCPD Dogan and Goodnight, in a stipulation with DDA Young sought to swap an October
    15th, 2012 hearing date in RCR2012-063341 with Dogan (though Dogan has not communicated with me at all in
    what seems like months, and Leslie appears to be taking ownership of that case, in RCR2012-065630, though
    Leslie does not communicate with me much at all either...and most of the information I glean from this matters is
    culled from repeated trips to the filing office, where bailiffs have implemented rules limiting my access to justice
    to 15 minute installments...). The public defenders (including Sotelo, whom only sent me a copy of his Motion to
    Withdraw after the Order granting it was signed...) repeatedly fail to adhere to the RPC concerning their duty to
    communicate with clients., particularly where I have put them on written notice respecting my demands to be
    copied on any and all filings and correspondence in any way connected to any of my cases.
    To wit:
    "CERTIFIED COPY OF DOCKET
    13 November 2011: Criminal Complaint issued upon the oath of Reno Police
    000386
    Department Officer Carter.
    Charge I: Trespass, a violation ofR.M.C 08.10.0lD.
    14 November 2011: Defendant appeared while in custody before Judge William
    Gardner
    for arraignment. The defendant was represented by Keith Loomis Esq. and on behalf of
    the City
    was Christopher Hazlett-Stevens. The defendant was advised of his Constitutional
    rights. The
    Defendant entered a plea of Not Guilty and a trial date was set for December 13, 2011.
    Lewis
    Taitel Esq. was appointed to represent defendant. Defendant's request for release on
    O.R. was
    denied.
    15 November 2011: Cash bail in the amount of$3 1 0.00 wa.s posted and the defendant
    was
    released from the Washoe County Jail.
    23 November 2011: Motion To Continue With Supporting Declaration filed by
    Deputy City Attorney Christopher Hazlett-Stevens.
    28 November 2011: Order Continuing Trial signed by Judge William Gardner.
    30 November 2011: Trial date of January 10,2012 set by the court. Legal Defender
    Roberto Puentes was appointed as Attorney for defendant for new trial date.
    14 December 2011: Motion To Proceed Inforrna Pauperis filed by defendant.
    03 January 2012: Motion for New Trial Date filed by Legal Defender Roberto
    Puentes.
    04 January 2012: Motion for New Trial Date granted by Judge William Gardner.
    18 January 2012: Motion For Withdrawal Of Attorney filed by Legal Defender
    Roberto Puentes. A motion hearing was set for February 2,2012.
    02 February 2012: Motion hearing held before Judge William Gardner. Present at
    the hearing on behalf of the City was Deputy City Attorney Jill Drake, for the defense
    Roberto
    Puentes and defendant Zachary Couglin. Motion To Withdraw was granted. Legal
    Defender
    Keith Loomis was appointed to represent defendant.
    13 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
    JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication Of
    Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
    16 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
    000387
    JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication Of
    Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
    22 February 2012: Opposition to Defendant's Motion filed February 13,2012, filed
    by Deputy City Attorney Jill Drake.
    05 March 2012: Trial date set for April 10, 2012 by Court.
    05 March 2012: Notice Of Appearace As Co-Counsel And Motion To Dismiss filed
    defendant.
    20 March 2012: Order #1 denying defendant's motion filed 13, February 2012 signed
    by
    Judge William Gardner.
    21 March 2012: Order #2 denying defendant's motion filed 5, March 2012 signed by
    Judge William Gardner.
    21 March 2012: Motion To Strike Defendant's Motion To Dismiss Complaint filed by
    Deputy City Attorney Christopher Hazlett- Stevens.
    10 April 2012: Defendant appeared for trial with counsel Keith Loomis, Judge William
    Gardner presiding. Present on behalf of the City was Christopher Hazlett-Stevens.
    Several
    pre-trial motions were heard. An Order Suspending Proceedings was signed. All
    proceedings suspended until the question of competence is determined. Case Status
    Hearing
    scheduled for 8, May 2012.
    08 May 2012: Case Status hearing held before Judge William Gardner. Present on
    behalf of the City was Deputy City Attorney Christopher Hazlett-Stevens, for the
    defense
    Keith Loomis and defendant Zachary Coughlin. Defendant was found to be competent.
    Defendant's motion to remove Keith Loomis as counsel granted. Trial date set by the
    court
    for June 18,2012.
    OS June 2012: Notice Of Appearance As Counsel ; Motion To Dismiss; Motion To
    Suppress; Motion For A Continuance Of Trial And Transfer To Mental Health Court
    filed by
    defendant.
    18 June 2012: Defendant appeared for trial pro-per, Judge William Gardner presiding.
    Present on behalf of the City was Christopher Hazlett-Stevens. Several pre-trial motions
    were heard. Motion to Continue filed by defendant denied. Motion to Dismiss filed by
    defendant denied. Motion to Suppress denied. Motion to Recuse denied. Motion to
    Transfer
    000388
    to Mental Health Court denied. Case tried on its merits and the Defendant was found
    guilty of the
    charge of Trespass, a violation of R.M.C 08.10.010.
    The Defendant was sentenced as follows:
    Trespass, a violation of R.M.C 08.10.0 10. : Time Served and a $310.00 fine.
    26 June 2012: Motion for New Trial filed by defendant.
    11 July 2012: Order Denying Motion For New Trial & For Other Relief signed by
    Judge
    William Gardner.
    18 July 2012: Notice Of Appeal filed by defendant.
    19 July 2012: Notice Of Appeal filed by defendant.
    2 3 July 2012: Notice Of Appeal filed by defendant.
    25 July 2012: Notice of Appeal, motion to Vacate and or Set Aside, JCRCP 59, JCRCP
    60,
    Motion for Reconsideration; Motion for Recusal; Motion For Publication Of Transcript
    at
    Public Expense, Petition for In Forma Pauperis Status filed by defendant.
    Municipal Judge.
    Department Two
    CERTIFICATE OF TRANSMITTAL OF COMPLETE RECORD ON APPEAL
    1, Cassandra Jackson, Court Administrator of the Reno Municipal Court, do hereby
    certifY that the attached documents include full, true and correct copies of all papers
    relating
    to Case Number II CR 26405 21, including a Certified Copy of Docket, Plaintiff's
    exhibits 1-
    3. Further, said documents have been transmitted to and filed with the clerk of the
    Washoe
    County District Court. Transcript to follow."
    Further, Taitel took on my representation despite a clear conflict existing, ie, I was
    suing his business partners, Nevada Court Services (with whom he shares a fax number,
    mailing and physical address, receptionist, is listed as "associated with" and "Staff
    Attorney" on the Nevada Court Services official web site, etc....all while NCS was
    trespassing against me at my former home law office, while being hired by Richard G.
    Hill and Casey Baker, Esq.. I submitted an IFP and propsed Complaint in the District
    Court on October 19th, 2011 CV11-
    000389
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    bar grievance against Richard Hill, Casey Baker, and Keith
    Loomis, Roberto Puentes, Lew Taitel
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 10/18/12 8:02 AM
    To: laurap@nvbar.org; patrick@nvbar.org; rosec@nvbar.org; glennm@nvbar.org;
    davidc@nvbar.org; tsusich@nvdetr.org; complaint@nvbar.org; complaints@nvbar.org;
    shornsby@nvdetr.org
    From: zachcoughlin@hotmail.com
    To: laurap@nvbar.org; patrick@nvbar.org; rosec@nvbar.org; glennm@nvbar.org; davidc@nvbar.org;
    tsusich@nvdetr.org; complaint@nvbar.org; complaints@nvbar.org; shornsby@nvdetr.org
    Subject: LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331 61383, SBN v. Coughlin CASE
    NUMBER NG12-0204, NG-0435, NG 0434
    Date: Wed, 17 Oct 2012 16:59:57 -0700
    Dear Office of Bar Counsel, Investigator Peters, Chairman Susich, et al,
    Please find important attachments supporting the assertions herein here:
    https://skydrive.live.com/redir?resid=43084638F32F5F28!3587
    Please don't try to old "my IT guy said I couldn't open it, because of viruses and stuff".
    That is no more plausible an excuse for reviewing materials material to your
    000390
    investigation than would be suggesting your fear of "anthrax" potentially being mailed
    to you prevents you from opening your paper mail...You have my personal guarantee
    that there is no virus or other harmful items in any emails I send you or any paper mail,
    either, for that matter. I submit these materials respectfully and ask you to consider
    how being wrongfully incarcerated ten times in one year following a divorce of sorts
    would affect our tone, behavior, or personality.
    Loomis refused to advocate at all on my behalf, refused to subpoena material percipient
    witness Merliss, and refused to make argument directed to issue I provided wealth of
    support on, ie, the invalidity of the eviction order where the lockout occurred outside of
    the "within 24 hours of receipt" window in the statue, and where technical service
    requirements were not met, vis a vis NRS 40.400, NRCP 6(e), and NRCP 5(b)(2), and
    where Loomis acted on matter during pendency of Competency Evluation in cr12-0376.
    Also, will you please have the NG- grievance or case numbers for all of the grievances
    and complaints I have filed this year provided to me in writing, including the new
    grievances found herein against Richard G. Hill, Casey Baker, and Christopher Hazlett-
    Stevens?
    note: please forward this written correspondence on to Bar Counsel King and
    Investigator/Clerk of Court Peters in light of their apparent and sudden, somewhat
    technical "issues" with emails from Coughlin, which in no way is interpreted as
    providing indications that they now seek to sully the SBN's image by attempting to add
    Coughlin to their blocked sender list or otherwise prevent any further duty accruing on
    their part to actually investigate Coughlin's claims, in some manner that at least a
    colorable argument can be made that the SBN treats Coughlin's and others allegation
    with anywhere near the urgency it treats those of Judge Nash Holmes or Richard G.
    Hill, Esq. (in contrast to the whole "attack dog for the rich and powerful" image, some
    might say, the SBN has built up....
    It is ironic, that Hill and Baker's own writing in their November 21st, 2011 Opposition
    to Coughlin's November 16th, 2011 Motion to Contest Personal Property lien may now
    be used against them, in light of the staleness, voidness, and invalidity of the October
    25th, 2011 and October 27th, 2011 Eviction Decision and Order and Findings of Fact,
    Conclusions of Law and Order for Summary Eviction in RJC Rev2011-001708. See
    000391
    Williams v Nagel, 643 N.E. 2d 816 and Wolf-Lillie, 504 F. Supp 1. Baker wrote on
    Hill's behalf:
    "Here, Coughlin filed his first motion pursuant to NRS 118A-460 on November
    16,2011. That motion was timely. However, when the court attempted to set the
    hearing, Coughlin refused to cooperate or communicate with the court to get the
    hearing on calendar, despite repeated requests from Merliss' counsel that he do so. As a
    sole and direct result of Mr. Coughlin's refusal to cooperate with the court to set his
    own hearing, that hearing never happened. The 10 days in which to hold the hearing
    under NRS 40.253(8) have now expired. Mr. Coughlin's motion is stale, and the relief
    he seeks is now time-barred. Because he abandoned that motion, it was, effectively,
    denied."
    To Baker's November 21st, 2011 Opposition (how clever, Baker writes it so he can
    make reckless allegations that aren't true in it that Hill would not be so free to make,
    given he was there during the November 12th, 2011 arrest), is attached the signed,
    sworn, November 21st, 2011 Declaration of Richard Hill, which reveals at the least an
    intent to mislead the tribunal by Hill, and also reveals Hill and Merliss contributed to a
    false arrest to a material extent. That Declaration reads:
    "4. On October 27, 2011, this court signed a summary eviction order, and on November 1, 2011, the Washoe County Sheriffs
    Department served that order. The notice was posted on the door of the home by the Washoe County Sheriffs Department in
    the manner customary in Washoe County for evictions. The locks on the front door and back door were changed, and we
    retained all keys to the home.
    5. After that date, I began to notice that it looked like somebody had been
    getting into the home. On approximately November 4,2011, I became concerned about the
    home and its contents. I entered it and was able to confirm that "somebody" had been getting in. I
    thought I had secured the means of entry being used by whoever it was that
    was getting in. However, on later visits to the home, it was clear that the home was still
    being surreptitiously accessed.
    6. On November 13, 2011, Dr. Merliss came to Reno because he wanted to
    inspect the home. Upon entry, it was clear that somebody had again accessed the home.
    7. We tried to enter the basement and found the door was barricaded, not locked, from the inside. We
    were concerned that whoever had been accessing the home was inside, so we called the police.
    8.
    When the police arrived, they agreed with us that it was very likely that somebody was barricaded in
    the basement. The police tried to coax the person to come out, but without success.
    9.
    When the police declined to break down the door, Dr. Merliss did so. The police looked inside and
    discovered the defendant, Zachary Coughlin, and his dog.
    10. Coughlin came out peacefully, went upstairs and was placed under arrest
    by the police for trespassing.
    11. After Coughlin was taken to jail, Dr. MerHss and I tried to videotape the contents of the basement
    where Coughlin had been hiding. It was too dark to effectively videotape, but we were able to ascertain
    that Coughlin and his dog have been living in th
    basement ofthe home for quite some time, likely even before the lockout. I observed that Coughlin had
    000392
    a bed set up. He had several computer monitors. He had a store ofhoth food
    and water. He had electric space heaters.
    12. Since the eviction order was served, my associate, Mr. Baker, and I had sent numerous emails to
    Coughlin, in which we both repeatedly made it clear to him that he was not to be at the borne without
    our prior permission. No such permission was given.
    Mr. Coughlin had no reason to possibly think he was permitted on the property. We had
    tried to coax him to cooperate on getting his possessions Qut, without success, or even a response.
    13. As a result ofMr. Coughlin's break-ins, Dr. Merliss has incurred a bill of $1,060 with a licensed
    contractor to secure the premises. That does not include the cost of the door that was broken in order
    to get Coughlin out. That does not include the numerous hours of me and my staff to deal witb Mr.
    Coughlin's repeated break-ins at the home.
    14. I am no expert, but I believe Mr. Coughlin is wbat is called a "hoarder."
    He has many car seats throughout the house. He has many dead televisions. He has a box of car
    window servo motors. The attic, which can only be accessed through a very narrow
    opening, is full of items, including dead electronic devices.
    15. We have found drugs at the home. We found a bag of what looks like
    marijuana on the kitchen counter. I found a crack pipe. The contractor found what he said
    was a large quantity of pills.
    16. Mr. Coughlin has been harassing and stalking me, and possibly, my staff.
    On Noyember 15, 2011, he burst into my office and created a scene. Then, he was parading up and
    down the sidewalk across the street with a video camera screaming obscenities at
    me and my staff."
    Now, if one reads that Declaration by Hill, then watches the videos Hill took of the moments
    before, during, and after Coughlin's arrest for criminal trespass on November 13th, 2011...well, one
    must conclude Hill and Merliss lied, and broke the law, resulting in profound reputational damage to
    Coughlin and vast damage to his family and career. They should do time for this, period. Where, in
    that Declaration, so soon after the arrest it is almost an "excited utterance" is Susich or Kings allegation
    of "breaking and entering" and the "locks being broken"? Why wouldn't Hill just say that in the
    Declaration if it was true? Where is the video of the basement that Hill mentions attempting to take.
    There wasn't one provided in the materials Hill gave to the city attorney, which were discovered to
    Coughlin. Why doesn't Hill correct his client when he lies, in front of the police, just before the
    handcuffing moment, in response to Coughlin's query as to who exactly, in anyone, had told Coughlin
    to leave, or issued a "warning". That basement was fixed up to be, basically, a studio apartment
    addition to the main floor for over a year before the eviction, and Hill admits this appears to be the
    case in another filing. Hill misleads the court above where he fails to mention the numerous times
    Coughlin indicated he had added HIll to his "blocked senders list" and or indicated he did not consent
    to any form of electronic service or notice of anything, and where Baker was on vacation in early
    November. The video's Hill took title Zach's arrest 0007-0014, found at the above link, show particularly
    well the fraud and criminal conduct by Merliss and HIll including lying to effectuate a false arrest and
    criminal trespass and invasion of privacy.
    What is actually stalid, invalid, void, null, expired, or otherwise ineffective is the
    October 25th and 27th Summary Eviction Orders by Judge Sferrazza in light of the
    WCSO's admission that on November 1st, 2011 (allegedly at 4:30 pm), Deputy Machen
    broke into Coughlin's former home law office with Hill or Baker in tow (and probably
    one of those lawyers legal assistant/videographers whom drive a new Mercedes SL-600
    convertible coup....the kind with a V-12 engine...that's right, a V-12, $130,000 new,
    three times the engine found in Coughlin's four banger 1996 Honda Accord LX (at least
    000393
    its not a DX, right?) with 110,000 miles on it):
    All the case cited below are relevant, and most are terrible, for Hill, Baker and Merliss, in addition to
    making the criminal trespass conviction extremely suspect:
    Iorio, 410 NYS 2d 195
    Russell v Kalian, 414 A.2d 462
    Burhams, 89 P.3d 629
    Roswick, 231 BR 841
    Hammond, 515 SE 2d 182
    Albert, 490 NYS 2d 951
    26405 and 03628 trespass case:
    unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
    Woods 19 NYS 2d 683, Regan 425 NYS 2d 725, Iorio, 410 NYS 2d 195, Russell v Kalian, 414 A.2d 462: expired
    warrant for eviction no good
    Leese v Horne, 47 P.2d 316, Burhams, 89 P.3d 629, Roswick, 231 BR 841, Hammond, 515 SE 2d 182, Albert, 490
    NYS 2d 951, O'Brien v. U.S., 444 A.2d 946, State v. MErnar, 786 A.2d 141 (01), Canavan v. State 38 So. 3d 885,
    Jordan V. State, 802 So. 2d 1180 (01), State v. Ash, 12 SW 3d 800 (TN '99). Jordan v. State 110 P.3d at 47,
    Williams v. Nagel 643 NE 2d 816, Koenig, 742 P.2d 649,Nelson, 909 NE 2 642, claim of right O'banion 519 SE
    2d 819, Bean 465 P.2d 1441
    attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d
    607.
    Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
    Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even
    though, given the incarceration was served, it is a finally appealable order, see Gilman 275 V. Comm 474, 657 SE
    2d 474.
    000394
    Bifurcate disciplinary matters:
    In re Porep (Nev. 1941) 111 P.2d 533, In re Kaemmer, 178 SW 2d 474, Terrell v. Miss. Bar 635 So 2d 1377, Matt
    of Briggs 502 NE 2d 879, In Re Hines 482 A. 2 378, triem 929 P.2d 634, Smith 85 P. 524, In re Finsh 27 A. 3d
    401, In re Character, 950 NE 2 177, Toledo v. Cook 88 NE 2d 973('07), Cohn, 151 SW 3d 477 ('04), In re
    Crandell, 754 NW 2 501, In re Cobb, 838 NE 2d 1197, In RE Ginsberg 690 NW 2d 539, North Carolina Bar v.
    Rogers, 596 SE 2d 337. Snyder 792 A. 2d 515
    joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427
    26405 and 03628 trespass case:
    unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
    Woods 19 NYS 2d 683, Regan 425 NYS 2d 725, Iorio, 410 NYS 2d 195, Russell v Kalian, 414 A.2d 462: expired
    warrant for eviction no good
    Leese v Horne, 47 P.2d 316, Burhams, 89 P.3d 629, Roswick, 231 BR 841, Hammond, 515 SE 2d 182, Albert, 490
    NYS 2d 951, O'Brien v. U.S., 444 A.2d 946, State v. MErnar, 786 A.2d 141 (01), Canavan v. State 38 So. 3d 885,
    Jordan V. State, 802 So. 2d 1180 (01), State v. Ash, 12 SW 3d 800 (TN '99). Jordan v. State 110 P.3d at 47,
    Williams v. Nagel 643 NE 2d 816, Koenig, 742 P.2d 649,Nelson, 909 NE 2 642, claim of right O'banion 519 SE
    2d 819, Bean 465 P.2d 1441
    Please indicate in writing what you have done to investigate Richard G. Hill's
    allegations, as set forth in his January 14th, 2012 grievance against me, in writing,
    including, but not limited to Hill's allegations vis a vis the criminal trespass arrest of me
    in on November 13th, 2011, leading to a custodial arrest, and three traffic citations by
    RPD Sargent Tarter following my release on November 15th, 2011 when I ventured to
    Hill's office to retrieve my state issued driver's license, wallet (credits card, money), and
    my client's files and my own files and hard drives and other materials. This is a formal,
    written grievance against Richard Hill and Casey Baker, in compliance with my RPC
    8.3 obligations respecting their failure to turn over my hard drives, driver's license,
    client's files and my own files, their impermissibly influencing the RJC to fail to give
    000395
    me a hearing on my November 16th, 2011 filing of a Motion to Contest Personal
    Property lien within the 10 days required by NRS 40.253(7)-(8) (hearing only took
    place after Richard's six week vacation, on December 20th, 2011, in accord with
    Richard's written indication to me that he would be able to get the RJC to wait that long
    on his account..., an impermissible suggestion by Richard that he could improperly
    influence a tribunal, as was Richard threats that he would have me given the Jordan v.
    State "vexatious litigant" treatment if I kept up my opposition to his nefarious aims.
    "Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Date: Tue, 7 Feb 2012 11:40:39 -0800
    From: LStuchell@washoecounty.us
    To: zachcoughlin@hotmail.com
    CC: mkandaras@da.washoecounty.us
    Mr. Coughlin
    Our records indicate that the eviction conducted on that day was personally served by Deputy Machen
    by posting a copy of the Order to the residence. The residence was unoccupied at the time.
    Liz Stuchell, Supervisor
    WCSO Civil Section"
    Additionally, this is a grievance against Hill and Baker concerning their lying under oath at the June
    18th, 2011 criminal trespass from my former law office trial in RMC 11 CR 26405. Please review the
    Claiborne decision for support for the contention that neither Bar Counsel King, SBN Investigator Peters,
    or the SBN will find availing any argument that no investigation was required on their part respecting
    those allegations (particularly during the 5 months period between Hill's January 14th, 2012 written, but
    unsigned, grievance to Pat King and the conviction on June 18th, 2012...certainly, the SBN has taken an
    interest in my pending criminal matters...). In Claiborne, the SBN was taken to task for making such a
    suggestion that no duty to investigate on their part was present, where the Court ruled it clearly was...
    Please review the sworn Declaration by Hill attached to his November 20th, 2011 Opposition to
    Coughlin's Motion to Contest Pesonal Property Lien and that Opposition itself, especially the bit in Hill's
    Declaration where he fails to allege the RPD identified themselves as law enforcement or issued an
    "lawful order" for Coughlin to "emerge from the" "basement" (which never had an outside lock to begin
    with) prior to landlord Merliss kicking the door down (and isn't is interesting that the RPD did not feel it
    had authority to kick a door down...suggesting they also felt they did not have authority to issue a
    "lawful order" or warning, pursuant to RMC 8.10.010 to Coughlin to leave the premises. I am
    000396
    complaining of an unlawful trespass and invasion by Hill, Baker, and Merliss, especially where in the
    other videos provided to Reno City Attorney Chris Hazlett-Stevens (and this is a formal grievance
    against Hazlett-Steven's as well, especially considering the extent to which he put on perjured
    testimony, failed to hold Hill to a subpoena, in violation of Coughlin's right to a speedy trial (during the
    same 6 week vacation by Hill that resulted in the RJC failing to give Coughlin a timely Hearing on his
    November 16th, 2011 filing of a Motion to Contest Personal Property Lien in the eviction matter from
    Coughlin's former home law office in the RJC, REV2011-001708...a Motion for Continuance was filed by
    city attorneys Hazlett, which Coughlin's then RMC appointed defense Counsel Lew Taitel failed to timely
    inform Coughlin of and agree to (despite Coughlin, at that time, having filed a lawsuit against Nevada
    Court Services, on October 19th, 2011 in CV-03051, CV11-03051 ZACH COUGHLIN VS. MATT MERLISS ET
    AL (D1). 19-OCT-2011.
    Further, any writings or filings by Bar Counsel King and or Chairman Susich that suggest or indicate
    Coughlin committed a "breaking and entering" of his former law office, or that the "locks were broken" is
    totally unsupported and reckless and contradicted explicitly by the videos Hill himself filmed and his
    statements therein. Please correct any such filings and alert the Court to your transgressions.
    Baker lied and violated NRCP 11 in his NOvember 21st, 2011 Opposition where he alleged the RPD
    identified themselves as law enforcement and issued a lawful order for Coughlin to emerge from the
    "basement" or leave the property:
    "Even though he had a week to do so, Coughlin did not remove his personal
    belongings from the property prior to the lockout. In fact, he did not even remove himself
    from the property. Unbeknownst to Merliss or his counsel, Coughlin continued to live in
    the basement of the property until he was discovered squatting there on November 13. 2011
    - nearly two weeks after he was legally locked out. Coughlin had barricaded himself, his
    dog, and some of his presumably more cherished possessions in the basement. When
    Coughlin refused to emerge from the basement after being ordered to do so by the police,
    Merliss was forced to kick down the door to gain access to his own property. Coughlin was
    arrested and charged with trespassing. Due to Coughlin's criminal activities, the security
    ofthe house was compromised. As a result, Merliss was forced to incur costs in the amount
    of $1,060.00 to secure the property in order to protect it and Coughlin's belongings. A true
    and correct copy of the bill from the contractor is attached hereto as EXHIBIT 2."
    Bakers NRCP 11 violation in his filing of November 20th, 2011 in RJC Rev2011-001708 occurs at pages
    1-3, where he attempts to mislead the tribunal in suggesting that Coughin failed to cooperate in setting
    a Hearing on the Motion to Contest Personal Property Lien, even where Coughlin responded to Hill's
    then email informing him of such a hearing, by Coughlin emailing Hill "Rich, you are aware the files can
    be on hard drive's, right?" in response to HIll's email of a Hearing (Coughlin subsequently revoked (and
    had made express previously written indication that no such acceptance of such electronic service or
    notice would be availing respecting communications with Coughlin, and HIll was added to Coughlin's
    "blocked sender list" on Coughlin's Hotmail account, as such, Coughlin did not receive Hill's emails from
    October any implicit authority Hill may assert to provide Coughlin notice via electronic means, and
    therein is vitiated any of Hill's testimony at the trespass trial that the "warning" against trespass was
    relayed in Hill's various attempts at emailing Coughlin during the first few weeks of November, including
    the period where Baker was on vacation and somethings appear to have slipped through the cracks at
    the Hill law firm respecting notifying Coughlin in an accepted means of service). Coughlin did not
    receive any emails from Hill's rhill@richardhillaw.com address between Hill's email of August 16th, 2011
    and November 18th, 2011, this Coughlin swears pursuant to NRS 53.045 under penalty of perjury:
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 3:15 PM
    To: rhill@richardhillaw.com
    000397
    Subject: RE: River rock
    Rich, you are aware that "files" can include things on hard drives, right?
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    > From: rhill@richardhillaw.com
    > To: zachcoughlin@hotmail.com
    > Subject: River rock
    > Date: Mon, 21 Nov 2011 14:53:03 -0800
    >
    > Mr coughlin -this confirms a voicemail left for you
    > I now have your drivers license & what I think are your client files.
    > Don't know, didn't look that closely - your privacy & all.
    >
    > Will release them to you at the hearing tomorrow.
    > Please confirm that the hearing is on calendar
    >
    > Rgh"
    Coughlin appeared at the RJC for the Hearing he was noticed on for November 22nd, 2011
    pursuant to the November 16th, 2011 filing by Coughlin of the Motion to Contest Personal Property lien
    in RJC REV2011-001708. Hill failed to appeared. Further, Hill continued to lie about his "offering to
    provide Coughlin" his client files, including those files on Coughlin's hard drives. Further, at least one of
    Coughlin's hard drives, upon their finally being returned to Coughlin on December 22nd, 2011 (with one
    of the expensive laptop screens completely cracked...) indicated a video card driver was loaded to the
    hard drive, including one on December 6th, 2011, during the period from Coughlin's arrest of November
    13th, 2011 to Hill's and Baker's finally returning Coughlin's client's files and hard drives to him on
    December 22nd, 2011 (unless you count the instance where Hill playfully set down a bag of trash and
    indicated to Coughlin "here is your client's files" at the time when Hill finally returned Coughlin's state
    issued driver's license one full week after Coughlin had demanded it, on November 22nd, 2011,
    something that Hill lied to the courts and the police about his willingness to do so up to that time
    absent a coercive demand that Coughlin sign away his rights, including those to his damage deposit.
    Further Hill violated Nevada law in placing demands upon Coughlin that Coughlin remove his property
    in the exact manner and order that HIll demanded (Hill required Coughlin to appear with certain
    vehicles and a "crew" of movers, and insisted Coughlin must remove all the property on the former
    home law office's exterior prior to Coughlin being allowed to "cherry pick" the items within that were of
    the most value, requirements for which there exists no support in Nevada law for Hill to make, including
    within NRS 118A.460, all to the detriment of Coughlin's client's concerns and the reputation of the Bar
    in Nevada and beyond. The RJC never needed Coughlin's permission previously to set Hearings,
    including the one on November 7th, 2011 that Coughlin was served an impromptu notice of while he
    was at the filing office on November 3rd, 2011, nor did the RJC need Coughlin's permission to to set
    the October 13th, 2011 summary eviction proceeding date, the October 25th, 2011 "Trial", or the
    December 20th, 2011 Hearing date.
    Further reckless and lacking in foundation mentions of "breaking into" the former law office and
    "broken locks" despite the fact that no factual support exists for such an allegation, there were no
    "broken locks" ever mentioned by anyone (and if Hill is willing to make up finding a "bag of weed and
    crack pipe" along with describing what Hill's own videos show to be vitamins as a "large quantity of
    000398
    pills", then you know Richard G. Hill, Esq. would have been all over any "broken locks" at the former
    home law office, yet, there simply were none, not that that would stop Pat King or J. Thomas Susich
    from cobbling together such an allegation in the SCR 117 Petition in 60975) along with something about
    Coughlin being subject to a custodial arrest for "jaywalking" by the Reno Police Department while
    Coughlin was filming Richard G. Hill, Esq.'s contractor's crew loading up a dump truck with items of
    personal property then located in Coughlin's former home law office (the arrest occurred shortly after
    Coughlin discovered that Hill's contractor, Phil Stewart, had used Coughlin's own distinctive plywood to
    "secure" or "board up the property" in December 2011, for which the landlord was ultimately awarded
    costs, $1,060 of which were based upon Stewart's invoice for "securing the property", which included
    the cost of plywood, and "fixing a leak in the basement" despite NRS 118A.460 only allowing costs for
    "moving, storing, and inventorying" a tenant's personal property), which Coughlin was unable to
    remove during the scant 13 hours he was afforded to do so by the Reno Justice Court's Order following
    a Hearing on Coughlin's November 16th, 2011 Motion to Contest Personal Property Lien (the Hearing
    was not set or conducted with the "10 days" required by NRS 40.253(7)-(8) because Richard G. Hill,
    Esq. needed to go on a six-week vacation shortly after Coughlin's November 16th, 2011 filing (in a
    matter now on appeal in SCR 60331 and 61838, wherein, somehow, a commercial tenant, Coughlin
    (whom was both running a law practice and Coughlin Memory Foam, a foam mattress business from his
    home, which was previously utilized for commercial purposes by a drug and alcohol rehabilitation
    counseling business and is zone for mixed use purposes) was summarily evicted based upon a No
    Cause Eviction Notice only (ie, the non-payment of rent was neither noticed, pled, nor argued by the
    landlord) despite the clear dictate against the use of summary eviction proceedings against commercial
    tenants not based upon the non-payment of rent (Bench Book stuff) set forth in NRS 40.253. The
    December 21st, 2011 Order "Resolving" Coughlin's Motion to Contest Personal Property Lien actually
    required Coughlin to pay the exact same amount of rent for 17 days (November 1 to November 17th,
    2011), $480 (ie, pro-rated from the $900 per month rental agreement) as Coughlin would have under a
    "fair rental value", for the "full use and occupancy of the premises" despite the fact that Hill somehow
    signed a Criminal Complaint for Trespass Against Coughlin, on November 13th, 2011 despite any
    Summary Eviction Order not being served in accordance with NRS 40.400 (and therefore NRCP 5 and
    6(e) vis a vis the "within 24 hours" of "receipt" of the lockout order, and, therefore, any such lockout
    that had occured being rendered a nullity or pursuant to a void Order) and where the Washoe County
    Sheriff's Office Civil Process Service Supervisor Liz Stuchell has admitted in writing that the Affidavit of
    Service filed November 7th, 2011 by Deputy Machen, attesting to having "personally served" the
    Summary Eviction Order on November 1st, 2011, was, in fact, purportedly merely posted to the door of
    Coughlin's former law office while Coughlin was not home, at which point a Soldal v. Cook County
    violating illegal lockout occurred. In a February 7th, 2012 written correspondence to Coughlin, Stuchell
    wrote: "Mr. Coughlin, Our records indicate that the eviction conducted on that day was personally
    served by Deputy Machen by posting a copy of the Order to the residence. The residence was
    unoccupied at the time. Liz Stuchell, Supervisor WCSO Civil Section". The text of NRS 40.253 speaks to
    service of Lockout Orders: The court may thereupon issue an order directing the sheriff or constable of
    the county to remove the tenant within 24 hours after receipt of the order... is inapplicable to this
    situation, where an Order Granting Summary Eviction was signed by October 27th, 2011 (though not
    mailed to Coughlin until after the November 1, 2011 lockout had allegedly already occured). That
    language is only found in situations inapplicable to the one incident that in the summary eviction from
    Coughlin's former home law office. NRS 40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of
    NRS 40 where this within 24 hours language occurs, and those situations only apply where, in:
    40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
    (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue a
    summary order for removal of the tenant or an order providing for the nonadmittance of the tenant,
    directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the
    order and, 40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords
    agent may apply by affidavit of complaint for eviction to the justice court of the township in which the
    dwelling, apartment, mobile home or commercial premises are located or to the district court of the
    county in which the dwelling, apartment, mobile home or commercial premises are located, whichever
    has jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
    constable remove the tenant within 24 hours after receipt of the order. The way these summary
    eviction proceedings are being carried out in Reno Justice Court presently shocks the conscience and
    violates Nevada law. There is not basis for effectuating a lockout the way WCSO's Deputy Machem did
    000399
    in this case. The requirements attendant to serving Summary Eviction Orders and conducting lockouts
    are found in NRS 40.253 in two sections containing the within 24 hours of receipt language are
    inapplicable, as those situations do not invoke the present circumstances, where the Tenant did file an
    Affidavit and did contest this matter to a degree not often seen. To require Nevada's tenants to get up
    and get out within 24 hours of receipt of the order (what does that even mean? The use of terms
    like rendition, rendered, notice of entry, pronounced, is absent here, and this receipt of the
    order language is something rarely found elsewhere in Nevada law-see attached DMV statutory
    citations, and in employment law litigations where one must file a Complaint within 90 days of receipt
    of a Right To Sue Letter, a situation which follows NRCP 5(b), and NRCP 6(e) in imputing receipt of
    such a letter, when actual receipt is not shown, by applying a constructive notice standard that relies
    upon the days for mailing extension of time for items served in the mailing, etc.). In Abraham v. Woods
    Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009), the record did not reflect when the plaintiff
    received his right-to-sue letter. The letter was issued on November 24, 2006. The court calculated that
    the 90-day period commenced on November 30, 2006, based on three days for mailing after excluding
    Saturdays and Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must
    exhaust administrative remedies and sue within 90 days of receipt of a right to sue letter. See 42 U.S.C.
    2000e-5(f)(1). See Baldwin County Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723,
    80 L.Ed.2d 196 (1984) (granting plaintiff an additional three days for mailing pursuant to Rule 6)....
    Further, as seen in the Anvui case, there is some argument respecting not effecting a lockout for at least 5 days
    where a lease has not expired by its terms, as Coughlin's arguably had not.
    However, in his January 20th, 2012 Second Motion for Order to Show Cause, Richard G. Hill, Esq. did
    not get all bogged down in legal research and stuff, instead he just pointed out: "FACTS SHOWING
    CONTEMPT OF COURT 6. EXHIBIT 1 (the Summary Eviction Lockout Order) was served on Coughlin on
    November 1, 2011 by the Washoe County Sheriffs Department in its customary manner, by posting
    same on the front door of the property in the manner customary for evictions in Washoe County. The
    locks to the premises were changed at that time, thereby ejecting and dispossessing Coughlin of
    possession of the Property." Hill went on to lie again in that January 20th, 2012 Motion when he
    equated his offer to let Coughlin get some of the personalty Coughlin was unable to remove, due
    largely to Hill failing to remove the chain link padlock from the backyard gate that Hill had only just
    installed in time for the 13 hours Coughlin had to remove his property in exchange for Coughlin waiving
    his rights to the $700 damage deposit Coughlin provided upon moving in, where Hill spins it: "12. On
    Friday, December 23, 2011, Coughlin had a crew of helpers, and made progress. Nonetheless, Coughlin
    failed to remove all of his belongings from the Property. Coughlin failed to remove his things despite
    having been given additional time to do so after the time set by the Reno Justice Court in its order of
    December 21, 2011 (EXHIBIT 2) had expired." Apparently, to Hill, at least one has " failed to remove all
    of his belongings from the Property. Coughlin failed to remove his things despite having been given
    additional time to do so" where Hill threatens to have one arrested for criminal trespass or larceny (of
    their own stuff, arguably) if one is on the property one minute past 5 p.m., unless one waives any right
    to their damage deposit (which neither Hill nor the Landlord eve did return, nor did they comply with
    the requirement that they provide an itemized statement indicating an application thereof justifying
    such a failure to return such deposit within 30 days....and Hill does not want to get into whether his
    conduct is violative of the FDCPA or whether he is licensed a as debt collector). In that Motion, Hill
    continued on: "13. On December 30, 2011, Coughlin moved this Court for a temporary restraining order
    to prevent Merliss from disposing of the items he (Coughlin) had abandoned on the Property. Coughlin's
    motion was fully briefed, and the Court entered its order denying the motion on January 11, 2012. A
    true and correct copy of this Court's January 11,2012 order is attached hereto as EXHIBIT 3. 14. On
    Thursday, January 12, 2012, in accordance with EXHIBIT 2 and EXHIBIT 3, a licensed contractor hired
    by Merliss began cleaning up the Property and disposing of the abandoned items still remaining there.
    15. Early that afternoon, while the contractor was hauling the first of several loads of abandoned
    property to the transfer station (dump) for disposal, Coughlin stopped the contractor in traffic and
    attempted to prevent him from carrying out his task. 16. Specifically, Coughlin stood in front of the
    contractor's vehicle in an effort to prevent him from proceeding to the transfer station. Coughlin
    threatened to sue the contractor. Coughlin climbed up on the contractor's vehicle. Coughlin then called
    the police and falsely told them that the contractor had stolen his possessions, and that the contractor
    had tried to run him over. Coughlin's acts were specifically calculated to prevent the contractor from
    disposing of the abandoned property, and to frustrate and interfere with Merliss' compliance with this
    Court's January 11, 2012 order. 17. When Mr. Hill of the undersigned's office was notified of the
    000400
    foregoing, he went to the transfer station and presented EXHIBIT 2 and EXHIBIT 3 to the police. The
    contractor was then allowed to proceed. 18. However, before the contractor could return to the River
    Rock Property, Coughlin was there. He had his video camera and was walking up and down the street
    screaming and yelling at the police, the contractor, and Mr. Hill, once Mr. Hill arrived. At the instruction
    of the police, Mr. Hill then obtained a temporary protective order ("TPO") against Coughlin from the
    Reno Justice Court. Coughlin ended up being arrested and taken to jail that day as a result of his antics at the transfer station
    and the Property."
    The thing is, and Coughlin would sure like to get the 911 tapes (or, more likely, with Hill, any
    recordings that may exist of Hill calling somebody in particular he may have had in mind with the RPD)
    of calls by Coughlin (and if Wal-Mart can call 911 over a candy bar, or a skater board over an iPhone
    he seems to have set down on the concrete ground in downtown Reno, then skaterboarded off some
    100 yards away for sufficiently long period of time to seem to have been pretty much the only person
    not to have heard somebody who picked it up threaten to throw it is in the river if it went unclaimed
    can call 911 (and make up a bunch of lies on the spot for the purpose of manipulating the police into
    assuages the skateboarders own negligence vis a vis the iPhone) is it unreasonable for Coughlin to call
    911 upon happening, totally by chance, to cross paths with Hill's contractor while driving, catching site
    of a huge dump truck full of Coughlin's personal property headed towards the town dump? Hill admits
    the Order denying Coughlin's Motion for a TPO (and hey, family heirlooms are pretty fungible, right?
    Who needs a TPO for that? And its not like the landlord could just accept rent in the meantime, or that
    the property still remains unrented to this day, some 11 months after the lockout, and apparently,
    some $60,000 worth of attorney's fees paid to Hill for a two bedroom home that appraises at around
    $90,000 currently, if that. And Hill's fantastic legal work ("wrong site surgery" and all) was surely worth
    the risk of a wrongful eviction lawsuit (and check out those potential damages under Winchell v. Schiff,
    124 Nev. 938, 193 P.3d 946 (2008), not that the loss of a patent attorney's career could amount to all
    that much). Regardless, its not all that colorable for Hill to allege Coughlin was violating some Order
    entered on January 11th, 2012 by Coughlin's conduct of January 12th, 2012 when NRCP 6(e) provides
    that 3 days for mailing is to be accorded to account for the service of filings, even filings electronically
    served on registered efilers like Coughlin. Its similar to Hill wanting a criminal trespass arrest where
    NRCP 6(e)'s three days for mailing where no personal service was accomplished (by way of NRS
    40.400) and Hill's et al did not even comply with the constructive service requirements of mailing the
    summary eviction lockout order prior to Hill's breaking into Coughlin's former home law office on
    November 1st, 2011, with the help of the WCSO, in violation of Soldal v. Cook County where Coughlin
    was not accorded the "24 hours" cushion after Coughlin's "receipt" of the lockout order mentioned in
    this Court's own packets on the service of Lockout Orders, which Hill himself attached as a subsequent
    exhibit recently...It gets funnier. The civil division of the Justice Court and the Sheriff's Office think that
    whole "within 24 hours" language in NRS 40.253 means "within 24 hours" of the Sheriff's "receipt" of
    the Order from the Justice Court...While other's think it is "within 24 hours" of the tenant's receipt of the
    Order from the Sheriff...and this Court's official forms and instructions seem to imply that "at least 24
    hours" from "receipt" of the lockout Order must be accorded to a tenant. Who knows? But, it is not
    clear, as Hill suggests, that the "usual custom and practice of the Washoe County Sheriff's Office" is
    black letter law upon which Bar grievances, custodial criminal trespass arrests, multiple Motion for Order
    To Show Cause, tens of thousands of dollars in attorney's fees sanctions against a pro se appellant, etc.
    are warranted. Somehow the District Court found a way to sanction Coughlin with $40,050 worth of
    attorney's fee in that appeal of the summary eviction without holding a single hearing, well, other than
    the Hearing on Hills Order to Show Cause, which was denied when Coughlin destroyed Hill's contractor
    Phil Stewart on cross-examination. (Really, Phil? Really? You could fell "a depression" in your 2 ton
    loaded to capacity dump truck upon Coughlin allegedly "climbing up on it", though you indicated you
    had already "alighted from the vehicle", but, wait, you could see Coughlin's head above the tailgate
    walls in your rear view mirror (which doesn't seem to be there on any the many videos of the events of
    that day. And even if such a mirror where present on Stewart's truck, that doesn't really explain how all the
    personalty stacked up so high in the truck bed (replete with specialized add-on high stack retaining walls) wouldn't obscure any
    purported view of Coughlin's head high above the area above the specialize hydraulic dump truck's tailgate, confirming
    Stewart's mere suspicion that Coughlin climbed on his truck. Coughlin swears under oath he did not climb on Stewart's truck.
    Hill needed a little "fact" to spice up his Motion to Show Cause just enough, and "Coughlin climbed up on the truck" was "just
    the ticket", and Stewart did not mind going along for the ride, so long as... And none of the many videos from that day actually
    show any of the Yosemite Sam cartoon villian type behavior Hill attributes to Coughlin in his wonderfully imaginative Motion for
    Order to Show Cause and or Application for Order of Protection concerning the events involved in the jaywalking custodial
    000401
    arrest Hill had Coughlin subjected to on January 12th, 2012.
    Much like Hill's contractor, Phil Stewart, flat out lying in an affidavit when he swore Coughlin "climbed
    up on" his truck, Hill similarly lied in an affidavit about Coughlin, apparently while "engraged" making
    "physical contact" with Hill. On Page 2 of Hill's Affidavit attach to his Motion for Order to Show Cause,
    January 20th, 2012, Hills attests: "5. On Friday, December 23, 2011, we unlocked the house at 9:00
    a.m. as ordered. We overlooked the chain on the back gate. There was nobody at the house when we
    were there. At approximately noon, my staff informed me that an enraged Mr. Coughlin had called the
    office screaming that he could not get in the back yard. When I finished the meeting I was in, I
    immediately went over and unlocked the back gate. Coughlin had a small crew. He charged at me and
    made physical contact. He was enraged. We left. When we returned at 5:00 p.m., Mr. Coughlin was
    screaming and yelling obscenities. He drove off in a small U -Haul. His crew remained. We walked the
    property with them. The inside .ground floor was mostly cleared of all but a big TV. The basement had
    been cleared somewhat, but there was still a lot of "junk. " We could not access the attic. We went outside. I told
    Coughlin's crew they could remove anything and everything outside, if they would only try to rehang the gate that Mr. Coughlin
    had taken off the hinges before we could get over to unlock it. I told them I would lock the gates in the morning.
    That is really interesting. Compare the above to the following excerpt from page 3 of Hills January 3rd,
    2012 Opposition in CV11-03628, the appeal of the summary eviction Order: "12. While at the property
    to remove the padlock, Coughlin, on more than one occasion, screamed profanities at Merliss' counsel,
    and, at one point, charged Mr. Hill and attempted to physically intimidate him. At least the audio of this
    incident was captured on tape. 13. Nevertheless, at 5:00 p.m. on Friday, December 23,2011, counsel
    granted Coughlin and his agents additional, unfettered, and unlimited access to the outside of the
    property to remove any remaining items." Whereas in his January 20th, 2012 sworn Declaration Hill
    goes so far as to indicate Coughlin "made physical contact" (which is a damn lie anyways), in Hill's then
    associate Casey Baker, Esq.'s NRCP 11 signed January 3rd, 2012 Opposition, HIll's associate Baker will
    only go so far as to say that Coughlin, "at one point, charged Mr. Hill and attempted to physically
    intimidate him." Baker was standing directly next to Hill during the interacation wherin Hill swore, under
    penalty of perjury, that Couglhin "made physical contact" with Hill). Sounds like Casey Baker, Esq. was
    not quite willing to "spice up" the story line as Hill himself was. Casey probably did not have enough
    reason to sign on to the lies about Coughlin "climbing on" the contractor's truck. In Hill's Application for
    a Protection Order against Coughlin Hill slips up and claims that Coughlin was "climbing on the
    contractor's truck, picking through the contents" back at Couglin's former home law after the interaction
    at the "transfer station" (town dump), whereas Hill's contractor indicated in his Affidavit that the alleged
    "climbing" on his truck occurred at the "transfer station". However, both Hill and his contractor, Phil
    Stewart indicate that the Reno Police Department "requested" that Hill filed a Protection Order
    Application against Coughlin. If that is true, its improper. The RPD can provide individuals information
    about seeking one, but when the RPD goes a step further and starts urging individuals to file protection
    order applications, or, as has recently been the case with RPD Officer Alan Weaver and Sargent Oliver
    Miller, whom, upon information and belief, urged Northwind's apartment maintenance man Milan Krebs
    to sign a fraudulent criminal complaint against Coughlin for "disturbing the peace" on July 3rd, 2011,
    and again urged Superior Mini Storage's Matt Grant to sign a similar baseless "disturbing the peace"
    criminal Complaint against Coughlin on approximately September 21st, 2012 then there is more than a
    little indication that the RPD is out of control and attempting to incite members of the public to sign
    fraudulent criminal complaints based upon a retaliatory animus by the RPD towards Coughlin. Officer
    Weaver and Sargent Dye showed up to an unnoticed July 5th, 2012 bail hearing for Coughlin, presided
    over by Judge Linda Gardner's brother RMC Judge William Gardner (whom received Coughlin's timely
    Notice of Appeal of the criminal trespass conviction, under NRS 189.010, yet failed to forward it on to
    the District Court, which somewhat recently dismissed Coughlin's appeal in that matter, wherein Sargent
    Dye and Officer Weaver testified under oath, with City Attorney Jill Drake singing backup, the the
    effectd that, despite bail only being valid based upon one reason in Nevada (to secure the defendant's
    attendance at trial) the "public health and safety" dictated increasing the cash required to bail out
    Couglin TENFOLD, from a bondable $1,415 to a CASH ONLY $3,000. Consequently, upon Judge Gardner
    so impermissibly raising Coughlin's bail, alleging a "public health and safety" rationale for so doing,
    Couglin was forced to spend 18 days in jail, wherein the opportunity to timely contest the $40,050
    attorney fees award to Richard Hill incident to the summary eviction appeal ran, all while Coughlin was
    denied any opportunity to access justice or file documents from jail, and where Coughlin sustained
    signficant damages, financial and otherwise, and where the jail refused to transport Coughlin to a
    hearing on a landlord tenant matter wherein he was a named party. The extent to which local law
    000402
    enforcement is willing to play "kick the can" with an attorney, particularly where Bar Counsel Pat King is
    so willing to join the chorus, is troubling, and indicates the judiciary need issue a clarion call out to
    announce the extent to which such misconduct can not, and will not, be tolerated. Such a retaliatory
    animus towards Coughlin by the RPD is likely due to his September 7th, 2011 Complaint with respect to
    a wrongful, retaliatory, and fraudulent arrest by RPD Officer Nicholas Duralde, which was accompanied
    by extortionate threats by RPD Officer Ron Rosa that if Coughlin didn't cooperate they would "call the
    Nevada Bar and let them know how you cooperated with our investigation. How's that runnin' for ya?"
    While Duralde testified that he did not hear or recall Rosa's coercive threats to Coughlin just prior to the
    arrest, the fact that Duralde echoed those threats by saying "Now, I can arrest you for larceny. Now, I
    can do a search incident to arrest. How's that?" tends to undermine Duralde's contention that "he
    doesn't recall" hearing anything like what Officer Rosa was capture on tape saying to Coughlin just prior
    to the arrest. Upon making a Fourth Amendment violating arrest completely lacking in probable cause,
    and smugly "joking" to Coughlin about the "benefits" associated with charging Coughlin with a "felony",
    (at the time of the August 20th, 2011 arrest, the felony larceny amount limit was $250 and above)
    compared to a misdemeanor (under some half baked "grand larceny" of an allegedly lost or mislaid or
    abandoned three year old iPhone 3G that the alleged victim testified was only then worth "about $80-
    100" on eBay or Craigslist), ie, search incident to custodial arrest possible where probable cause lacking
    to arrest, or even reasonable suspicion missing to do a pat down, where alleged crime occured outside
    officer's presence, after 7 p.m., and no citizens arrest immediately effectuated, particularly where
    Coughlin himself made a 911 call prior to Officer's arriving and where video from minutes prior to
    officer arriving reveal Coughlin suggesting the 8-12 hostile late teens to early twenties skater boarders relax, stay
    peaceful, refrain from assaulting and battering Couglin, and wait for the police arrive so a lawful, peaceful resolution could be
    attained (with Coughlin even cautioning the youths about a then recent tragic death occurring not far from that location).
    Further Hill just flat out lies in his January 3rd, 2012 Opposition to Amended Motion for Emergency
    Restraining Order. Well, he did tell the truth when he wrote, on page 3: "11. On Friday, December
    23,2011, counsel for Merliss neglected to remove the padlock to the back gate of the property." That is
    true, he did do that, and it did prevent Coughlin from removing all his property during the scant 13
    hours Coughlin had to move it. But, when Hill swears, on page 3, that: "Coughlin's access to the house
    itself was never hindered.:" he is just "sippin' drank" or something, as, obviously failing to remove a
    lock on a gate gonna tend to have that effect, now...and when Hill swears: " 13. Nevertheless, at 5:00
    p.m. on Friday, December 23,2011, counsel granted Coughlin and his agents additional, unfettered, and
    unlimited access to the outside of the property to remove any remaining items. The only condition
    placed on that access was that Coughlin's helpers agreed to replace the gate on its hinges as best they
    could. Coughlin and his agents failed to remove the remainder of Coughin's property from the yard that
    night, and failed to put the gate back on the hinges." Coughlin was never made aware of any such
    "offer" by Hill, and, even if he had been, hey, it's the "outside of the property", Rich, people generally
    put their valuables inside, you know?
    Then the HIll prevarication and obfuscation express kicks into overdrive, when, in his January 3rd,
    2012 Opposition he continues on: "C. Coughlin is Not Entitled to A Stay Coughlin claims to have
    deposited $250 with the justice's court pursuant to NRS 40.385, although he has not provided any
    proof in support of his claim. Attached hereto as EXHIBIT 10 is a true and correct copy of the justice's
    court's docket as of December 19, 2011. That docket shows that Coughlin paid a filing fee for his
    appeal on December 12, 2011, in the amount of $216.00." Well, actually, Judge Sferrazza waived the
    Justice Court's $24.00 filing fee, and the $216.00 represents the District Court's filing fee, and its not
    really clear whether that date is when the check was cashed by the District Court, or whether the
    Justice Court held on to the check for quit4e awhile before shipping it along with the ROA to the District
    Court, etc., etc. Hill continues: "It is entirely unclear from the following entries of that docket whether
    or when Coughlin ever paid an additional $250.00 under NRS 40.385." That might, technically be true,
    Rich, to the extent that you wrote it on January 3rd, 2012, and are sneakily indicating that you are
    looking at an old docket from the Justice Court from December 19th, 2012, even though Coughlin made
    a big deal to you and the Justice Court, in writing, that he was depositing the $250.00 supersedeas
    bond mentioned in NRS 40.385, on December 22nd, 2011, a fact which Hill himself mentions in his own
    filings...So, kind of a lack of candor to the tribunal there to make all this argument based upon some
    old docket and the extent to which it fails to reveal or "make clear" matters to which Hill had ready
    written notice of via his own e-Flex account and service of filings upon him connected thereto, in
    addition to Coughlin's faxes, emails, and there might have even been a service of a Notice of Posting
    Supersedeas Bond (need to check on that more), etc. in connection with the depositing on December
    000403
    22nd 2012, the $250 required for a stay during appeal of a summary eviction in NRS 40.385. And,
    actually, Hill slipped up a bit there, in light of the following: And, actually, Hill, in his January 20th, 2012
    filing, admitted that Coughlin sent him that December 22nd, 2011 email notifying him of the posting of
    the $250 supersedeas bond seeking a stay, when he admits, on page 3: "11. Pursuant to EXHIBIT 2,
    Coughlin was provided access to the Property on Thursday, December 22, 2011. That day, Coughlin
    sent an email to the undersigned and Judge Sferrazza, in which he essentially announced that he was
    entitled to a stay, and to return to and continue in possession of the Property. Judge Sferrazza
    quickly responded by email, and reminded Mr. Coughlin that the stay had been denied." Found in Exhibit 1 is the December
    22nd email to Hill's Office that alerts them to the posting of $250 , specified as a "supersedeas bond", with a citation to NRS
    40.385:
    Hill's January 3rd, 2012 Opposition continues, on page 8: "Even if Coughlin eventually paid some
    amount toward an appeal bond, it was not in time to stay the eviction during this appeal. To do that, a
    proper motion must be made and granted, and the bond posted, prior to the lockout. The lockout here
    occurred on November 1, 2011. By the time Coughlin managed to find that statute and pay any money
    to the court, he had been locked out of the property for six weeks. As such, any request for a stay was,
    and is, moot. At this point, Coughlin does not have any rights in either the real or personal". Oddly,
    Anvui saw a stay granted after a lockout was conducted, and Hill (RPC 3.1 "meritorious contention"
    issues) cites to no legal authority for his contention that "to stay the eviction during this appeal...a
    proper motion must be made and granted, and the bond posed, prior to the lockout." Citation? None.
    Despite Hill's strange approach of not actually indicating that his office did not get an
    December 22nd, 2011 email notifying them of the posting of $250 for a supersedeas bond seeking a
    stay under NRS 118A.385 (but rather, Hill focuses on what one cannot glean from looking at a dated
    docket...), Hill's Office was made aware of such matters, in writing, in the following December 22nd
    email to Hill's Offiee: "...Further, this is all moot at this point as I have filed a Supersedeas Bond of
    $250, and according to NRS 40.385, I automatically get a stay of eviction and am entitled to return to
    the property and continue in possession. The statute sets the Supersedeas Bond (which yields a stay) at
    $250 if rent is under $1000, unless the Court wishes to rule that I am a commercial tenant. However, if
    the court does rule that I am a commercial tenant, the No Cause Eviction Notice in this case, under
    NRS 40.253 makes a Summary Eviction Proceeding impermissible, as Summary Eviction Proceedings are
    not allowed against commercial tenants where only a No Cause Eviction Notice is filed. Its one or the
    other, but Mr. Hill and Baker cannot have it both ways. Further, the Courts Order of December 21, 2011
    is just that, and Order, its not an agreement, its not a settlement, etc, etc. and the audio record clearly
    reflects that. NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of
    premises to pay rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253: 1.
    Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with the
    trial court a bond in the amount of $250 to cover the expected costs on appeal. In an action concerning
    a lease of commercial property or any other property for which the monthly rent exceeds $1,000, the
    court may, upon its own motion or that of a party, and upon a showing of good cause, order an
    additional bond to be posted to cover the expected costs on appeal. A surety upon the bond submits to
    the jurisdiction of the appellate court and irrevocably appoints the clerk of that court as the surety's
    agent upon whom papers affecting the surety's liability upon the bond may be served. Liability of a
    surety may be enforced, or the bond may be released, on motion in the appellate court without
    independent action. 2. A tenant who retains possession of the premises that are the subject of the
    appeal during the pendency of the appeal shall pay to the landlord rent in the amount provided in the
    underlying contract between the tenant and the landlord as it becomes due. If the tenant fails to pay
    such rent, the landlord may initiate new proceedings for a summary eviction by serving the tenant with
    a new notice pursuant to NRS 40.253. Sincerely, Zach Coughlin, Esq.". Oh, and Hill and Stewart admit
    to this in a video. Richard Hill's contractor, for some strange reason, removed a ladder Coughlin owns
    from the property, preventing Coughlin's access to the attic upon his being allowed that scant 13 hours
    to remove his property (and the attic had been renovated to allow for storage of a considerable
    amount of property. If Coughlin was Hill he would have called the RPD to report the "larceny" of his
    ladder by Hill, in a RICO thing with his contractor. But Hill escaped prosecution that time, over they
    whole ladder deal. It never was made clear why the contractor removed the ladder from the property,
    other than, perhaps, like the applying of a lock to the backyard gate, make it even more unlikely that
    Coughlin would be able to remove all he needed to, especially given the limited funds for moving
    vehicles and hired help, in the scant 13 hours allowed under the December 21st, 2012 Order.
    000404
    Also, this is a complaint against Hill and his contractor for petty larceny of the ladder
    from Coughlin's former law office, admitted to on tape on December 22nd, 2011 by Hill
    (though the issue of whether they intended to "permanently deprive" Coughlin of the use
    and enjoyment thereof may be grounds for debate, Hill should get to spend the next 12
    months defending himself as Coughlin has from the onslaught of SBN, WCDA, and City of
    Reno prosecutor investigation...otherwise...gee, doesn't it kinda being to mind Coughlin's
    question to RPD Officer Chris Carter, Jr. while Coughlin was in cuffs during the custodial
    arrest of November 13th, 2011 when Coughlin asked Officer Carter: "are you on Richard
    Hill's payroll too?". Coughlin has faithfully reported on exactly what Officer Carter's response was,
    however ill-advised a sarcastic response he may claim it to have been. Hill has failed to faithfully report
    on just what he meant where he filed documents attesting to have found "a crack pipe and a bag of
    weed", a "vial of some sort", and "a large quantity of pills" and "drugs" in Coughlin's former home law
    office.
    Respecting Coughlin's written communications to HIll's office concerning Coughlin's express refusal to
    accept electronic notice or service of anything from HIll's Office, includes the following:
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 4:10 PM
    To: cdbaker@richardhillaw.com
    Subject: RE: Merliss v. Coughlin
    Casey, couldn't open them, and even if I could, I don't consent to service by email of pleadings, nor by fax. I have told you
    that many times. I will file a Motion for Sanctions if you do not cease attempting to circumvent the procedural protections
    accorded tenants. The only matter for which I consent to having you or your office contact me by email, is to tell me if and
    when I can get my exigent client/law practice materials/state issued identification, etc. I refuse to accept service of pleadings
    and motions you wish to sling through the courts at warp speed while withholding my mail and wallet. Come on! Your better
    than this!
    Zach Coughlin, Esq.
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
    Subject: LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331 61383
    Date: Mon, 15 Oct 2012 17:03:34 -0700
    Mr. King,
    This writing memorializes, in part, our conversation about your failure to investigate, in
    any real way, the criminal trespass allegations, in violation of the Claiborne decision.
    Upon my asking you pointed questions, you hurriedly filed a SCR 111 Petition in an
    attempt to excuse your failure to ask any of the pointed questions I have previously put
    000405
    forth to you regarding that criminal trespass matter, further you admitted to being
    unaware (allegedly) of the familial relation between Judge William Gardner and Judge
    Linda Gardner (despite that being quite clear in my recent filings to you).
    You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
    This correspondence reminds you of and further places you on notice of that the fact
    that you have been placed on a LITIGATION HOLD NOTICE. THE VIDEO FILMED
    BY RICHARD HILL OF THE RENO POLICE DEPARTMENT'S CHRIS CARTER
    AND SARGENT LOPEZ IN THE TIME PRIOR TO THE LANDLORD, MERLISS
    ALLEGEDLY KICKING DOWN THE DOOR, IS OF MATERIALLY RELEVANCE
    TO SEVERAL CIVIL LAWSUITS AND CRIMINAL PROCEEDINGS. RICHARD
    LIED IN COURT, UNDER OATH WHEN HE TESTIFIED THAT THE RPD
    ANNOUNCED THEMSELVES AS LAW ENFORCEMENT AND ORDERED
    COUGHLIN TO COME OUT OF THE BASEMENT PRIOR TO THE DOOR BEING
    KICKED IN. RICHARD SENDS THE STATE BAR OF NEVADA LETTERS ON
    FURTHER, OFFICER CARTER'S POLICE REPORT IS DEMONSTRATED TO BE
    FULL OF LIES BY THE VERY VIDEOS THAT HILL PROPOUNDED TO THE
    CITY OF RENO PROSECUTORS, PARTICULARLY WITH RESPECT TO
    WHETHER COUGHLIN REFUSED TO LEAVE AFTER BEING WARNED OR
    TOLD TO DO SO AND THE EXTENT TO WHICH CARTER WAS UNABLE TO
    ISSUE A CITATION OR RELY ON A SIMPLE WARNING IN LIGHT THEREOF.
    COUGHLIN ACTUALLY ASKS CARTER IN THE VIDEO HILL FILMED WHY
    HE DOESN'T JUST ISSUE SUCH A WARNING OR CITATION. Then, Carter goes
    on to attempt to offer his views on "service", however rudimentary they may be. being
    careful to note to Coughlin "you're not the victim here." To the extent that Hill and
    Merliss trespass into Coughlin's former law office on this date, with the help of the
    RPD, Soldal v Cook County has been violated, and Carter and Lopez have violated
    Wheeler v Coss.
    Any Eviction Order signed by Judge Sferrazza was stale in light of the failure to have
    the lockout order served upon Coughlin and a lockout performed "within 24 hours" of
    the Sheriff's receipt of the Order of both Oct 25th, 2011 (the simple one page Order
    signed by Judge Sferrazza and notated in his own handwriting) and or the October 27th,
    2011 Findings of Fact, Conclusions of Law, and Order for Summary Eviction) both of
    000406
    which were received by the WCSO well over 24 hours from when the lockout's were
    conducted, and therefore, both such Orders were stale, and therefore, Richard G. Hill,
    Esq. committed trespass upon Coughlin's former home law office, threw away a great
    deal of Coughlin's personalty (some of it very sentimental), and both Hill and Baker
    have lied repeatedly in court filings in indicating that Coughlin was served the
    Summary Eviction Order on November 1st, 2011 were they also admit that Coughlin
    was not at his former home law office at the time WCSO Deputy Machen posted it on
    the door thereof and effectuated a lockout (and Machen lied under oath in his
    November 7th, 2011 filed Affidavit of Service attesting to have "personally served"
    Coughlin the Summary Eviction Order on November 1st, 2011 (WCSO Civil Division
    Supervisor admitted as much to Coughlin in writing:
    NRS 40.253:
    5. Upon noncompliance with the notice:
    (a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the
    justice court of the township in which the dwelling, apartment, mobile home or commercial premises
    are located or to the district court of the county in which the dwelling, apartment, mobile home or
    commercial premises are located, whichever has jurisdiction over the matter. The court may
    thereupon issue an order directing the sheriff or constable of the county to remove the tenant
    within 24 hours after receipt of the order. The affidavit must state or contain:
    (1) The date the tenancy commenced.
    (2) The amount of periodic rent reserved.
    (3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the
    first months rent, by the tenant.
    (4) The date the rental payments became delinquent.
    (5) The length of time the tenant has remained in possession without paying rent.
    (6) The amount of rent claimed due and delinquent.
    (7) A statement that the written notice was served on the tenant in accordance with NRS
    40.280.
    (8) A copy of the written notice served on the tenant.
    (9) A copy of the signed written rental agreement, if any.
    (b) Except when the tenant has timely filed the affidavit described in subsection 3 and a file-
    stamped copy of it has been received by the landlord or the landlords agent, and except when the
    landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may, in a
    peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
    otherwise.
    Further where is my damage deposit (either $500, or, arguably $700 given the extent to
    which the Standard Rental Agreement afforded me the choice with respect to how
    cleaning was to be done and the extent to which Hill and Baker have failed to comply
    with
    000407
    Mr. Baker, you have committed professional misconduct (and Hill filed a grievance
    against me in a letter to the SBN dated January 14th, 2012 purporting to be sent on your
    behalf in "fulfilling your RPC 3.8 obligation"...simpy put, Mr. Baker, in your
    Opposition to MOtion to constest Personal Property Lien in Rev2011-001708, on page
    5, you lie where you write "when Coughlin refused to emerge from the basement after
    being ordered to do so by the police, Merliss was forced to kick down the door to gain
    access to his own property". You know that that is not true. The Reno Police
    Department did not identify themselves as law enforcement or otherwise issue an lawful
    Orders directing Coughlin to "emerge from the basement". You have demonstrated a
    lack of candor to the tribunal in that regard in conspiracy with Richard Hill. In a
    videotaped interview, RPD Sargent Lopez admits that neither she nor Officer Carter,
    nor anyone else that day, identified themselves in any way to Coughlin in the
    "basement" or otherwise issued him any sort of "warning to leave" or "order to emerge"
    of any sort, whatsoever. Mr. Baker, you were not even there. Yet, you viewed the video
    taken by Richard Hill of the moments in question where the RPD were at the basement
    door prior to Dr. Merliss kicking it down, including those moments where Dr. Merliss is
    seen in one video whispering to Richard Hill. If there really was all this identifying
    themselves as law enforcement and issuing Coughlin an order to emerge which went
    unheeded, then why the whispering? Why did Richard fail to include the he took of the
    moments where the RPD were at the "basement" door an failed to identify themselves
    or issue any lawful Orders? How would Coughlin know that any voices that may have
    been audible did not simply belong to more of the goons Hill and Baker routinely hire
    from Nevada Court Services to trespass behind Coughlin's former home law office's
    backyard gate, visiting in pairs, threes times a day, one ringing the door bell repeatedly
    for 30 minutes at a time, while the other (R. Wray, Joel Durden, and other licensed
    process servers) trespasses behind a a latched backyard gate and bangs on windows and
    peers through closed blinds while issuing threats intended to indicate they are being
    made by someone with color of law behind their words, while dressed up in an outfit
    specifically intended to confuse the public into thinking these process servers are
    Sheriff's Deputies?
    Regardless, the real fly in the ointment is the fact that RPD Sargent Lopez admitted that
    neither she, nor Carter, nor anyone else identified themselves as law enforcement and or
    issued Coughlin an order to emerge from the "basement". Indeed, in Hill's Declaration
    in REv2011-001708, filed a scant 7 days after the arrest, Hill certainly fails to mention
    000408
    any such alleged moment where the RPD identify themselves as law enforcement and
    issue Coughlin an order to emerge prior to Merliss kicking the door in. Hill writes
    letters to the SBN accusing Coughlin of having a "crack pipe and bag of weed" and
    "large quantity of pills" (the videos Hill took that day reveal those "pills" are vitamins,
    something Hill fails to clarify with the SBN, and Hill never has provided any sort of
    indication of what the "crack pipe and bag of weed" looked like exactly, nor has he
    responded to requests for photographs thereof, or made indication why he did not call
    the police, given the fact that he has involved law enforcement at every other possible
    turn.
    Hill and Baker have continued to fail to deliver Coughlin's security deposit, and in
    doing so, where they failed to provide the requisite correspondence within 30 days of
    any such eviction, have violated Nevada law:
    NRS 118A.242 Security: Limitation on amount or value; surety bond in lieu of security; duties and liability of landlord; damages;
    disputing itemized accounting of security; prohibited provisions.
    1. The landlord may not demand or receive security or a surety bond, or a combination thereof, including the last months rent, whose
    total amount or value exceeds 3 months periodic rent.
    2. In lieu of paying all or part of the security required by the landlord, a tenant may, if the landlord consents, purchase a surety bond to
    secure the tenants obligation to the landlord under the rental agreement to:
    (a) Remedy any default of the tenant in the payment of rent.
    (b) Repair damages to the premises other than normal wear and tear.
    (c) Clean the dwelling unit.
    3. The landlord:
    (a) Is not required to accept a surety bond purchased by the tenant in lieu of paying all or part of the security; and
    (b) May not require a tenant to purchase a security bond in lieu of paying all or part of the security.
    4. Upon termination of the tenancy by either party for any reason, the landlord may claim of the security or surety bond, or a combination
    thereof, only such amounts as are reasonably necessary to remedy any default of the tenant in the payment of rent, to repair damages to the
    premises caused by the tenant other than normal wear and to pay the reasonable costs of cleaning the premises. The landlord shall provide the
    tenant with an itemized written accounting of the disposition of the security or surety bond, or a combination thereof, and return any
    remaining portion of the security to the tenant no later than 30 days after the termination of the tenancy by handing it to the tenant personally
    at the place where the rent is paid, or by mailing it to the tenant at the tenants present address or, if that address is unknown, at the tenants
    last known address.
    5. If a tenant disputes an item contained in an itemized written accounting received from a landlord pursuant to subsection 4, the tenant
    may send a written response disputing the item to the surety. If the tenant sends the written response within 30 days after receiving the
    itemized written accounting, the surety shall not report the claim of the landlord to a credit reporting agency unless the surety obtains a
    judgment against the tenant.
    6. If the landlord fails or refuses to return the remainder of a security deposit within 30 days after the end of a tenancy, the landlord is
    liable to the tenant for damages:
    (a) In an amount equal to the entire deposit; and
    (b) For a sum to be fixed by the court of not more than the amount of the entire deposit.
    7. In determining the sum, if any, to be awarded under paragraph (b) of subsection 6, the court shall consider:
    (a) Whether the landlord acted in good faith;
    (b) The course of conduct between the landlord and the tenant; and
    000409
    (c) The degree of harm to the tenant caused by the landlords conduct.
    NRS 118A.360 Failure of landlord to comply with rental agreement or maintain dwelling unit in habitable condition where cost of
    compliance less than specified amount.
    1. If the landlord fails to comply with the rental agreement or his or her obligation to maintain the dwelling unit in a habitable condition as
    required by this chapter, and the reasonable cost of compliance or repair is less than $100 or an amount equal to one months periodic rent,
    whichever amount is greater, the tenant may recover damages for the breach or notify the landlord of the tenants intention to correct the
    condition at the landlords expense. If the landlord fails to use his or her best efforts to comply within 14 days after being notified by the
    tenant in writing or more promptly if conditions require in case of emergency, the tenant may cause the work to be done in a workmanlike
    manner and after submitting to the landlord an itemized statement, the tenant may deduct from his or her rent the actual and reasonable cost or
    the fair or reasonable value of the work, not exceeding the amount specified in this subsection.
    2. The landlord may specify in the rental agreement or otherwise that work done under this section and NRS 118A.380must be performed
    by a named person or firm or class of persons or firms qualified to do the work and the tenant must comply with the specifications. If the
    person qualified to do the work is unavailable or unable to perform the repairs the tenant shall use another qualified person who performs
    repairs.
    3. A tenant may not repair at the landlords expense if the condition was caused by the deliberate or negligent act or omission of the
    tenant, a member of the tenants household or other person on the premises with his or her consent.
    4. The landlords liability under this section is limited to $100 or an amount equal to one months periodic rent, whichever amount is
    greater, within any 12-month period.
    5. A tenant may not proceed under this section unless the tenant has given notice to the landlord that the dwelling is not in a habitable
    condition as required by this chapter.
    NRS 118A.355 Failure of landlord to maintain dwelling unit in habitable condition.
    1. Except as otherwise provided in this chapter, if a landlord fails to maintain a dwelling unit in a habitable condition as
    required by this chapter, the tenant shall deliver a written notice to the landlord specifying each failure by the landlord to
    maintain the dwelling unit in a habitable condition and requesting that the landlord remedy the failures. If a failure is
    remediable and the landlord adequately remedies the failure or uses his or her best efforts to remedy the failure within 14 days
    after receipt of the notice, the tenant may not proceed under this section. If the landlord fails to remedy a material failure to
    maintain the dwelling unit in a habitable condition or to make a reasonable effort to do so within the prescribed time, the
    tenant may:
    (a) Terminate the rental agreement immediately.
    (b) Recover actual damages.
    (c) Apply to the court for such relief as the court deems proper under the circumstances.
    (d) Withhold any rent that becomes due without incurring late fees, charges for notice or any other charge or fee authorized
    by this chapter or the rental agreement until the landlord has remedied, or has attempted in good faith to remedy, the failure.
    2. The tenant may not proceed under this section:
    (a) For a condition caused by the tenants own deliberate or negligent act or omission or that of a member of his or her
    household or other person on the premises with his or her consent; or
    (b) If the landlords inability to adequately remedy the failure or use his or her best efforts to remedy the failure within 14
    days is due to the tenants refusal to allow lawful access to the dwelling unit as required by the rental agreement or this
    chapter.
    3. If the rental agreement is terminated, the landlord shall return all prepaid rent and security recoverable by the tenant
    under this chapter.
    4. A tenant may not proceed under this section unless the tenant has given notice as required by subsection 1, except that
    the tenant may, without giving that notice:
    (a) Recover damages under paragraph (b) of subsection 1 if the landlord:
    (1) Admits to the court that the landlord had knowledge of the condition constituting the failure to maintain the
    dwelling in a habitable condition; or
    000410
    (2) Has received written notice of that condition from a governmental agency authorized to inspect for violations of
    building, housing or health codes.
    (b) Withhold rent under paragraph (d) of subsection 1 if the landlord:
    (1) Has received written notice of the condition constituting the failure to maintain the dwelling in a habitable condition
    from a governmental agency authorized to inspect for violations of building, housing or health codes; and
    (2) Fails to remedy or attempt in good faith to remedy the failure within the time prescribed in the written notice of that
    condition from the governmental agency.
    5. Justice courts shall establish by local rule a mechanism by which tenants may deposit rent withheld under
    paragraph (d) of subsection 1 into an escrow account maintained or approved by the court. A tenant does not
    have a defense to an eviction under paragraph (d) of subsection 1 unless the tenant has deposited the withheld
    rent into an escrow account pursuant to this subsection.
    Mr's. Baker and HIll, would you not say it more accurate to characterize the situation in rev2011-001708 as one fitting under the NRS
    118A.355 heading, particulary where the RJC, at the time of that summary eviction "Trial" had, according to Judge Sferrazza, no "local rule"
    or "mechanism by which tenants may deposit rent withheld under paragraph..." and therfore acknowledging the brilliance in Coughlin's
    JCRLV Rule 44 corollary in the RJC argument? Certainly, under the NRS 118A.355 analysis, after one strips away the agreed to $350 for
    weeds maintenance (which kind of amounts to a waiver of term in the Standard Rental Agreement that Judge Sferrazza interprets to require
    such "care" of the "lawn and surrounding grounds" (which, to the Court, apparently, included "weeds"), doesn't it?), and the agreed upon
    credit for fixing the stairs, well, then, and other amounts fit quite nicely into the "fix and deduct" approach set forth in NRS 118A.360. But,
    regardless, you proceeded under a No Cause Eviction basis, but against a commercial tenant, a fact you are stuck with, as the Tenant's
    Answer, numerous phone calls to Baker, and many, many instances throughout the filings in that matter make clear thta this was Coughlin's
    home law office, a commercial lease which the Standard Rental Agreement specifically allows for. And take a look at that 2008 Winchell v
    Schiff seafood business goes under because of wrongful eviction case wherein damages accounting for the loss of one's entire business (and
    what is a patent attorney's business worth, do you think, Dr. Merliss?) are allowable under Nevada law. Please remit $450,000 to me within 7
    days of this email being sent to you in satisfaction of this dispute against you, Dr. Merliss. Richard and Casey, I will deal with you later, but
    your liability is on par with Dr. Merliss's, no doubt, and that is before the FDCPA stuff and the fact that your office is not licensed as a bill
    collector.
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    FW: update proof of service
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/17/12 11:04 PM
    To: rosec@nvbar.org; glennm@nvbar.org
    Please forward to Investigator/Clerk Peters as her email is having some issues.
    000411
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: laurap@nvbar.org
    Subject: update proof of service
    Date: Wed, 17 Oct 2012 11:39:45 -0700
    The proof of service on the documents I dropped off yesterday need to be updated to
    indicate the date of service was 10/16/12 to the extent the fax is not effective service.
    Thanks,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    LITIGATION HOLD NOTICE rev2011-001708 cv11-03628,
    60331 61383, SBN v. Coughlin CASE NUMBER NG12-0204,
    NG-0435, NG 0434
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/17/12 5:00 PM
    To: laurap@nvbar.org; patrick@nvbar.org; rosec@nvbar.org; glennm@nvbar.org;
    davidc@nvbar.org; tsusich@nvdetr.org; complaint@nvbar.org; complaints@nvbar.org;
    shornsby@nvdetr.org
    8 attachments
    000412
    DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) , CR12-1262-
    3059269 transcript from criminal trespass trial testimony of richard hill and his associate
    before RMC Judge William Gardner.pdf (3.5 MB) , zach's arrest 010.flv (19.4 MB) , EXHIBIT
    TO AB226.pdf (50.7 KB) , MINUTES OF THE MEETING COMMITTEE ON JUDICIARY AB226 3
    31 11.pdf (13.7 KB) , AB226 PAGES 40-47 OF COMMITTE ON THE JUDICIARY HEARING 3
    31 11 MERLISS NCS RPD WEAVER.pdf (44.9 KB) , 11 21 11 ocr tagged Declaration of
    Richard Hill attach to his M for OSC (11-21-11) Compare to Police Reports and deposition of
    RPD's Carter and Lopez and Merliss.pdf (759.6 KB) , Baker's November 21st, 2011
    Opposition in rev2011-001708 rjc.pdf (223.0 KB)
    Dear Bar Counsel, Investigator Peters,
    note: please forward this written correspondence on to Bar Counsel King and
    Investigator, Clerk of Court Peters in light of their apparent indications that they now
    seek to sully the SBN's image by attempting to add Coughlin to their blocked sender list
    or otherwise prevent any further duty accruing on their part to actually investigate
    Coughlin's claims, in some manner that at least a colorable argument can be made that
    the SBN treats Coughlin's and others allegation with anywhere near the urgency it treats
    those of Judge Nash Holmes or Richard G. Hill, Esq. (in contrast to the whole "attack
    dog for the rich and powerful" image the SBN has built up....
    It is ironic, that Hill and Baker's own writing in their November 20th, 2011
    Opposition to Coughlin's November 16th, 2011 Motion to Contest Personal Property
    lien may now be used against them, in light of the staleness, voidness, and invalidity of
    the October 25th, 2011 and October 27th, 2011 Eviction Decision and Order and
    Findings of Fact, Conclusions of Law and Order for Summary Eviction in RJC
    Rev2011-001708. See Williams v Nagel, 643 N.E. 2d 816 and Wolf-Lillie, 504 F.
    Supp 1. Baker wrote on Hill's behalf:
    "Here, Coughlin filed his first motion pursuant to NRS 118A-460 on November
    16,2011. That motion was timely. However, when the court attempted to set the
    hearing, Coughlin refused to cooperate or communicate with the court to get the
    hearing on calendar, despite repeated requests from Merliss' counsel that he do so. As a
    sole and direct result of Mr. Coughlin's refusal to cooperate with the court to set his
    own hearing, that hearing never happened. The 10 days in which to hold the hearing
    under NRS 40.253(8) have now expired. Mr. Coughlin's motion is stale, and the relief
    he seeks is now time-barred. Because he abandoned that motion, it was, effectively,
    000413
    denied."
    Please indicate in writing what you have done to investigate Richard G. Hill's
    allegations, as set forth in his January 14th, 2012 grievance against me, in writing,
    including, but not limited to Hill's allegations vis a vis the criminal trespass arrest of me
    in on November 13th, 2011, leading to a custodial arrest, and three traffic citations by
    RPD Sargent Tarter following my release on November 15th, 2011 when I ventured to
    Hill's office to retrieve my state issued driver's license, wallet (credits card, money), and
    my client's files and my own files and hard drives and other materials. This is a formal,
    written grievance against Richard Hill and Casey Baker, in compliance with my RPC
    8.3 obligations respecting their failure to turn over my hard drives, driver's license,
    client's files and my own files, their impermissibly influencing the RJC to fail to give
    me a hearing on my November 16th, 2011 filing of a Motion to Contest Personal
    Property lien within the 10 days required by NRS 40.253(7)-(8) (hearing only took
    place after Richard's six week vacation, on December 20th, 2011, in accord with
    Richard's written indication to me that he would be able to get the RJC to wait that long
    on his account..., an impermissible suggestion by Richard that he could improperly
    influence a tribunal, as was Richard threats that he would have me given the Jordan v.
    State "vexatious litigant" treatment if I kept up my opposition to his nefarious aims.
    "Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Date: Tue, 7 Feb 2012 11:40:39 -0800
    From: LStuchell@washoecounty.us
    To: zachcoughlin@hotmail.com
    CC: mkandaras@da.washoecounty.us
    Mr. Coughlin
    Our records indicate that the eviction conducted on that day was personally served by Deputy Machen
    by posting a copy of the Order to the residence. The residence was unoccupied at the time.
    000414
    Liz Stuchell, Supervisor
    WCSO Civil Section"
    Additionally, this is a grievance against Hill and Baker concerning their lying under oath at the June
    18th, 2011 criminal trespass from my former law office trial in RMC 11 CR 26405. Please review the
    Claiborne decision for support for the contention that neither Bar Counsel King, SBN Investigator Peters,
    or the SBN will find availing any argument that no investigation was required on their part respecting
    those allegations (particularly during the 5 months period between Hill's January 14th, 2012 written, but
    unsigned, grievance to Pat King and the conviction on June 18th, 2012...certainly, the SBN has taken an
    interest in my pending criminal matters...). In Claiborne, the SBN was taken to task for making such a
    suggestion that no duty to investigate on their part was present, where the Court ruled it clearly was...
    Please review the sworn Declaration by Hill attached to his November 20th, 2011 Opposition to
    Coughlin's Motion to Contest Pesonal Property Lien and that Opposition itself, especially the bit in Hill's
    Declaration where he fails to allege the RPD identified themselves as law enforcement or issued an
    "lawful order" for Coughlin to "emerge from the" "basement" (which never had an outside lock to begin
    with) prior to landlord Merliss kicking the door down (and isn't is interesting that the RPD did not feel it
    had authority to kick a door down...suggesting they also felt they did not have authority to issue a
    "lawful order" or warning, pursuant to RMC 8.10.010 to Coughlin to leave the premises. I am
    complaining of an unlawful trespass and invasion by Hill, Baker, and Merliss, especially where in the
    other videos provided to Reno City Attorney Chris Hazlett-Stevens (and this is a formal grievance
    against Hazlett-Steven's as well, especially considering the extent to which he put on perjured
    testimony, failed to hold Hill to a subpoena, in violation of Coughlin's right to a speedy trial (during the
    same 6 week vacation by Hill that resulted in the RJC failing to give Coughlin a timely Hearing on his
    November 16th, 2011 filing of a Motion to Contest Personal Property Lien in the eviction matter from
    Coughlin's former home law office in the RJC, REV2011-001708...a Motion for Continuance was filed by
    city attorneys Hazlett, which Coughlin's then RMC appointed defense Counsel Lew Taitel failed to timely
    inform Coughlin of and agree to (despite Coughlin, at that time, having filed a lawsuit against Nevada
    Court Services, on October 19th, 2011 in CV-03051, CV11-03051 ZACH COUGHLIN VS. MATT MERLISS ET
    AL (D1). 19-OCT-2011.
    Further, any writings or filings by Bar Counsel King and or Chairman Susich that suggest or indicate
    Coughlin committed a "breaking and entering" of his former law office, or that the "locks were broken" is
    totally unsupported and reckless and contradicted explicitly by the videos Hill himself filmed and his
    statements therein. Please correct any such filings and alert the Court to your transgressions.
    Baker lied and violated NRCP 11 in his NOvember 21st, 2011 Opposition where he alleged the RPD
    identified themselves as law enforcement and issued a lawful order for Coughlin to emerge from the
    "basemet" or leave the proprty:
    "Even though he had a week to do so, Coughlin did not remove his personal
    belongings from the property prior to the lockout. In fact, he did not even remove himself
    from the property. Unbeknownst to Merliss or his counsel, Coughlin continued to Jive in
    the basement of the property until he was discovered squatting there on November 13. 2011
    - nearly two weeks after he was legally locked out. Coughlin had barricaded himself, his
    dog, and some of his presumably more cherished possessions in the basement. When
    Coughlin refused to emerge from the basement after being ordered to do so by the police,
    Merliss was forced to kick down the door to gain access to his own property. Coughlin was
    arrested and charged with trespassing. Due to Coughlin's criminal activities, the security
    ofthe house was compromised. As a result, Merliss was forced to incur costs in the amount
    of $1,060.00 to secure the property in order to protect it and Coughlin's belongings. A true
    and correct copy of the bill from the contractor is attached hereto as EXHIBIT 2."
    000415
    Bakers NRCP 11 violation in his filing of November 20th, 2011 in RJC Rev2011-001708 occurs at pages
    1-3, where he attempts to mislead the tribunal in suggesting that Coughin failed to cooperate in setting
    a Hearing on the Motion to Contest Personal Property Lien, even where Coughlin responded to Hill's
    then email informing him of such a hearing, by Coughlin emailing Hill "Rich, you are aware the files can
    be on hard drive's, right?" in response to HIll's email of a Hearing (Coughlin subsequently revoked (and
    had made express previously written indication that no such acceptance of such electronic service or
    notice would be availing respecting communications with Coughlin, and HIll was added to Coughlin's
    "blocked sender list" on Coughlin's Hotmail account, as such, Coughlin did not receive Hill's emails from
    October any implicit authority Hill may assert to provide Coughlin notice via electronic means, and
    therein is vitiated any of Hill's testimony at the trespass trial that the "warning" against trespass was
    relayed in Hill's various attempts at emailing Coughlin during the first few weeks of November, including
    the period where Baker was on vacation and somethings appear to have slipped through the cracks at
    the Hill law firm respecting notifying Coughlin in an accepted means of service). Coughlin did not
    receive any emails from Hill's rhill@richardhillaw.com address between Hill's email of August 16th, 2011
    and November 18th, 2011, this Coughlin swears pursuant to NRS 53.045 under penalty of perjury:
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 3:15 PM
    To: rhill@richardhillaw.com
    Subject: RE: River rock
    Rich, you are aware that "files" can include things on hard drives, right?
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    > From: rhill@richardhillaw.com
    > To: zachcoughlin@hotmail.com
    > Subject: River rock
    > Date: Mon, 21 Nov 2011 14:53:03 -0800
    >
    > Mr coughlin -this confirms a voicemail left for you
    > I now have your drivers license & what I think are your client files.
    > Don't know, didn't look that closely - your privacy & all.
    >
    > Will release them to you at the hearing tomorrow.
    > Please confirm that the hearing is on calendar
    >
    > Rgh"
    Coughlin appeared at the RJC for the Hearing he was noticed on for November 22nd, 2011
    pursuant to the November 16th, 2011 filing by Coughlin of the Motion to Contest Personal Property lien
    in RJC REV2011-001708. Hill failed to appeared. Further, Hill continued to lie about his "offering to
    provide Coughlin" his client files, including those files on Coughlin's hard drives. Further, at least one of
    Coughlin's hard drives, upon their finally being returned to Coughlin on December 22nd, 2011 (with one
    of the expensive laptop screens completely cracked...) indicated a video card driver was loaded to the
    hard drive, including one on December 6th, 2011, during the period from Coughlin's arrest of November
    13th, 2011 to Hill's and Baker's finally returning Coughlin's client's files and hard drives to him on
    000416
    December 22nd, 2011 (unless you count the instance where Hill playfully set down a bag of trash and
    indicated to Coughlin "here is your client's files" at the time when Hill finally returned Coughlin's state
    issued driver's license one full week after Coughlin had demanded it, on November 22nd, 2011,
    something that Hill lied to the courts and the police about his willingness to do so up to that time
    absent a coercive demand that Coughlin sign away his rights, including those to his damage deposit.
    Further Hill violated Nevada law in placing demands upon Coughlin that Coughlin remove his property
    in the exact manner and order that HIll demanded (Hill required Coughlin to appear with certain
    vehicles and a "crew" of movers, and insisted Coughlin must remove all the property on the former
    home law office's exterior prior to Coughlin being allowed to "cherry pick" the items within that were of
    the most value, requirements for which there exists no support in Nevada law for Hill to make, including
    within NRS 118A.460, all to the detriment of Coughlin's client's concerns and the reputation of the Bar
    in Nevada and beyond. The RJC never needed Coughlin's permission previously to set Hearings,
    including the one on November 7th, 2011 that Coughlin was served an impromptu notice of while he
    was at the filing office on November 3rd, 2011, nor did the RJC need Coughlin's permission to to set
    the October 13th, 2011 summary eviction proceeding date, the October 25th, 2011 "Trial", or the
    December 20th, 2011 Hearing date.
    Further reckless and lacking in foundation mentions of "breaking into" the former law office and
    "broken locks" despite the fact that no factual support exists for such an allegation, there were no
    "broken locks" ever mentioned by anyone (and if Hill is willing to make up finding a "bag of weed and
    crack pipe" along with describing what Hill's own videos show to be vitamins as a "large quantity of
    pills", then you know Richard G. Hill, Esq. would have been all over any "broken locks" at the former
    home law office, yet, there simply were none, not that that would stop Pat King or J. Thomas Susich
    from cobbling together such an allegation in the SCR 117 Petition in 60975) along with something about
    Coughlin being subject to a custodial arrest for "jaywalking" by the Reno Police Department while
    Coughlin was filming Richard G. Hill, Esq.'s contractor's crew loading up a dump truck with items of
    personal property then located in Coughlin's former home law office (the arrest occurred shortly after
    Coughlin discovered that Hill's contractor, Phil Stewart, had used Coughlin's own distinctive plywood to
    "secure" or "board up the property" in December 2011, for which the landlord was ultimately awarded
    costs, $1,060 of which were based upon Stewart's invoice for "securing the property", which included
    the cost of plywood, and "fixing a leak in the basement" despite NRS 118A.460 only allowing costs for
    "moving, storing, and inventorying" a tenant's personal property), which Coughlin was unable to
    remove during the scant 13 hours he was afforded to do so by the Reno Justice Court's Order following
    a Hearing on Coughlin's November 16th, 2011 Motion to Contest Personal Property Lien (the Hearing
    was not set or conducted with the "10 days" required by NRS 40.253(7)-(8) because Richard G. Hill,
    Esq. needed to go on a six-week vacation shortly after Coughlin's November 16th, 2011 filing (in a
    matter now on appeal in SCR 60331 and 61838, wherein, somehow, a commercial tenant, Coughlin
    (whom was both running a law practice and Coughlin Memory Foam, a foam mattress business from his
    home, which was previously utilized for commercial purposes by a drug and alcohol rehabilitation
    counseling business and is zone for mixed use purposes) was summarily evicted based upon a No
    Cause Eviction Notice only (ie, the non-payment of rent was neither noticed, pled, nor argued by the
    landlord) despite the clear dictate against the use of summary eviction proceedings against commercial
    tenants not based upon the non-payment of rent (Bench Book stuff) set forth in NRS 40.253. The
    December 21st, 2011 Order "Resolving" Coughlin's Motion to Contest Personal Property Lien actually
    required Coughlin to pay the exact same amount of rent for 17 days (November 1 to November 17th,
    2011), $480 (ie, pro-rated from the $900 per month rental agreement) as Coughlin would have under a
    "fair rental value", for the "full use and occupancy of the premises" despite the fact that Hill somehow
    signed a Criminal Complaint for Trespass Against Coughlin, on November 13th, 2011 despite any
    Summary Eviction Order not being served in accordance with NRS 40.400 (and therefore NRCP 5 and
    6(e) vis a vis the "within 24 hours" of "receipt" of the lockout order, and, therefore, any such lockout
    that had occured being rendered a nullity or pursuant to a void Order) and where the Washoe County
    Sheriff's Office Civil Process Service Supervisor Liz Stuchell has admitted in writing that the Affidavit of
    Service filed November 7th, 2011 by Deputy Machen, attesting to having "personally served" the
    Summary Eviction Order on November 1st, 2011, was, in fact, purportedly merely posted to the door of
    Coughlin's former law office while Coughlin was not home, at which point a Soldal v. Cook County
    violating illegal lockout occurred. In a February 7th, 2012 written correspondence to Coughlin, Stuchell
    wrote: "Mr. Coughlin, Our records indicate that the eviction conducted on that day was personally
    000417
    served by Deputy Machen by posting a copy of the Order to the residence. The residence was
    unoccupied at the time. Liz Stuchell, Supervisor WCSO Civil Section". The text of NRS 40.253 speaks to
    service of Lockout Orders: The court may thereupon issue an order directing the sheriff or constable of
    the county to remove the tenant within 24 hours after receipt of the order... is inapplicable to this
    situation, where an Order Granting Summary Eviction was signed by October 27th, 2011 (though not
    mailed to Coughlin until after the November 1, 2011 lockout had allegedly already occured). That
    language is only found in situations inapplicable to the one incident that in the summary eviction from
    Coughlin's former home law office. NRS 40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of
    NRS 40 where this within 24 hours language occurs, and those situations only apply where, in:
    40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
    (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue a
    summary order for removal of the tenant or an order providing for the nonadmittance of the tenant,
    directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the
    order and, 40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords
    agent may apply by affidavit of complaint for eviction to the justice court of the township in which the
    dwelling, apartment, mobile home or commercial premises are located or to the district court of the
    county in which the dwelling, apartment, mobile home or commercial premises are located, whichever
    has jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or
    constable remove the tenant within 24 hours after receipt of the order. The way these summary
    eviction proceedings are being carried out in Reno Justice Court presently shocks the conscience and
    violates Nevada law. There is not basis for effectuating a lockout the way WCSO's Deputy Machem did
    in this case. The requirements attendant to serving Summary Eviction Orders and conducting lockouts
    are found in NRS 40.253 in two sections containing the within 24 hours of receipt language are
    inapplicable, as those situations do not invoke the present circumstances, where the Tenant did file an
    Affidavit and did contest this matter to a degree not often seen. To require Nevada's tenants to get up
    and get out within 24 hours of receipt of the order (what does that even mean? The use of terms
    like rendition, rendered, notice of entry, pronounced, is absent here, and this receipt of the
    order language is something rarely found elsewhere in Nevada law-see attached DMV statutory
    citations, and in employment law litigations where one must file a Complaint within 90 days of receipt
    of a Right To Sue Letter, a situation which follows NRCP 5(b), and NRCP 6(e) in imputing receipt of
    such a letter, when actual receipt is not shown, by applying a constructive notice standard that relies
    upon the days for mailing extension of time for items served in the mailing, etc.). In Abraham v. Woods
    Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009), the record did not reflect when the plaintiff
    received his right-to-sue letter. The letter was issued on November 24, 2006. The court calculated that
    the 90-day period commenced on November 30, 2006, based on three days for mailing after excluding
    Saturdays and Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must
    exhaust administrative remedies and sue within 90 days of receipt of a right to sue letter. See 42 U.S.C.
    2000e-5(f)(1). See Baldwin County Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723,
    80 L.Ed.2d 196 (1984) (granting plaintiff an additional three days for mailing pursuant to Rule 6)....
    Further, as seen in the Anvui case, there is some argument respecting not effecting a lockout for at least 5 days
    where a lease has not expired by its terms, as Coughlin's arguably had not.
    However, in his January 20th, 2012 Second Motion for Order to Show Cause, Richard G. Hill, Esq. did
    not get all bogged down in legal research and stuff, instead he just pointed out: "FACTS SHOWING
    CONTEMPT OF COURT 6. EXHIBIT 1 (the Summary Eviction Lockout Order) was served on Coughlin on
    November 1, 2011 by the Washoe County Sheriffs Department in its customary manner, by posting
    same on the front door of the property in the manner customary for evictions in Washoe County. The
    locks to the premises were changed at that time, thereby ejecting and dispossessing Coughlin of
    possession of the Property." Hill went on to lie again in that January 20th, 2012 Motion when he
    equated his offer to let Coughlin get some of the personalty Coughlin was unable to remove, due
    largely to Hill failing to remove the chain link padlock from the backyard gate that Hill had only just
    installed in time for the 13 hours Coughlin had to remove his property in exchange for Coughlin waiving
    his rights to the $700 damage deposit Coughlin provided upon moving in, where Hill spins it: "12. On
    Friday, December 23, 2011, Coughlin had a crew of helpers, and made progress. Nonetheless, Coughlin
    failed to remove all of his belongings from the Property. Coughlin failed to remove his things despite
    having been given additional time to do so after the time set by the Reno Justice Court in its order of
    December 21, 2011 (EXHIBIT 2) had expired." Apparently, to Hill, at least one has " failed to remove all
    of his belongings from the Property. Coughlin failed to remove his things despite having been given
    000418
    additional time to do so" where Hill threatens to have one arrested for criminal trespass or larceny (of
    their own stuff, arguably) if one is on the property one minute past 5 p.m., unless one waives any right
    to their damage deposit (which neither Hill nor the Landlord eve did return, nor did they comply with
    the requirement that they provide an itemized statement indicating an application thereof justifying
    such a failure to return such deposit within 30 days....and Hill does not want to get into whether his
    conduct is violative of the FDCPA or whether he is licensed a as debt collector). In that Motion, Hill
    continued on: "13. On December 30, 2011, Coughlin moved this Court for a temporary restraining order
    to prevent Merliss from disposing of the items he (Coughlin) had abandoned on the Property. Coughlin's
    motion was fully briefed, and the Court entered its order denying the motion on January 11, 2012. A
    true and correct copy of this Court's January 11,2012 order is attached hereto as EXHIBIT 3. 14. On
    Thursday, January 12, 2012, in accordance with EXHIBIT 2 and EXHIBIT 3, a licensed contractor hired
    by Merliss began cleaning up the Property and disposing of the abandoned items still remaining there.
    15. Early that afternoon, while the contractor was hauling the first of several loads of abandoned
    property to the transfer station (dump) for disposal, Coughlin stopped the contractor in traffic and
    attempted to prevent him from carrying out his task. 16. Specifically, Coughlin stood in front of the
    contractor's vehicle in an effort to prevent him from proceeding to the transfer station. Coughlin
    threatened to sue the contractor. Coughlin climbed up on the contractor's vehicle. Coughlin then called
    the police and falsely told them that the contractor had stolen his possessions, and that the contractor
    had tried to run him over. Coughlin's acts were specifically calculated to prevent the contractor from
    disposing of the abandoned property, and to frustrate and interfere with Merliss' compliance with this
    Court's January 11, 2012 order. 17. When Mr. Hill of the undersigned's office was notified of the
    foregoing, he went to the transfer station and presented EXHIBIT 2 and EXHIBIT 3 to the police. The
    contractor was then allowed to proceed. 18. However, before the contractor could return to the River
    Rock Property, Coughlin was there. He had his video camera and was walking up and down the street
    screaming and yelling at the police, the contractor, and Mr. Hill, once Mr. Hill arrived. At the instruction
    of the police, Mr. Hill then obtained a temporary protective order ("TPO") against Coughlin from the
    Reno Justice Court. Coughlin ended up being arrested and taken to jail that day as a result of his antics at the transfer station
    and the Property."
    The thing is, and Coughlin would sure like to get the 911 tapes (or, more likely, with Hill, any
    recordings that may exist of Hill calling somebody in particular he may have had in mind with the RPD)
    of calls by Coughlin (and if Wal-Mart can call 911 over a candy bar, or a skater board over an iPhone
    he seems to have set down on the concrete ground in downtown Reno, then skaterboarded off some
    100 yards away for sufficiently long period of time to seem to have been pretty much the only person
    not to have heard somebody who picked it up threaten to throw it is in the river if it went unclaimed
    can call 911 (and make up a bunch of lies on the spot for the purpose of manipulating the police into
    assuages the skateboarders own negligence vis a vis the iPhone) is it unreasonable for Coughlin to call
    911 upon happening, totally by chance, to cross paths with Hill's contractor while driving, catching site
    of a huge dump truck full of Coughlin's personal property headed towards the town dump? Hill admits
    the Order denying Coughlin's Motion for a TPO (and hey, family heirlooms are pretty fungible, right?
    Who needs a TPO for that? And its not like the landlord could just accept rent in the meantime, or that
    the property still remains unrented to this day, some 11 months after the lockout, and apparently,
    some $60,000 worth of attorney's fees paid to Hill for a two bedroom home that appraises at around
    $90,000 currently, if that. And Hill's fantastic legal work ("wrong site surgery" and all) was surely worth
    the risk of a wrongful eviction lawsuit (and check out those potential damages under Winchell v. Schiff,
    124 Nev. 938, 193 P.3d 946 (2008), not that the loss of a patent attorney's career could amount to all
    that much). Regardless, its not all that colorable for Hill to allege Coughlin was violating some Order
    entered on January 11th, 2012 by Coughlin's conduct of January 12th, 2012 when NRCP 6(e) provides
    that 3 days for mailing is to be accorded to account for the service of filings, even filings electronically
    served on registered efilers like Coughlin. Its similar to Hill wanting a criminal trespass arrest where
    NRCP 6(e)'s three days for mailing where no personal service was accomplished (by way of NRS
    40.400) and Hill's et al did not even comply with the constructive service requirements of mailing the
    summary eviction lockout order prior to Hill's breaking into Coughlin's former home law office on
    November 1st, 2011, with the help of the WCSO, in violation of Soldal v. Cook County where Coughlin
    was not accorded the "24 hours" cushion after Coughlin's "receipt" of the lockout order mentioned in
    this Court's own packets on the service of Lockout Orders, which Hill himself attached as a subsequent
    exhibit recently...It gets funnier. The civil division of the Justice Court and the Sheriff's Office think that
    whole "within 24 hours" language in NRS 40.253 means "within 24 hours" of the Sheriff's "receipt" of
    000419
    the Order from the Justice Court...While other's think it is "within 24 hours" of the tenant's receipt of the
    Order from the Sheriff...and this Court's official forms and instructions seem to imply that "at least 24
    hours" from "receipt" of the lockout Order must be accorded to a tenant. Who knows? But, it is not
    clear, as Hill suggests, that the "usual custom and practice of the Washoe County Sheriff's Office" is
    black letter law upon which Bar grievances, custodial criminal trespass arrests, multiple Motion for Order
    To Show Cause, tens of thousands of dollars in attorney's fees sanctions against a pro se appellant, etc.
    are warranted. Somehow the District Court found a way to sanction Coughlin with $40,050 worth of
    attorney's fee in that appeal of the summary eviction without holding a single hearing, well, other than
    the Hearing on Hills Order to Show Cause, which was denied when Coughlin destroyed Hill's contractor
    Phil Stewart on cross-examination. (Really, Phil? Really? You could fell "a depression" in your 2 ton
    loaded to capacity dump truck upon Coughlin allegedly "climbing up on it", though you indicated you
    had already "alighted from the vehicle", but, wait, you could see Coughlin's head above the tailgate
    walls in your rear view mirror (which doesn't seem to be there on any the many videos of the events of
    that day. And even if such a mirror where present on Stewart's truck, that doesn't really explain how all the
    personalty stacked up so high in the truck bed (replete with specialized add-on high stack retaining walls) wouldn't obscure any
    purported view of Coughlin's head high above the area above the specialize hydraulic dump truck's tailgate, confirming
    Stewart's mere suspicion that Coughlin climbed on his truck. Coughlin swears under oath he did not climb on Stewart's truck.
    Hill needed a little "fact" to spice up his Motion to Show Cause just enough, and "Coughlin climbed up on the truck" was "just
    the ticket", and Stewart did not mind going along for the ride, so long as... And none of the many videos from that day actually
    show any of the Yosemite Sam cartoon villian type behavior Hill attributes to Coughlin in his wonderfully imaginative Motion for
    Order to Show Cause and or Application for Order of Protection concerning the events involved in the jaywalking custodial
    arrest Hill had Coughlin subjected to on January 12th, 2012.
    Much like Hill's contractor, Phil Stewart, flat out lying in an affidavit when he swore Coughlin "climbed
    up on" his truck, Hill similarly lied in an affidavit about Coughlin, apparently while "engraged" making
    "physical contact" with Hill. On Page 2 of Hill's Affidavit attach to his Motion for Order to Show Cause,
    January 20th, 2012, Hills attests: "5. On Friday, December 23, 2011, we unlocked the house at 9:00
    a.m. as ordered. We overlooked the chain on the back gate. There was nobody at the house when we
    were there. At approximately noon, my staff informed me that an enraged Mr. Coughlin had called the
    office screaming that he could not get in the back yard. When I finished the meeting I was in, I
    immediately went over and unlocked the back gate. Coughlin had a small crew. He charged at me and
    made physical contact. He was enraged. We left. When we returned at 5:00 p.m., Mr. Coughlin was
    screaming and yelling obscenities. He drove off in a small U -Haul. His crew remained. We walked the
    property with them. The inside .ground floor was mostly cleared of all but a big TV. The basement had
    been cleared somewhat, but there was still a lot of "junk. " We could not access the attic. We went outside. I told
    Coughlin's crew they could remove anything and everything outside, if they would only try to rehang the gate that Mr. Coughlin
    had taken off the hinges before we could get over to unlock it. I told them I would lock the gates in the morning.
    That is really interesting. Compare the above to the following excerpt from page 3 of Hills January 3rd,
    2012 Opposition in CV11-03628, the appeal of the summary eviction Order: "12. While at the property
    to remove the padlock, Coughlin, on more than one occasion, screamed profanities at Merliss' counsel,
    and, at one point, charged Mr. Hill and attempted to physically intimidate him. At least the audio of this
    incident was captured on tape. 13. Nevertheless, at 5:00 p.m. on Friday, December 23,2011, counsel
    granted Coughlin and his agents additional, unfettered, and unlimited access to the outside of the
    property to remove any remaining items." Whereas in his January 20th, 2012 sworn Declaration Hill
    goes so far as to indicate Coughlin "made physical contact" (which is a damn lie anyways), in Hill's then
    associate Casey Baker, Esq.'s NRCP 11 signed January 3rd, 2012 Opposition, HIll's associate Baker will
    only go so far as to say that Coughlin, "at one point, charged Mr. Hill and attempted to physically
    intimidate him." Baker was standing directly next to Hill during the interacation wherin Hill swore, under
    penalty of perjury, that Couglhin "made physical contact" with Hill). Sounds like Casey Baker, Esq. was
    not quite willing to "spice up" the story line as Hill himself was. Casey probably did not have enough
    reason to sign on to the lies about Coughlin "climbing on" the contractor's truck. In Hill's Application for
    a Protection Order against Coughlin Hill slips up and claims that Coughlin was "climbing on the
    contractor's truck, picking through the contents" back at Couglin's former home law after the interaction
    at the "transfer station" (town dump), whereas Hill's contractor indicated in his Affidavit that the alleged
    "climbing" on his truck occurred at the "transfer station". However, both Hill and his contractor, Phil
    Stewart indicate that the Reno Police Department "requested" that Hill filed a Protection Order
    Application against Coughlin. If that is true, its improper. The RPD can provide individuals information
    about seeking one, but when the RPD goes a step further and starts urging individuals to file protection
    000420
    order applications, or, as has recently been the case with RPD Officer Alan Weaver and Sargent Oliver
    Miller, whom, upon information and belief, urged Northwind's apartment maintenance man Milan Krebs
    to sign a fraudulent criminal complaint against Coughlin for "disturbing the peace" on July 3rd, 2011,
    and again urged Superior Mini Storage's Matt Grant to sign a similar baseless "disturbing the peace"
    criminal Complaint against Coughlin on approximately September 21st, 2012 then there is more than a
    little indication that the RPD is out of control and attempting to incite members of the public to sign
    fraudulent criminal complaints based upon a retaliatory animus by the RPD towards Coughlin. Officer
    Weaver and Sargent Dye showed up to an unnoticed July 5th, 2012 bail hearing for Coughlin, presided
    over by Judge Linda Gardner's brother RMC Judge William Gardner (whom received Coughlin's timely
    Notice of Appeal of the criminal trespass conviction, under NRS 189.010, yet failed to forward it on to
    the District Court, which somewhat recently dismissed Coughlin's appeal in that matter, wherein Sargent
    Dye and Officer Weaver testified under oath, with City Attorney Jill Drake singing backup, the the
    effectd that, despite bail only being valid based upon one reason in Nevada (to secure the defendant's
    attendance at trial) the "public health and safety" dictated increasing the cash required to bail out
    Couglin TENFOLD, from a bondable $1,415 to a CASH ONLY $3,000. Consequently, upon Judge Gardner
    so impermissibly raising Coughlin's bail, alleging a "public health and safety" rationale for so doing,
    Couglin was forced to spend 18 days in jail, wherein the opportunity to timely contest the $40,050
    attorney fees award to Richard Hill incident to the summary eviction appeal ran, all while Coughlin was
    denied any opportunity to access justice or file documents from jail, and where Coughlin sustained
    signficant damages, financial and otherwise, and where the jail refused to transport Coughlin to a
    hearing on a landlord tenant matter wherein he was a named party. The extent to which local law
    enforcement is willing to play "kick the can" with an attorney, particularly where Bar Counsel Pat King is
    so willing to join the chorus, is troubling, and indicates the judiciary need issue a clarion call out to
    announce the extent to which such misconduct can not, and will not, be tolerated. Such a retaliatory
    animus towards Coughlin by the RPD is likely due to his September 7th, 2011 Complaint with respect to
    a wrongful, retaliatory, and fraudulent arrest by RPD Officer Nicholas Duralde, which was accompanied
    by extortionate threats by RPD Officer Ron Rosa that if Coughlin didn't cooperate they would "call the
    Nevada Bar and let them know how you cooperated with our investigation. How's that runnin' for ya?"
    While Duralde testified that he did not hear or recall Rosa's coercive threats to Coughlin just prior to the
    arrest, the fact that Duralde echoed those threats by saying "Now, I can arrest you for larceny. Now, I
    can do a search incident to arrest. How's that?" tends to undermine Duralde's contention that "he
    doesn't recall" hearing anything like what Officer Rosa was capture on tape saying to Coughlin just prior
    to the arrest. Upon making a Fourth Amendment violating arrest completely lacking in probable cause,
    and smugly "joking" to Coughlin about the "benefits" associated with charging Coughlin with a "felony",
    (at the time of the August 20th, 2011 arrest, the felony larceny amount limit was $250 and above)
    compared to a misdemeanor (under some half baked "grand larceny" of an allegedly lost or mislaid or
    abandoned three year old iPhone 3G that the alleged victim testified was only then worth "about $80-
    100" on eBay or Craigslist), ie, search incident to custodial arrest possible where probable cause lacking
    to arrest, or even reasonable suspicion missing to do a pat down, where alleged crime occured outside
    officer's presence, after 7 p.m., and no citizens arrest immediately effectuated, particularly where
    Coughlin himself made a 911 call prior to Officer's arriving and where video from minutes prior to
    officer arriving reveal Coughlin suggesting the 8-12 hostile late teens to early twenties skater boarders relax, stay
    peaceful, refrain from assaulting and battering Couglin, and wait for the police arrive so a lawful, peaceful resolution could be
    attained (with Coughlin even cautioning the youths about a then recent tragic death occurring not far from that location).
    Further Hill just flat out lies in his January 3rd, 2012 Opposition to Amended Motion for Emergency
    Restraining Order. Well, he did tell the truth when he wrote, on page 3: "11. On Friday, December
    23,2011, counsel for Merliss neglected to remove the padlock to the back gate of the property." That is
    true, he did do that, and it did prevent Coughlin from removing all his property during the scant 13
    hours Coughlin had to move it. But, when Hill swears, on page 3, that: "Coughlin's access to the house
    itself was never hindered.:" he is just "sippin' drank" or something, as, obviously failing to remove a
    lock on a gate gonna tend to have that effect, now...and when Hill swears: " 13. Nevertheless, at 5:00
    p.m. on Friday, December 23,2011, counsel granted Coughlin and his agents additional, unfettered, and
    unlimited access to the outside of the property to remove any remaining items. The only condition
    placed on that access was that Coughlin's helpers agreed to replace the gate on its hinges as best they
    could. Coughlin and his agents failed to remove the remainder of Coughin's property from the yard that
    night, and failed to put the gate back on the hinges." Coughlin was never made aware of any such
    "offer" by Hill, and, even if he had been, hey, it's the "outside of the property", Rich, people generally
    000421
    put their valuables inside, you know?
    Then the HIll prevarication and obfuscation express kicks into overdrive, when, in his January 3rd,
    2012 Opposition he continues on: "C. Coughlin is Not Entitled to A Stay Coughlin claims to have
    deposited $250 with the justice's court pursuant to NRS 40.385, although he has not provided any
    proof in support of his claim. Attached hereto as EXHIBIT 10 is a true and correct copy of the justice's
    court's docket as of December 19, 2011. That docket shows that Coughlin paid a filing fee for his
    appeal on December 12, 2011, in the amount of $216.00." Well, actually, Judge Sferrazza waived the
    Justice Court's $24.00 filing fee, and the $216.00 represents the District Court's filing fee, and its not
    really clear whether that date is when the check was cashed by the District Court, or whether the
    Justice Court held on to the check for quit4e awhile before shipping it along with the ROA to the District
    Court, etc., etc. Hill continues: "It is entirely unclear from the following entries of that docket whether
    or when Coughlin ever paid an additional $250.00 under NRS 40.385." That might, technically be true,
    Rich, to the extent that you wrote it on January 3rd, 2012, and are sneakily indicating that you are
    looking at an old docket from the Justice Court from December 19th, 2012, even though Coughlin made
    a big deal to you and the Justice Court, in writing, that he was depositing the $250.00 supersedeas
    bond mentioned in NRS 40.385, on December 22nd, 2011, a fact which Hill himself mentions in his own
    filings...So, kind of a lack of candor to the tribunal there to make all this argument based upon some
    old docket and the extent to which it fails to reveal or "make clear" matters to which Hill had ready
    written notice of via his own e-Flex account and service of filings upon him connected thereto, in
    addition to Coughlin's faxes, emails, and there might have even been a service of a Notice of Posting
    Supersedeas Bond (need to check on that more), etc. in connection with the depositing on December
    22nd 2012, the $250 required for a stay during appeal of a summary eviction in NRS 40.385. And,
    actually, Hill slipped up a bit there, in light of the following: And, actually, Hill, in his January 20th, 2012
    filing, admitted that Coughlin sent him that December 22nd, 2011 email notifying him of the posting of
    the $250 supersedeas bond seeking a stay, when he admits, on page 3: "11. Pursuant to EXHIBIT 2,
    Coughlin was provided access to the Property on Thursday, December 22, 2011. That day, Coughlin
    sent an email to the undersigned and Judge Sferrazza, in which he essentially announced that he was
    entitled to a stay, and to return to and continue in possession of the Property. Judge Sferrazza
    quickly responded by email, and reminded Mr. Coughlin that the stay had been denied." Found in Exhibit 1 is the December
    22nd email to Hill's Office that alerts them to the posting of $250 , specified as a "supersedeas bond", with a citation to NRS
    40.385:
    Hill's January 3rd, 2012 Opposition continues, on page 8: "Even if Coughlin eventually paid some
    amount toward an appeal bond, it was not in time to stay the eviction during this appeal. To do that, a
    proper motion must be made and granted, and the bond posted, prior to the lockout. The lockout here
    occurred on November 1, 2011. By the time Coughlin managed to find that statute and pay any money
    to the court, he had been locked out of the property for six weeks. As such, any request for a stay was,
    and is, moot. At this point, Coughlin does not have any rights in either the real or personal". Oddly,
    Anvui saw a stay granted after a lockout was conducted, and Hill (RPC 3.1 "meritorious contention"
    issues) cites to no legal authority for his contention that "to stay the eviction during this appeal...a
    proper motion must be made and granted, and the bond posed, prior to the lockout." Citation? None.
    Despite Hill's strange approach of not actually indicating that his office did not get an
    December 22nd, 2011 email notifying them of the posting of $250 for a supersedeas bond seeking a
    stay under NRS 118A.385 (but rather, Hill focuses on what one cannot glean from looking at a dated
    docket...), Hill's Office was made aware of such matters, in writing, in the following December 22nd
    email to Hill's Offiee: "...Further, this is all moot at this point as I have filed a Supersedeas Bond of
    $250, and according to NRS 40.385, I automatically get a stay of eviction and am entitled to return to
    the property and continue in possession. The statute sets the Supersedeas Bond (which yields a stay) at
    $250 if rent is under $1000, unless the Court wishes to rule that I am a commercial tenant. However, if
    the court does rule that I am a commercial tenant, the No Cause Eviction Notice in this case, under
    NRS 40.253 makes a Summary Eviction Proceeding impermissible, as Summary Eviction Proceedings are
    not allowed against commercial tenants where only a No Cause Eviction Notice is filed. Its one or the
    other, but Mr. Hill and Baker cannot have it both ways. Further, the Courts Order of December 21, 2011
    is just that, and Order, its not an agreement, its not a settlement, etc, etc. and the audio record clearly
    reflects that. NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of
    premises to pay rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253: 1.
    Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with the
    trial court a bond in the amount of $250 to cover the expected costs on appeal. In an action concerning
    000422
    a lease of commercial property or any other property for which the monthly rent exceeds $1,000, the
    court may, upon its own motion or that of a party, and upon a showing of good cause, order an
    additional bond to be posted to cover the expected costs on appeal. A surety upon the bond submits to
    the jurisdiction of the appellate court and irrevocably appoints the clerk of that court as the surety's
    agent upon whom papers affecting the surety's liability upon the bond may be served. Liability of a
    surety may be enforced, or the bond may be released, on motion in the appellate court without
    independent action. 2. A tenant who retains possession of the premises that are the subject of the
    appeal during the pendency of the appeal shall pay to the landlord rent in the amount provided in the
    underlying contract between the tenant and the landlord as it becomes due. If the tenant fails to pay
    such rent, the landlord may initiate new proceedings for a summary eviction by serving the tenant with
    a new notice pursuant to NRS 40.253. Sincerely, Zach Coughlin, Esq.". Oh, and Hill and Stewart admit
    to this in a video. Richard Hill's contractor, for some strange reason, removed a ladder Coughlin owns
    from the property, preventing Coughlin's access to the attic upon his being allowed that scant 13 hours
    to remove his property (and the attic had been renovated to allow for storage of a considerable
    amount of property. If Coughlin was Hill he would have called the RPD to report the "larceny" of his
    ladder by Hill, in a RICO thing with his contractor. But Hill escaped prosecution that time, over they
    whole ladder deal. It never was made clear why the contractor removed the ladder from the property,
    other than, perhaps, like the applying of a lock to the backyard gate, make it even more unlikely that
    Coughlin would be able to remove all he needed to, especially given the limited funds for moving
    vehicles and hired help, in the scant 13 hours allowed under the December 21st, 2012 Order.
    Also, this is a complaint against Hill and his contractor for petty larceny of the ladder
    from Coughlin's former law office, admitted to on tape on December 22nd, 2011 by Hill
    (though the issue of whether they intended to "permanently deprive" Coughlin of the use
    and enjoyment thereof may be grounds for debate, Hill should get to spend the next 12
    months defending himself as Coughlin has from the onslaught of SBN, WCDA, and City of
    Reno prosecutor investigation...otherwise...gee, doesn't it kinda being to mind Coughlin's
    question to RPD Officer Chris Carter, Jr. while Coughlin was in cuffs during the custodial
    arrest of November 13th, 2011 when Coughlin asked Officer Carter: "are you on Richard
    Hill's payroll too?". Coughlin has faithfully reported on exactly what Officer Carter's response was,
    however ill-advised a sarcastic response he may claim it to have been. Hill has failed to faithfully report
    on just what he meant where he filed documents attesting to have found "a crack pipe and a bag of
    weed", a "vial of some sort", and "a large quantity of pills" and "drugs" in Coughlin's former home law
    office.
    Respecting Coughlin's written communications to HIll's office concerning Coughlin's express refusal to
    accept electronic notice or service of anything from HIll's Office, includes the following:
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 4:10 PM
    To: cdbaker@richardhillaw.com
    Subject: RE: Merliss v. Coughlin
    Casey, couldn't open them, and even if I could, I don't consent to service by email of pleadings, nor by fax. I have told you
    that many times. I will file a Motion for Sanctions if you do not cease attempting to circumvent the procedural protections
    accorded tenants. The only matter for which I consent to having you or your office contact me by email, is to tell me if and
    when I can get my exigent client/law practice materials/state issued identification, etc. I refuse to accept service of pleadings
    and motions you wish to sling through the courts at warp speed while withholding my mail and wallet. Come on! Your better
    000423
    than this!
    Zach Coughlin, Esq.
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
    Subject: LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331 61383
    Date: Mon, 15 Oct 2012 17:03:34 -0700
    Mr. King,
    This writing memorializes, in part, our conversation about your failure to investigate, in
    any real way, the criminal trespass allegations, in violation of the Claiborne decision.
    Upon my asking you pointed questions, you hurriedly filed a SCR 111 Petition in an
    attempt to excuse your failure to ask any of the pointed questions I have previously put
    forth to you regarding that criminal trespass matter, further you admitted to being
    unaware (allegedly) of the familial relation between Judge William Gardner and Judge
    Linda Gardner (despite that being quite clear in my recent filings to you).
    You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
    This correspondence reminds you of and further places you on notice of that the fact
    that you have been placed on a LITIGATION HOLD NOTICE. THE VIDEO FILMED
    BY RICHARD HILL OF THE RENO POLICE DEPARTMENT'S CHRIS CARTER
    AND SARGENT LOPEZ IN THE TIME PRIOR TO THE LANDLORD, MERLISS
    ALLEGEDLY KICKING DOWN THE DOOR, IS OF MATERIALLY RELEVANCE
    TO SEVERAL CIVIL LAWSUITS AND CRIMINAL PROCEEDINGS. RICHARD
    LIED IN COURT, UNDER OATH WHEN HE TESTIFIED THAT THE RPD
    ANNOUNCED THEMSELVES AS LAW ENFORCEMENT AND ORDERED
    COUGHLIN TO COME OUT OF THE BASEMENT PRIOR TO THE DOOR BEING
    KICKED IN. RICHARD SENDS THE STATE BAR OF NEVADA LETTERS ON
    FURTHER, OFFICER CARTER'S POLICE REPORT IS DEMONSTRATED TO BE
    FULL OF LIES BY THE VERY VIDEOS THAT HILL PROPOUNDED TO THE
    CITY OF RENO PROSECUTORS, PARTICULARLY WITH RESPECT TO
    WHETHER COUGHLIN REFUSED TO LEAVE AFTER BEING WARNED OR
    TOLD TO DO SO AND THE EXTENT TO WHICH CARTER WAS UNABLE TO
    ISSUE A CITATION OR RELY ON A SIMPLE WARNING IN LIGHT THEREOF.
    000424
    COUGHLIN ACTUALLY ASKS CARTER IN THE VIDEO HILL FILMED WHY
    HE DOESN'T JUST ISSUE SUCH A WARNING OR CITATION. Then, Carter goes
    on to attempt to offer his views on "service", however rudimentary they may be. being
    careful to note to Coughlin "you're not the victim here." To the extent that Hill and
    Merliss trespass into Coughlin's former law office on this date, with the help of the
    RPD, Soldal v Cook County has been violated, and Carter and Lopez have violated
    Wheeler v Coss.
    Any Eviction Order signed by Judge Sferrazza was stale in light of the failure to have
    the lockout order served upon Coughlin and a lockout performed "within 24 hours" of
    the Sheriff's receipt of the Order of both Oct 25th, 2011 (the simple one page Order
    signed by Judge Sferrazza and notated in his own handwriting) and or the October 27th,
    2011 Findings of Fact, Conclusions of Law, and Order for Summary Eviction) both of
    which were received by the WCSO well over 24 hours from when the lockout's were
    conducted, and therefore, both such Orders were stale, and therefore, Richard G. Hill,
    Esq. committed trespass upon Coughlin's former home law office, threw away a great
    deal of Coughlin's personalty (some of it very sentimental), and both Hill and Baker
    have lied repeatedly in court filings in indicating that Coughlin was served the
    Summary Eviction Order on November 1st, 2011 were they also admit that Coughlin
    was not at his former home law office at the time WCSO Deputy Machen posted it on
    the door thereof and effectuated a lockout (and Machen lied under oath in his
    November 7th, 2011 filed Affidavit of Service attesting to have "personally served"
    Coughlin the Summary Eviction Order on November 1st, 2011 (WCSO Civil Division
    Supervisor admitted as much to Coughlin in writing:
    NRS 40.253:
    5. Upon noncompliance with the notice:
    (a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the
    justice court of the township in which the dwelling, apartment, mobile home or commercial premises
    are located or to the district court of the county in which the dwelling, apartment, mobile home or
    commercial premises are located, whichever has jurisdiction over the matter. The court may
    thereupon issue an order directing the sheriff or constable of the county to remove the tenant
    within 24 hours after receipt of the order. The affidavit must state or contain:
    (1) The date the tenancy commenced.
    (2) The amount of periodic rent reserved.
    (3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the
    first months rent, by the tenant.
    (4) The date the rental payments became delinquent.
    (5) The length of time the tenant has remained in possession without paying rent.
    (6) The amount of rent claimed due and delinquent.
    000425
    (7) A statement that the written notice was served on the tenant in accordance with NRS
    40.280.
    (8) A copy of the written notice served on the tenant.
    (9) A copy of the signed written rental agreement, if any.
    (b) Except when the tenant has timely filed the affidavit described in subsection 3 and a file-
    stamped copy of it has been received by the landlord or the landlords agent, and except when the
    landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may, in a
    peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
    otherwise.
    Further where is my damage deposit (either $500, or, arguably $700 given the extent to
    which the Standard Rental Agreement afforded me the choice with respect to how
    cleaning was to be done and the extent to which Hill and Baker have failed to comply
    with
    Mr. Baker, you have committed professional misconduct (and Hill filed a grievance
    against me in a letter to the SBN dated January 14th, 2012 purporting to be sent on your
    behalf in "fulfilling your RPC 3.8 obligation"...simpy put, Mr. Baker, in your
    Opposition to MOtion to constest Personal Property Lien in Rev2011-001708, on page
    5, you lie where you write "when Coughlin refused to emerge from the basement after
    being ordered to do so by the police, Merliss was forced to kick down the door to gain
    access to his own property". You know that that is not true. The Reno Police
    Department did not identify themselves as law enforcement or otherwise issue an lawful
    Orders directing Coughlin to "emerge from the basement". You have demonstrated a
    lack of candor to the tribunal in that regard in conspiracy with Richard Hill. In a
    videotaped interview, RPD Sargent Lopez admits that neither she nor Officer Carter,
    nor anyone else that day, identified themselves in any way to Coughlin in the
    "basement" or otherwise issued him any sort of "warning to leave" or "order to emerge"
    of any sort, whatsoever. Mr. Baker, you were not even there. Yet, you viewed the video
    taken by Richard Hill of the moments in question where the RPD were at the basement
    door prior to Dr. Merliss kicking it down, including those moments where Dr. Merliss is
    seen in one video whispering to Richard Hill. If there really was all this identifying
    themselves as law enforcement and issuing Coughlin an order to emerge which went
    unheeded, then why the whispering? Why did Richard fail to include the he took of the
    moments where the RPD were at the "basement" door an failed to identify themselves
    or issue any lawful Orders? How would Coughlin know that any voices that may have
    been audible did not simply belong to more of the goons Hill and Baker routinely hire
    000426
    from Nevada Court Services to trespass behind Coughlin's former home law office's
    backyard gate, visiting in pairs, threes times a day, one ringing the door bell repeatedly
    for 30 minutes at a time, while the other (R. Wray, Joel Durden, and other licensed
    process servers) trespasses behind a a latched backyard gate and bangs on windows and
    peers through closed blinds while issuing threats intended to indicate they are being
    made by someone with color of law behind their words, while dressed up in an outfit
    specifically intended to confuse the public into thinking these process servers are
    Sheriff's Deputies?
    Regardless, the real fly in the ointment is the fact that RPD Sargent Lopez admitted that
    neither she, nor Carter, nor anyone else identified themselves as law enforcement and or
    issued Coughlin an order to emerge from the "basement". Indeed, in Hill's Declaration
    in REv2011-001708, filed a scant 7 days after the arrest, Hill certainly fails to mention
    any such alleged moment where the RPD identify themselves as law enforcement and
    issue Coughlin an order to emerge prior to Merliss kicking the door in. Hill writes
    letters to the SBN accusing Coughlin of having a "crack pipe and bag of weed" and
    "large quantity of pills" (the videos Hill took that day reveal those "pills" are vitamins,
    something Hill fails to clarify with the SBN, and Hill never has provided any sort of
    indication of what the "crack pipe and bag of weed" looked like exactly, nor has he
    responded to requests for photographs thereof, or made indication why he did not call
    the police, given the fact that he has involved law enforcement at every other possible
    turn.
    Hill and Baker have continued to fail to deliver Coughlin's security deposit, and in
    doing so, where they failed to provide the requisite correspondence within 30 days of
    any such eviction, have violated Nevada law:
    NRS 118A.242 Security: Limitation on amount or value; surety bond in lieu of security; duties and liability of landlord; damages;
    disputing itemized accounting of security; prohibited provisions.
    1. The landlord may not demand or receive security or a surety bond, or a combination thereof, including the last months rent, whose
    total amount or value exceeds 3 months periodic rent.
    2. In lieu of paying all or part of the security required by the landlord, a tenant may, if the landlord consents, purchase a surety bond to
    secure the tenants obligation to the landlord under the rental agreement to:
    (a) Remedy any default of the tenant in the payment of rent.
    (b) Repair damages to the premises other than normal wear and tear.
    (c) Clean the dwelling unit.
    3. The landlord:
    (a) Is not required to accept a surety bond purchased by the tenant in lieu of paying all or part of the security; and
    (b) May not require a tenant to purchase a security bond in lieu of paying all or part of the security.
    000427
    4. Upon termination of the tenancy by either party for any reason, the landlord may claim of the security or surety bond, or a combination
    thereof, only such amounts as are reasonably necessary to remedy any default of the tenant in the payment of rent, to repair damages to the
    premises caused by the tenant other than normal wear and to pay the reasonable costs of cleaning the premises. The landlord shall provide the
    tenant with an itemized written accounting of the disposition of the security or surety bond, or a combination thereof, and return any
    remaining portion of the security to the tenant no later than 30 days after the termination of the tenancy by handing it to the tenant personally
    at the place where the rent is paid, or by mailing it to the tenant at the tenants present address or, if that address is unknown, at the tenants
    last known address.
    5. If a tenant disputes an item contained in an itemized written accounting received from a landlord pursuant to subsection 4, the tenant
    may send a written response disputing the item to the surety. If the tenant sends the written response within 30 days after receiving the
    itemized written accounting, the surety shall not report the claim of the landlord to a credit reporting agency unless the surety obtains a
    judgment against the tenant.
    6. If the landlord fails or refuses to return the remainder of a security deposit within 30 days after the end of a tenancy, the landlord is
    liable to the tenant for damages:
    (a) In an amount equal to the entire deposit; and
    (b) For a sum to be fixed by the court of not more than the amount of the entire deposit.
    7. In determining the sum, if any, to be awarded under paragraph (b) of subsection 6, the court shall consider:
    (a) Whether the landlord acted in good faith;
    (b) The course of conduct between the landlord and the tenant; and
    (c) The degree of harm to the tenant caused by the landlords conduct.
    NRS 118A.360 Failure of landlord to comply with rental agreement or maintain dwelling unit in habitable condition where cost of
    compliance less than specified amount.
    1. If the landlord fails to comply with the rental agreement or his or her obligation to maintain the dwelling unit in a habitable condition as
    required by this chapter, and the reasonable cost of compliance or repair is less than $100 or an amount equal to one months periodic rent,
    whichever amount is greater, the tenant may recover damages for the breach or notify the landlord of the tenants intention to correct the
    condition at the landlords expense. If the landlord fails to use his or her best efforts to comply within 14 days after being notified by the
    tenant in writing or more promptly if conditions require in case of emergency, the tenant may cause the work to be done in a workmanlike
    manner and after submitting to the landlord an itemized statement, the tenant may deduct from his or her rent the actual and reasonable cost or
    the fair or reasonable value of the work, not exceeding the amount specified in this subsection.
    2. The landlord may specify in the rental agreement or otherwise that work done under this section and NRS 118A.380must be performed
    by a named person or firm or class of persons or firms qualified to do the work and the tenant must comply with the specifications. If the
    person qualified to do the work is unavailable or unable to perform the repairs the tenant shall use another qualified person who performs
    repairs.
    3. A tenant may not repair at the landlords expense if the condition was caused by the deliberate or negligent act or omission of the
    tenant, a member of the tenants household or other person on the premises with his or her consent.
    4. The landlords liability under this section is limited to $100 or an amount equal to one months periodic rent, whichever amount is
    greater, within any 12-month period.
    5. A tenant may not proceed under this section unless the tenant has given notice to the landlord that the dwelling is not in a habitable
    condition as required by this chapter.
    NRS 118A.355 Failure of landlord to maintain dwelling unit in habitable condition.
    1. Except as otherwise provided in this chapter, if a landlord fails to maintain a dwelling unit in a habitable condition as
    required by this chapter, the tenant shall deliver a written notice to the landlord specifying each failure by the landlord to
    maintain the dwelling unit in a habitable condition and requesting that the landlord remedy the failures. If a failure is
    remediable and the landlord adequately remedies the failure or uses his or her best efforts to remedy the failure within 14 days
    after receipt of the notice, the tenant may not proceed under this section. If the landlord fails to remedy a material failure to
    maintain the dwelling unit in a habitable condition or to make a reasonable effort to do so within the prescribed time, the
    tenant may:
    (a) Terminate the rental agreement immediately.
    000428
    (b) Recover actual damages.
    (c) Apply to the court for such relief as the court deems proper under the circumstances.
    (d) Withhold any rent that becomes due without incurring late fees, charges for notice or any other charge or fee authorized
    by this chapter or the rental agreement until the landlord has remedied, or has attempted in good faith to remedy, the failure.
    2. The tenant may not proceed under this section:
    (a) For a condition caused by the tenants own deliberate or negligent act or omission or that of a member of his or her
    household or other person on the premises with his or her consent; or
    (b) If the landlords inability to adequately remedy the failure or use his or her best efforts to remedy the failure within 14
    days is due to the tenants refusal to allow lawful access to the dwelling unit as required by the rental agreement or this
    chapter.
    3. If the rental agreement is terminated, the landlord shall return all prepaid rent and security recoverable by the tenant
    under this chapter.
    4. A tenant may not proceed under this section unless the tenant has given notice as required by subsection 1, except that
    the tenant may, without giving that notice:
    (a) Recover damages under paragraph (b) of subsection 1 if the landlord:
    (1) Admits to the court that the landlord had knowledge of the condition constituting the failure to maintain the
    dwelling in a habitable condition; or
    (2) Has received written notice of that condition from a governmental agency authorized to inspect for violations of
    building, housing or health codes.
    (b) Withhold rent under paragraph (d) of subsection 1 if the landlord:
    (1) Has received written notice of the condition constituting the failure to maintain the dwelling in a habitable condition
    from a governmental agency authorized to inspect for violations of building, housing or health codes; and
    (2) Fails to remedy or attempt in good faith to remedy the failure within the time prescribed in the written notice of that
    condition from the governmental agency.
    5. Justice courts shall establish by local rule a mechanism by which tenants may deposit rent withheld under
    paragraph (d) of subsection 1 into an escrow account maintained or approved by the court. A tenant does not
    have a defense to an eviction under paragraph (d) of subsection 1 unless the tenant has deposited the withheld
    rent into an escrow account pursuant to this subsection.
    Mr's. Baker and HIll, would you not say it more accurate to characterize the situation in rev2011-001708 as one fitting under the NRS
    118A.355 heading, particulary where the RJC, at the time of that summary eviction "Trial" had, according to Judge Sferrazza, no "local rule"
    or "mechanism by which tenants may deposit rent withheld under paragraph..." and therfore acknowledging the brilliance in Coughlin's
    JCRLV Rule 44 corollary in the RJC argument? Certainly, under the NRS 118A.355 analysis, after one strips away the agreed to $350 for
    weeds maintenance (which kind of amounts to a waiver of term in the Standard Rental Agreement that Judge Sferrazza interprets to require
    such "care" of the "lawn and surrounding grounds" (which, to the Court, apparently, included "weeds"), doesn't it?), and the agreed upon
    credit for fixing the stairs, well, then, and other amounts fit quite nicely into the "fix and deduct" approach set forth in NRS 118A.360. But,
    regardless, you proceeded under a No Cause Eviction basis, but against a commercial tenant, a fact you are stuck with, as the Tenant's
    Answer, numerous phone calls to Baker, and many, many instances throughout the filings in that matter make clear thta this was Coughlin's
    home law office, a commercial lease which the Standard Rental Agreement specifically allows for. And take a look at that 2008 Winchell v
    Schiff seafood business goes under because of wrongful eviction case wherein damages accounting for the loss of one's entire business (and
    what is a patent attorney's business worth, do you think, Dr. Merliss?) are allowable under Nevada law. Please remit $450,000 to me within 7
    days of this email being sent to you in satisfaction of this dispute against you, Dr. Merliss. Richard and Casey, I will deal with you later, but
    your liability is on par with Dr. Merliss's, no doubt, and that is before the FDCPA stuff and the fact that your office is not licensed as a bill
    collector.
    Further,
    000429
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000430
    Print Close
    update proof of service
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/17/12 11:39 AM
    To: laurap@nvbar.org
    The proof of service on the documents I dropped off yesterday need to be updated to
    indicate the date of service was 10/16/12 to the extent the fax is not effective service.
    Thanks,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331
    61383
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 10/15/12 5:03 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
    4 attachments
    sbn v coughlin CASE NUMBER NG12-0204, NG-0435, NG 0434 combined filing 10 15 12.pdf
    (378.5 KB) , DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) ,
    rev2011-001708 opposition to coughlin's second motion to contest personal property lien merliss hill
    sbn.pdf (3.2 MB) , CR12-1262-3059269 transcript from criminal trespass trial testimony of richard
    hill and his associate before RMC Judge William Gardner.pdf (3.5 MB)
    Mr. King,
    This writing memorializes, in part, our conversation about your failure to investigate, in
    any real way, the criminal trespass allegations, in violation of the Claiborne decision.
    000431
    Upon my asking you pointed questions, you hurriedly filed a SCR 111 Petition in an
    attempt to excuse your failure to ask any of the pointed questions I have previously put
    forth to you regarding that criminal trespass matter, further you admitted to being
    unaware (allegedly) of the familial relation between Judge William Gardner and Judge
    Linda Gardner (despite that being quite clear in my recent filings to you).
    You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
    This correspondence reminds you of and further places you on notice of that the fact
    that you have been placed on a LITIGATION HOLD NOTICE. THE VIDEO
    FILMED BY RICHARD HILL OF THE RENO POLICE DEPARTMENT'S CHRIS
    CARTER AND SARGENT LOPEZ IN THE TIME PRIOR TO THE LANDLORD,
    MERLISS ALLEGEDLY KICKING DOWN THE DOOR, IS OF MATERIALLY
    RELEVANCE TO SEVERAL CIVIL LAWSUITS AND CRIMINAL
    PROCEEDINGS. RICHARD LIED IN COURT, UNDER OATH WHEN HE
    TESTIFIED THAT THE RPD ANNOUNCED THEMSELVES AS LAW
    ENFORCEMENT AND ORDERED COUGHLIN TO COME OUT OF THE
    BASEMENT PRIOR TO THE DOOR BEING KICKED IN. RICHARD SENDS
    THE STATE BAR OF NEVADA LETTERS ON
    FURTHER, OFFICER CARTER'S POLICE REPORT IS DEMONSTRATED TO BE
    FULL OF LIES BY THE VERY VIDEOS THAT HILL PROPOUNDED TO THE
    CITY OF RENO PROSECUTORS, PARTICULARLY WITH RESPECT TO
    WHETHER COUGHLIN REFUSED TO LEAVE AFTER BEING WARNED OR
    TOLD TO DO SO AND THE EXTENT TO WHICH CARTER WAS UNABLE TO
    ISSUE A CITATION OR RELY ON A SIMPLE WARNING IN LIGHT THEREOF.
    COUGHLIN ACTUALLY ASKS CARTER IN THE VIDEO HILL FILMED WHY
    HE DOESN'T JUST ISSUE SUCH A WARNING OR CITATION. Then, Carter
    goes on to attempt to offer his views on "service", however rudimentary they may be.
    being careful to note to Coughlin "you're not the victim here." To the extent that Hill
    and Merliss trespass into Coughlin's former law office on this date, with the help of the
    RPD, Soldal v Cook County has been violated, and Carter and Lopez have violated
    Wheeler v Coss.
    Any Eviction Order signed by Judge Sferrazza was stale in light of the failure to have
    the lockout order served upon Coughlin and a lockout performed "within 24 hours" of
    000432
    the Sheriff's receipt of the Order of both Oct 25th, 2011 (the simple one page Order
    signed by Judge Sferrazza and notated in his own handwriting) and or the October 27th,
    2011 Findings of Fact, Conclusions of Law, and Order for Summary Eviction) both of
    which were received by the WCSO well over 24 hours from when the lockout's were
    conducted, and therefore, both such Orders were stale, and therefore, Richard G. Hill,
    Esq. committed trespass upon Coughlin's former home law office, threw away a great
    deal of Coughlin's personalty (some of it very sentimental), and both Hill and Baker
    have lied repeatedly in court filings in indicating that Coughlin was served the
    Summary Eviction Order on November 1st, 2011 were they also admit that Coughlin
    was not at his former home law office at the time WCSO Deputy Machen posted it on
    the door thereof and effectuated a lockout (and Machen lied under oath in his
    November 7th, 2011 filed Affidavit of Service attesting to have "personally served"
    Coughlin the Summary Eviction Order on November 1st, 2011 (WCSO Civil Division
    Supervisor admitted as much to Coughlin in writing:
    NRS 40.253:
    5. Upon noncompliance with the notice:
    (a) The landlord or the landlords agent may apply by affidavit of complaint for
    eviction to the justice court of the township in which the dwelling, apartment, mobile home or
    commercial premises are located or to the district court of the county in which the dwelling,
    apartment, mobile home or commercial premises are located, whichever has jurisdiction over the
    matter. The court may thereupon issue an order directing the sheriff or constable of the county
    to remove the tenant within 24 hours after receipt of the order. The affidavit must state or
    contain:
    (1) The date the tenancy commenced.
    (2) The amount of periodic rent reserved.
    (3) The amounts of any cleaning, security or rent deposits paid in advance,
    in excess of the first months rent, by the tenant.
    (4) The date the rental payments became delinquent.
    (5) The length of time the tenant has remained in possession without paying
    rent.
    (6) The amount of rent claimed due and delinquent.
    (7) A statement that the written notice was served on the tenant in
    accordance with NRS 40.280.
    (8) A copy of the written notice served on the tenant.
    (9) A copy of the signed written rental agreement, if any.
    (b) Except when the tenant has timely filed the affidavit described in subsection 3 and a
    file-stamped copy of it has been received by the landlord or the landlords agent, and except when
    the landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may,
    in a peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
    otherwise.
    000433
    Further where is my damage deposit (either $500, or, arguably $700 given the extent to
    which the Standard Rental Agreement afforded me the choice with respect to how
    cleaning was to be done and the extent to which Hill and Baker have failed to comply
    with
    Mr. Baker, you have committed professional misconduct (and Hill filed a grievance
    against me in a letter to the SBN dated January 14th, 2012 purporting to be sent on your
    behalf in "fulfilling your RPC 3.8 obligation"...simpy put, Mr. Baker, in your
    Opposition to MOtion to constest Personal Property Lien in Rev2011-001708, on page
    5, you lie where you write "when Coughlin refused to emerge from the basement after
    being ordered to do so by the police, Merliss was forced to kick down the door to gain
    access to his own property". You know that that is not true. The Reno Police
    Department did not identify themselves as law enforcement or otherwise issue an lawful
    Orders directing Coughlin to "emerge from the basement". You have demonstrated a
    lack of candor to the tribunal in that regard in conspiracy with Richard Hill. In a
    videotaped interview, RPD Sargent Lopez admits that neither she nor Officer Carter,
    nor anyone else that day, identified themselves in any way to Coughlin in the
    "basement" or otherwise issued him any sort of "warning to leave" or "order to emerge"
    of any sort, whatsoever. Mr. Baker, you were not even there. Yet, you viewed the
    video taken by Richard Hill of the moments in question where the RPD were at the
    basement door prior to Dr. Merliss kicking it down, including those moments where Dr.
    Merliss is seen in one video whispering to Richard Hill. If there really was all this
    identifying themselves as law enforcement and issuing Coughlin an order to emerge
    which went unheeded, then why the whispering? Why did Richard fail to include the
    he took of the moments where the RPD were at the "basement" door an failed to
    identify themselves or issue any lawful Orders? How would Coughlin know that any
    voices that may have been audible did not simply belong to more of the goons Hill and
    Baker routinely hire from Nevada Court Services to trespass behind Coughlin's former
    home law office's backyard gate, visiting in pairs, threes times a day, one ringing the
    door bell repeatedly for 30 minutes at a time, while the other (R. Wray, Joel Durden,
    and other licensed process servers) trespasses behind a a latched backyard gate and
    bangs on windows and peers through closed blinds while issuing threats intended to
    indicate they are being made by someone with color of law behind their words, while
    dressed up in an outfit specifically intended to confuse the public into thinking these
    process servers are Sheriff's Deputies?
    000434
    Regardless, the real fly in the ointment is the fact that RPD Sargent Lopez admitted that
    neither she, nor Carter, nor anyone else identified themselves as law enforcement and or
    issued Coughlin an order to emerge from the "basement". Indeed, in Hill's
    Declaration in REv2011-001708, filed a scant 7 days after the arrest, Hill certainly fails
    to mention any such alleged moment where the RPD identify themselves as law
    enforcement and issue Coughlin an order to emerge prior to Merliss kicking the door in.
    Hill writes letters to the SBN accusing Coughlin of having a "crack pipe and bag of
    weed" and "large quantity of pills" (the videos Hill took that day reveal those "pills" are
    vitamins, something Hill fails to clarify with the SBN, and Hill never has provided any
    sort of indication of what the "crack pipe and bag of weed" looked like exactly, nor has
    he responded to requests for photographs thereof, or made indication why he did not
    call the police, given the fact that he has involved law enforcement at every other
    possible turn.
    Hill and Baker have continued to fail to deliver Coughlin's security deposit, and in
    doing so, where they failed to provide the requisite correspondence within 30 days of
    any such eviction, have violated Nevada law:
    NRS 118A.242 Security: Limitation on amount or value; surety bond in lieu of security; duties and liability of landlord;
    damages; disputing itemized accounting of security; prohibited provisions.
    1. The landlord may not demand or receive security or a surety bond, or a combination thereof, including the last months
    rent, whose total amount or value exceeds 3 months periodic rent.
    2. In lieu of paying all or part of the security required by the landlord, a tenant may, if the landlord consents, purchase a surety
    bond to secure the tenants obligation to the landlord under the rental agreement to:
    (a) Remedy any default of the tenant in the payment of rent.
    (b) Repair damages to the premises other than normal wear and tear.
    (c) Clean the dwelling unit.
    3. The landlord:
    (a) Is not required to accept a surety bond purchased by the tenant in lieu of paying all or part of the security; and
    (b) May not require a tenant to purchase a security bond in lieu of paying all or part of the security.
    4. Upon termination of the tenancy by either party for any reason, the landlord may claim of the security or surety bond, or a
    combination thereof, only such amounts as are reasonably necessary to remedy any default of the tenant in the payment of rent, to repair
    damages to the premises caused by the tenant other than normal wear and to pay the reasonable costs of cleaning the premises. The landlord
    shall provide the tenant with an itemized written accounting of the disposition of the security or surety bond, or a combination thereof, and
    return any remaining portion of the security to the tenant no later than 30 days after the termination of the tenancy by handing it to the tenant
    personally at the place where the rent is paid, or by mailing it to the tenant at the tenants present address or, if that address is unknown, at
    the tenants last known address.
    5. If a tenant disputes an item contained in an itemized written accounting received from a landlord pursuant to subsection 4, the
    tenant may send a written response disputing the item to the surety. If the tenant sends the written response within 30 days after receiving the
    itemized written accounting, the surety shall not report the claim of the landlord to a credit reporting agency unless the surety obtains a
    judgment against the tenant.
    6. If the landlord fails or refuses to return the remainder of a security deposit within 30 days after the end of a tenancy, the
    landlord is liable to the tenant for damages:
    (a) In an amount equal to the entire deposit; and
    000435
    (b) For a sum to be fixed by the court of not more than the amount of the entire deposit.
    7. In determining the sum, if any, to be awarded under paragraph (b) of subsection 6, the court shall consider:
    (a) Whether the landlord acted in good faith;
    (b) The course of conduct between the landlord and the tenant; and
    (c) The degree of harm to the tenant caused by the landlords conduct.
    NRS 118A.360 Failure of landlord to comply with rental agreement or maintain dwelling unit in habitable condition where
    cost of compliance less than specified amount.
    1. If the landlord fails to comply with the rental agreement or his or her obligation to maintain the dwelling unit in a habitable
    condition as required by this chapter, and the reasonable cost of compliance or repair is less than $100 or an amount equal to one months
    periodic rent, whichever amount is greater, the tenant may recover damages for the breach or notify the landlord of the tenants intention
    to correct the condition at the landlords expense. If the landlord fails to use his or her best efforts to comply within 14 days after being
    notified by the tenant in writing or more promptly if conditions require in case of emergency, the tenant may cause the work to be done in a
    workmanlike manner and after submitting to the landlord an itemized statement, the tenant may deduct from his or her rent the actual and
    reasonable cost or the fair or reasonable value of the work, not exceeding the amount specified in this subsection.
    2. The landlord may specify in the rental agreement or otherwise that work done under this section and NRS 118A.380must be
    performed by a named person or firm or class of persons or firms qualified to do the work and the tenant must comply with the specifications.
    If the person qualified to do the work is unavailable or unable to perform the repairs the tenant shall use another qualified person who
    performs repairs.
    3. A tenant may not repair at the landlords expense if the condition was caused by the deliberate or negligent act or
    omission of the tenant, a member of the tenants household or other person on the premises with his or her consent.
    4. The landlords liability under this section is limited to $100 or an amount equal to one months periodic rent,
    whichever amount is greater, within any 12-month period.
    5. A tenant may not proceed under this section unless the tenant has given notice to the landlord that the dwelling is not in a
    habitable condition as required by this chapter.
    NRS 118A.355 Failure of landlord to maintain dwelling unit in habitable condition.
    1. Except as otherwise provided in this chapter, if a landlord fails to maintain a dwelling unit in a habitable condition as required
    by this chapter, the tenant shall deliver a written notice to the landlord specifying each failure by the landlord to maintain the dwelling unit in
    a habitable condition and requesting that the landlord remedy the failures. If a failure is remediable and the landlord adequately remedies the
    failure or uses his or her best efforts to remedy the failure within 14 days after receipt of the notice, the tenant may not proceed under this
    section. If the landlord fails to remedy a material failure to maintain the dwelling unit in a habitable condition or to make a reasonable effort
    to do so within the prescribed time, the tenant may:
    (a) Terminate the rental agreement immediately.
    (b) Recover actual damages.
    (c) Apply to the court for such relief as the court deems proper under the circumstances.
    (d) Withhold any rent that becomes due without incurring late fees, charges for notice or any other charge or fee authorized by this
    chapter or the rental agreement until the landlord has remedied, or has attempted in good faith to remedy, the failure.
    2. The tenant may not proceed under this section:
    (a) For a condition caused by the tenants own deliberate or negligent act or omission or that of a member of his or her
    household or other person on the premises with his or her consent; or
    (b) If the landlords inability to adequately remedy the failure or use his or her best efforts to remedy the failure within 14 days
    is due to the tenants refusal to allow lawful access to the dwelling unit as required by the rental agreement or this chapter.
    3. If the rental agreement is terminated, the landlord shall return all prepaid rent and security recoverable by the tenant under this
    chapter.
    4. A tenant may not proceed under this section unless the tenant has given notice as required by subsection 1, except that the
    000436
    tenant may, without giving that notice:
    (a) Recover damages under paragraph (b) of subsection 1 if the landlord:
    (1) Admits to the court that the landlord had knowledge of the condition constituting the failure to maintain the
    dwelling in a habitable condition; or
    (2) Has received written notice of that condition from a governmental agency authorized to inspect for violations of
    building, housing or health codes.
    (b) Withhold rent under paragraph (d) of subsection 1 if the landlord:
    (1) Has received written notice of the condition constituting the failure to maintain the dwelling in a habitable
    condition from a governmental agency authorized to inspect for violations of building, housing or health codes; and
    (2) Fails to remedy or attempt in good faith to remedy the failure within the time prescribed in the written notice of
    that condition from the governmental agency.
    5. Justice courts shall establish by local rule a mechanism by which tenants may deposit rent withheld under paragraph
    (d) of subsection 1 into an escrow account maintained or approved by the court. A tenant does not have a defense to an eviction under
    paragraph (d) of subsection 1 unless the tenant has deposited the withheld rent into an escrow account pursuant to this subsection.
    Mr's. Baker and HIll, would you not say it more accurate to characterize the situation in rev2011-001708 as one fitting under the
    NRS 118A.355 heading, particulary where the RJC, at the time of that summary eviction "Trial" had, according to Judge Sferrazza, no "local
    rule" or "mechanism by which tenants may deposit rent withheld under paragraph..." and therfore acknowledging the brilliance in Coughlin's
    JCRLV Rule 44 corollary in the RJC argument? Certainly, under the NRS 118A.355 analysis, after one strips away the agreed to $350 for
    weeds maintenance (which kind of amounts to a waiver of term in the Standard Rental Agreement that Judge Sferrazza interprets to require
    such "care" of the "lawn and surrounding grounds" (which, to the Court, apparently, included "weeds"), doesn't it?), and the agreed upon
    credit for fixing the stairs, well, then, and other amounts fit quite nicely into the "fix and deduct" approach set forth in NRS 118A.360.
    But, regardless, you proceeded under a No Cause Eviction basis, but against a commercial tenant, a fact you are stuck with, as the Tenant's
    Answer, numerous phone calls to Baker, and many, many instances throughout the filings in that matter make clear thta this was Coughlin's
    home law office, a commercial lease which the Standard Rental Agreement specifically allows for. And take a look at that 2008 Winchell v
    Schiff seafood business goes under because of wrongful eviction case wherein damages accounting for the loss of one's entire business (and
    what is a patent attorney's business worth, do you think, Dr. Merliss?) are allowable under Nevada law. Please remit $450,000 to me within
    7 days of this email being sent to you in satisfaction of this dispute against you, Dr. Merliss. Richard and Casey, I will deal with you later,
    but your liability is on par with Dr. Merliss's, no doubt, and that is before the FDCPA stuff and the fact that your office is not licensed as a bill
    collector.
    Further,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel and Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000437
    Print Close
    RE: Notification of Electronic Filing in IN RE: DISCIPLINE OF
    ZACHARY COUGHLIN, No. 60838
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 10/11/12 5:05 PM
    To: patrickk@nvbar.org; laurap@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org;
    nvscclerk@nvcourts.nv.gov
    Dear Bar Counsel, Chairman Susich, and Clerk of Court Peters,
    Clerk of Court Peters made representations to Coughlin on or around September 11th,
    2011 that she had mailed a certified copy of a SBN v. Coughlin Complaint on or about
    August 23rd, 2012, but that she has received it back in the mail as unclaimed on
    September 10th, 2012. Clerk Peters made representation to Coughlin that he would not
    be deemed "served" the Complaint by the SBN incident to any August 23rd, 2012
    mailing, but that she would resend such SBN v. Coughlin Complaint sooner after the
    communications with Coughlin on or about September 11th, 2012, and that Coughlin
    would not be deemed "served" until a signed returned certified mail receipt was
    recieved by the SBN. Coughlin is entitled to rely upon representation made by the
    SBN's Clerk of Court Peters. Further, Patrick King made representations that the
    earliest Coughlin would be viewed as "served" an SBN v. Coughlin Complaint would
    be September 25th, 2012, providing Coughlin a guarantee that he had 20 days to file an
    Answer from that date. Now it seems Bar Counsel King is attempting to remix this
    situation, and potentially deem Coughlin "served" all the way back to, say, 5 days from
    when Clerk of Court Peters indicates she sent Coughlin via certified mail a SBN v.
    Coughlin Complaint or or about August 23rd, 2012. Of Course, Bar Counsel King has
    done no legal research to see if there exists any authority to interpret this situation or
    SCR 109, but merely makes it up as he goes along, contradicting himself along the well,
    and going back on representations made by the SBN, sullying its image.
    In anticipation of that very sort of approach, Coughlin filed a Motion to Dismiss on
    September 17th, 2012 (which would be timely under even the most draconian
    interpretations of SCR 109, even where the SBN is allowed to go back on promises and
    express indications detailed above, sometimes in writing, too), and Clerk of Court
    Peters indicated to Coughlin that Bar Counsel King forbade her from filing it, citing
    000438
    various specious arguments as to why NRCP 5(e) did not have to be followed by the
    SBN. Now, Bar Counsel King has sent a confusing email on October 8th, 2012
    purporting a Verified Answer to a SBN v Coughlin Complaint to be due by "Tuesday
    September 9, 2012"...which is in the past....and which is less than 20 days from even
    the August 23rd, 2012 date the Clerk of Court Peters indicated to Coughlin she mailed,
    via certified letter, a SBN v. Coguhlin Complaint.
    Please provide an indication of whether King's email of October 8th, 2012 contained a
    typo as to the due date for an Answer, and whether the SBN views that date to have
    already passed, and the extent to which the SBN and or the NNDB is going back on the
    indications by King and Clerk Peters as to when, at the earliest, such a SBN v. Coughlin
    Complaint woud be deemed "served".
    Respectfully,
    Zach Coughlin
    PS. I will provide my physical address, as I have indicated previously, if the SBN
    demands it, but given the abuse of me by local law enforcement in my crusade for civil
    rights and lawfulness and against prosecutorial misconduct, I have became fearful of
    having my physical address all that well known, plus I was adjudged a victim of
    domestic violence earlier this year in FV12-00187 and FV12-00188, which further
    supports such an arrangment. Please see my previous correspondence with offers of
    presenting a reasonable manner in which the SBN can readily and quickly serve me.
    RE: motion to dismiss attached
    To see messages related to this one, group messages by conversation.
    10/08/12
    5HSO\
    Patrick King
    Add to contacts
    To Zach Coughlin
    000439
    From: Patrick King (PatrickK@nvbar.org)
    Sent: Mon 10/08/12 11:39 AM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Dear Mr. Coughlin,
    As I have explained, the Complaint against you has been served. Your verified answer
    is due by Tuesday September 9, 2012. You should file a verified answer to the
    complaint.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Saturday, October 06, 2012 4:36 AM
    To: Patrick King; Laura Peters; tsusich@nvdetr.org
    Subject: FW: motion to dismiss attached
    Dear Bar Counsel,
    Please note that the Motion to Dismiss that I filed in SBN v. Coughlin, on September
    17th, 2012, has gone unopposed, and therefore, should be granted...Mr. King was
    telling me the other day: "Zach, you don't take responsibility for your actions and that is
    why things don't work out for you..." I wonder, does Mr. King take responsibility for
    his actions here, or lack thereof, in failing to oppose my Motion to Dismiss? It will be
    interesting to see.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000440
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; tsusich@nvdetr.org
    Subject: motion to dismiss attached
    Date: Mon, 17 Sep 2012 23:59:42 -0700
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.comu
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com; DavidC@nvbar.org; LauraP@nvbar.org;
    barcounseloversightcommission@gmail.com; tsusich@nvdetr.org
    Subject: RE: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    000441
    Date: Mon, 8 Oct 2012 16:56:30 +0000
    Mr. Coughlin was served with the Complaint by regular and by certified mail. In an abundance of caution Mr. Coughlin
    was personally served with the Complaint on September 25, 2012 when he came to the office of the state bar. Mr.
    Coughlin has not yet filed a verified Answer to the Complaint.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Saturday, October 06, 2012 4:49 AM
    To: Patrick King; David Clark; Laura Peters; barcounseloversightcommission@gmail.com; tsusich@nvdetr.org
    Subject: FW: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    Dear Bar Counsel, Clerk of Court of the SBN, and Chairman Susich,
    Please let me know if you must have my physical address ( I have indicated that due to my being a domestic violence victim (I
    was granted two protection orders) and the fact that local law enforcement obviously enjoys playing "kick the can" with me
    (and given the complete paucity of support from the SBN, etc., I would rather just meet your process server somewhere or
    have you sent whatever it is you want to serve via certified mail. However, Bar Counsel King has already, in writing, stipulated
    to an extension to file and answer or response to whatever it the SBN wishes to serve as far out as 20 days from the
    September 25th, 2012 date that Mr. King purports to have served my on (Please see that written indication below, which I am
    relying upon, in addition to the various statements made by Clerk of Court Peters), and provide me an indication, via email, or
    fax, preferably (I prefer communications that bare digital stamping and content reproduction and do not understand why the
    SBN is not an electronic filer) if my understanding is incorrect. Please note again my request that the hearing called for by the
    Court's June 7th, 2012 ORder and SCR 111(8) and SCR 102(4)(d) and any Proceeding/Hearing?Trial that would stem from a
    SCR 102 or SCR 105 Complaint by the SBN, as a complainant, be bifurcated, and not consolidated, given the basic due process
    notions of fairness that would be violated by so consolidating such. Please provide a response in writing detailing the SBN and
    NNDB's position with respect to the legal foundation for your claim that either the Court's June 7th, 2012 Order or something in
    the SCR's allows for such a "consolidation".
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    000442
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Date: Fri, 5 Oct 2012 09:43:15 -0700
    From: efiling@nvcourts.nv.gov
    To: zachcoughlin@hotmail.com
    Subject: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Oct 05 2012 09:43 a.m.
    Date and Time of
    Notice:
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed
    Docket Text:
    Filed Proof of Service Proof of Service of Petition on Bar Counsel and the
    NNDB
    000443
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-Filing
    website. Click here to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The time to
    respond to the document, if required, is computed from the date and time of this notice. Refer to NEFR
    9(f) for further details.
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the document must serve a
    copy of the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any questions, contact
    the Nevada Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    otification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    efiling@nv courts.nv.g ov
    10/05/12
    Reply
    Add to contacts
    To zachcoughlin@hotmail.com
    From: efiling@nvcourts.nv.gov
    Sent: Fri 10/05/12 9:43 AM

    000444
    To: zachcoughlin@hotmail.com
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Date and Time of
    Oct 05 2012 09:43 a.m.
    Notice:
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed

    Filed Proof of Service Proof of Service of Petition on Bar Counsel and the
    Docket Text:
    NNDB
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-Filing
    website. Clickhere to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The time to
    respond to the document, if required, is computed from the date and time of this notice. Refer to NEFR
    9(f) for further details.
    000445
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the document must serve a
    copy of the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any questions, contact
    the Nevada Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    RE: citation to legal authority?
    To see messages related to this one, group messages by conversation.
    9/25/12
    Reply

    Patrick King
    Add to contacts
    To Zach Coughlin, David Clark
    From: Patrick King (PatrickK@nvbar.org)
    Sent: Tue 9/25/12 10:49 AM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Cc: David Clark (DavidC@nvbar.org)
    September 25, 2012
    Good Morning Mr. Coughlin,
    000446
    This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG
    12-0434.
    A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada,
    9456 Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR
    109.
    The reason I have requested your physical address is to facilitate our ability to contact you. The mail that was
    sent to you via certified mail was returned to the State Bar as unclaimed.
    Patrick King, Assistant Bar Counsel
    RE: pending final disposition of disciplinary
    proceedings....language SCR 111(7) versus SCR 111(8) and
    the June 7th, 2012 Order of the NV. S. Ct.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 10/11/12 4:56 PM
    To: laurap@nvbar.org
    1 attachment
    1 29 2012 letter to Clerk of Court Orduna Hastings regarding Eflex rejections with
    attachments 41 pages total.pdf (957.8 KB)
    Dear Clerk of Court Peters,
    Are you sure I indicated one way or the other whether I received the Complaint? Was there some
    mention of August 23rd, 2012? Can Bar Counsel King actually do some legal research for once, ever?
    Does he have a citation to any authority or cases that says a Motion to Dismss may not be filed unless
    the Respondent makes some affirmative indcation to the Clerk of Court as to whether he actually
    received a Complaint? NRCP 5(e) makes clear the Clerk of Court and filing office of the SBN are not
    permitted to refuse filings. So, the September 17th, 2012 Motion to Dismiss must be filed by Clerk of
    Court Peters, or misconduct exists.
    FACTS
    Further, NRCP 5(e) holds that:
    000447
    "(e) Filing With the Court Defined. The filing of pleadings and other papers with the court as required
    by these rules shall be made by filing them with the clerk of the court, except that the judge may
    permit the papers to be filed with the judge, in which event the judge shall note thereon the filing date
    and forthwith transmit them to the office of the clerk. A court may by local rule permit papers to be
    filed, signed or verified by electronic means that are consistent with technical standards, if any, that the
    Judicial Conference of the United States establishes. A paper signed by electronic means in compliance
    with the local rule constitutes a written paper presented for the purpose of applying these rules. The
    clerk shall not refuse to accept for filing any paper presented for that purpose solely because it is not
    presented in proper form as required by these rules or any local rules or practices."
    The filing officer clerk's in the 2nd Judicial District Court for Washoe County, and the managers,
    supervisors, and administrators regularly refuse filing in contravention of NRCP 5(e). Further, the drop
    box required by WDCR 12(10) is no more. The drop box was removed about 6 months ago. The efiling
    fee tripled, about six months ago, on July 1, 2011. The connection is hard to ignore. I seriously,
    seriously doubt the drop box was as underutilized as I have heard suggested. I would imagine the hard
    working, dedicated filing office staff may actually prefer having the drop box to cut down on the lines.
    Nonetheless, I would be surprised if the dictates of WDCR 12(10) were rendered null by any under use.
    With regard to the WDC filing office/ eFlex staff refusing to file papers submitted for filing, please
    consider:
    Sullivan v. Eighth Judicial Dist. Court In and For County of Clark, 904 P.2d 1039, 111 Nev. 1367 (Nev.,
    1995): This proper person petition for a writ of mandamus seeks an order from this court directing the
    Eighth Judicial District Court to file petitioner's application to proceed in forma pauperis and his civil
    complaint. 1 On July 25, 1995, we ordered the state to file an answer to this petition. The state's
    answer was filed on August 11, 1995. 2 Documentation submitted by petitioner to this court establishes
    that petitioner submitted to the clerk of the district court for filing an application to proceed in forma
    pauperis and a civil complaint on May 15, 1995. Although the application for leave to proceed in forma
    pauperis was in proper form and was sworn to under penalty of perjury, the clerk of the district court
    did not file that application. 3 The failure to file the application was in violation of the clear statutory
    mandate that such an application be filed. NRS 12.015(1) provides that "[a]ny person ... may file an
    affidavit [seeking leave to proceed without payment of fees]." Further, we have repeatedly instructed
    the clerk of the Eighth Judicial District Court that such documents must be filed. See Bowman v. District
    Court, 102 Nev. 474, 728 P.2d 433 (1986) (clerk has a ministerial duty to accept and file documents if
    those documents are in proper form; clerk must not exercise any judicial discretion); Barnes v. District
    Court, 103 Nev. 679, 748 P.2d 483 (1987) (prisoner's right of access to court cannot be denied on
    basis of indigency); Huebner v. State, 107 Nev. 328, 810 P.2d 1209 (1991) (clerk must create an
    accurate record of all pleadings submitted for filing, whether or not the documents are actually filed);
    Whitman v. Whitman, 108 Nev. 949, 840 P.2d 1232 (1992) (clerk has no authority to return documents
    submitted for filing; instead, clerk must stamp documents that cannot be immediately filed "received,"
    and must maintain such documents in the record of the case); Donoho v. District Court, 108 Nev. 1027,
    842 P.2d 731 (1992) (the clerk of the district court has a duty to file documents and to keep an
    accurate record of the proceedings before the court); Grey v. Grey, 111 Nev. 388, 892 P.2d 595 (1995)
    (clerk of district court admonished for failure to keep accurate record of documents submitted for
    filing). Petitioner alleges that the district court has refused to file his application and has returned it
    with directions to provide more information regarding employment. Indeed, petitioner has attached to
    his petition for a writ in this court his original application as it was returned to him. Attached to the top
    of the document is a "post-it" note with the handwritten notation: "application denied incomplete info-
    employment currently." 4 The state informs us that the note was written by "the chief judge." In
    addition, petitioner alleges, and the allegation is apparently true, that along with his "denied"
    application for leave to proceed in forma pauperis, his civil complaint was returned to him unfiled.
    Finally, petitioner alleges, and has attached documentation to support the allegation, that judges' law
    clerks often return to prisoners unfiled motions along with letters purporting to rule on the legal
    sufficiency of those motions. The state argues in its answer to this petition that "petitioner's application
    ... was denied on the basis that the address of the Petitioner which was later given to the Court by
    Petitioner ... did not appear to be a jail and that such information was contrary to the information
    shown in the application which stated that the Petitioner was in prison. The 'out of jail' address
    000448
    suggested an ability of the Petitioner to be employed." This vague reference to an "out of jail" address
    is not explained in the documents before this court. Nevertheless, the state's assertion that petitioner's
    application was denied is incorrect. The handwritten notation on petitioner's unfiled application clearly
    does not constitute a proper judicial disposition of that application. Further, the action of the clerk of
    the district court in returning petitioner's application and civil complaint to him unfiled is in direct
    violation of this court's instructions to the clerk of the district court in Whitman v. Whitman, 108 Nev.
    949, 840 P.2d 1232 (1992). This court has several times confirmed the absolute obligation of the
    district courts to file documents submitted to them and to preserve the right of citizens to access to the
    courts, whether indigent or not. Barnes v. District Court, 103 Nev. 679, 748 P.2d 483 (1987); Huebner
    v. State, 107 Nev. 328, 810 P.2d 1209 (1991). Indeed, in Donoho v. District Court, 108 Nev. 1027, 842
    P.2d 731 (1992), a case directly analogous to this case, we held that the clerk of the district court
    violated the rights of an indigent party when she neglected to file a motion for leave to proceed in
    forma pauperis and a motion for relief from a default judgment. Specifically, we stated: "[T]he clerk [of
    the district court] had an absolute duty to file the motion for leave to proceed in forma pauperis and to
    clearly stamp the date of receipt of the other documents on the documents. Further, the clerk had a
    duty to keep an accurate record of the case pending before the district court." Id. at 1029, 842 P.2d at
    733 (citation omitted; emphasis added). Thus, petitioner's application for leave to proceed in forma
    pauperis must be filed. If, on subsequent review of the application, the district court determines that
    petitioner has not shown he is indigent, the district court may order petitioner to provide further
    information or may deny the application in an appropriately filed written order. If, on the other hand,
    the district court grants the application, the district court must then proceed to require the filing of
    petitioner's other documents and to consider them in due course. Donoho, 108 Nev. at 1030, 842 P.2d
    at 733. Of course, for statute of limitations purposes, the complaint would have to be considered filed
    on the date of actual receipt by the clerk of the district court. To continue the analysis, with respect to
    petitioner's civil complaint which he is attempting to file concurrently, the district court clerk had an
    absolute obligation to stamp the document "received" and to record the date on which the document
    was in fact received at the courthouse. See Huebner v. State, 107 Nev. 328, 810 P.2d 1209 (1991).
    This the clerk of the district court did. However, the clerk then had a duty to maintain a copy of the
    received document in the record of the case, whether or not the document is ever filed. Whitman v.
    Whitman, 108 Nev. 949, 840 P.2d 1232 (1992). This, the clerk neglected to do. While Huebner dealt
    with the timeliness of a notice of appeal, the rationale compelling this court's ruling in Huebner, that all
    documents must be marked received and dated, applies with equal force to a party's submission of a
    complaint. "The legal rights of the parties to litigation, whether acting in proper person or through
    counsel, often turn on the date of receipt by the clerk of the district court of documents and pleadings."
    Huebner, 107 Nev. at 330, 810 P.2d at 1211. As with a notice of appeal, the untimely filing of a
    complaint may prevent the court from hearing the matter on its merits. It is the responsibility of the
    clerk of the district court to keep an accurate record of all documents submitted to her, whether or not
    they are filed. As in Huebner, ambiguities regarding when documents were received or filed must
    ultimately be resolved in favor of the party submitting them. Id. at 332, 810 P.2d at 1212. The issue
    presently before this court is not whether petitioner's motion for leave to proceed in forma pauperis is
    sufficient to establish petitioner's indigence. Further, we are not now concerned with the merits of
    petitioner's civil complaint. We are vitally concerned, however, with the preservation of the
    constitutional right of access to the courts and with the protection of the constitutional right to due
    process of law. A writ of mandamus is available to compel the performance of an act which the law
    requires as a duty resulting from an office, trust or station. NRS 34.160. The clerk of the district court
    has an absolute duty to file petitioner's application and to properly receive and keep a record of
    petitioner's complaint. Accordingly, we grant this petition for a writ of mandamus. 6 The clerk of this
    court shall serve a copy of petitioner's application and complaint on the clerk of the district court
    forthwith. The clerk of this court shall also issue a writ of mandamus compelling the clerk of the district
    court to file petitioner's application, and to receive petitioner's complaint. These documents will be
    considered to have been filed and received on May 15, 1995. --------------- 1 Petitioner also seeks a writ
    of prohibition enjoining the district court, the clerk of the district court and her employees from denying
    prisoners access to the courts in the future. We deny petitioner's request for a writ of prohibition. 2
    Cause appearing, we grant petitioner's proper person request for leave to file a reply to the state's
    answer. The clerk of this court shall file the reply, entitled "petitioner's reply to petition for writs of
    mandamus and prohibition," which was received by this court on August 21, 1995. 3 Although the
    document was entitled "application" rather than "affidavit," it was sworn to under penalties of perjury,
    000449
    provided information concerning petitioner's financial condition and clearly sought a judicial ruling
    regarding the question of whether petitioner would be allowed to proceed with a civil action without the
    payment of fees. Thus, any deviation as to form was not significant enough to justify the clerk's failure
    to file the document. The
    clerk of the court has no discretion to make any judicial ruling regarding the legal sufficiency of a
    document. When a document in proper form is submitted to the clerk, the clerk has a ministerial duty
    to file that document. 4 We note that petitioner is presently an inmate at the Nevada State Prison, and
    that his affidavit filed in this court in support of this petition states that he is currently unemployed and
    has no prison job. He also avers that his only asset is $6.57 in his prison account. 5 One such letter
    from a law clerk to an inmate states: "Attached please find your Motions to Proceed in Forma Pauperis
    which you recently submitted. NRS 12.015 requires an indigent litigant to set forth 'with particularity
    facts concerning his income, property, and other resources ...' Your application to proceed sets forth
    this information very generally." "Please resubmit the Motion with a more particular statement
    regarding your finances and any property you own...." Although this letter does not directly deny the
    motion, it clearly has the effect of denying the motion without filing. Of course, like the clerk of the
    district court, a judge's law clerk lacks judicial authority. 6 The state represents that "the District Court
    will file the Petitioner's complaint upon submittal by the petitioner." This statement was based on the
    state's view that we determined in our Order to Show Cause that petitioner should be allowed to
    proceed in forma pauperis. We, however, express no opinion regarding the merits of petitioner's
    application or complaint. We merely determine that the application should have been filed and judicially
    resolved, and the complaint should have been properly received. We note that petitioner has sent the
    original documents to this court, and thus may not be in a position to resubmit them. Also, for statute
    of limitations purposes, the documents must be considered filed as of the date of original receipt. Thus,
    we have determined that this petition must be granted. Another very important and instructive case is
    Whitman v. Whitman, 108 Nev. 949, 840 P.2d 1232 (Nev., 1992): On rehearing, appellant has
    submitted documents that conclusively demonstrate that appellant submitted a timely notice of appeal
    to the clerk of the district court. Although the clerk of the district court stamped the notice of appeal
    "received" on December 30, 1991, the clerk did not file the notice of appeal. Instead, the clerk of the
    district court returned appellant's notice of appeal to appellant because it was not accompanied by a
    filing fee and, although the notice was accompanied by a motion for leave to proceed on appeal in
    forma pauperis, appellant's affidavit in support of that motion was apparently not signed. Consequently,
    there is no record of the submission of appellant's timely notice of appeal. We note that the clerk of the
    district court filed appellant's motion for leave to proceed on appeal in forma pauperis on the date of
    receipt, December 30, 1991, and that the district court eventually granted that motion. We have
    previously stated that "it is extremely important that the clerk of the district court keep an accurate
    record of the date of receipt of every document submitted to the clerk, regardless of whether the
    document is in the appropriate form. Indeed, it is a gross dereliction of duty for the clerk of the district
    court to neglect this ministerial duty." Huebner v. State, 107 Nev. 328, 330, 810 P.2d 1209, 1211
    (1991) (footnote omitted). In this case, the clerk of the district court has failed to keep any record of
    the date of receipt of appellant's notice of appeal; instead, the clerk stamped the document "received"
    and returned it to appellant. The clerk of the district court had no authority to take such action.
    Although the clerk of the district court had no duty to file appellant's notice of appeal before appellant
    paid the requisite filing fee or was relieved of the duty to pay the filing fee by order of the district court,
    see NRS 19.013(2), the clerk had a duty to receive the document and to keep an accurate record of the
    case pending before the district court. Particularly in this case it was essential that the notice of appeal
    be retained in the record, because we have held that a notice of appeal is effective on the date of
    receipt by the district court clerk. See Huebner v. State, [108 Nev. 952] 107 Nev. 328, 810 P.2d 1209
    (1991). Rather than returning the notice of appeal to appellant, the clerk of the district court should
    have retained the notice of appeal in the record, and should have informed appellant by letter of any
    perceived deficiencies in the document. 4 Appellant could then have taken whatever action was
    appropriate to pursue his appeal. In light of the foregoing, we conclude that appellant timely submitted
    to the clerk of the district court a notice of appeal from an appealable order of the district court, and
    that appellant's timely notice of appeal is not contained in the record due to the inappropriate action of
    the district court clerk. Accordingly, we grant appellant's petition for rehearing, and we proceed to
    address the merits of this appeal. Id. At 1232-1234. See, also, Barnes v. Eighth Judicial Dist. Court of
    State of Nev., In and For Clark County, 748 P.2d 483, 103 Nev. 679 (Nev., 1987).
    000450
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: LauraP@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR
    111(8) and the June 7th, 2012 Order of the NV. S. Ct.
    Date: Thu, 11 Oct 2012 00:58:57 +0000
    Please don't put words in my mouth, Zach. You are the one that indicated that you had not received the Complaint when we
    talked on the phone. Why, then, would I file in a Motion to Dismiss? I am responsible for my own actions.
    - Laura (aka Clerk Peters)
    From: Zach Coughlin [zachcoughlin@hotmail.com]
    Sent: Wednesday, October 10, 2012 11:51 AM
    To: tsusich@nvdetr.org; Laura Peters; David Clark; Patrick King; nvscclerk@nvcourts.nv.gov
    Subject: FW: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and the June 7th,
    2012 Order of the NV. S. Ct.
    Dear Chairman Susich and Clerk Peters,
    Bar Counsel King sees himself as a the Director of this movie, placing you two in the scenes where he sees fit.
    Chairman Susich, it is your responsibility to comply with the Court's Order and the Supreme Court Rules, and at
    this point, you need to send a clear message to Bar Counsel that "the kid stays in the picture", and inform Mr.
    King that he is not to attempt to take your job or duties from you. Same goes for Clerk Peters, especially vis a vis
    her admission that King told her not to file Coughlin's Motion to Dismiss in SBN v Coughlin on September 17th,
    2012, which has now gone unopposed, and therefore, shall be granted.
    Sincerely,
    Zach Coughlin
    000451
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and
    the June 7th, 2012 Order of the NV. S. Ct.
    Date: Wed, 10 Oct 2012 16:44:27 +0000
    Dear Mr. Coughlin,
    When you met with me and David Clark to discuss the Complaint and the process. Mr. Clark explained that since there
    was a conviction, the sole issue to be determined was the extent of the discipline. Not if you committed the crime,
    since that was already determined beyond a reasonable doubt. It is that context that we are reading the rule. Not that
    the state bar is precluded from bringing additional allegations against you. Any additional allegations that have not
    already resulted in criminal convictions will need to be proved by clear and convincing evidence. As such, at the
    hearing, on the issue of your criminal convictions, the only issue for the panel to decide is the appropriate discipline.
    However, I will be providing evidence as to the other allegations in the Complaint. The Panel will decide if the state bar
    has met its burden of proof as to those allegations in the complaint, other than the criminal convictions, and will decide
    the appropriate discipline on the totality of the case, including mitigating and aggravating factors that may be presented
    at the hearing.
    As such, I do not intend bifurcate these proceedings. I think to do so would cause unnecessary confusion, undue time and
    expense and would be prejudicial to the administration of justice.
    I am advised that you have not yet filed an Answer to the Complaint. I have sent you a notice of intent to proceed on a
    default basis. The hearing date is expected to be Wednesday November 14, 2012. I will be sending you a notice of
    hearing, along with a list of witness, and evidence that I intend to introduce at the hearing.
    Patrick King, Assistant Bar Counsel.
    000452
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, October 10, 2012 6:18 AM
    To: tsusich@nvdetr.org; David Clark; Laura Peters; Patrick King
    Subject: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and the June 7th,
    2012 Order of the NV. S. Ct.
    Dear Chairman Susich, Bar Counsel, and Clerk Peters,
    I am writing formally request a bifurcation of sorts, consiering:
    SCR 111(7). Suspension on certification. Upon the filing with the supreme court of a petition with a certified copy of proof of the
    conviction, demonstrating that an attorney has been convicted of a serious crime, the court shall enter an order suspending the attorney,
    regardless of the pendency of an appeal, pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board upon referral by the supreme court. For good cause, the court may set aside its order suspending the
    attorney from the practice of law.
    I think Bar Counsel's argument that the "proceeding" call for in the Court's June 7th, 2012 Order (which quotes SCR 111(7)
    may include some SCR 105 Complaint (ie, a SBN v. Zachary B. Coughlin Complaints bringin in all sorts of matters, including
    pending criminal actions, and wearing pajamas, and Orders by Judges purporting to take away this or that right of Coughlin's to
    practice this or that in some court (an Order which Patrick King reference to me and Chief Bar Counsel Clark, and, apparently,
    to a client of mine in early May 2012 (the client is the only other place I have ever heard of such an unpublished "Order"
    purporting to have said effect) despite the dictate against Bar Counsel's doign so in SCR 121 (the SCR 11 Petition was not even
    filed at that point, and one has to wonder if some deal between that client, Bar Counsel, and the new attorney that client can
    now magically afford was worked out, with nothing said of any torts that client committed against Coughin, etc., etc., much
    less criminal law violations, which Coughlin just put up with).
    But my point is, Bar Counsel King points ot the "pending final disposition of a disciplinary proceeding" language of SCR
    111(7)...which is quoted in the Court's June 7th, 2012 ORder (though I feel Bar Counsel is taking the quote out of context and
    ignoring the express language of SCR 111(7) in making this argument that the "pending final disposition of the disciplinary
    proceedings" language in the Court's June 7th, 2012 Order entitles Bar Counsel to file a SBN v. Coughlin Complaint deny
    Coughlin that afforded under SCR 111(8) (which the JUne 7th, 2012 Order cites to as well), and, given Coughlin's Petition in
    61426, filed and served on August 13th, 2012 (the service of which was consented to or waived by Bar Counsel King and Clark
    where they directed Clerk Laura Peters to sign "Proof of Receipt" thereof on August 13th, 2012...), Coughlin is now entitled to
    an "immediate hearing" pursuant to SCR 102(4)(d), and SCR 111(10).
    The Court's June 7th, 2012 Order reads, in relevant part: "Pursuant to SCR 111, temporary suspension and referral to the
    appropriate disciplinary board are mandatory when an attorney has been convicted of a "serious" crime, which includes theft.
    SCR 111 (6)-(8). Accordingly, pursuant to SCR 111 (8), we refer this matter to the appropriate disciplinary board for
    the institution of 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. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend Zachary B. Coughlin from the
    000453
    practice of law in Nevada, pending final disposition of the disciplinary proceedings." Note that the Order says "pending
    final disposition of the disciplinary proceedings" . It does not say "pending final disposition of an SCR 105 Complaint filed by
    SBN as the complainant (see Ching). And, in fact, SCR 111(8) clear that up further,
    I give Patrick King credit for making a crafty argument, but its just not colorable. I am so used to this with Pat by now, he
    plays dumb in a way that screw one out of their due process, but it is clear he knows exactly what he is doing, that crafty
    sum'itch.
    SCR 111(8): "8. Referral to disciplinary board. Upon receipt of a petition filed under subsection 4 of this rule, demonstrating that an
    attorney has been convicted of a serious crime, the supreme court shall, in addition to suspending the attorney in accordance with the
    provisions of subsection 7 of this rule, refer the matter to the appropriate disciplinary board for the institution of 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."
    But the clearest expression of authority to defeat Bar Counsels stated goal of "combining" the Hearing required by the Court's
    June 7th, 2012 Order and the Supreme Court Rules with some SCR 105 (or SCR 102, natch) style SBN v. Coughlin Complaint
    that Bar Counsel wishes to file is found in SCR 111(7): "the court shall enter an order suspending the attorney...pending final
    disposition of a disciplinary proceeding, which shall be commenced by the appropriate disciplinary board upon
    referral by the supreme court."
    And, right there, Bar Counsel's attempt to combine these affairs must fail. That's the thing, though...the phrase "commenced
    by the appropriate disciplinary board". It does not say "commenced by the State Bar of Nevada as a complainant, under
    Ching, filing an SCR 105 Complaint...It just does not say that. SCR 111(7), rather, reads "which shall e commenced by the
    appropriate disciplinary board".
    So, to sum it up Bar Counsel's attempts combine these must fail in light of the following:
    "SCR 111(8): "the supreme court shall...refer the matter to the appropriate disciplinary board for the institution of 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."
    SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a disciplinary proceeding,
    which shall be commenced by the appropriate disciplinary board upon referral by the supreme court."
    However, Bar Counsel and the Disciplinary Board should recognize the import of SCR 111(7)-(8) and refuse to allow Bar
    Counsel to "combine" or consolidate, or "fail to bifurcate. What Bar Counsel is thinking of is SCR 105(2):. "Commencement of
    formal proceedings. Formal disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar.
    The complaint shall be sufficiently clear and specific to inform the attorney of the charges against him or her and the underlying conduct
    supporting the charges."
    However, SCR 111(7) and SCR 105(2) are entirely different animals. In one, SCR 111(7) calls for: "the court shall enter an order
    000454
    suspending the attorney...pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board..."
    In the other, it is Bar Counsel doing the "commencing" of SCR 105(2):. "Commencement of formal proceedings. Formal
    disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar...."
    The distiction and diferences are revealed in the Supreme Court Rules by whom is doing the "commencing" and just what it is they
    are "commencing", ie, a "formal proceeding (in the case of SCR 105(2), or a "dsiciplinary proceeding",
    There is a difference, and that difference entails bifurcating things or refusing to consolidate these affairs, and I am formally making
    that request upon the Board here now.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    FW: pending final disposition of disciplinary
    proceedings....language SCR 111(7) versus SCR 111(8) and
    the June 7th, 2012 Order of the NV. S. Ct.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/10/12 11:51 AM
    To: tsusich@nvdetr.org; laurap@nvbar.org; davidc@nvbar.org; patrickk@nvbar.org;
    nvscclerk@nvcourts.nv.gov
    Dear Chairman Susich and Clerk Peters,
    Bar Counsel King sees himself as a the Director of this movie, placing you two in the scenes where he
    000455
    sees fit. Chairman Susich, it is your responsibility to comply with the Court's Order and the Supreme
    Court Rules, and at this point, you need to send a clear message to Bar Counsel that "the kid stays in
    the picture", and inform Mr. King that he is not to attempt to take your job or duties from you. Same
    goes for Clerk Peters, especially vis a vis her admission that King told her not to file Coughlin's Motion
    to Dismiss in SBN v Coughlin on September 17th, 2012, which has now gone unopposed, and therefore,
    shall be granted.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR
    111(8) and the June 7th, 2012 Order of the NV. S. Ct.
    Date: Wed, 10 Oct 2012 16:44:27 +0000
    Dear Mr. Coughlin,
    When you met with me and David Clark to discuss the Complaint and the process. Mr. Clark explained that since there
    was a conviction, the sole issue to be determined was the extent of the discipline. Not if you committed the crime,
    since that was already determined beyond a reasonable doubt. It is that context that we are reading the rule. Not that
    the state bar is precluded from bringing additional allegations against you. Any additional allegations that have not
    already resulted in criminal convictions will need to be proved by clear and convincing evidence. As such, at the
    hearing, on the issue of your criminal convictions, the only issue for the panel to decide is the appropriate discipline.
    However, I will be providing evidence as to the other allegations in the Complaint. The Panel will decide if the state bar
    has met its burden of proof as to those allegations in the complaint, other than the criminal convictions, and will decide
    the appropriate discipline on the totality of the case, including mitigating and aggravating factors that may be presented
    at the hearing.
    As such, I do not intend bifurcate these proceedings. I think to do so would cause unnecessary confusion, undue time and
    expense and would be prejudicial to the administration of justice.
    000456
    I am advised that you have not yet filed an Answer to the Complaint. I have sent you a notice of intent to proceed on a
    default basis. The hearing date is expected to be Wednesday November 14, 2012. I will be sending you a notice of
    hearing, along with a list of witness, and evidence that I intend to introduce at the hearing.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, October 10, 2012 6:18 AM
    To: tsusich@nvdetr.org; David Clark; Laura Peters; Patrick King
    Subject: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and the June 7th,
    2012 Order of the NV. S. Ct.
    Dear Chairman Susich, Bar Counsel, and Clerk Peters,
    I am writing formally request a bifurcation of sorts, consiering:
    SCR 111(7). Suspension on certification. Upon the filing with the supreme court of a petition with a certified copy of proof of the
    conviction, demonstrating that an attorney has been convicted of a serious crime, the court shall enter an order suspending the attorney,
    regardless of the pendency of an appeal, pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board upon referral by the supreme court. For good cause, the court may set aside its order suspending the
    attorney from the practice of law.
    I think Bar Counsel's argument that the "proceeding" call for in the Court's June 7th, 2012 Order (which quotes SCR 111(7)
    may include some SCR 105 Complaint (ie, a SBN v. Zachary B. Coughlin Complaints bringin in all sorts of matters, including
    pending criminal actions, and wearing pajamas, and Orders by Judges purporting to take away this or that right of Coughlin's to
    practice this or that in some court (an Order which Patrick King reference to me and Chief Bar Counsel Clark, and, apparently,
    to a client of mine in early May 2012 (the client is the only other place I have ever heard of such an unpublished "Order"
    purporting to have said effect) despite the dictate against Bar Counsel's doign so in SCR 121 (the SCR 11 Petition was not even
    filed at that point, and one has to wonder if some deal between that client, Bar Counsel, and the new attorney that client can
    now magically afford was worked out, with nothing said of any torts that client committed against Coughin, etc., etc., much
    less criminal law violations, which Coughlin just put up with).
    But my point is, Bar Counsel King points ot the "pending final disposition of a disciplinary proceeding" language of SCR
    000457
    111(7)...which is quoted in the Court's June 7th, 2012 ORder (though I feel Bar Counsel is taking the quote out of context and
    ignoring the express language of SCR 111(7) in making this argument that the "pending final disposition of the disciplinary
    proceedings" language in the Court's June 7th, 2012 Order entitles Bar Counsel to file a SBN v. Coughlin Complaint deny
    Coughlin that afforded under SCR 111(8) (which the JUne 7th, 2012 Order cites to as well), and, given Coughlin's Petition in
    61426, filed and served on August 13th, 2012 (the service of which was consented to or waived by Bar Counsel King and Clark
    where they directed Clerk Laura Peters to sign "Proof of Receipt" thereof on August 13th, 2012...), Coughlin is now entitled to
    an "immediate hearing" pursuant to SCR 102(4)(d), and SCR 111(10).
    The Court's June 7th, 2012 Order reads, in relevant part: "Pursuant to SCR 111, temporary suspension and referral to the
    appropriate disciplinary board are mandatory when an attorney has been convicted of a "serious" crime, which includes theft.
    SCR 111 (6)-(8). Accordingly, pursuant to SCR 111 (8), we refer this matter to the appropriate disciplinary board for
    the institution of 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. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend Zachary B. Coughlin from the
    practice of law in Nevada, pending final disposition of the disciplinary proceedings." Note that the Order says "pending
    final disposition of the disciplinary proceedings" . It does not say "pending final disposition of an SCR 105 Complaint filed by
    SBN as the complainant (see Ching). And, in fact, SCR 111(8) clear that up further,
    I give Patrick King credit for making a crafty argument, but its just not colorable. I am so used to this with Pat by now, he
    plays dumb in a way that screw one out of their due process, but it is clear he knows exactly what he is doing, that crafty
    sum'itch.
    SCR 111(8): "8. Referral to disciplinary board. Upon receipt of a petition filed under subsection 4 of this rule, demonstrating that an
    attorney has been convicted of a serious crime, the supreme court shall, in addition to suspending the attorney in accordance with the
    provisions of subsection 7 of this rule, refer the matter to the appropriate disciplinary board for the institution of 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."
    But the clearest expression of authority to defeat Bar Counsels stated goal of "combining" the Hearing required by the Court's
    June 7th, 2012 Order and the Supreme Court Rules with some SCR 105 (or SCR 102, natch) style SBN v. Coughlin Complaint
    that Bar Counsel wishes to file is found in SCR 111(7): "the court shall enter an order suspending the attorney...pending final
    disposition of a disciplinary proceeding, which shall be commenced by the appropriate disciplinary board upon
    referral by the supreme court."
    And, right there, Bar Counsel's attempt to combine these affairs must fail. That's the thing, though...the phrase "commenced
    by the appropriate disciplinary board". It does not say "commenced by the State Bar of Nevada as a complainant, under
    Ching, filing an SCR 105 Complaint...It just does not say that. SCR 111(7), rather, reads "which shall e commenced by the
    appropriate disciplinary board".
    So, to sum it up Bar Counsel's attempts combine these must fail in light of the following:
    "SCR 111(8): "the supreme court shall...refer the matter to the appropriate disciplinary board for the institution of 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."
    000458
    SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a disciplinary proceeding,
    which shall be commenced by the appropriate disciplinary board upon referral by the supreme court."
    However, Bar Counsel and the Disciplinary Board should recognize the import of SCR 111(7)-(8) and refuse to allow Bar
    Counsel to "combine" or consolidate, or "fail to bifurcate. What Bar Counsel is thinking of is SCR 105(2):. "Commencement of
    formal proceedings. Formal disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar.
    The complaint shall be sufficiently clear and specific to inform the attorney of the charges against him or her and the underlying conduct
    supporting the charges."
    However, SCR 111(7) and SCR 105(2) are entirely different animals. In one, SCR 111(7) calls for: "the court shall enter an order
    suspending the attorney...pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board..."
    In the other, it is Bar Counsel doing the "commencing" of SCR 105(2):. "Commencement of formal proceedings. Formal
    disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar...."
    The distiction and diferences are revealed in the Supreme Court Rules by whom is doing the "commencing" and just what it is they
    are "commencing", ie, a "formal proceeding (in the case of SCR 105(2), or a "dsiciplinary proceeding",
    There is a difference, and that difference entails bifurcating things or refusing to consolidate these affairs, and I am formally making
    that request upon the Board here now.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000459
    Print Close
    pending final disposition of disciplinary
    proceedings....language SCR 111(7) versus SCR 111(8) and
    the June 7th, 2012 Order of the NV. S. Ct.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/10/12 6:17 AM
    To: tsusich@nvdetr.org; davidc@nvbar.org; laurap@nvbar.org; patrickk@nvbar.org
    Dear Chairman Susich, Bar Counsel, and Clerk Peters,
    I am writing formally request a bifurcation of sorts, consiering:
    SCR 111(7). Suspension on certification. Upon the filing with the supreme court of a petition with a certified copy of proof of the
    conviction, demonstrating that an attorney has been convicted of a serious crime, the court shall enter an order suspending the attorney,
    regardless of the pendency of an appeal, pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board upon referral by the supreme court. For good cause, the court may set aside its order suspending the
    attorney from the practice of law.
    I think Bar Counsel's argument that the "proceeding" call for in the Court's June 7th, 2012 Order (which
    quotes SCR 111(7) may include some SCR 105 Complaint (ie, a SBN v. Zachary B. Coughlin Complaints
    bringin in all sorts of matters, including pending criminal actions, and wearing pajamas, and Orders by
    Judges purporting to take away this or that right of Coughlin's to practice this or that in some court (an
    Order which Patrick King reference to me and Chief Bar Counsel Clark, and, apparently, to a client of
    mine in early May 2012 (the client is the only other place I have ever heard of such an unpublished
    "Order" purporting to have said effect) despite the dictate against Bar Counsel's doign so in SCR 121
    (the SCR 11 Petition was not even filed at that point, and one has to wonder if some deal between that
    client, Bar Counsel, and the new attorney that client can now magically afford was worked out, with
    nothing said of any torts that client committed against Coughin, etc., etc., much less criminal law
    violations, which Coughlin just put up with).
    But my point is, Bar Counsel King points ot the "pending final disposition of a disciplinary proceeding"
    language of SCR 111(7)...which is quoted in the Court's June 7th, 2012 ORder (though I feel Bar
    Counsel is taking the quote out of context and ignoring the express language of SCR 111(7) in making
    this argument that the "pending final disposition of the disciplinary proceedings" language in the Court's
    June 7th, 2012 Order entitles Bar Counsel to file a SBN v. Coughlin Complaint deny Coughlin that
    afforded under SCR 111(8) (which the JUne 7th, 2012 Order cites to as well), and, given Coughlin's
    Petition in 61426, filed and served on August 13th, 2012 (the service of which was consented to or
    waived by Bar Counsel King and Clark where they directed Clerk Laura Peters to sign "Proof of Receipt"
    thereof on August 13th, 2012...), Coughlin is now entitled to an "immediate hearing" pursuant to SCR
    102(4)(d), and SCR 111(10).
    000460
    The Court's June 7th, 2012 Order reads, in relevant part: "Pursuant to SCR 111, temporary suspension
    and referral to the appropriate disciplinary board are mandatory when an attorney has been convicted
    of a "serious" crime, which includes theft. SCR 111 (6)-(8). Accordingly, pursuant to SCR 111 (8), we
    refer this matter to the appropriate disciplinary board for the institution of 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. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend Zachary B. Coughlin
    from the practice of law in Nevada, pending final disposition of the disciplinary proceedings."
    Note that the Order says "pending final disposition of the disciplinary proceedings" . It does not say
    "pending final disposition of an SCR 105 Complaint filed by SBN as the complainant (see Ching). And,
    in fact, SCR 111(8) clear that up further,
    I give Patrick King credit for making a crafty argument, but its just not colorable. I am so used to this
    with Pat by now, he plays dumb in a way that screw one out of their due process, but it is clear he
    knows exactly what he is doing, that crafty sum'itch.
    SCR 111(8): "8. Referral to disciplinary board. Upon receipt of a petition filed under subsection 4 of this rule, demonstrating that an
    attorney has been convicted of a serious crime, the supreme court shall, in addition to suspending the attorney in accordance with the
    provisions of subsection 7 of this rule, refer the matter to the appropriate disciplinary board for the institution of 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."
    But the clearest expression of authority to defeat Bar Counsels stated goal of "combining" the Hearing
    required by the Court's June 7th, 2012 Order and the Supreme Court Rules with some SCR 105 (or SCR
    102, natch) style SBN v. Coughlin Complaint that Bar Counsel wishes to file is found in SCR 111(7):
    "the court shall enter an order suspending the attorney...pending final disposition of a disciplinary
    proceeding, which shall be commenced by the appropriate disciplinary board upon referral
    by the supreme court."
    And, right there, Bar Counsel's attempt to combine these affairs must fail. That's the thing,
    though...the phrase "commenced by the appropriate disciplinary board". It does not say "commenced
    by the State Bar of Nevada as a complainant, under Ching, filing an SCR 105 Complaint...It just does
    not say that. SCR 111(7), rather, reads "which shall e commenced by the appropriate disciplinary
    board".
    So, to sum it up Bar Counsel's attempts combine these must fail in light of the following:
    "SCR 111(8): "the supreme court shall...refer the matter to the appropriate disciplinary board for the institution of 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."
    SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a disciplinary proceeding,
    which shall be commenced by the appropriate disciplinary board upon referral by the supreme court."
    000461
    However, Bar Counsel and the Disciplinary Board should recognize the import of SCR 111(7)-(8) and refuse to allow Bar
    Counsel to "combine" or consolidate, or "fail to bifurcate. What Bar Counsel is thinking of is SCR 105(2):. "Commencement of
    formal proceedings. Formal disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar.
    The complaint shall be sufficiently clear and specific to inform the attorney of the charges against him or her and the underlying conduct
    supporting the charges."
    However, SCR 111(7) and SCR 105(2) are entirely different animals. In one, SCR 111(7) calls for: "the court shall enter an order
    suspending the attorney...pending final disposition of a disciplinary proceeding, which shall be commenced by the
    appropriate disciplinary board..."
    In the other, it is Bar Counsel doing the "commencing" of SCR 105(2):. "Commencement of formal proceedings.
    Formal disciplinary proceedings are commenced by bar counsel filing a written complaint in the name of the state bar...."
    The distiction and diferences are revealed in the Supreme Court Rules by whom is doing the "commencing" and just what it is they
    are "commencing", ie, a "formal proceeding (in the case of SCR 105(2), or a "dsiciplinary proceeding",
    There is a difference, and that difference entails bifurcating things or refusing to consolidate these affairs, and I am formally making
    that request upon the Board here now.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    FW: Notification of Electronic Filing in IN RE: DISCIPLINE OF
    ZACHARY COUGHLIN, No. 60838
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 10/06/12 5:01 AM
    To: patrickk@nvbar.org; laurap@nvbar.org; tsusich@nvdetr.org
    000462
    2 attachments
    filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 (1).pdf
    (294.3 KB) , file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution
    of Temporary Suspension on Susich NNDB King Clark Peters SBN.pdf (294.5 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; davidc@nvbar.org; laurap@nvbar.org;
    barcounseloversightcommission@gmail.com; tsusich@nvdetr.org
    Subject: FW: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    Date: Sat, 6 Oct 2012 04:48:59 -0700
    Dear Bar Counsel, Clerk of Court of the SBN, and Chairman Susich,
    Please let me know if you must have my physical address ( I have indicated that due to my being a
    domestic violence victim (I was granted two protection orders) and the fact that local law enforcement
    obviously enjoys playing "kick the can" with me (and given the complete paucity of support from the
    SBN, etc., I would rather just meet your process server somewhere or have you sent whatever it is you
    want to serve via certified mail. However, Bar Counsel King has already, in writing, stipulated to an
    extension to file and answer or response to whatever it the SBN wishes to serve as far out as 20 days
    from the September 25th, 2012 date that Mr. King purports to have served my on (Please see that
    written indication below, which I am relying upon, in addition to the various statements made by Clerk
    of Court Peters), and provide me an indication, via email, or fax, preferably (I prefer communications
    that bare digital stamping and content reproduction and do not understand why the SBN is not an
    electronic filer) if my understanding is incorrect. Please note again my request that the hearing called
    for by the Court's June 7th, 2012 ORder and SCR 111(8) and SCR 102(4)(d) and any
    Proceeding/Hearing?Trial that would stem from a SCR 102 or SCR 105 Complaint by the SBN, as a
    complainant, be bifurcated, and not consolidated, given the basic due process notions of fairness that
    would be violated by so consolidating such. Please provide a response in writing detailing the SBN and
    NNDB's position with respect to the legal foundation for your claim that either the Court's June 7th,
    2012 Order or something in the SCR's allows for such a "consolidation".
    Sincerely,
    000463
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Date: Fri, 5 Oct 2012 09:43:15 -0700
    From: efiling@nvcourts.nv.gov
    To: zachcoughlin@hotmail.com
    Subject: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Oct 05 2012 09:43 a.m.
    Date and Time of
    Notice:
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed
    Filed Proof of Service Proof of Service of Petition on Bar Counsel and
    Docket Text:
    the NNDB
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-
    000464
    Filing website. Click here to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The
    time to respond to the document, if required, is computed from the date and time of this notice.
    Refer to NEFR 9(f) for further details.
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the
    document must serve a copy of the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any
    questions, contact the Nevada Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    otification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    efiling@nv courts.nv.g ov
    10/05/12
    Reply

    Add to contacts
    To zachcoughlin@hotmail.com
    From: efiling@nvcourts.nv.gov
    Sent: Fri 10/05/12 9:43 AM
    To: zachcoughlin@hotmail.com
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Date and Time of Notice: Oct 05 2012 09:43 a.m.
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    000465
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed
    Docket Text: Filed Proof of Service Proof of Service of Petition on Bar Counsel and the NNDB
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-Filing website.
    Clickhere to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The time to respond to the
    document, if required, is computed from the date and time of this notice. Refer to NEFR 9(f) for further details.
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the document must serve a copy of
    the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any questions, contact the Nevada
    Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    RE: citation to legal authority?
    To see messages related to this one, group messages by conversation.
    Patrick King
    9/25/12

    Reply
    Add to contacts
    To Zach Coughlin, David Clark
    From: Patrick King (PatrickK@nvbar.org)
    Sent: Tue 9/25/12 10:49 AM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Cc: David Clark (DavidC@nvbar.org)
    September 25, 2012
    000466
    Good Morning Mr. Coughlin,
    This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG 12-
    0434.
    A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada, 9456
    Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR 109.
    The reason I have requested your physical address is to facilitate our ability to contact you. The mail that was
    sent to you via certified mail was returned to the State Bar as unclaimed.
    Patrick King, Assistant Bar Counsel
    FW: Notification of Electronic Filing in IN RE: DISCIPLINE OF
    ZACHARY COUGHLIN, No. 60838
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 10/06/12 4:49 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; laurap@nvbar.org;
    barcounseloversightcommission@gmail.com; tsusich@nvdetr.org
    Dear Bar Counsel, Clerk of Court of the SBN, and Chairman Susich,
    Please let me know if you must have my physical address ( I have indicated that due to my being a
    domestic violence victim (I was granted two protection orders) and the fact that local law enforcement
    obviously enjoys playing "kick the can" with me (and given the complete paucity of support from the
    SBN, etc., I would rather just meet your process server somewhere or have you sent whatever it is you
    want to serve via certified mail. However, Bar Counsel King has already, in writing, stipulated to an
    extension to file and answer or response to whatever it the SBN wishes to serve as far out as 20 days
    from the September 25th, 2012 date that Mr. King purports to have served my on (Please see that
    written indication below, which I am relying upon, in addition to the various statements made by Clerk
    of Court Peters), and provide me an indication, via email, or fax, preferably (I prefer communications
    that bare digital stamping and content reproduction and do not understand why the SBN is not an
    electronic filer) if my understanding is incorrect. Please note again my request that the hearing called
    for by the Court's June 7th, 2012 ORder and SCR 111(8) and SCR 102(4)(d) and any
    Proceeding/Hearing?Trial that would stem from a SCR 102 or SCR 105 Complaint by the SBN, as a
    complainant, be bifurcated, and not consolidated, given the basic due process notions of fairness that
    would be violated by so consolidating such. Please provide a response in writing detailing the SBN and
    NNDB's position with respect to the legal foundation for your claim that either the Court's June 7th,
    2012 Order or something in the SCR's allows for such a "consolidation".
    000467
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Date: Fri, 5 Oct 2012 09:43:15 -0700
    From: efiling@nvcourts.nv.gov
    To: zachcoughlin@hotmail.com
    Subject: Notification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Oct 05 2012 09:43 a.m.
    Date and Time of
    Notice:
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed
    Filed Proof of Service Proof of Service of Petition on Bar Counsel and
    Docket Text:
    000468
    the NNDB
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-
    Filing website. Click here to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The
    time to respond to the document, if required, is computed from the date and time of this notice.
    Refer to NEFR 9(f) for further details.
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the
    document must serve a copy of the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any
    questions, contact the Nevada Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    otification of Electronic Filing in IN RE: DISCIPLINE OF ZACHARY COUGHLIN, No. 60838
    efiling@nv courts.nv.g ov
    10/05/12
    Reply

    Add to contacts
    To zachcoughlin@hotmail.com
    From: efiling@nvcourts.nv.gov
    Sent: Fri 10/05/12 9:43 AM
    To: zachcoughlin@hotmail.com
    Supreme Court of Nevada
    NOTICE OF ELECTRONIC FILING
    Notice is given of the following activity:
    Date and Time of Notice: Oct 05 2012 09:43 a.m.
    000469
    Case Title: IN RE: DISCIPLINE OF ZACHARY COUGHLIN
    Docket Number: 60838
    Case Category: Original Proceeding
    Document Category: Proof of Service
    Submitted by: Zachary Barker Coughlin, Esq.
    Official File Stamp: Oct 05 2012 09:42 a.m.
    Filing Status: Accepted and Filed
    Docket Text: Filed Proof of Service Proof of Service of Petition on Bar Counsel and the NNDB
    The Clerk's Office has filed this document. It is now available on the Nevada Supreme Court's E-Filing website.
    Clickhere to log in to Eflex and view the document.
    Electronic service of this document is complete at the time of transmission of this notice. The time to respond to the
    document, if required, is computed from the date and time of this notice. Refer to NEFR 9(f) for further details.
    Clerk's Office has electronically mailed notice to:
    Zachary Coughlin
    No notice was electronically mailed to those listed below; counsel filing the document must serve a copy of
    the document on the following:
    Patrick King
    This notice was automatically generated by the electronic filing system. If you have any questions, contact the Nevada
    Supreme Court Clerk's Office at 775-684-1600 or 702-486-9300.
    RE: citation to legal authority?
    To see messages related to this one, group messages by conversation.
    Patrick King
    9/25/12

    Reply
    Add to contacts
    To Zach Coughlin, David Clark
    From: Patrick King (PatrickK@nvbar.org)
    Sent: Tue 9/25/12 10:49 AM
    To: Zach Coughlin (zachcoughlin@hotmail.com)
    Cc: David Clark (DavidC@nvbar.org)
    000470
    September 25, 2012
    Good Morning Mr. Coughlin,
    This morning you were served with the Disciplinary Complaint, for Case No: NG12-0204, NG12-0435 and NG 12-
    0434.
    A verified Response or Answer to this Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada, 9456
    Double R. Blvd, Ste. B, Reno, Nevada 89521 within 20 days. The Procedure regarding service is addressed in SCR 109.
    The reason I have requested your physical address is to facilitate our ability to contact you. The mail that was
    sent to you via certified mail was returned to the State Bar as unclaimed.
    Patrick King, Assistant Bar Counsel
    FW: motion to dismiss attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 10/06/12 4:36 AM
    To: patrickk@nvbar.org; laurap@nvbar.org; tsusich@nvdetr.org
    1 attachment
    sbn v coughlin motion to dismiss.pdf (80.5 KB)
    Dear Bar Counsel,
    Please note that the Motion to Dismiss that I filed in SBN v. Coughlin, on September
    17th, 2012, has gone unopposed, and therefore, should be granted...Mr. King was
    telling me the other day: "Zach, you don't take responsibility for your actions and that is
    why things don't work out for you..." I wonder, does Mr. King take responsibility for
    his actions here, or lack thereof, in failing to oppose my Motion to Dismiss? It will be
    interesting to see.
    000471
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; tsusich@nvdetr.org
    Subject: motion to dismiss attached
    Date: Mon, 17 Sep 2012 23:59:42 -0700
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000472
    Print Close
    more courtesy copies
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent:
    To:
    Wed 10/03/12 9:35 AM
    patrickk@nvbar.org; laurap@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org
    1 attachment
    proof of service of 8 13 12 In Re Coughlin Petiton for Dissolution of Temporary Suspension on
    Susich NNDB King Clark Peters SBN.pdf (300.6 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    my physical address
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/03/12 9:31 AM
    To: patrickk@nvbar.org; laurap@nvbar.org
    Dear Bar Counsel King and Court Clerk Peters,

    I would prefer not to give my physical address given that I am a victim of domestic violence and
    have also been subject to quite a few attacks by law enforcement this year. I will provide it if you
    write back demanding it, as I want to cooperate, but could we arrange for me to accept service by
    certified mail of anything you wish to serve me? Or I could meet your process server somewhere?

    000473
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    courtesy copies of what was filed today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 10/03/12 9:29 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; laurap@nvbar.org
    2 attachments
    contempt scr 119(2) in re coughlin 61426.pdf (297.0 KB) , contempt scr 119(2) in re coughlin
    60838.pdf (297.0 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    problem with the file in RCR2011-063341
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 10/02/12 10:25 PM
    To: stuttle@washoecounty.us; zyoung@da.washoecounty.us; bdogan@washoecounty.us;
    jleslie@washoecounty.us; jbosler@washoecounty.us; jgoodnight@washoecounty.us; davidc@nvbar.org;
    rjcweb@wasoecounty.us; rbaker@washoecounty.us; kstancil@washoecounty.us;
    lgray@washoecounty.us; ltibbals@washoecounty.us; patrickk@nvbar.org; laurap@nvbar.org
    000474
    Dear Clerk of Court Tuttle,

    Today, I was reviewing my file in RCR 2011-063341 and found that a half sheet of paper directed
    towards the extent to whether or not the August 29th, 2012 court date was merely for a Hearing on
    the Motion to Suppress, or, in fact, a "Trial" date, especially in relation to the Order as rendered by
    Judge Sferrazza at the previous Trial date on July 16th, 2011. I maintain that the August 29th,
    2012 date was never intended to be a "Trial" date, and that Judge Sferrazza rendered such an Order
    on July 16th, 2012, something I have bitterly disagreed with my public defender, Jim Leslie about,
    and whom was not present on July 16th, 2012 (Jeremy Bosler showed up for Joe Goodnight that
    Monday morning, despite the fact that Joe had videoconferenced with my at 4pm on the previous
    Friday and indicated he would be there the following Monday morning for Trial...only to have Bosler
    show up out of the blue, refuse to tell me why Joe was taken off the case, then force Jim Leslie on
    me, whom I have not gotten along with at all since he and I first me in October of 2011. Anyways,
    the half sheet of paper in the file that I am referring to also had two handwritten post-it notes
    curiously attached to the back of it (only a truly obsessive person would have noticed this, and
    unfortunately for some involved here...) that spoke to all three of the matters, in handwritten notation
    of my three cases RCR2011-065630, RCR2012-067980, and RCR2012-065630) as well as the extent
    to which the August 29th, 2012 date would, in fact be a trial. I am placing you non a
    LITIGATION HOLD NOTICE with respect to the positioning and orientation and content of that half
    sheet of paper and those two post-it notes in that file for RCR2011-063341, especially with respect to
    the fact that it was placed before the May 2012 filings and documentation in that matter...whic is
    awfully curious given the extent to which that setting has become a subject of debate and the fact that
    the post its and that half sheet were only created, necessarily, after the July 16th, 2012 Trial in
    RCR2011-063341, that was continued, and in the hallway, at the RJC counter, after I had been
    returned to custody, in response to Judge Sferrazza's indication on the record that DDA Young and
    Jim Leslie shoudl meet and confer in the hallway, off the record, and pick a date for the Hearing on
    the the Motion to Suppress (as Judge Sferrazza pointed out it would not be prudent to force Trial
    Witnesses to show up on August 29th, 2011 should Coughlin's Motion to Suppress be granted, in
    which case a Trial would likely be unnecessary). While I am not telling you I have a picture or
    other documentation of the placement and content of this half sheet of paper and two post-it notes in
    the file in RCR2011-063341, I am placing the RJC ON A LITIGATION HOLD NOTICE with
    respect to the matters detailed herein and politely requesting that you provide me with some such
    proof thereof.

    Further problematic in that file is the extent to which the docket misdates several key filings,
    especially where the misdating is helpful to DDA Youngs case and the defense of any professional
    misconduct violation he ultimately may need defend against. To wit, the Amended Criminal
    Complaint is listed as having a filing date of August 24th, 2011, while the Amended Criminal
    Complaint was actually filed December 5th, 2011, an in my estimation was only filed in retaliation
    (and the charge added violates RPC 3.8 in that it lacks probable cause and is also likely duplicative
    and or presenting a "double jeopardy" violation) to the Motion for Sanctions I filed, or attempted to
    file, on or about November 26th, 2011. I ask that the docket be corrected in that regard. Further,
    upon broaching the subject of the extent to which Judge Sferrazza had already rendered an Order
    specifying the August 29th, 2012 court date as merely devoted to a Hearing on the Motion to
    Suppress, Judge Sferrazza (in addressing my due process concerns for the lack of notice attendant to
    Jim Leslie apparently converting it to a hurry up Trial) alleged to have entered an "Order" on August
    000475
    9th,2012 (very soon after, coincidentally to the August 6th, 2012 Hearing for which the Public
    Defender's Office, in either Leslie or Biray Dogan (counsel for me, along with Leslie, apparently, in
    RCR2012-065630 completely failed to notice me on in any way...likely due to the date picked by
    DDA Young and Mr. Bosler in the hallway after I was taken back into custody not being noticed to
    me in the customary manner of a tear off slip of paper from a public defender and also where Jim
    Leslie's legal assistant, Linda Gray, has admitted to me that no notice was mailed to me respecting
    the August 6th, 2012 Hearing in RCR2012-067980 and RCR2012-065630 in light of her Office's
    mistaken belief that PO BOX 3961, Reno, NV 89505 was no longer my "valid address". I never
    made any indication that my address had changed, and the Public Defender's Office failed to mail me
    notice or provide a tear off slip regarding the hearing date picked by Bosler and Young and curiously
    buried in the filed the records thereof in RCR2011-063341, with post-it notes placed on the back of a
    half sheet of paper.) Respecting the alleged Order or "Notice" that Judge Sferrazza mentioned
    entering on August 9th, 2012, which he indicated made clear specified or clarified that the August
    29th, 2012 court date was indeed a Trial date, I saw that "Order" or "Notice" today upon reviewing
    the file. It was a post-it note, handwritten, attached to my February 14th, 2012 (filed stamped
    February 15th, 2012) Pre-Trial Motions filing (consisting of 101 pages of the Pre-Trial Motion and
    77 pages worth of Exhibit 1). I asked for the filing office clerk to make me copies of certain things
    from the file today, yet the half page with two post-it notes affixed to the back of the half page I refer
    to above were not copied or included by the clerk despite her agreeing to copy the pages I marked for
    copying, and the cover page of my February 14th (filestamped February 15th, 2012) Pre-Trial
    Motion, with Judge Sferrazza's August 9th, 2012 "Notice" (as listed in the Docket for RCR2011-
    063341 under August 9th, 2012, as a "Notice") were note copied for me. The RJC Bailiffs rushed
    me along and told me you had entered an Order limiting my access to justice to ten minutes, even
    where there was no other individuals in the line at the filing office, and where I protested that the the
    most salient and materials pages of those few I requested copied, were curiously missing. I ask that
    the RJC please fax or email me the half page with two post it notes on the back thereof (placed
    before the May 2012 filings in RCR2011-063341 that I refer to above) in addition to th August 9th,
    2011 "Notice" by Judge Sferrazza (on a post-it handwritten note on the cover page of my February
    15th, 2012 filestamped Pre-Trial Motion). Incidentally, that August 9th, 2012 dated post-it
    handwritten note did not specify that the August 29th, 2012 court date was for a Trial, it merely
    indicated that my February 15th, 2012 Pre-Trial Motion would be disposed of along with other pre-
    trial motions on August 29th, 2012, just as Judge Sferrazza rendered in an Order on the record, on
    July 16th, 2012 in RCR2011-063341.

    I am requesting the RJC provide me a copy of or retain under a LITIGATION HOLD NOTICE
    the audio and any records of the August 6th, 2011 "combo hearing" (my public defenders think so
    much of the MSC rules that they combo-pack mine, two and three cases at a time, in hearings that
    they don't even notice me on in any way...) Dogan and Leslie refuse to provide me a copy of the
    audio for that hearing, and Leslie provides evasive answers as to whether Dogan was even at that
    combo-hearing, while Dogan indicates the hearing did not occur in a court room (much like my
    September 10th, 2011 hearing in RCR2011-063341, where Carl Hylin, through a "counter motion"
    obtained an Order for Competency Evaluation that purported to be entered in response to a "motion
    by counsel".
    Lastly, Birary Dogan and DDA Young. Further, Jim Leslie refused to reset or vacate the
    September 18th, 2012 Trial date he set on August 6th, 2012 in RCR2012-067980 despite it being
    clear that his Office failed to send me any notice of the August 6th court date in that case, and it was
    000476
    only due to Mr. Leslie's attempt to buy some time to figure out how to get out of the malpractice and
    professional misconduct stew he has created, some might say, in RCR2011-063341 by way of
    having me subjected to a third Order for Competency Evaluation that I was able to avoid going to
    trial on that "false statement to a public officer" charge in RCR2012-067980, which involved an
    alleged failure on my part to do something or some alleged false statement I made while having the
    metal overhead door to my rental at 1680 Sky Mountain Drive saw-zalled open by Deputy Machen of
    the WCSO, in connection with an Summary Eviction Order that was issued despite my advance
    notice to the RJC that I submitted for filing a Tenant's Affidavit or Answer in Sparks Justice Court in
    light of the specifying of the forum for the Tenant to file such a tenant's answer (as required by law
    under NRS 40.253, the landlord or his "agent" must set forth the forum to file a Tenant's Answer in
    the 5 day Notice for Unlawful Detainer, found in the attached emails below to the RJC, and Chief
    Civil Clerk Stancil, wherein such defective a 5 day notice was drafted by one committing the
    unauthorized practice of law for Nevada Court Services, and "eviction consulting and process
    service" business comprised of non-laywers who dress up like Sheriffs, and even cross the bar and
    argue before RJC Judges, like in RJC Rev2012-001048. Oh, and there is the fact that Nevada
    Court Services process server, R. Wray, filed a false affidavit, attesting to personally serving me a 5
    day unlawful detainer notice on June 14th, 2012 when he was met only with a metal garage door
    and a room with no windows to serve the Notice to. R. Wray's lying in a sworn affidavit cut
    short by 3 days my time to file a Tenant's Affidavit (and arguably, given the listing of Sparks
    Justice Court as the forum to file the Notice, I didn't even need file one in the RJC). And, in
    light of my chosen profession and the dictates of SCR 111(6), even a misdemeanor like "false
    statement to a public officer", even in the context of such a retaliatory prosecution devoid of probable
    cause and based upon a void Summary Eviction Order, or one that should have declared void to the
    extent the RJC Judge presiding over the Hearing on the Motion to Set Aside said Order indicated
    today that such matters are only properly determined by the Legislature...well, a conviction in that
    matter, would likely end my law career. And Jim Leslie describes his decision to not seek to
    vacate or reset the September 17th, 2012 Trial date in that case, RCR2012-067980, which he made
    on August 6th, 2012 at a combo-pack MSC that his assistant Linda Gray admits I was not provided
    notice of in any way, as an "executive decision" that he made.

    One last thing, the docket in RCR2011-063341 is further incorrect in that it fails to detail the extent
    to which DDA Young violated NRS 178.405 by filing, with a filestamp time of 2:55 pm an
    Opposition to Defendant's Motion to Appear as Co-Counsel despite the fact that DDA Young and
    my public defender Biray Dogan, in RCR2012-065630 met in a clandestine status conference on
    February 27th, 2012 at 1:30 pm, despite the fact that on February 24th, 2012 (and the files documents
    this as well) that very MSC was continued until March 29th, 2012 in light of a scheduling conflict
    attendant to the fact that I had a traffic citation trial involving myself in the RMC on that very day,
    February 27th, 2012 in 11 TR 26800 set for 1:00 pm. Judge Nash Holmes admits to
    communications with those involved in that clandestine, unnoticed, violating of attorney client
    privelege, February 27th, 2012 MSC in RCR2012-065630 involving Dogan and DDA Young.
    However, that did not, apparently, despite the dicates of NRS 178.405, stop Judge Nash Holmes from
    continuing on with the traffic citation Trial minutes later in 11 TR 26800, wherein she sentenced me
    to 5 days in jail, and denied a stay to me despite my then representing client's as a lawyer in time
    sensitive matters, finding me guilty of "summary criminal contempt" (which I had to report to the
    United States Patent and Trademark Office and State Bar of Nevada as a SCR 111 criminal
    000477
    conviction). PLEASE BE AWARE I AM PLACING YOU AND THE RJC ON A
    LITIGATION HOLD NOTICE WITH RESPECT TO ANY MATERIALS BARING IN ANY WAY
    ON THAT CLANDESTINE FEBRUARY 27TH, 2012 STATUS CONFERENCE INVOLVING
    DDA YOUNG AND BIRAY DOGAN. Curiously, the Order for Competency Evaluation was
    signed by Judge Clifton, but the RJC's file and docket therein indicate that Judge Schroeder presided
    over the 2/27/12 1:30 pm Status Conference, despite the fact that the files indicates such a conference
    was reset, on 2/24/12 to 3/29/12...I have ordered the audio from that 2/27/12 1:30 pm status
    conference in RCR2012-065630 from the RJC, yet it has not been provided. Please email it to me
    or provide it otherwise. Speaking of the extent to which Judge Nash Holmes continued on to
    conduct the Trial in 11 TR 26800 despite the 2/29/12 Order for Competency Evaluation signed by
    Judge Clifton and file stamped 1:31 pm, despite the statutory dictate that "the other departments"
    "shall suspend any other proceedings relating to the defendant until to defendant is determined to be
    competent", found in NRS 178.405, DDA Young himself violated NRS 178.405 in that his 2/29/12
    Opposition to Defendant's Motion to Appear as Co-counsel bares a file stamp of 2:55 pm.
    Please correct the docket in this regard, as well as revising it to reflect all of my filings, which were
    all file stamped, yet are not indicated on the docket, especially the Notice of Appearance I filed,
    while I was still a licensed attorney, in addition to any Substitutions of Counsel I filed so very long
    ago (no matter what DDA Young tries to argue about how "untimely" my attempts to be rid of the
    public defenders obstructive presence are).

    Sincerely,

    Zach Coughlin
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    000478
    FW: Reno eviction noticed for Sparks Justice Court

    7/02/12

    Zach CoughlZach Coughlin


    zachcoughlin@hotmail.com

    To kbrown@nvbar.org, milllerr@reno.gov, millerr@reno.gov, stuttle@washoecounty.gov,


    rsilva@washoecounty.us, stuttle@washoecounty.us, jamchen@washoecounty.us, 037nor4@acg.com, info@acg-
    apmi.com, rjcweb@wasoecounty.us, jboles@callatg.com, apminfo@acg.com
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 7/02/12 5:21 PM
    kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov;
    To: rsilva@washoecounty.us; stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com;
    info@acg-apmi.com; rjcweb@wasoecounty.us; jboles@callatg.com; apminfo@acg.com

    2 attachments (total 1164.6 KB)

    combined ...pdf
    Download(1086.2 KB)
    Download all as zip
    NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on
    July 29th, 2012"...giving me five days to get my stuff out of unit 29 (the one the subject of Judge
    Schroeer's Eviction Order, which was effectively rescinded by their serving a new 5 day unlawful
    detainer notice....) as well as units 71 and 45...whicih are two units to which i still have valide lease
    agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated they will arrest
    me for criminal trespass for accessing any units in the complex, including those to which I still have
    a valid possessory or property interest, in violation of 42 usc 1983).
    why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel"
    good looks and a much higher paying job than I will ever have? What up wit that?
    Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed
    up and put "Sparks Justice Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer
    or Affidavit. Doing so will make the RJC Order by Judge Schroeder null and void (Karen Stancil,
    Chief Civil Clerk at RJC admits this, but really, the fault lies with NCS and Northwind, not the
    000479
    6
    committed professional at the RJC).
    The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe
    where they have a valid reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.
    In
    Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
    predecessor statute to NRS 40.2516 to mean that the alternative five (5) day notice must be given
    before the tenants can be dispossed and a lease can be validly terminated. The court stated that this
    five (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
    ttp://www.constitution.org/ussc/506-056a.htm
    U.S. Supreme Court
    SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
    506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
    CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
    SEVENTH CIRCUIT
    No. 91-6516
    Argued October 5, 1992
    Decided December 8, 1992
    While eviction proceedings were pending, Terrace Properties and Margaret Hale forcibly evicted
    petitioners, the Soldal family, and their mobile home from a Terrace Properties' mobile home park.
    At Hale's request, Cook County, Illinois, Sheriff's Department deputies were present at the eviction.
    Although they knew that there was no eviction order and that Terrace Properties' actions were illegal,
    the deputies refused to take Mr. Soldal's complaint for criminal trespass or otherwise interfere with
    the eviction. Subsequently, the state judge assigned to the pending eviction proceedings ruled that the
    eviction had been unauthorized, and the trailer, badly damaged during the eviction, was returned to
    the lot. Petitioners brought an action in the Federal District Court under 42 U.S.C. 1983, claiming
    that Terrace Properties and Hale had conspired with the deputy sheriffs to unreasonably seize and
    remove their home in violation of their Fourth and Fourteenth Amendment rights. The court granted
    defendants' motion for summary judgment, and the Court of Appeals affirmed. Acknowledging that
    what had occurred was a "seizure" in the literal sense of the word, the court reasoned that it was not a
    seizure as contemplated by the Fourth Amendment because, inter alia, it did not invade petitioners'
    privacy.
    Held:
    The seizure and removal of the trailer home implicated petitioners' Fourth Amendment rights. Pp. 61-
    72.
    (a) A "seizure" of property occurs when "there is some meaningful interference with an
    000480
    individual's possessory interests in that property." United States v. Jacobsen, 466 U.S.
    109, 113 . The language of the Fourth Amendment - which protects people from
    unreasonable searches and seizures of "their persons, houses, papers, and effects" - cuts
    against the novel holding below, and this Court's cases unmistakably hold that the
    Amendment protects property even where privacy or liberty is not implicated. See, e.g.,
    ibid.; Katz v. United States, 389 U.S. 347, 350 . This Court's "plain view" decisions also
    make untenable the lower court's construction of the Amendment. If the Amendment's
    boundaries were defined exclusively by rights of privacy, "plain view" seizures, rather
    than being scrupulously subjected to Fourth Amendment inquiry, Arizona v. Hicks, 480
    U.S. 321, 326 -327, would not implicate that constitutional provision at all. Contrary to
    the Court of Appeals' [506 U.S. 56, 57] position, the Amendment protects seizure even though
    no search within its meaning has taken place. See, e.g., Jacobsen, supra, at 120-125. Also
    contrary to that court's view, Graham v. Connor, 490 U.S. 386 , does not require a court,
    when it finds that a wrong implicates more than one constitutional command, to look at
    the dominant character of the challenged conduct to determine under which constitutional
    standard it should be evaluated. Rather, each constitutional provision is examined in
    turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp. 61-71.
    (b) The instant decision should not foment a wave of new litigation in the federal courts.
    Activities such as repossessions or attachments, if they involve entering a home, intruding
    on individuals' privacy, or interfering with their liberty, would implicate the Fourth
    Amendment even on the Court of Appeals' own terms. And numerous seizures of this type
    will survive constitutional scrutiny on "reasonableness" grounds. Moreover, it is unlikely
    that the police will often choose to further an enterprise knowing that it is contrary to the
    law, or proceed to seize property in the absence of objectively reasonable grounds for
    doing so. Pp. 71-72.
    942 F.2d 1073, reversed and remanded.
    WHITE, J., delivered the opinion for a unanimous Court.
    John L. Stainthorp argued the cause and filed briefs for petitioners.
    Kenneth L. Gillis argued the cause for respondents. With him on the brief were Jack O'Malley, Renee
    G. Goldfarb, and Kenneth T. McCurry. [*]
    [ Footnote *] James D. Holzhauer, Timothy S. Bishop, John A. Powell, Steven R. Shapiro, Harvey
    M. Grossman, and Alan K. Chen filed a brief for the American Civil Liberties Union et al. as amici
    curiae urging reversal.
    Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad filed a brief for the National
    League of Cities et al. as amici curiae urging affirmance.
    JUSTICE WHITE delivered the opinion of the Court.
    I
    Edward Soldal and his family resided in their trailer home, which was located on a rented lot in the
    Willoway Terrace mobile [506 U.S. 56, 58] home park in Elk Grove, Illinois. In May 1987, Terrace
    Properties, the owner of the park, and Margaret Hale, its manager, filed an eviction proceeding
    against the Soldals in an Illinois state court. Under the Illinois Forcible Entry and Detainer Act,
    Ill.Rev.Stat., ch. 110, 9-101 et seq. (1991), a tenant cannot be dispossessed absent a judgment of
    eviction. The suit was dismissed on June 2, 1987. A few months later, in August 1987, the owner
    000481
    brought a second proceeding of eviction, claiming nonpayment of rent. The case was set for trial on
    September 22, 1987.
    Rather than await judgment in their favor, Terrace Properties and Hale, contrary to Illinois law, chose
    to evict the Soldals forcibly two weeks prior to the scheduled hearing. On September 4, Hale notified
    the Cook County's Sheriff's Department that she was going to remove the trailer home from the park,
    and requested the presence of sheriff deputies to forestall any possible resistance. Later that day, two
    Terrace Properties employees arrived at the Soldals' home accompanied by Cook County Deputy
    Sheriff O'Neil. The employees proceeded to wrench the sewer and water connections off the side of
    the trailer home, disconnect the phone, tear off the trailer's canopy and skirting, and hook the home to
    a tractor. Meanwhile, O'Neil explained to Edward Soldal that "`he was there to see that [Soldal]
    didn't interfere with [Willoway's] work.'" Brief for Petitioner 6.
    By this time, two more deputy sheriffs had arrived at the scene, and Soldal told them that he wished
    to file a complaint for criminal trespass. They referred him to deputy Lieutenant Jones, who was in
    Hale's office. Jones asked Soldal to wait outside while he remained closeted with Hale and other
    Terrace Properties employees for over 20 minutes. After talking to a district attorney and making
    Soldal wait another half hour, Jones told Soldal that he would not accept a complaint because "`it
    was between the landlord and the tenant ... [and] they were going to go ahead and continue to move
    [506 U.S. 56, 59] out the trailer.'" Id., at 8. 1 Throughout this period, the deputy sheriffs knew that Terrace
    Properties did not have an eviction order and that its actions were unlawful. Eventually, and in the
    presence of an additional two deputy sheriffs, the Willoway workers pulled the trailer free of its
    moorings and towed it onto the street. Later, it was hauled to a neighboring property.
    On September 9, the state judge assigned to the pending eviction proceedings ruled that the eviction
    had been unauthorized, and ordered Terrace Properties to return the Soldals' home to the lot. The
    home, however, was badly damaged.
    [2]
    The Soldals brought this action under 42 U.S.C. 1983,
    alleging a violation of their rights under the Fourth and Fourteenth Amendments. They claimed that
    Terrace Properties and Hale had conspired with Cook County deputy sheriffs to unreasonably seize
    and remove the Soldals' trailer home. The District Judge granted defendants' motion for summary
    judgment on the grounds that the Soldals had failed to adduce any evidence to support their
    conspiracy theory and, therefore, the existence of state action necessary under 1983.
    [3]
    The Court of Appeals for the Seventh Circuit, construing the facts in petitioners' favor, accepted their
    contention that there was state action. However, it went on to hold that [506 U.S. 56, 60] the removal of
    the Soldals' trailer did not constitute a seizure for purposes of the Fourth Amendment or a deprivation
    of due process for purposes of the Fourteenth.
    On rehearing, a majority of the Seventh Circuit, sitting en banc, reaffirmed the panel decision.
    [4]
    Acknowledging that what had occurred was a "seizure" in the literal sense of the word, the court
    reasoned that, because it was not made in the course of public law enforcement, and because it did
    not invade the Soldals' privacy, it was not a seizure as contemplated by the Fourth Amendment. 942
    F.2d 1073, 1076 (1991). Interpreting prior cases of this Court, the Seventh Circuit concluded that,
    absent interference with privacy or liberty, a "pure deprivation of property" is not cognizable under
    the Fourth Amendment. Id., at 1078-1079. Rather, petitioners' property interests were protected only
    by the Due Process Clauses of the Fifth and Fourteenth Amendments.
    [5]
    We granted certiorari to consider whether the seizure and removal of the Soldals' trailer home
    implicated their Fourth Amendment rights, 503 U.S. 918 (1992), and now reverse.
    [6]
    [506 U.S. 56, 61]
    II
    000482
    The Fourth Amendment, made applicable to the States by the Fourteenth, Ker v. California, 374 U.S.
    23, 30 (1963), provides in pertinent part that the "right of the people to be secure in their persons,
    houses, papers, and effects, against unreasonable searches and seizures, shall not be violated... ."
    A "seizure" of property, we have explained, occurs when "there is some meaningful interference with
    an individual's possessory interests in that property." United States v. Jacobsen, 466 U.S. 109, 113
    (1984). In addition, we have emphasized that "at the very core" of the Fourth Amendment "stands the
    right of a man to retreat into his own home." Silverman v. United States, 365 U.S. 505, 511 (1961).
    See also Oliver v. United States, 466 U.S. 170, 178 -179 (1984); Wyman v. James, 400 U.S. 309,
    316 (1971); Payton v. New York, 445 U.S. 573, 601 (1980).
    As a result of the state action in this case, the Soldals' domicile was not only seized, it literally was
    carried away, giving new meaning to the term "mobile home." We fail to see how being
    unceremoniously dispossessed of one's home in the manner alleged to have occurred here can be
    viewed as anything but a seizure invoking the protection of the Fourth Amendment. Whether the
    Amendment was in fact [506 U.S. 56, 62] violated is, of course, a different question that requires
    determining if the seizure was reasonable. That inquiry entails the weighing of various factors, and is
    not before us.
    The Court if Appeals recognized that there had been a seizure, but concluded that it was a seizure
    only in a "technical" sense, not within the meaning of the Fourth Amendment. This conclusion
    followed from a narrow reading of the Amendment, which the court construed to safeguard only
    privacy and liberty interests, while leaving unprotected possessory interests where neither privacy nor
    liberty was at stake. Otherwise, the court said,
    "a constitutional provision enacted two centuries ago [would] make every repossession and
    eviction with police assistance actionable under - of all things - the Fourth Amendment[,
    which] would both trivialize the amendment and gratuitously shift a large body of routine
    commercial litigation from the state courts to the federal courts. That trivializing, this
    shift, can be prevented by recognizing the difference between possessory and privacy
    interests." 942 F.2d, at 1077.
    Because the officers had not entered Soldal's house, rummaged through his possessions, or, in the
    Court of Appeals' view, interfered with his liberty in the course of the eviction, the Fourth
    Amendment offered no protection against the "grave deprivation" of property that had occurred. Ibid.
    We do not agree with this interpretation of the Fourth Amendment. The Amendment protects the
    people from unreasonable searches and seizures of "their persons, houses, papers, and effects." This
    language surely cuts against the novel holding below, and our cases unmistakably hold that the
    Amendment protects property as well as privacy.
    [7]
    This much [506 U.S. 56, 63] was made clear in
    Jacobsen, supra, where we explained that the first Clause of the Fourth Amendment
    "protects two types of expectations, one involving "searches," the other "seizures." A
    "search" occurs when an expectation of privacy that society is prepared to consider
    reasonable is infringed. A "seizure" of property occurs where there is some meaningful
    interference with an individual's possessory interests in that property." 466 U.S., at 113
    (footnote omitted).
    See also id., at 120; Horton v. California, 496 U.S. 128, 133 (1990); Arizona v. Hicks, 480 U.S. 321,
    000483
    328 (1987); Maryland v. Macon, 472 U.S. 463, 469 (1985); Texas v. Brown, 460 U.S. 730, 747 -748
    (1983) (STEVENS, J., concurring in judgment); United States v. Salvucci, 448 U.S. 83, 91 , n. 6
    (1980). Thus, having concluded that chemical testing of powder found in a package did not
    compromise its owner's privacy, the Court in Jacobsen did not put an end to its inquiry, as would be
    required under the view adopted by the Court of Appeals and advocated by respondents. Instead,
    adhering to the teachings of United States v. Place, 462 U.S. 696 (1983), it went on to determine
    whether the invasion of the owners' "possessory interests" occasioned by the destruction of the
    powder was reasonable under the Fourth Amendment. Jacobsen, supra, at 124-125. In Place, although
    we found that subjecting luggage to a "dog sniff" did not constitute a search for Fourth Amendment
    purposes because it did not compromise any privacy interest, taking custody of Place's suitcase was
    deemed an unlawful seizure, for it unreasonably infringed "the suspect's possessory interest in his
    luggage." 462 U.S., at 708 . 8 Although lacking a privacy component, the property rights in both
    instances nonetheless were not [506 U.S. 56, 64] disregarded, but rather were afforded Fourth Amendment
    protection.
    Respondents rely principally on precedents such as Katz v. United States, 389 U.S. 347 (1967),
    Warden, Maryland Penitentiary v. Hayden, 387 U.S. 294 (1967), and Cardwell v. Lewis, 417 U.S.
    583 (1974), to demonstrate that the Fourth Amendment is only marginally concerned with property
    rights. But the message of those cases is that property rights are not the sole measure of Fourth
    Amendment violations. The Warden opinion thus observed, citing Jones v. United States, 362 U.S.
    257 (1960), and Silverman v. United States, 365 U.S. 505 (1961), that the "principal" object of the
    Amendment is the protection of privacy, rather than property, and that "this shift in emphasis from
    property to privacy has come about through a subtle interplay of substantive and procedural reform."
    387 U.S., at 304 . There was no suggestion that this shift in emphasis had snuffed out the previously
    recognized protection for property under the Fourth Amendment. Katz, in declaring violative of the
    Fourth Amendment the unwarranted overhearing of a telephone booth conversation, effectively ended
    any lingering notions that the protection of privacy depended on trespass into a protected area. In the
    course of its decision, the Katz Court stated that the Fourth Amendment can neither be translated into
    a provision dealing with constitutionally protected areas nor into a general constitutional right to
    privacy. The Amendment, the Court said, protects individual privacy against certain kinds of
    governmental intrusion, "but its protections go further, and often have nothing to do with privacy at
    all." 389 U.S., at 350 .
    As for Cardwell, a plurality of this Court held in that case that the Fourth Amendment did not bar the
    use in evidence of paint scrapings taken from and tire treads observed on the defendant's automobile,
    which had been seized in a parking lot and towed to a police lockup. Gathering this evidence was not
    deemed to be a search, for nothing from the [506 U.S. 56, 65] interior of the car and "no personal effects,
    which the Fourth Amendment traditionally has been deemed to protect" were searched or seized. 417
    U.S., at 591 (opinion of BLACKMUN, J.). No meaningful privacy rights were invaded. But this left
    the argument, pressed by the dissent, that the evidence gathered was the product of a warrantless, and
    hence illegal, seizure of the car from the parking lot where the defendant had left it. However, the
    plurality was of the view that, because, under the circumstances of the case, there was probable cause
    to seize the car as an instrumentality of the crime, Fourth Amendment precedent permitted the seizure
    without a warrant. Id., at 593. Thus, both the plurality and dissenting Justices considered the
    defendant's auto deserving of Fourth Amendment protection even though privacy interests were not at
    stake. They differed only in the degree of protection that the Amendment demanded.
    The Court of Appeals appeared to find more specific support for confining the protection of the
    Fourth Amendment to privacy interests in our decision in Hudson v. Palmer, 468 U.S. 517 (1984).
    000484
    There, a state prison inmate sued, claiming that prison guards had entered his cell without consent
    and had seized and destroyed some of his personal effects. We ruled that an inmate, because of his
    status, enjoyed neither a right to privacy in his cell nor protection against unreasonable seizures of his
    personal effects. Id., at 526-528, and n. 8; id., at 538 (O'CONNOR, J., concurring). Whatever else the
    case held, it is of limited usefulness outside the prison context with respect to the coverage of the
    Fourth Amendment.
    We thus are unconvinced that any of the Court's prior cases supports the view that the Fourth
    Amendment protects against unreasonable seizures of property only where privacy or liberty is also
    implicated. What is more, our "plain view" decisions make untenable such a construction of the
    Amendment. Suppose, for example, that police officers lawfully enter a house, by either complying
    with the warrant requirement or satisfying one of its recognized exceptions - [506 U.S. 56, 66] e.g.,
    through a valid consent or a showing of exigent circumstances. If they come across some item in
    plain view and seize it, no invasion of personal privacy has occurred. Horton, 496 U.S., at 133 -134;
    Brown, supra, at 739 (opinion of REHNQUIST, J.). If the boundaries of the Fourth Amendment were
    defined exclusively by rights of privacy, "plain view" seizures would not implicate that constitutional
    provision at all. Yet, far from being automatically upheld, "plain view" seizures have been
    scrupulously subjected to Fourth Amendment inquiry. Thus, in the absence of consent or a warrant
    permitting the seizure of the items in question, such seizures can be justified only if they meet the
    probable-cause standard, Arizona v. Hicks, 480 U.S. 321, 326 -327 (1987), 9 and if they are
    unaccompanied by unlawful trespass, Horton, 496 U.S., at 136 -137. 10 That is because, the absence
    of a privacy interest notwithstanding, "[a] seizure of the article ... would obviously invade the owner's
    possessory interest." Id., at 134; see also Brown, 460 U.S., at 739 (opinion of REHNQUIST, J.). The
    plain-view doctrine "merely reflects an application of the Fourth Amendment's central requirement of
    reasonableness to the law governing seizures of property." Ibid.; Coolidge v. New Hampshire, 403
    U.S. 443, 468 (1971); id., at 516 (WHITE, J., concurring and dissenting).
    The Court of Appeals understandably found it necessary to reconcile its holding with our recognition
    in the plain-view cases that the Fourth Amendment protects property as such. In so doing, the court
    did not distinguish this case on the ground that the seizure of the Soldals' home took place in a [506
    U.S. 56, 67] noncriminal context. Indeed, it acknowledged what is evident from our precedents - that the
    Amendment's protection applies in the civil context as well. See O'Connor v. Ortega, 480 U.S. 709
    (1987); New Jersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v. Tyler, 436 U.S. 499, 504
    -506 (1978); Marshall v. Barlow's, Inc., 436 U.S. 307, 312 -313 (1978); Camara v. Municipal Court
    of San Francisco, 387 U.S. 523, 528 (1967). 11
    Nor did the Court of Appeals suggest that the Fourth Amendment applied exclusively to law
    enforcement activities. It observed, for example, that the Amendment's protection would be triggered
    "by a search or other entry into the home incident to an eviction or repossession," 942 F.2d, at 1077.
    12 Instead, the court sought to explain why the Fourth Amendment protects against seizures of
    property in the plain-view context, but not in this case, as follows:
    "[S]eizures made in the course of investigations by police or other law enforcement
    officers are almost always, as in the plain view cases, the culmination of searches. The
    police search in order to seize, and it is the search [506 U.S. 56, 68] and ensuing seizure that
    the Fourth Amendment, by its reference to "searches and seizures," seeks to regulate.
    Seizure means one thing when it is the outcome of a search; it may mean something else
    when it stands apart from a search or any other investigative activity. The Fourth
    Amendment may still nominally apply, but, precisely because there is no invasion of
    000485
    privacy, the usual rules do not apply." Id., at 1079 (emphasis in original).
    We have difficulty with this passage. The court seemingly construes the Amendment to protect only
    against seizures that are the outcome of a search. But our cases are to the contrary, and hold that
    seizures of property are subject to Fourth Amendment scrutiny even though no search within the
    meaning of the Amendment has taken place. See, e.g., Jacobsen, 466 U.S., at 120 -125; Place, 462
    U.S., at 706 -707; Cardwell, 417 U.S., at 588 -589. 13 More generally, an officer who happens to
    come across an individual's property in a public area could seize it only if Fourth Amendment
    standards are satisfied - for example, if the items are evidence of a crime or contraband. Cf. Payton v.
    New York, [506 U.S. 56, 69] 445 U.S., at 587 . We are also puzzled by the last sentence of the excerpt,
    where the court announces that the "usual rules" of the Fourth Amendment are inapplicable if the
    seizure is not the result of a search or any other investigative activity "precisely because there is no
    invasion of privacy." For the plain-view cases clearly state that, notwithstanding the absence of any
    interference with privacy, seizures of effects that are not authorized by a warrant are reasonable only
    because there is probable cause to associate the property with criminal activity. The seizure of the
    weapons in Horton, for example, occurred in the midst of a search, yet we emphasized that it did not
    "involve any invasion of privacy." 496 U.S., at 133 . In short, our statement that such seizures must
    satisfy the Fourth Amendment and will be deemed reasonable only if the item's incriminating
    character is "immediately apparent," id., at 136-137, is at odds with the Court of Appeals' approach.
    The Court of Appeals' effort is both interesting and creative, but, at bottom, it simply reasserts the
    earlier thesis that the Fourth Amendment protects privacy, but not property. We remain unconvinced,
    and see no justification for departing from our prior cases. In our view, the reason why an officer
    might enter a house or effectuate a seizure is wholly irrelevant to the threshold question whether the
    Amendment applies. What matters is the intrusion on the people's security from governmental
    interference. Therefore, the right against unreasonable seizures would be no less transgressed if the
    seizure of the house was undertaken to collect evidence, verify compliance with a housing regulation,
    effect an eviction by the police, or on a whim, for no reason at all. As we have observed on more
    than one occasion, it would be "anomalous to say that the individual and his private property are fully
    protected by the Fourth Amendment only when the individual is suspected of criminal behavior."
    Camara 387 U.S., at 530 ; see also O'Connor, 480 U.S., at 715 ; T.L.O., 469 U.S., at 335 . [506 U.S. 56,
    70]
    The Court of Appeals also stated that, even if, contrary to its previous rulings, "there is some element
    or tincture of a Fourth Amendment seizure, it cannot carry the day for the Soldals." 942 F.2d, at
    1080. Relying on our decision in Graham v. Connor, 490 U.S. 386 (1989), the court reasoned that it
    should look at the "dominant character of the conduct challenged in a section 1983 case [to]
    determine the constitutional standard under which it is evaluated." 942 F.2d, at 1080. Believing that
    the Soldals' claim was more akin to a challenge against the deprivation of property without due
    process of law than against an unreasonable seizure, the court concluded that they should not be
    allowed to bring their suit under the guise of the Fourth Amendment.
    But we see no basis for doling out constitutional protections in such fashion. Certain wrongs affect
    more than a single right, and, accordingly, can implicate more than one of the Constitution's
    commands. Where such multiple violations are alleged, we are not in the habit of identifying, as a
    preliminary matter, the claim's "dominant" character. Rather, we examine each constitutional
    provision in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment and
    Fourteenth Amendment Due Process Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth
    Amendment and Fourteenth Amendment Due Process Clause). Graham is not to the contrary. Its
    000486
    holding was that claims of excessive use of force should be analyzed under the Fourth Amendment's
    reasonableness standard, rather than the Fourteenth Amendment's substantive due process test. We
    were guided by the fact that, in that case, both provisions targeted the same sort of governmental
    conduct and, as a result, we chose the more "explicit textual source of constitutional protection" over
    the "more generalized notion of `substantive due process.'" 490 U.S., at 394 -395. Surely, Graham
    does not bar resort in this case to the Fourth Amendment's specific protection for "houses, papers,
    [506 U.S. 56, 71] and effects," rather than the general protection of property in the Due Process Clause.
    III
    Respondents are fearful, as was the Court of Appeals, that applying the Fourth Amendment in this
    context inevitably will carry it into territory unknown and unforeseen: routine repossessions,
    negligent actions of public employees that interfere with individuals' right to enjoy their homes, and
    the like, thereby federalizing areas of law traditionally the concern of the States. For several reasons,
    we think the risk is exaggerated. To begin, our decision will have no impact on activities such as
    repossessions or attachments if they involve entry into the home, intrusion on individuals' privacy, or
    interference with their liberty, because they would implicate the Fourth Amendment even on the
    Court of Appeals' own terms. This was true of the Tenth Circuit's decision in Specht, with which, as
    we previously noted, the Court of Appeals expressed agreement.
    More significantly, "reasonableness is still the ultimate standard" under the Fourth Amendment,
    Camara, supra, at 539, which means that numerous seizures of this type will survive constitutional
    scrutiny. As is true in other circumstances, the reasonableness determination will reflect a "careful
    balancing of governmental and private interests." T.L.O., supra, at 341. Assuming, for example, that
    the officers were acting pursuant to a court order, as in Specht v. Jensen, 832 F.2d 1516 (CA10
    1987), or Fuentes v. Shevin, 407 U.S. 67 , (1972), and, as often would be the case, a showing of
    unreasonableness on these facts would be a laborious task indeed. Cf. Simms v. Slacum, 3 Cranch
    300, 301 (1806). Hence, while there is no guarantee against the filing of frivolous suits, had the
    ejection in this case properly awaited the state court's judgment, it is quite unlikely that the federal
    court would have been bothered with a 1983 action alleging a Fourth Amendment violation. [506 U.S.
    56, 72]
    Moreover, we doubt that the police will often choose to further an enterprise knowing that it is
    contrary to the law, or proceed to seize property in the absence of objectively reasonable grounds for
    doing so. In short, our reaffirmance of Fourth Amendment principles today should not foment a wave
    of new litigation in the federal courts.
    IV
    The complaint here alleges that respondents, acting under color of state law, dispossessed the Soldals
    of their trailer home by physically tearing it from its foundation and towing it to another lot. Taking
    these allegations as true, this was no "garden variety" landlord-tenant or commercial dispute. The
    facts alleged suffice to constitute a "seizure" within the meaning of the Fourth Amendment, for they
    plainly implicate the interests protected by that provision. The judgment of the Court of Appeals is,
    accordingly, reversed, and the case is remanded for further proceedings consistent with this opinion.
    So ordered.
    000487
    Footnotes
    [1] Jones' statement was prompted by a district attorney's advice that no criminal charges could be
    brought because, under Illinois law, a criminal action cannot be used to determine the right of
    possession. See Ill.Rev.Stat. ch. 110, 9-101 et seq. (1991); People v. Evans, 163 Ill.App. 3d 561, 114
    Ill.Dec. 662, 516 N.E.2d 817 (1st Dist. 1987).
    [2] The Soldals ultimately were evicted per court order in December 1987.
    [3] Title 42 U.S.C. 1983 provides that:
    "Every person who, under color of any statute, ordinance, regulation, custom or usage, of
    any State ... subjects, or causes to be subjected, any citizen of the United States ... to the
    deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
    shall be liable to the party injured in an action at law, suit in equity, or other proper
    proceeding for redress."
    [4] The court reiterated the panel's conclusion that a conspiracy must be assumed on the state of the
    record and, therefore, that the case must be treated in its current posture "as if the deputy sheriffs
    themselves seized the trailer, disconnected it from the utilities, and towed it away." 942 F.2d 1073,
    1075 (CA7 1991) (en banc).
    [5] The court noted that, in light of the existence of adequate judicial remedies under state law, a
    claim for deprivation of property without due process of law was unlikely to succeed. Id., at 1075-
    1076. See Parratt v. Taylor, 451 U.S. 527 (1981). In any event, the Soldals did not claim a violation
    of their procedural rights. As noted, the Seventh Circuit also held that respondents had not violated
    the Soldals' substantive due process rights under the Fourteenth Amendment. Petitioners assert that
    this was error, but, in view of our disposition of the case, we need not address the question at this
    time.
    [6] Under 42 U.S.C. 1983, the Soldals were required to establish that the respondents, acting under
    color of state law, deprived them of a constitutional right, in this instance, their Fourth and
    Fourteenth Amendment freedom from unreasonable seizures by the State. See Monroe v. Pape, [506
    U.S. 56, 61] 365 U.S. 167, 184 (1961). Respondents request that we affirm on the ground that the Court
    of Appeals erred in holding that there was sufficient state action to support a 1983 action. The alleged
    injury to the Soldals, it is urged, was inflicted by private parties for whom the county is not
    responsible. Although respondents did not cross-petition, they are entitled to ask us to affirm on that
    ground if such action would not enlarge the judgment of the Court of Appeals in their favor. The
    Court of Appeals found that, because the police prevented Soldal from using reasonable force to
    protect his home from private action that the officers knew was illegal, there was sufficient evidence
    of conspiracy between the private parties and the officers to foreclose summary judgment for
    respondents. We are not inclined to review that holding. See Adickes v. S.H. Kress & Co., 398 U.S.
    144, 152 -161 (1970).
    [7] In holding that the Fourth Amendment's reach extends to property as such, we are mindful that
    the Amendment does not protect possessory interests in all kinds of property. See, e.g., Oliver v.
    United States, 466 U.S. 170, 176 -177 (1984). This case, however, concerns a house, which the
    Amendment's language explicitly includes, as it does a person's effects.
    [8] Place also found that to detain luggage for 90 minutes was an unreasonable deprivation of the
    individual's "liberty interest in proceeding with his itinerary," which also is protected by the Fourth
    000488
    Amendment. 462 U.S., at 708 -710.
    [9] When "operational necessities" exist, seizures can be justified on less than probable cause. 480
    U.S., at 327 . That in no way affects our analysis, for even then it is clear that the Fourth Amendment
    applies. Ibid; see also United States v. Place, 462 U.S. 696 , at 703 (1983).
    [10] Of course, if the police officers' presence in the home itself entailed a violation of the Fourth
    Amendment, no amount of probable cause to believe that an item in plain view constitutes
    incriminating evidence will justify its seizure. Horton, 496 U.S., at 136 -137.
    [11] It is true that Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), cast
    some doubt on the applicability of the Amendment to noncriminal encounters such as this. Id., 18
    How. at 285. But cases since that time have shed a different light, making clear that Fourth
    Amendment guarantees are triggered by governmental searches and seizures "without regard to the
    use to which [houses, papers, and effects] are applied." Warden, Maryland Penitentiary v. Hayden,
    387 U.S. 294, 301 (1967). Murray's Lessee's broad statement that the Fourth Amendment "has no
    reference to civil proceedings for the recovery of debt" arguably only meant that the warrant
    requirement did not apply, as was suggested in G.M. Leasing Corp. v. United States, 429 U.S. 338,
    352 (1977). Whatever its proper reading, we reaffirm today our basic understanding that the
    protection against unreasonable searches and seizures fully applies in the civil context.
    [12] This was the view expressed by the Court of Appeals for the Tenth Circuit in Specht v. Jensen,
    832 F.2d 1516 (1987), remanded on unrelated grounds, 853 F.2d 805 (1988) (en banc), with which
    the Seventh Circuit expressly agreed. 942 F.2d, at 1076.
    [13] The officers in these cases were engaged in law enforcement, and were looking for something
    that was found and seized. In this broad sense, the seizures were the result of "searches," but not in
    the Fourth Amendment sense. That the Court of Appeals might have been suggesting that the plain-
    view cases are explainable because they almost always occur in the course of law enforcement
    activities receives some support from the penultimate sentence of the quoted passage, where the court
    states that the word "seizure" might lose its usual meaning "when it stands apart from a search or any
    other investigative activity." Id., at 1079 (emphasis added). And, in the following paragraph, it
    observes that, "[o]utside of the law enforcement area, the Fourth Amendment retains its force as a
    protection against searches, because they invade privacy. That is why we decline to confine the
    amendment to the law enforcement setting." Id., at 1079-1080. Even if the court meant that seizures
    of property in the course of law enforcement activities, whether civil or criminal, implicate interests
    safeguarded by the Fourth Amendment, but that pure property interests are unprotected in the non-
    law-enforcement setting, we are not in accord, as indicated in the body of this opinion. [506 U.S. 56, 73]
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    000489
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: chansen@washoecounty.us
    Subject: Reno eviction noticed for Sparks Justice Court
    Date: Tue, 26 Jun 2012 09:10:14 -0700
    Dear Civil Supervisor Hansen
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Dear Sparks Justice Court,
    I called and received permission to file this by fax...I am indigent and request a fee waiver, and failing that, an
    opportunity to cure any filing fee deficiency.
    From: zachcoughlin@hotmail.com
    To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us;
    chansen@washoecounty.us; milllerr@reno.gov
    Subject: Reno eviction noticed for Sparks Justice Court
    Date: Tue, 26 Jun 2012 07:58:36 -0700
    Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
    I have received (though not personally served) what appears to be an eviction notice (5 day unlawful detainer?)
    for rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the notice indicates that I must file a Tenant's
    Answer with the Sparks Justice Court.
    Am I mistaken in viewing this matter to be outside the jurisdiction of the Sparks Justice Court, and rather, a matter
    to be handled in Reno Justice Court?
    Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court has 4
    judicial days a week, the deadline for filing a special appearance (to contest jurisdiction) and or a Tenant's Answer
    of Affidavit is difficult to measure.
    000490
    I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he indicated the
    WCSO planned to come effectuate an eviction on this date, June 26, 2012. I believe that would be premature, as
    Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit by noon after the fifth full day
    (judicial days) and Fridays in Sparks Justice Court are not full days in that sense, and regardless, Sparks Justice
    Court, I believe, is not the appropriate forum where, as here, the situs is located in Reno (Ward 1-nap?)
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    tel 775 338 8118
    fax 949 667 7403
    Civil Division
    630 Greenbrae Drive
    Sparks, Nevada 89431
    (775)353.7603 Phone
    (775)352.3004 Fax
    Civil Department Supervisor
    Chris Hansen
    chansen@washoecounty.us
    The Civil Division of Sparks Justice Court is made up of three major functions:
    Civil
    Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive damages, an
    action to obtain possession of property, a writ of restitution, or other like actions, legal counsel is suggested for
    these types of actions.
    Evictions
    An act or process of legally dispossessing a person of land or rental property.
    Small Claims
    An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims action may
    be filed with the Sparks Justice Court if one of the following applies to the defendant:
    1. They reside within the boundaries of the Sparks Township;
    2. They are employed within the boundaries of the Sparks Township; and/or,
    3. They do business within the boundaries of the Sparks Township.
    FW: ATTORNEY GRIEVANCE OR COMPLAINT
    000491
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 10/01/12 3:53 PM
    To: complaints@nvbar.org; complaint@nvbar.org; davidc@nvbar.org
    1 attachment
    COMPLAINT TO BAR COUNSEL REGARDING WCPD 8 21 12.pdf (146.8 KB)
    Dear Bar Counsel,
    Just checking to make sure you received this grievance.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: complaints@nvbar.org
    Subject: ATTORNEY GRIEVANCE OR COMPLAINT
    Date: Tue, 21 Aug 2012 16:18:27 -0700
    Dear Bar Counsel,

    Please see attached.

    Sincerely
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    000492
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    citation to legal authority?
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 9/24/12 5:13 PM
    To: patrickk@nvbar.org
    Mr. King, this is the first I have heard of you wanting a physical address for me. Can you indicate, in writing,
    when, if ever the SBN has requested as much and whether it was in writing or verbal? Do you have an legal
    citation for your contentions.

    Thanks,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Clerk's liabilities for failing to file documents submitted FW: Motion to
    Dismiss SBN v. Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 9/24/12 4:24 PM
    To: laurap@nvbar.org
    3 attachments
    sbn v coughlin motion to dismiss.pdf (78.1 KB) , 9 12 12 fax to Chariman Susich and Bar Counsel
    King.pdf (98.4 KB) , failure of court clerk to maintain proper records.pdf (28.8 KB)
    000493
    COMES NOW, ZACHARY BARKER COUGHLIN, ESQ., and writes this email moves this Board for the relief
    requested herein. This filing is further based upon the papers and pleadings on file herein and in the companion
    case before the Nevada Supreme Court in 60838 and 61426.
    FACTS
    1. Patrick King, Esq., Bar Counsel of the North, and NNDB Chairman J. Thomas Susich continue to display an
    alarming lack of appreciation for due process, basic fairness, and other notions of fair play and substantial
    justice...and now seeks to subvert the express ruling of the Nevada Supreme Court in its June 7th, 2012 Order by
    turning the Hearing that has already been set (as confirmed by the SBN's Laura Peters, in writing) for September
    25th, 2012 into a "due process combo pack express package" wherein all the various matters set forth in King's
    Complain shall also be addressed, despite the Order by the Nevada Supreme Court and the text of SCR 111 very
    clearly indicating the "sole purpose" of the hearing will be to determine the punishment for the one criminal
    conviction contained in Bar Counsel's SCR 111 petition of May 10, 2012 in 60838 and where an "immediate
    hearing" is further required in light of Coughlin's SCR 102(4)(d) Petition filed, and unopposed by the SBN in
    61426..
    6. SBN Clerk of Court of the Laura Peters has assured Coughlin that no service of any SBN v Coughlin Complaint
    has been effected as of this date and that Coughlin is in no danger of defaulting for failure to answer any such
    Complaint. However, Clerk of Court Peters indicated to Coughlin that she did not file Coughlin's September 17th,
    2012 Motion to Dismiss in light of directions from Bar Counsel Patrick O. King, Esq., and further, NNDB
    Chairman, J. Thomas Susich has made similar indications of the extent to which King is attempting to circumvent
    procedural rules attendant to these matters and cause Coughlin further damages and delay, particularly with regard
    to the dictates of SCR 116. The scheduling of the hearing is the domain of the NNDB and is not to be handed of
    to the prosecutor here, Bar Counsel Pat King. Peters, King, and Clark have all admitted that King and Clark are
    seeking to circumvent the procedural rules and Order related to the scheduling and holding of the hearing in
    response to the Court's June 7th, 2012 Order in 60838 and with regard to the "immediate hearing" required upon
    Coughlin's August 13th, 2012 Petition in SCR 61426, which Bar Counsel has failed to Oppose, and for which,
    therefore, Coughlin is entitled to the relief he therein sought, ie, the dissolution of the temporary suspension of his
    license to practice law.
    LAW AND LEGAL ARGUMENT
    000494
    SCR Rule 119. Additional rules of procedure.
    1. Record. The record of a hearing shall be made available to the attorney at the attorney's expense
    on request made to bar counsel.
    2. Time limits not jurisdictional. Except as is otherwise provided in these rules, time is directory
    and not jurisdictional. Time limitations are administrative, not jurisdictional. Failure to
    observe directory time intervals may result in contempt of the appropriate disciplinary board
    or hearing panel having jurisdiction, but will not justify abatement of any disciplinary investigation
    or proceeding.
    3. Other rules of procedure. Except as otherwise provided in these rules, the Nevada Rules
    of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
    It is the official duty of the clerk of a court to record[FN1] or file all the papers in a cause
    presented by the parties, and to indorse the correct date of the filing on them.[FN2] The duty
    is purely ministerial[FN3] and the clerk may not refuse to perform except on the order of the
    court.[FN4] [FN1] Nash v. Campbell County Fiscal Court, 2011 WL 1620587 (Ky. 2011). [FN2] Estate of
    Johnson v. Ciarpelli, 71 A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010); In re Simmonds, 271 S.W.3d 874
    (Tex. App. Waco 2008). [FN3] Benson v. District Clerk, 331 S.W.3d 431 (Tex. Crim. App. 2011) (writ of
    habeas corpus). [FN4] Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010); In re Smith, 270 S.W.3d 783 (Tex.
    App. Waco 2008).
    Rule 104(3). State bar counsel....
    "3. A grievance against bar counsel or bar counsel's staff shall be investigated at the
    direction of the president of the state bar and heard by the board of governors. A decision of the
    board of governors against bar counsel may be appealed to the supreme court under the Nevada
    Rules of Appellate Procedure."
    SCR 105(2):. "Commencement of formal proceedings. Formal disciplinary proceedings are
    commenced by bar counsel filing a written complaint in the name of the state bar. The complaint
    shall be sufficiently clear and specific to inform the attorney of the charges against him or her
    and the underlying conduct supporting the charges. A copy of the complaint shall be served on
    the attorney and it shall direct that a verified response or answer be served on bar counsel within 20
    days of service; the original shall be filed with bar counsel's office. The time to respond may be
    000495
    extended once by the chair for not more than 20 days for good cause or upon stipulation of the parties.
    In the event the attorney fails to plead, the charges shall be deemed admitted; provided, however, that
    an attorney who fails to respond within the time provided may thereafter obtain permission of the
    appropriate disciplinary board chair to do so, if failure to file is attributable to mistake, inadvertence,
    surprise, or excusable neglect.
    The SBN has admitted, via Clerk of Court Laura Peters, that not only has the SBN agreed to and already set for
    hearing the referral to the Board called for in the Nevada Supreme Court's June 7th, 2012 Order Temporarily
    Suspending Coughlin's License to Practice Law, but also that any SBN v. Coughlin Complaint Bar Counsel Pat
    King wishes to throw together at the last minute in an attempt to skirt the limits of the jurisdiction granted the
    Board in the Court's June 7th, 2012 Order, given King's stated intention to attempt to make a "combo-hearing"
    out of the Hearing called for in that Order, despite its "sole purpose" language and the same found in SCR
    111(8), in addition to the fact that given Coughlin's Petition in 61426, under SCR 102(4)(d), requires an
    immediate hearing, and that Petition was duly served on August 13th, 2012, both on the Board via Chairman
    Susich and both offices of the SBN, via Clark and King, and Peters personal receipt thereof, which the SBN has
    still failed to respond to (much less challenge the reconsideration motion in 60383, etc. (who is talking about
    who's competence, again?)...
    Further, it is a virtual certainty, given Pat King's established modes., that any such Complaint he files, upon it
    being properly served and not insufficient due to illegibility of the photocopies of any exhibits (take it from me
    given 60302 and 60317, I know...) will be wholly insufficient in that it will in no way comply with SCR 105(2),
    and so, as a preemptive measure, please be advised that any such Complaint ought take particular care to state
    who brought what grievance, and avoid conclusory assertions about something "lacking legal merit" or otherwise
    broadly "demonstrating incompetence".
    Further, any assertions by the SBN that sending such a Complaint via certified mail, especially where a phone
    call to SBN Clerk of Court Peters on September 14th, 2012 yield her giving Coughlin the SBN's word that given
    the SBN's apparent attempt to serve Coughlin via Certified mail some Complaint Pat King apparently followed
    through on in his promise to thrown together haphazardly in hopes of defeating any due process accorded the
    hearing on September 25th, 2012, would not require a response at least until the SBN receives back as unclaimed
    some second attempted certified mailing under SCR 109.
    Proceedings instituted a long time after the commission of the act complained of are regarded with disfavor. In re
    Bridwell, 25 Utah 2d 1, 474 P.2d 116 (1970). Bar Counsel is purportedly, and ever so conveniently seeking delay
    Coughlin's procedural rights to a hearing on the temporary suspension of his law license (which has already lasted
    000496
    longer than the NNDB's punishment for an attorney who admitted to misappropriating about 755,000 candy bars,
    from his clients, during the course of his duties as an attorney rather than, allegedly, on a Saturday night at a Wal-
    Mart an in no way connected to the practice of law, and under circumstances that indicate the conviction stemmed
    from a proceedign wholly devoid of due process, and where the appeal thereto was improperly dismissed based
    upon a failure of the RMC to order the transcripts produced within 10 days (the District Court cited to a civil
    statute in blaming Coughlin for failing ot point to a transcript in his Appeal Brief where the RMC's practice of
    demanding indigent defendants use one and only one court approved transcriptionist and pay her up front is
    violative of Nevada law.
    Since it is essential that the bar and the public perceive the process of the discipline of an attorney as fair, orderly,
    and rational, and implicit in this perception is the timely and efficient resolution of complaints. In re Grossman,
    448 Mass. 151, 859 N.E.2d 423 (2007). A delay in bringing disciplinary proceedings against an attorney does not
    necessarily warrant a reduction in the recommended sanction; instead, it is to be placed into context as but one
    mitigating factor to be balanced against a number of aggravating factors. In re Disciplinary Proceeding Against
    Boelter, 139 Wash. 2d 81, 985 P.2d 328 (1999).
    30. Purpose of proceeding
    Modern status of law regarding solicitation of business by or for attorney, 5 A.L.R.4th 866
    The purpose of suspending or disbarring an attorney is to remove from the profession a person
    whose misconduct has proved such person unfit to be entrusted with the duties and
    responsibilities belonging to the office of an attorney, and thus to protect the public and those
    charged with the administration of justice, rather than to punish the attorney,[FN1] although
    disbarment is nonetheless a punishment or penalty imposed on the lawyer[FN2] and the
    sanctions imposed may have that incidental effect.[FN3]
    The purpose of the attorney disciplinary process is not to punish the offender[FN4] but to protect
    the public.[FN5] The principal reason for attorney discipline is to preserve the confidence of the
    public in the integrity and trustworthiness of lawyers in general.[FN6] Attorney discipline is
    designed to protect the public, the legal profession, and the legal system and to deter other
    attorneys from engaging in unprofessional conduct.[FN7] Thus, the judgment of a disciplinary
    proceeding must be fair to society,[FN8] both in terms of protecting the public from unethical
    conduct[FN9] and, at the same time, not denying the public the services of a qualified lawyer; it
    must be fair to the attorney,[FN10] being sufficient to punish a breach of ethics and, at the same
    time, encourage reformation and rehabilitation;[FN11] and it must be severe enough to deter
    others who might be prone or tempted to become involved in like violations.[FN12]
    The court does not lightly impose on an attorney the sanction of permanent disbarment.[FN13]
    000497
    A court disciplining an attorney does so not to punish the attorney but to safeguard the
    administration of justice and to protect the public from the misconduct or unfitness of those who
    are members of the legal profession. Statewide Grievance Committee v. Johnson, 108 Conn.
    App. 74, 946 A.2d 1256 (2008), certification denied, 288 Conn. 915, 954 A.2d 187 (2008).
    In determining the appropriate attorney disciplinary sanction, the Supreme Court is mindful that
    disciplinary proceedings are designed to maintain high standards of conduct, protect the public,
    preserve the integrity of the profession, and deter future misconduct. In re Williams, 85 So. 3d
    583 (La. 2012).
    Supreme Court, in determining a sanction in an attorney disciplinary proceeding, is mindful that
    disciplinary proceedings are designed to maintain high standards of conduct, protect the public,
    preserve the integrity of the profession, and deter future misconduct. In re New-man, 83 So. 3d
    1018 (La. 2012).
    Disciplinary proceedings protect the public through sanctions against offending attorneys in two
    ways: through deterrence of the type of conduct which will not be tolerated, and by removing
    those unfit to continue in the practice of law from the rolls of those authorized to practice.
    Attorney Grievance Com'n of Maryland v. Zodrow, 419 Md. 286, 19 A.3d 381 (2011).
    Court of Appeals's aim in imposing sanctions for attorney misconduct is to protect the public
    and the public's confidence in the legal profession rather than to punish the attorney. Attorney
    Grievance Com'n v. Taylor, 405 Md. 697, 955 A.2d 755 (2008).
    The primary purpose in imposing discipline on an attorney for violation of the rules of
    professional conduct is not to punish the lawyer but rather to protect the public and the public's
    confidence in the legal profession. Attorney Grievance Com'n of Maryland v. Ugwuonye, 405
    Md. 351, 952 A.2d 226 (2008).
    The purpose of disciplinary proceedings is to protect the public, rather than to punish the
    attorney. Attorney Grievance Com'n of Maryland v. Zuckerman, 403 Md. 695, 944 A.2d 525
    (2008).
    The purpose of a disciplinary proceeding against an attorney is not so much to punish the
    attorney as it is to determine whether in the public interest an attorney should be permitted to
    practice. State ex rel. Counsel for Discipline of Nebraska Supreme Court v. Carter, 282 Neb.
    596, 808 N.W.2d 342 (2011).
    When determining whether to impose the ultimate sanction of disbarment, the Supreme Court
    focuses not on punishing the offender, but on protecting the public, maintaining public
    confidence in the bar, preserving the integrity of the legal profession, and preventing similar
    conduct in the future. In re Morse, 160 N.H. 538, 7 A.3d 1259 (2010).
    In deciding on a sanction, Supreme Court is always mindful that the attorney disciplinary
    process exists not to punish the offender but to protect the public from lawyers who are
    unworthy of the trust and confidence essential to the attorney-client relationship and to allow
    the Supreme Court to ascertain the lawyer's fitness to practice law. Akron Bar Assn. v.
    Catanzarite, 119 Ohio St. 3d 313, 2008-Ohio-4063, 893 N.E.2d 835 (2008).
    The Supreme Court's primary purpose in imposing disciplinary sanctions is not to punish the
    offender, but to protect the public. Stark Cty. Bar Assn. v. Marosan, 119 Ohio St. 3d 113, 2008-
    Ohio-3882, 892 N.E.2d 447 (2008).
    The primary purpose of disciplinary sanctions against an attorney is not to punish the offender,
    but to protect the public. Cincinnati Bar Assn. v. Lawson, 119 Ohio St. 3d 58, 2008-Ohio-3340,
    891 N.E.2d 749 (2008).
    A disciplinary proceeding is instituted to safeguard the courts and to protect the public from the
    misconduct of those who are licensed to practice law, and is neither a criminal nor a civil
    proceeding. Disciplinary Counsel v. Heiland, 116 Ohio St. 3d 521, 2008-Ohio-91, 880 N.E.2d
    000498
    467 (2008).
    [FN1] Ex parte Wall, 107 U.S. 265, 2 S. Ct. 569, 27 L. Ed. 552 (1883); In re Attorney Discipline
    System, 19 Cal. 4th 582, 79 Cal. Rptr. 2d 836, 967 P.2d 49 (1998). As to the nature of
    disciplinary proceedings, generally, see 101. [FN2] In re Ruffalo, 390 U.S. 544, 88 S. Ct.
    1222, 20 L. Ed. 2d 117 (1968). The lawyer discipline system was not designed to be either
    punitive or penal in nature. In re Tenenbaum, 918 A.2d 1109 (Del. 2007). [FN3] In re Non-
    Member of State Bar of Arizona, Van Dox, 214 Ariz. 300, 152 P.3d 1183 (2007). [FN4]
    Attorney Grievance Com'n of Maryland v. Goff, 399 Md. 1, 922 A.2d 554 (2007), reinstatement
    granted, 2007 WL 2128391 (Md. 2007). [FN5] Attorney Grievance Com'n of Maryland v. Goff,
    399 Md. 1, 922 A.2d 554 (2007), reinstatement granted, 2007 WL 2128391 (Md. 2007). [FN6]
    In re Scanio, 919 A.2d 1137 (D.C. 2007). [FN7] In re Non-Member of State Bar of Arizona,
    Van Dox, 214 Ariz. 300, 152 P.3d 1183 (2007). [FN8] The Florida Bar v. Cox, 718 So. 2d 788
    (Fla. 1998). [FN9] The Florida Bar v. Krasnove, 697 So. 2d 1208 (Fla. 1997). [FN10] The
    Florida Bar v. Cox, 718 So. 2d 788 (Fla. 1998). [FN11] The Florida Bar v. Poplack, 599 So. 2d
    116 (Fla. 1992). [FN12] The Florida Bar v. Cox, 718 So. 2d 788 (Fla. 1998). [FN13] In re
    Shortess, 950 So. 2d 570 (La. 2007).
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: laurap@nvbar.org; patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org
    Subject: FW: Motion to Dismiss SBN v. Coughlin
    Date: Mon, 24 Sep 2012 14:49:32 -0700
    Dear Clerk of the Court of the State Bar of Nevada Peters,
    Please note the forwarded Motion to Dismiss SBN v Coughlin filed on September 17th, 2012 (I also will forward
    the one I sent just prior to midnight of the 17th, of Setpember 2012. Please let me know anything I should know
    about the Hearing tomorrow, September 25th, 2012 on and only on the matters limited to those set forth in the N,.
    S. Ct ORder of june 7th, 212 in 60383 and pursuant to my SCR102(4)(3) Petition 61426. Please make sure
    Bar counsel is aware of the extent to which you previously guaranteed me that no service of any Complaint in
    SBN V Coughlin sent by certified mail would be deemed effectuated by the SBN where based merely upon the
    return to sender of the first attempt to so serve me under SCR 109 such a Complaint, which you indicated you had
    just received as returned to sender on September 10th, 2012, and where you further indicated that I could serve
    any filings on my behalf thereafter upon the SBN via electronic means including fax or email.

    000499
    Sincerley,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: tsusich@nvdetr.org; patrickk@nvbar.org; davidc@nvbar.org
    Subject: Motion to Dismiss SBN v. Coughlin
    Date: Tue, 18 Sep 2012 00:02:54 -0700
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    FW: Motion to Dismiss SBN v. Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 9/24/12 2:49 PM
    To: laurap@nvbar.org; patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org
    1 attachment
    sbn v coughlin motion to dismiss.pdf (78.1 KB)
    Dear Clerk of the Court of the State Bar of Nevada Peters,
    000500

    Please note the forwarded Motion to Dismiss SBN v Coughlin filed on September 17th, 2012 (I also will forward
    the one I sent just prior to midnight of the 17th, of Setpember 2012. Please let me know anything I should know
    about the Hearing tomorrow, September 25th, 2012 on and only on the matters limited to those set forth in the N,.
    S. Ct ORder of june 7th, 212 in 60383 and pursuant to my SCR102(4)(3) Petition 61426. Please make sure
    Bar counsel is aware of the extent to which you previously guaranteed me that no service of any Complaint in
    SBN V Coughlin sent by certified mail would be deemed effectuated by the SBN where based merely upon the
    return to sender of the first attempt to so serve me under SCR 109 such a Complaint, which you indicated you had
    just received as returned to sender on September 10th, 2012, and where you further indicated that I could serve
    any filings on my behalf thereafter upon the SBN via electronic means including fax or email.

    Sincerley,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: tsusich@nvdetr.org; patrickk@nvbar.org; davidc@nvbar.org
    Subject: Motion to Dismiss SBN v. Coughlin
    Date: Tue, 18 Sep 2012 00:02:54 -0700
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000501
    Motion to Dismiss SBN v. Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 9/18/12 12:02 AM
    To: tsusich@nvdetr.org; patrickk@nvbar.org; davidc@nvbar.org
    1 attachment
    sbn v coughlin motion to dismiss.pdf (78.1 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000502
    Print Close
    FW: motion to dismiss attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 9/18/12 12:00 AM
    To: davidc@nvbar.org
    1 attachment
    sbn v coughlin motion to dismiss (78.1 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; tsusich@nvdetr.org
    Subject: motion to dismiss attached
    Date: Mon, 17 Sep 2012 23:59:42 -0700
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    000503
    ZachCoughlin@hotmail.com
    motion to dismiss attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 9/17/12 11:59 PM
    To: patrickk@nvbar.org; tsusich@nvdetr.org
    1 attachment
    sbn v coughlin motion to dismiss (78.1 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Disciplinary Hearing for Coughlin on September 25th, 2012 at SBN 9
    am
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 9/12/12 12:04 PM
    To: patrickk@nvbar.org; tsusich@nvdetr.org
    4 attachments
    9 12 12 fax to Chariman Susich and Bar Counsel King.pdf (98.4 KB) , rmc transcript rules in
    violation of nrs longioni.pdf (262.3 KB) , pat kings resolution of keith loomis greivance.pdf (172.8
    KB) , laurap@nvbar.org proof of september 25th, 2012 hearing.htm (8.5 KB)
    Zach Coughlin
    000504
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    --Forwarded Message Attachment--
    Print Close
    RE: Hearing date
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/17/12 6:26 PM
    To: Laura Peters (LauraP@nvbar.org)
    That works thanks Laura
    -----Original Message-----
    From: Laura Peters
    Sent: 17 Aug 2012 21:54:45 GMT
    To: 'Zach Coughlin'
    Subject: RE: Hearing date
    Zach:
    How about September 25th, work for you?
    - Laura
    -----Original Message-----
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, August 17, 2012 2:26 PM
    To: Laura Peters
    Subject: Hearing date
    Dear Ms. Peters,
    Please set the hearing date as soon as possible for any matter involving me that has been
    referred to the bar or the disciplinary panel.
    thanks
    Zach Coughlin
    grievancew filed in April yet to be acknowledged or given a case
    number FW: Please see attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 9/08/12 2:04 PM
    To: complaint@nvbar.org; complaints@nvbar.org
    1 attachment
    4 12 12 fax to Bar Counsel State Bar of Nevada.pdf (147.3 KB)
    000505
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Subject: Please see attached
    Date: Fri, 13 Apr 2012 15:46:04 -0700

    Zach Coughlin, Esq.


    Nevada Bar No: 9473
    PO Box 3961
    RENO, NV 89505
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    PLEASE NOTE THE NEW CHANGE OF ADDRESS ABOVE
    THIS IS A FREEDOM OF INFORMATION ACT REQUEST (FOIA) AND
    A REQUEST MADE PURSUANT TO THE NEVADA OPEN RECORDS
    LAW UNDER NRS 239
    000506
    http://sunshinereview.org/index.php/Nevada_FOIA_procedures
    TO: David Clark, Esq., Patrick King, Esq., Glenn Machado, Esq.
    State Bar of Nevada Bar Counsel
    sent via email to: PatrickK@nvbar.org, GlennM@nvbar.org, and ClarkD@nvbar.org
    and via fax, ATTN BAR COUNSEL to 702 385 2878 and 775 329 0522
    PLEASE NOTE THE NEW CHANGE OF ADDRESS ABOVE
    April 12, 2012
    Dear Bar Counsel,
    I am writing to formally request a copy of the materials provided to the State Bar of Nevada in connection with
    any and all grievances filed against me. I believe I have a right to all materials submitted in connection with
    any grievance, not just excerpts of the materials. Further, these grievances, particularly that filed by Judge Nash
    Holmes, are complicating currently pending court proceedings, particularly to the extent that Judge Nash Holmes
    purports to speak on behalf of all three other RMC judges, in addition to judge pro tempores (I have no idea whom
    she is referring to in that regard). Further Judge William Gardner of the RMC is the brother of Judge Linda
    Gardner of the Second Judicial District Court. While in court last week, Judge William Gardner indicated he
    could not recall if he had seen Judge Nash Holmes' grievance letter relating to me, which she supplied to the State
    Bar of Nevada. Judge William Gardner's memory did serve him to relate that, indeed, his sister, Judge Linda
    Gardner, recently forward to him, which he forwarded to the other RMC Judges, a copy of Judge Linda Gardner's
    Order for Sanctions against me in April of 2009. Bar Counsel Patrick King has refused to indicate to me
    whom submitted to the State Bar of Nevada Judge Linda Gardner's Order for Sanctions, and therefore, it is entirely
    unclear as to how an entire grievance, with its own case number could be opened respecting Judge Linda
    Gardner's Order for Sanctions, particularly given I have been supplied no grievance letter purporting to open a
    complaint or grievance in relation to that April 2009 Order for Sanctions.
    Please note I have a new SCR 79 Public Address and a new PO BOX that I have identified as my preferred
    mailing address. I have attempted to make these changes via the Portal at www.nvbar.org, but the
    website is not allowing me to make them. Please accept this writing as a communication meant to effect such
    changes.
    My SCR 79 Address should be:
    000507
    Zach Coughlin, Esq.
    945 W. 12
    th
    St.
    Reno, NV 89503
    My preferred mailing address and PO BOX address should be:
    Zach Coughlin, Esq.
    PO Box 3961
    Reno, NV 89505
    My publicly listed telephone number should be 775 338 8118.
    My publicly listed fax should be 949 667 7402.

    I would like a complete, signed, copy of all the grievances filed against me, and any other similar style written or
    oral complaints (including those Mr. King eludes to from March 22, 2012 of the Reno Marshals for the RMC). I
    am requesting a complete copy of any an all material submitted along with those grievances or complaints, again.
    I would like an indication, in writing, from Bar Counsel as to when I must respond to each of the various
    complaints and or grievances by. I do not believe Hill's grievance should be treated as official at this point
    given he failed to sign it and further, he lacks standing to make the complaints that he makes. Additionally, Judge
    Nash Holmes lacks standing to purport to speak on behalf of all other RMC Judges, in addition to unnamed Judge
    Pro Tempores. I ask for a written indication from Bar Counsel as to whether or not such deficiencies prevent any
    such correspondences from appropriately being deemed grievances calling for any response on my part.
    Judge William Gardner has now refused to recuse himself from a case wherein I am a party, despite receiving
    materials about me from his sister, despite his being employed by the Reno City Attorney's office as recently as
    2010 (I have currently pending litigation against the Reno City Attorney's Office and or litigation which is
    reasonably likely to arise in the near future), and despite Judge Nash Holmes filing a grievance with the State Bar
    of Nevada (apparently in response to prompting from Bar Counsel Patrick King, as she apologies for "taking two
    days to get you the materials you requested" in a letter to Mr. King) wherein Judge Nash Holmes purports to file
    that grievance on behalf of, amongst others, RMC Judge William Gardner.

    I have submitted both a FOIA and a Nevada Open Records Law request to the State Bar of Nevada for copies of
    all materials supplied to the State Bar and Bar Counsel in connection with these "grievances" and have had my
    requests denied and or they have gone unresponded to. Further,returned to me only 7 days after the RMC's
    3/30/12 Order requiring as much (meaning my personal property, including a cell phone, a smart phone, an
    electric shaver, and a 32gb micro sd card) by way of the WCSO, with all data deleted or otherwise made
    inaccesible was a 32gb micro sd card that Judge Nash Holmes and the City of Reno Marshal seized from me
    incident to what certainly appears to be a pretextual arrest allowing them to conductd a search incident to arrest in
    connection with my cross examination of Reno Police Department Sargent Tarter concerning RPD Officer Chris
    Carter admitting that Richard G. Hill, Esq. was bribing him (Hill filed the initial bar grievance against me and Bar
    Counsel King, despite have a published decision of the Nevada Supreme Court in Carstarphen v. Milsner from
    March 2012 in which Mr. Hill was opposing counsel and despite Mr. King's previous shared employment with
    current Reno City Attorney Dan Wong (Wong and King worked for the Attorney General's Office at the same
    time, despite all that Mr. King failed to disclose any such potential conflict and apparently remains on this matter)
    http://law.justia.com/cases/nevada/supreme-court/2012/51631.html
    I have been provided no date by which I must file my response to any of these grievances, save perhaps a date for
    responding to the Hill grievance However, the Hill grievance purported to implicate matters which necessitated
    000508
    seeking clarification from Bar Counsel with regard to whether the pendency of a criminal proceeding or prior
    reporting to other Bar Counsel divested Mr. King of jurisdiction to conduct an inquiry. Mr. King failed to
    respond to such request.

    I have currently pending or anticipated litigation against the United States Postal Service in connection with the
    malfeasance of Golden Valley Station Postal Supervisors Terri James, Buck Hyde, and "Ms." Passot and their
    violations of the Federal Tort Claims Act. I have filed an Official USPS Change of Address and have received
    some mail to the PO BOX 60952. However, Judge Nash Holmes and Judge Gardner recently have informed me in
    court that the RMC received returned as undeliverable several orders the RMC had attempted to send me Buck
    Hyde, a woman whose last name is Passot, and Terri James of the Golden Valley Station USPS post office made
    threatening and retaliation commentary to me with regard to my mail, maintaining that they are feds and
    therefore need not put up with your garbage, in response to my inquiries related to the access to the mailbox
    at 1422 E. 9
    th
    St. #2, a place where I was lawfully entitled to be located at. Gayle Kern, Esq., is not violating
    NRCP Rule 11 in REV RJC 2012-000374 by attempting to classify me as a squatter there (something these
    USPS employees were saying prior to any judicial determination in that regard), despite the fact that the property
    management company that Ms. Kern's client, Park Terrace Townhomes Association employes, Western Nevada
    Management, was forced to admit under oath that the individuals whom entered a rental agreement with me, and
    against whom I have been awarded Orders of Protection in FV12-00188, and FV12-00187, Christopher Allaback
    and Laura Foreshee, were, in fact, given express approval to inhabit that townhome by both Robyn Batalado, then
    a manager at Western Nevada management and by the Park Terrace Townhome's Home Owner's Association
    (PTTHOA), in exchange for carpentry work, keeping on the utilities, and the benefit of a lessened insurance
    premium attendant to such a unit not being vacant. Whether or not those individuals entered a subtenancy with
    me, or whether any lease they entered with me (118A.160 holds that leases, in Nevada, may be either written or
    oral, but don't tell that to the USPS Golden Valley Station supervisors, as they are feds and don't have to
    follow your stupid state laws, duh) was entered into on behalf of either Western Nevada management or
    PTTHOA or Gayle Kern, LTD, is a matter for the justice courts to determine, unless the amount in controversy
    exceeds $10,000, in which case, the Justice Court and the District Court have jurisdictional disputes that seem to
    lack a clear resolution at this point.
    Regardless, Ms. Kern's recent argument in her Opposition to my Motion to Alter or Amend the Order of
    Summary Eviction in RJC Rev2012-000374, deserve a bar grievance. Ms. Kern and or her client PTTHOA sent
    an individual without a law license, Sue King, owner and manager of Western Nevada Management to two
    different hearings to practice law on behalf of Gayle Kern, LTD and PTTHOA, in addition to on behalf of
    Western Nevada management. This is the unauthorized practice of law. Further, Ms. Kern is held to know what
    her own agents, the secretary for the PTTHOA (Becci, I believe is her name) and Sue King, Owner and Operator
    of Western Nevada Management testified to as to the express approval provided to my former housemates and
    domestic abusers Christoper Erin Ervin Allaback and Laura Foreshee (ne Petrone, and more recently, ne
    Harrison) allowing them to inhabit that particular townhome for over 8 months prior to my moving in to it.
    Further, Kern is now persisting with this eviction under an eviction Notice that was No Cause, only to, the day of
    the hearing, file an affidavit that indicates it was a Non Payment of Rent eviction. This is clearly an attempt to get
    around the prohibition against using summary eviction procedures against a commercial tenant (which I was,
    given the location was my home law office, a permissible professional home office use exception to any
    applicable zoning laws) and the delay which would have been attendant to correcting the deficient original
    Eviction Notice. This letter constitutes and official grievance and complaint against Gayle Kern, Esq., and Gayle
    000509
    Kern, LTD. Robyn Batalado, was the PTTHOA for Western Nevada management whom received express approval
    form the PTTHOA Board of Directors to have Allaback and Foreshee inhabit that townhome in exchange for
    some form of consideration. To the extent the consideration was not a monetary rental payment, the summary
    eviction procedures under NRS 40.253 are impermissibly applied in like of the Glazier v Justice Court ruling of
    the Nevada Supreme Court. Both Kern and Hill have violated RPC 3.4. Further, Hill purposefully filed what he
    believes to be my social security number is a very short filing with the RJC (something for which Hill and Baker
    actually received sanctions on John Gessin's behalf in the cases involving Glade Hall, Esq.). This is a violation of
    state law and clearly a hostile act by Richard Hill.
    Hill's allegation with respect to any service issues, and and inability of Bar Counsel or the Court's to send mail to
    me, or for me to receive such mail, necessarily implicates those matters, in addition to the interference with my
    mail by those against whom I was awarded Orders of Protection in FV12-00188 and FV12-00187, my former
    housemates. I demonstrated a great deal of diligence in attempting to maintain a viable mailing address, inform
    courts and Bar Counsel of these issues, and maintain client contact. I have proof of my filing official Changes
    of Address and alerting opposing counsel and the court's of the same.
    I suspect Bar Counsel King is coyly refusing to tell me if he has received any mail as "undeliverable" or some
    other similar designation that he has attempted to send to me.
    I am formally requesting that Bar Counsel inform me, in writing, via fax or email (at the email and fax listed
    below and on my official contact information page as listed at www.nvbar.org) as to the existence of
    any undelivered mail that the State Bar of Nevada has had returned to it after sending it to me. I
    wish to pick such mail up immediately and to retain all of my rights to respond to any such
    grievance or notice of the State Bar of Nevada. PLEASE NOTE MY NEW PO BOX CHANGE OF
    ADDRESS ATOP THIS LETTER. PLEASE SEND ANY PAST MAILINGS THAT WERE
    RETURNED AS UNDELIVERABLE TO THAT ADDRESS, IN ADDITION TO COPYING ME
    ON THEM VIA FAX AND EMAIL AND PLEASE SEND ALL FUTURE MAILINGS TO THIS
    NEW PO BOX ATOP THIS CORRESPONDENCE.
    In the following cases the courts took the view that, under the particular disciplinary rules
    of the jurisdiction, the attorney's failure to co-operate with disciplinary authorities does not
    constitute an independent ground for disciplining counsel. Okla State ex rel. Oklahoma Bar Ass'n v
    Adams (1995, Okla) 895 P2d 701
    Although rejecting an attorney's assertion in a disciplinary proceeding that the constitutional
    privilege not to be a witness against himself applied since the attorney made no assertion
    that his response to a question in the proceeding could be used against him in a criminal
    prosecution, the court, in Re Geurts (1980) 290 Or 241, 620 P2d 1373, held that the accused's
    failure to respond to the bar's inquiries did not constitute grounds for discipline where the bar
    did not show what legal or disciplinary rule the accused violated by failing to respond to the
    bar's inquiry. The disciplinary review board had found that the accused's only response to
    three letters requesting a response to a client's complaint was a telephone call stating that he
    000510
    had mailed a reply and would send a copy of it. When no copy was received, the bar appoin-
    ted an investigator who was informed by the accused that he would furnish him with either a
    copy of the original letter or a new letter outlining the substance of the original letter. As the
    investigator would not accept a new letter and the accused testified that he did not keep office
    copies of his letters, the attorney stated that he felt there was no purpose in replying to the
    investigator
    and hence did not reply. Stating that it did not imply approval of nonco-operation
    with the process of investigation into complaints about a lawyer's professional conduct, the
    court reasoned that if nonco-operation itself is to be made a ground for imposing a disciplinary
    penalty, the rules of professional discipline must give fair notice of the terms and limits of
    the obligation and that they did not do so at the present time.
    Although the disciplinary review board recommended a 30-day suspension based on the
    attorney's neglecting a legal matter entrusted to him by failing to proceed in a dissolution of
    marriage and failing to respond to the bar's inquiries, the court, in Re Conduct of Rudie (1981)
    290 Or 471, 622 P2d 1098, held that the appropriate discipline was a public reprimand where
    notwithstanding the court's express disapproval of the attorney's failure to respond to the bar's
    inquiries, that failure was not itself clearly condemned by a disciplinary rule, independent of
    what bearing it might have on the matter under inquiry. It noted that the attorney failed to respond
    to inquiries from the bar in four disciplinary matters, and that he stipulated to the accusations
    subject to the extenuating reason that his parents were killed in an airplane crash leaving
    him too preoccupied with family affairs and emotionally incapacitated to function effectively
    in his practice.
    In a later proceeding involving the same attorney disciplined in Re Conduct of Rudie
    (1981) 290 Or 471, 622 P2d 1098, supra, recognizing that although the failure to respond by
    making an answer or appearance to disciplinary charges may not have been a violation of the
    000511
    disciplinary rules, the court held, in Re Conduct of Rudie (1983) 294 Or 740, 662 P2d 321,
    that it demonstrated a lack of an important element of professionalism and that the disciplinary
    review board did not draw an unwarranted inference from the accused's failure to appear
    in the disciplinary proceedingsthat is, that it showed that the accused's problems with being
    able to accord his conduct with the requirements of the code of professional conduct were of a
    "more serious nature." The court ordered that the attorney be suspended for 7 months and until
    reinstatement on an affirmative showing of fitness to be readmitted where he was found to
    have, inter alia, conducted representation of his clients without preparation adequate under the
    circumstances, intentionally failed to carry out a contract of employment, and neglected a legal
    matter.
    Holding that an attorney's refusal to co-operate with the ethics committee cannot be used
    as an independent assignment of cause of discipline, the court, in Committee on Legal Ethics
    of West Virginia State Bar v Mullins (1976) 159 W Va 647, 226 SE2d 427, ordered the indefinite
    suspension of an attorney who failed to perform the services for which he had been employed
    and misled his clients as to his activities in their behalf, but rejected the committee's
    determination that his lack of co-operation with the ethics committee should be interjected as
    a charge against him. The committee had found that he failed to respond to all communications
    from the offices of the executive director of the state bar and the chairman of the committee
    on legal ethics and failed to appear, answer, or otherwise respond to the charges against
    him. The court stated that the attorney in a disciplinary proceeding has an absolute right to react
    to charges against him as to be considered uncooperativethat is, he may make a defense,
    employ counsel, testify, or refuse to do any of the former. The court noted that such unco-
    operative attitude toward the ethics committee is undertaken at the attorney's peril, and may
    compel the committee to accept as true all allegations of fact on which a complaint is based.
    However, the court observed that an attorney may conduct himself in a disciplinary proceeding
    000512
    in a manner that he deems to be proper, and his manner of doing so cannot be used as an
    independent basis for discipline.
    CUMULATIVE SUPPLEMENT
    Cases:
    Allegations in petition by Director of Office of Lawyers Professional Responsibility for
    temporary suspension of attorney's license to practice law, which alleged that attorney had
    failed to cooperate with Director's further investigation and that attorney's failure to cooperate
    had prevented Director from implementing probation, were deemed admitted, and thus temporary
    suspension of attorney who had previously been placed on probation was warranted,
    where attorney failed to answer Director's petition for temporary suspension. 52 M.S.A., Lawyers
    Prof. Resp., Rule 16(c). In re Disciplinary Action Against Jellinger, 632 N.W.2d 640
    (Minn. 2001).
    Attorney could not be sanctioned for failure to cooperate with county bar association's disciplinary
    processes, where attorney was not member of voluntary county bar association and
    state attorney general had not requested assistance by association. State ex rel. Oklahoma Bar
    Ass'n v Bolton (1994, Okla) 880 P2d 339.
    In disciplinary proceeding, attorney's failure to cooperate with grievance committee in its
    investigative procedures concerning filed complaints received from individual citizens was
    not separate, independent ground for disciplinary action, but could be considered in determining
    punishment. State v Malone (1985, Tex App Beaumont) 692 SW2d 888, later app (Tex
    App Beaumont) 720 SW2d 842.
    Attorney's neglect of multiple clients' immigration matters, including failing to file applications
    and failing to keep clients informed of status of cases, together with his failing to
    promptly furnish a written response to disciplinary counsel requests, warranted two-year suspension
    from the practice of law; aggravating factors were not sufficiently egregious, nor were
    000513
    mitigating factors sufficiently compelling to justify departure from presumptive sanction of
    disbarment, but presumptive sanction of disbarment was disproportionate to misconduct in
    light of prior disciplinary decisions involving similar misconduct. RPC 1.3, 1.4(a, b), 1.5(a),
    1.15(d); RLD 2.8. In re Disciplinary Proceeding Against Anschell, 141 Wash. 2d 593, 9 P.3d
    193 (2000).
    Rule that disciplinary action may not be ordered for invoking right against selfincrimination
    [Cumulative Supplement]
    In the following cases the court held or recognized that disbarment or other disciplinary
    action against an attorney may not be ordered for properly invoking the attorney's right
    against self-incrimination.US
    Spevack v Klein (1967) 385 US 511, 17 L Ed 2d 574, 87 S Ct 625
    Del
    Re Kennedy (1982, Del Sup) 442 A2d 79
    Ill
    Re Zisook (1981) 88 Ill 2d 321, 58 Ill Dec 786, 430 NE2d 1037, 30 ALR4th 228, cert
    den 457 US 1134, 73 L Ed 2d 1352, 102 S Ct 2962 (apparently recognizing rule)
    Mich
    Sternberg v State Bar of Michigan (1971) 384 Mich 588, 185 NW2d 395 (recognizing
    rule)
    Miss
    Mississippi State Bar v Attorney-Respondent in Disciplinary Proceedings (1979, Miss)
    367 So 2d 179 (recognizing rule)
    Wis
    State v Postorino (1972) 53 Wis 2d 412, 193 NW2d 1 (recognizing rule)
    000514
    Thus, reversing an order of disbarment, the United States Supreme Court held, in Spevack
    v Klein (1967) 385 US 511, 17 L Ed 2d 574, 87 S Ct 625, that an attorney who, in reliance on
    the privilege against self-incrimination, refused to testify and refused to produce records demanded
    at a proceeding to discipline him for professional misconduct is not subject to disbarment,
    since the self-incrimination clause of the Fifth Amendment forbids the imposition of
    disbarment as the penalty for remaining silent. The court noted that the self-incrimination
    clause of the Fifth Amendment applies to the states, and therefore to state proceedings,
    through the Fourteenth Amendment. It explained that under the self-incrimination clause of
    the Fifth Amendment, a person has the right to remain silent without suffering any penalty for
    such silence, stating that "penalty" in this context means the imposition of any sanction that
    makes assertion of the Fifth Amendment privilege "costly." The court observed that the threat
    of disbarment and a loss of professional reputation and standing are powerful forms of compulsion
    to make a lawyer relinquish the privilege against self-incrimination. It added that lawyers
    are not excepted from the words "no person shall be compelled in any criminal case to be
    a witness against himself."[17]
    In Mississippi State Bar v Attorney-Respondent in Disciplinary Proceedings (1979, Miss)
    367 So 2d 179, although recognizing the rule in Spevack v Klein (1967) 385 US 511, 17 L Ed
    2d 574, 87 S Ct 625, supra, that an attorney may not be disbarred simply because he made a
    valid assertion of the privilege against self-incrimination, the court held that a disciplinary
    proceeding does not require blanket immunity as in a criminal case, but nevertheless, having
    taken the witness stand, the attorney may, on a question-by-question basis, make valid assertion
    of the Fifth Amendment privilege as to those questions that would tend to incriminate
    him of a state or federal criminal offense. The court reasoned that a disciplinary proceeding,
    while concededly having penal elements, is not a criminal case and that an attorney, unlike in
    a criminal case, may be compelled to appear and take the witness stand.
    000515
    CUMULATIVE SUPPLEMENT
    Cases:
    Privilege against self-incrimination extends to attorneys, and attorney may not be disbarred
    for invoking privilege in Bar disciplinary proceedings. U.S.C.A. Const. Amend. 5.
    State v. Spiegel, 710 So. 2d 13 (Fla. Dist. Ct. App. 3d Dist. 1998), reh'g denied, (June 10,
    1998) and review denied (Fla. Nov. 18, 1998).
    One-year suspension was warranted for attorney who failed to pursue legal matter on behalf
    of client and failed to respond to disciplinary authorities. State Bar Rules and Regulations,
    Rule 4102(b), Standards 44, 68. In re Zoota, 272 Ga. 496, 532 S.E.2d 107 (2000).
    Protection against self-incrimination did not apply to, and thus did not excuse, attorney's
    failure to comply with request by State Lawyers Assistance Committee (SLAC) that attorney,
    his personal physician, and SLAC member meet to develop alcohol dependency treatment
    plan for attorney; no incrimination would have occurred, as participation in alcohol dependency
    treatment would not be admissible in attorney disciplinary proceeding, and such proceeding
    would not be criminal proceeding. U.S.C.A. Const. Amend. 5; Const. Art. 1, 12;
    ORS 9.545; Code of Prof. Resp., DR 1-103(F). In re Conduct of Wyllie, 326 Or. 622, 956
    P.2d 951 (1998).
    Defending Lawyers in Disciplinary Proceedings, 31 AMJUR TRIALS 633:
    24. The role of retained counsel; in generalNegotiations with bar counsel
    Quite often bar counsel will be a well-known practicing attorney with a large, prominent law
    firm, that is, an attorney who can afford to take time off for bar-related activities. He is likely to be
    middle-aged, wealthy, conservative, and quite busy with his own private practice. He is also unlikely
    to be sympathetic to an unrepresented accused attorney, and will find it difficult to understand the
    problems of young, sole practitioner, for he customarily represents corporate clients, insurance
    companies,
    and banks. He will probably do no divorce or criminal work, and he is likely to be highly specialized
    in his own practice.[31] His goal will be to dispose of the matter as painlessly and as quickly
    as possible, and he will resent lack of cooperation or a hostile attitude. By the time retained counsel
    enters the case, the accused attorney may have had two or three bitter confrontations with this
    attorney,
    000516
    and he may have given him no cooperation nor shown any contrition. The attitude of the investigating
    attorney is likely to be guarded, if not hostile.[32]
    The considerable powers of bar counsel should be understood: he has the authority to file formal
    charges and set the case for hearing, or he may dispose of it without further investigation. He may sit
    on a case indefinitely, or he can see that it is thoroughly prosecuted, even getting assistance of the
    attorney
    general's office or the local district attorney. Indeed, occasionally bar counsel may coordinate
    his efforts with the local United States Attorney or district attorney for the purpose of prosecuting a
    particular attorney for perjury or for some breach of fiduciary duty. He may even suggest to the
    district
    attorney that the case be presented to a grand jury.
    It is therefore obvious that early in the case, retained counsel must communicate, in a friendly
    way with the committee's attorney. He should first determine whether the client has offended him and
    make necessary apologies, although this courtesy will not always fall on receptive ears. If bar counsel
    is irreversibly opposed to the client because of personal animosity, however, he may be amenable to
    replacement by another attorney. This should be requested in a tactful way.
    As a general rule, the committee's counsel will be pleased to suggest prompt methods of settlement.
    If he makes specific suggestions, they should be complied with if at all possible. This is true
    even where they resolve doubts in matters of equity in favor of the complainant. The investigator has
    the power to see that his wishes are enforced. Concrete steps should be proposed and efforts made to
    determine the bar counsel's attitude toward possible rehabilitation through Alcoholics Anonymous or
    psychotherapy treatment or whatever is appropriate of a medical or educational nature.
    Everything that should obviously be done should be done promptly. For example, if a refund of a
    few hundred dollars is clearly in order, it should be done speedily. It is wise to coordinate such
    efforts
    with the committee's staff personnel.
    Sometimes a proposed written agreement for an immediate specific refund, or attendance at ethics
    seminars or remedial courses, to be completed within a given period of time, will be favorably
    received.
    Trickery or failing to live up to agreements made are almost certain to have bad results.
    Therefore it is particularly important that any restitution promised be promptly paid. Occasionally,
    the curative action is simplicity itself, and a request for a letter of apology to the complainant or the
    immediate turning over of a file to substitute counsel should be promptly complied with. However,
    the most important points to make with the investigating bar attorney, where there is no defense
    under
    the facts of the case, are contrition, cooperation, and corrective measures.
    There will be cases, however, where the client has committed no wrongful act and is innocent. It
    should be explained to the bar attorney that innocence will be the defense and that it will be
    vigorously
    pursued. Weaknesses in the complainant's case, his or her past criminal or psychiatric history
    should be pointed out, and an inquiry made as to what steps are necessary to settle the matter under
    those circumstances.
    In some jurisdictions, the investigating bar attorney is a full-time employee of the state bar
    association,
    the attorney general's office or an employee of the local judicial district. The approach in that
    case will probably be somewhat different. Whereas the committee member participating in the
    000517
    investigation
    is seldom compensated for his work, counsel employed by a state bar association or the attorney
    general's office always is. The only exception would be a "special prosecutor" appointed to
    handle a particular, and usually quite spectacular, case. This is rare, but when it does occur, it usually
    involves a political figure or a judge.
    An investigating attorney who is employed full time to investigate and prosecute grievances will
    be harder to deal with. He is less likely to be sympathetic to the accused attorney, particularly if he
    has a record of prior disciplinary action. Nonetheless, most of these grievance committee prosecutors
    have more than enough work, and they tend to concentrate their efforts on the worst offenders, those
    who have been least cooperative, or those who have offended them.
    Retained counsel can expect closer cooperation with federal criminal or state and local district
    attorney
    investigators if the investigating committee attorney is a state or bar association employee.
    Committee counsel acts as the prosecutor, and he may have had considerable experience working
    with the Internal Revenue Service, the Federal Bureau of Investigation or comparable state office,
    and he may have been a former prosecutor himself. If such an investigating attorney is handling the
    matter, a quick determination must be made of the probability of criminal prosecution, and possibly
    serious, adverse tax consequences.[33]
    Regardless of whether the investigating attorney is a committee member or a state bar or attorney
    general's employee, the duty of all investigating or prosecuting attorneys is the same: to do justice.
    They are bound by the code of professional responsibility just as others are. Regrettably, they do not
    seem to enjoy hearing that from defense counsel, and reminding them of their ethical duties will be
    irritating. Nonetheless, most of these investigating attorneys have a heavy workload, and they do tend
    to concentrate their efforts on those attorneys who are the most obnoxious, the most infamous, and
    the least cooperative.
    Retained defense counsel must also make an early determination on whether to supply evidence
    that may build part of a criminal prosecution in the hopes of gaining leniency before the bar
    association
    at the risk of more severe detriment to his client if criminal charges are formally pursued. Such
    decisions are never easy.
    In any event, it is generally good practice at the beginning of representation for an attorney-client
    accused of professional misconduct to contact the grievance or hearing committee's counsel and
    advise
    him that he may expect full cooperation from counsel and the client, any undelivered file will be
    forwarded immediately to the former client or substitute counsel, an informal or formal reply, as
    appropriate,
    will be promptly submitted, and some inquiry about settlement or some other disposition of
    the matter will be made without the filing of formal charges.
    25. The role of retained counsel; in generalSettlement or disposition without hearing; form
    of release
    Settlement is the ideal goal in every case. Seldom can any good come from having a hearing.
    Even though the accused attorney claims complete innocence, the committee members may wonder
    why the matter was not disposed of earlier. They are quite aware of the fact that such matters
    do not get to the hearing stage without the recommendation of the investigating bar attorney, who
    must have found evidence of wrongdoing to justify filing formal charges. Thus, the defense is
    faced with a suspicion of some act of misconduct. Logically, therefore, the goal of avoiding a
    000518
    hearing is the most desirable one, and the approach taken should be one that is least likely to lead
    to a hearing. It makes little sense to set one's goal for a hearing when the use of diplomacy can
    avoid it. Settlement is possible only up to a point prior to the hearing, however. Once the hearing
    commences, it is usually too late for the accused attorney to settle with the complainant. The most
    satisfactory and beneficial settlements are those reached within two weeks of the filing of the
    complaint.
    The potential for various settlement possibilities are plentiful, but, unfortunately, they are usually
    predicated on a commodity in short supply for most attorneys: money. Often it will be necessary
    for the client to contact family members and give promissory notes for loans in order to bargain
    with cash that may be easily replaced, rather than his license, which cannot.
    It should be noted that while it is unethical conduct to "buy off" complaining witnesses, nearly all
    states provide that if the district attorney either approves or encourages a civil settlement, then
    disciplinary proceedings may be avoided. Retained counsel must make certain he violates none of
    the canons of ethics himself. The key to avoiding trouble is to be open and candid with all concerned.
    Retained counsel should immediately make clear to the accused attorney that he is to take no action
    whatever following representation, and a careful inquiry should be made to determine what
    action he has taken to date. Invariably, steps will have to be taken to straighten out the harm that
    he may already have done.
    The single most important ingredient for success is the attitude of the accused attorney. If the
    grievance committee receives the impression that he is merely interested in a "dodge" to avoid the
    consequences of his acts, then great difficulty can be expected. If on the other hand the accused is
    genuinely contrite, both in his words and his actions, few committees are likely to take severe action,
    even in serious cases. On the other hand, some attorneys may attempt some sort of cover-up.
    They may lie to the committee or may otherwise do great disservice to their own cause when they
    are not represented.
    It should always be kept in mind that a contrite attitude by the accused attorney is a difficult one
    for a grievance committee to resist, particularly when it is coupled with a clear and definite plan
    of corrective action.
    Contrition, however, must always be coupled with cooperation, and cooperation must always be
    coupled with corrective action. Should one of these elements be missing, a good result cannot be
    expected. Once defense counsel takes the client firmly in hand, directs a corrective-action program,
    and, most importantly, establishes and maintains a good relationship with bar counsel, he
    may expect good results, even in serious cases.
    The key task for the retained attorney is to coordinate the defensive effort with the goal toward
    receiving
    for the accused the least amount of punishment. For example, the investigating attorney
    for the grievance committee should be informed that the money in dispute has been returned, and
    that the young attorney is facing considerable trouble with the district attorney's office for the
    drunk-driving, collision, and the marijuana possession. It may be appropriate in such case, to suggest
    that the committee take no action until the criminal matter is exposed of.
    If the client is uninsured, and many will be, defense counsel should seek to settle as much of the
    case as he can by the mere payment of money as opposed to disciplinary proceedings. This, of
    course, does not mean fraudulent claims should be paid. If the claimant comes into the hearing
    room with unclean hands, having attempted to extort an unfair cash settlement, the committee is
    entitled to know. However, in the given fact situation, there is a claim for a large sum of money
    the complainant allegedly lost in profit from the sale of the piece of property. A full investigation
    000519
    may be required. Did the complainant have full title to the property, free and clear? Was there a
    bona fide written offer? Did the complainant have the right to sell the property without the approval
    of other heirs? A malpractice carrier must certainly know the answer to these questions before
    parting with any money.
    The district attorney's office should be approached with a similar offer: "Because of the DWI and
    marijuana case, the accused attorney is in trouble with the grievance committee. If a civil settlement
    with the persons who sustained damage in the car wreck can be reached, would the district
    attorney be willing to dismiss the case?" Where changes of misconduct involve theft, it is best to
    make the district attorney aware of settlement negotiations and secure his participation to avoid
    potentially serious problems in a related criminal proceeding.
    The person most important to an overall settlement will be the investigating attorney. The key to
    success is to decide at an early stage upon a specific, reasonable, and achievable course of action,
    and to stick with it. If promises for payment of damages or refunds to clients are made, they must
    be honored, to avoid displeasure of the grievance committee. Plans should be made to raise the
    necessary funds, and an overall plan to solve all the problems of the accused attorney in one
    settlement,
    if possible, should be made. These plans often include requiring attendance at Alcoholics
    Anonymous meetings, psychotherapy with a psychiatrist or clinical social worker, or, in cases of
    negligence or extreme ignorance, attendance at legal ethics classes, continuing legal education
    programs, or other remedial or curative activities. In such cases, the sooner the corrective action
    is undertaken, the more likely good results can be had. Many of the best plans are implemented
    months before the hearing.
    Persuading the investigating bar attorney to propose a solution acceptable to all the parties is
    tantamount to a successful defense. Throughout the attempts at settlement, the bar attorney should be
    informed of the status of negotiations, and the position of the accused attorney should be shown
    as one of reasonableness. If the investigating attorney is made aware that the complainant is seeking
    thousands of dollars when he lost only a few hundred, he very well may suggest that only the
    few hundred be refunded, and may agree to a dismissal of the grievance.
    Set forth below is a suggested form of release by the complainant on receipt of the amount agreed
    to in settlement:
    Form of release:
    RELEASE
    KNOW ALL MEN BY THESE PRESENTS:
    That I, ____________,[complainant] of ____________[address], in consideration of the sum of
    ____________[amount of settlement] to me in hand paid by ____________[attorney], the receipt
    of which is hereby acknowledged and conferred, and recognized as adequate by these presents,
    for myself, my heirs, executors and administrators, release and forever discharge the said
    ____________[accused attorney] of and from all manner of debts, demands, obligations, liabilities,
    suits, and causes of action, whatever, against him, the said ____________[accused attorney],
    in my own right, at the time of executing these presents.
    [Date, subscription, and other formal parts omitted.]
    Dismissal of the hearing should always be a part of any settlement, and all offers should be made
    known to the investigating attorney and subject to his approval. This will insure his good will;
    only rarely will he interpose an objection. However, the defense attorney should not take up too
    much of bar counsel's time. Bar counsel is usually busy with his private practice; he has his own
    cases to handle. He will not appreciate lengthy discussions with the defense attorney over strategy
    000520
    or the petty details of the looked for solution.
    Many jurisdictions provide for a "letter of caution," which is sometimes nothing more than an
    informal
    "if-it's true-you-should-not have-done-it." In other words, the bar is simply pointing out
    that the accused attorney is on thin ice, has gotten the attention of the grievance committee, and,
    while the matter may not be serious enough for full inquiry, his conduct could and should improve.
    In some jurisdictions, the investigating attorney himself has the authority to issue a letter
    of caution.[34]
    In some jurisdictions, previous letters of caution may be used to enhance punishment, in others
    they may not. In some cases the letter of caution may be issued without a complete investigation,
    based only on the complaint of the former client and the answer of the accused. A letter is frequently
    issued when the accused attorney is not cooperative as to a minor inquiry. Often the lack
    of cooperation is the central theme of the letter of caution. Nonetheless, the letter of caution falls
    into the milder end of the discipline range provided by law, and many attorneys can withstand
    receiving
    the letter with only modest wear on their nerves. Usually the issuing of the letter is the
    end of the matter.
    When Bates v. Arizona Bar Association[35] was decided by the United States Supreme Court,
    many advertising taboos fell for the legal profession. The limits which the advertising must observe,
    rather than all advertising, then became the issue. While advertising under certain circumstances
    was held to be proper by the United States Supreme Court, it did not approve of solicitation.
    Where advertising leaves off and solicitation begins is unclear in many cases.
    Attorneys who advertise seem to have far more grievances lodged against them than lawyers who
    do not. Because of the conservative nature of the members of the grievance committee, it is usually
    best to attempt to settle an advertising grievance by ceasing an activity that is questionable. If
    an advertising violation goes to the grievance committee, harsh punishment may follow.
    However, because the law is uncertain as to legal advertising, some grievance committees might
    be willing to forego discipline if the accused attorney agrees to discontinue the activities disapproved
    of. There is a question whether such agreements are enforceable, but because of the uncertain
    state of the law it should be assumed that they are enforceable. The agreements should be
    drawn up with specificity to indicate the extent of advertising that will be allowed.
    V. Defense of Formal Charges
    A. Pleading and Prehearing Procedures
    26. In general
    If it appears that an early settlement or disposition of the matter will not be forthcoming, counsel
    must prepare for a stout defense of the formal charges against his attorney-client. He needs to prepare
    a thoughtful, effective plan of action, if one has not yet been made,[36] analyze the complaint and
    formal charges[37] and prepare an appropriate response to them,[38] prepare his client's defenses to
    the charges[39] or matters to offer in mitigation of punishment,[40] conduct discovery[41] and make
    appropriate procedural motions,[42] and begin preparation for the defense of the client at the formal
    hearing of the grievance committee. These steps are all discussed in the following sections.
    27. Complaints; form
    Virtually all jurisdictions require that grievances be filed in writing. Many require that the complaint
    be sworn to. They are usually rambling, inarticulate, and barely legible. If they are well
    written and make specific reference to violations of particular canons of ethics, the defense attorney
    may logically conclude that an attorney is aiding the complainant.
    000521
    ___________________
    A typical client complaint against an attorney, based on the factual background of the present article,
    might read:
    My name is ____________. My mother passed away about three years ago. I went to
    ____________[attorney] to have him probate my mother's will. I wanted to sell the real estate.
    He charged me $____________ and told me he would take care of everything, but I have not
    heard from him since. I have called his office at least twenty times, and he has only returned two
    or three of those calls. When I finally talked to him, he had done nothing.
    Further, about a year ago, I went to his office to pick up the file so I could go to another lawyer
    and he would not give it to me. He would not give me the will or the other material so that I could
    take it to another attorney. Another attorney has told me I have an absolute right to pick up my
    file. I want my file so that I can get somebody who knows he is doing to file the will to be probated.
    His delay cost me the sale of the house and my lost profit was $____________. I demand an
    immediate
    hearing. Signed: ____________.
    There is usually a small questionaire attached which the complainant is expected to fill out. A
    typical one would read as follows:
    Name of the attorney complained of: ____________.
    How much did he charge you? $____________.
    Did you get a receipt? [] Yes [] No
    Had he done any work for you before? [] Yes [] No
    Are you willing to be a witness and offer sworn testimony? [] Yes [] No
    A copy of the complaint will be sent to the accused attorney with a letter from the chairman of the
    grievance committee that may read as follows:
    Dear ____________:
    Attached herewith please find the complaint of ____________, who has filed a formal grievance
    against you.
    It has also come to the attention of the committee that on ____________, 20___, you were arrested
    for the crime of driving while intoxicated and negligent collision in violation of the penal laws
    of this state. Further, it has come to our attention that when you were arrested, a quantity of
    marijuana and cocaine was found on your person, and that criminal charges are pending against
    you for those three offenses.
    This case has been assigned for investigation to ____________, an attorney of this city. You are
    required to file a written reply with him, with a copy to me and a copy to the complainant,
    ____________, whose address is ____________, within ten days of your receipt of this letter.
    Failure to do so may result in disciplinary action against you. You have a right to an attorney and
    the right to be heard. A hearing for this complaint, if necessary, will be held at a later date. You
    will be advised of the date of the hearing. Of course, in accordance with the secrecy provisions of
    the State Bar Act, we will not discuss the other matters with ____________, the complainant.
    Feel free to file separate replies to each matter.
    Sincerely,
    In the factual background of the article, the complainant has gone to the district attorney's office
    to file theft charges against the attorney, under the theory that his attorney accepted money, did
    no work, and would not return the money. The district attorney has, at this time, rejected the
    charges, and while it is unlikely that they will be accepted for filing in the future, it does give the
    complainant an added option to the detriment of the accused attorney.
    000522
    [] Practice Note: Venue. Most state bar acts provide that an attorney must be disciplined in his
    home district. Most states are divided into a number of "districts," usually corresponding to judicial
    districts, and complaints are forwarded to the accused's home area for processing. The only
    exception is discipline before a federal court and contempt proceedings, which are conducted before
    the court where the misconduct took place. Should a complaint be filed in the wrong area, a
    motion to dismiss or a motion to transfer or a plea in abatement is in order.
    28. Formal charges
    [Cumulative Supplement]
    Formal charges of professional misconduct should not be recommended by bar counsel without
    notifying the attorney who is accused of unethical or illegal conduct.[43] The notice need not be
    given
    immediately, however; it can await the outcome of the bar's investigation into the allegations.[44]
    Following the investigation, the proceedings may be disposed of, without formal charges being
    filed, in one of three ways[45] all of which require the recommendation of bar counsel and the
    concurrence
    of the chairman of the grievance or hearing committee.[46] (1) The proceedings may be dismissed
    if there is insufficient probable cause to believe misconduct has occurred.[47] (2) An admonition
    may be issued if there is probable cause to believe that misconduct has occurred but the problem
    is minor and isolated.[48] (3) Probation can be imposed, with or without an admonition, if there is
    probable cause to believe misconduct has occurred for which probation is appropriate.[49]
    Furthermore,
    if there is a civil or criminal proceeding pending in which the respondent is a party and which
    involves the same subject matter (conduct), the disciplinary proceedings may be stayed if that is
    appropriate.[
    50] A stay will be appropriate where the respondent will suffer prejudice in the pending
    proceeding should the disciplinary action proceed immediately and where the grievance committee
    hearing may be expedited by evidence adduced in the criminal or civil matter.[51]
    Formal proceedings against the accused attorney are warranted where there is probable cause to
    believe misconduct has occurred which is neither minor nor isolated and probation is not appropriate
    or where the respondent does not agree to a recommendation of admonition or probation.[52] The
    charges are prepared by bar counsel who is required to file with the disciplinary board and serve on
    the respondent a written statement of the charges giving a fair and adequate notice of the nature of the
    alleged misconduct.[53] Once the formal charges are filed, the proceedings are no longer confidential
    and are open to the public except for deliberations of the hearing committee, disciplinary board or
    court and information the hearing committee has ordered kept confidential.[54] After the charges
    have been filed, the matter is referred to a specific grievance or hearing committee.[55]
    CUMULATIVE SUPPLEMENT
    Cases:
    No due process errors occurred during the grievance committee proceedings investigating an
    attorney's
    behavior, where attorney alleged that notice of the hearing was untimely and charges against
    him were vague, because grievance committee proceedings are principally investigatory and
    comparable
    to proceedings before a grand jurythey are nonadversarial and there is no right of confrontation
    or cross-examination; the attorney under investigation is not entitled to a bill of particulars until
    the grievance committee completes its investigation. In this context, at a reasonable time before a
    000523
    finding of probable cause is made, the attorney will be advised of the conduct under investigation and
    the rules which may have been violated; in addition, the attorney must be given all materials
    considered
    by the committee and an opportunity to make a written statement regarding the alleged misconduct
    under R Reg Fla Bar 3-7.4(g). In any event the notice actually given was sufficient where the
    attorney received notice of the rules allegedly violated 13 days before the hearing was scheduled, and
    he was represented by counsel at the hearing and had an opportunity to cross-examine witnesses. The
    Florida Bar v. Swickle (1991, Fla) 589 So 2d 901, 16 FLW S737, later proceeding (US) 117 L Ed 2d
    101, 112 S Ct 929, supp op (US) 118 L Ed 2d 203, 112 S Ct 1552.
    Evidence supported the finding of panel of the Kansas Board for Discipline of Attorneys that attorney
    engaged in illegal conduct, as an aggravating factor for purposes of imposing discipline, even
    though criminal charges were not filed against attorney; attorney admitted that he exposed himself to
    administrative assistant for district court, statute defined lewd and lascivious behavior as "publicly
    exposing a sex organ or exposing a sex organ in the presence of a person who is not the spouse of the
    offender and who had not consented thereto," administrative assistant was not attorney's spouse, and
    the American Bar Association's (ABA) standards did not require that an attorney be charged or
    convicted
    by law enforcement before his or her conduct could be considered illegal. West's K.S.A.
    213508(a)(2). In re Depew, 237 P.3d 24 (Kan. 2010).
    Discipline of attorney who engaged in conduct adversely reflecting on fitness to practice and
    placed personal interests above those of clients would be limited to censure where medical evidence
    showed he suffered from mild neurological dysfunction due to cerebral aneurysm at time of
    misconduct,
    years of exemplary practice preceded affliction, he acknowledged misconduct, and he demonstrated
    willingness to take appropriate steps to prevent recurrence. Re Kiley (1991, 4th Dept) 170
    App Div 2d 90, 572 NYS2d 601.
    [Top of Section]
    [END OF SUPPLEMENT]
    29. Response; form
    [Cumulative Supplement]
    Within a prescribed period of time following service of the formal charges, the respondent should
    file a written reply or answer with the board or committee and serve a copy of it on bar counsel.[
    56] Allegations that are not disputed should be admitted to narrow the issues at the hearing and
    denials of fact should be separately stated. Moreover, if the respondent chooses to refuse to answer
    an allegation on constitutional or other grounds, the ground of such refusal should be explicitly
    asserted.[57] Counsel should note that the failure to answer the charges timely may be
    treated as an admission of their truth.[58]
    It should be kept in mind that the reply itself is admissible in both civil, criminal, and disciplinary
    proceedings. The records of the grievance committee themselves are not usually subject to discovery
    proceedings, as they are almost always allowed to be secret by statute. However, the accused
    will be required to send a copy of the reply to the complainant, which may be introduced, in
    evidence at a subsequent civil trial for malpractice, or at a criminal proceeding.
    Many jurisdictions require that the reply be sworn to, and some provide that failure to file a
    timely reply is in itself grounds for disciplinary proceedings. At the very least, the failure to file a
    timely reply will irritate the investigating attorney and the committee, and this conduct will be
    reported
    000524
    to the committee and may be viewed as lack of cooperation. Where failure to reply is in
    and of itself an admission that all charges are true and correct, the statement of charges alone can
    be the basis for disciplinary proceedings.
    A good deal of thought and effort must go into the reply, and a well-drafted answer may result in
    no further action by the investigating attorney. For example, legal research into the various issues
    may result in finding cases that exonerate the defendant in the particular fact situation. A motion
    to dismiss should then be filed with the answer, citing the appropriate authority. In preparing the
    reply, counsel should attach to a motion to dismiss photocopies of important favorable cases or a
    brief in support. If no research is offered, none will be done by the committee on behalf of the client.
    An amazing number of attorneys are unaware of the fact that there has been considerable litigation
    over the years regarding what is and what is not unethical conduct, and formal published ethics
    opinions have been issued by many committees for decades. There is a wealth of authority that
    can be cited. Moreover, most state bar associations have on file advisory opinions from their ethics
    committees. These can sometimes be of immense use, especially where the accused attorney
    actually may have relied upon a prior ethics opinion in trying to conform his behavior to the right
    canon. The problem is that advisory opinions may not be binding, and authority from other states
    or jurisdictions may be cited only as persuasive authority. Finally, the American Bar Association
    has issued numerous opinions over the years, and provides materials that may be purchased for
    ethics law research. The bar association's opinions carry considerable weight.[59]
    Generally, there is no required form for a reply. A typical and acceptable method is to go through
    the allegations and admit those that should be admitted, to identify those as to which corrective
    action has been taken (such as returning the file to the client or to his new attorney), to deny those
    that should be denied and to deny for lack of information or belief other allegations as appropriate.
    A reply similar to answering requests for admissions or interrogatories may be appropriate.
    The second part of the reply should consist of a brief on the issue of whether the conduct complained
    of is (a) a crime or act of moral turpitude; or (b) conduct that normally would subject the
    accused to disciplinary action.
    Based on the factual background of the article, an appropriate response to formal charges might
    be composed as follows:
    [Caption of forum, title of case and other formal parts omitted.]
    ANSWER TO FORMAL CHARGES
    1. The allegations of paragraphs ____________ of the formal charges are admitted.
    2. The allegations of paragraphs ____________ are denied without qualification or reservation.
    3. In response to the remaining allegations, respondent cannot admit or deny the truth of the
    allegations
    for lack of sufficient information and belief. He therefore denies those allegations subject,
    however, to the following factual statement, which is offered in defense of the formal charges and
    in mitigation of punishment as to any charges and allegations found to be true:
    a. I was formally the attorney for the complainant. I advised him at the time I accepted the case
    that I would also need a contractual relationship with his two sisters, and he has never had them
    contact me. I felt uneasy with probating the will without the participation of the two sisters, and I
    did not know how to get in touch with them. He gave me a retainer of $500. Attached herewith
    please find a photocopy of the check for $500, which I have sent to his new counsel since he has
    now made arrangements for another attorney.
    b. I admit that I did not return his file to him when he first requested it because I did not know I
    was required to do so. I have apologized to the complainant with an explanation. [Attach copy of
    000525
    letter.]
    c. I admit sending the letter to the complainant referred to in his complaint as I mistakenly
    thought that I was entitled to hold the file until I had been compensated for the time I had spent
    on the case. I was mistaken as to my obligations, and I have stated my regret for any inconvenience
    this has caused the complainant.
    d. ____________[Other statements as appropriate].
    [Date, subscription, and other formal parts omitted.]
    Particularly when the defense attorney has not been permitted much time to prepare a reply, or the
    accused attorney has filed his own reply, an amended reply may be appropriate. In most cases,
    there are no bar rules to prevent this. Occasionally the grievance committee will frown on very
    late replies, especially those filed just before the hearing.
    The best use of the amended reply is to bring to the committee's attention legal precedents not
    previously shown to them, and particularly any legal authority that the defense attorney feels is
    compelling. [] Practice Hint: The money to fund any costs or refunds should be placed in the defense
    attorney's trust account, and a written statement from the accused attorney should be taken
    granting the attorney full and exclusive power to disperse the money in settlement of the case, in
    his discretion.
    Virtually all jurisdictions require that a written answer to the grievance be filed within a certain
    time limit. Most jurisdictions allow a minimum of 7 days, and some allow up to a maximum of
    60. Nearly always the time by which a reply must be filed is included in the notice of formal
    charges. In many cases, however, with as much as 30 or 40 hours of investigating and preparation
    to do, a timely answer cannot be made. Rather than filing a late answer, it is always appropriate to
    call the investigating attorney and ask for an extension of time in which to file the answer. It
    nearly always will be granted. Indeed, this may be a wise consideration in most cases. The bar
    association
    grievance committee is anxious to have the accused attorney submit to their authority
    and control. Resisting it invariably results in its taking a harsher stance. Therefore, a request for a
    delay in filing a response has the advantage of allowing a more thorough investigation that will
    produce a better and more detailed reply and in letting the committee know that the accused attorney
    has submitted himself to their committee's jurisdiction.
    A case may present itself where the complainant seeks a large and unjustified refund from the accused
    attorney or otherwise seeks to take unfair advantage of him. This is not uncommon, particularly
    among "con men," who may have succeeded in this ploy in the past. The interview with the
    accused attorney will sometimes reveal that the complainant is an accomplished liar who is adept
    at adjusting his testimony to accomplish his goal. In such cases, a vague answer to the grievance
    may be advantageous.
    As a general rule, the committee does not like the holding back of information, but neither does it
    like its offices being used for purposes of extortion. Further, the majority of virtually all committees
    is made up of lawyers, and they are likely to appreciate good tactics. There are exceptions,
    however, and prudent practice requires that the appropriate approach be taken.
    [] Case Illustration: A client paid his attorney a flat fee for defense in a fraud case. When the
    litigation
    was satisfactorily concluded, the client demanded half of the fee back, claiming that the
    attorney had told him that he expected to lose, that that fee would include the costs of an appeal,
    and that if the case was won at the trial stage he would give him a 50 percent refund. Defense
    counsel investigated the matter after the demand was first made but before the grievance was
    000526
    filed, and checked the complainant's litigation records at the courthouse, discovering that other
    attorneys
    had defended the complainant in fraud actions as well. He contacted them and learned
    that two had been approached along the same lines; one paid back half of the money to avoid a
    grievance, and the second made a small adjustment in the fee. A purposely vague answer was
    filed, and, at the hearing, the complainant was allowed to tell his story to the committee and
    cross-examination solidified it. Then, to the surprise of the complainant, the two attorneys against
    whom he had made the same threat several years before were presented as witnesses. Since there
    were two witnesses to the attorney's employment agreement, the attorney and his secretary, and a
    signed written contract that provided as the attorney stated, the fundamentals for presentation of a
    perjury charge existed and the record was turned over to the appropriate authorities. The
    complainant's
    protests that his previous extortions were privileged communications were overruled by
    the committee.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney who on 3 separate occasions refused to cooperate in committee's investigation of client
    complaints, until it became necessary to procure subpoena directing his appearance for examination
    under oath, would be censured despite mitigating factor that he was in midst of terminating
    longstanding
    marriage during period in question, since failure to cooperate in investigation of alleged
    misconduct constitutes misconduct in and of itself, and warrants discipline. Re Feit (1989, 3d Dept)
    156 AD2d 810, 549 NYS2d 829.
    [Top of Section]
    [END OF SUPPLEMENT]
    30. Motion to dismiss; illustrative forms
    The scope of motions to dismiss grievances is limited only by the ingenuity and experience of the
    defense attorney. They can take practically any form, but should, if possible, be supported with
    case citations and a brief in support. Forms for two typical motions, (a) motion to dismiss on the
    ground of res judicata, and (b) a motion to dismiss for lack of standing, are set forth below:
    MOTION TO DISMISS (RES JUDICATA)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, the Respondent in this action, and would show the committee as
    follows:
    I.
    The complaint of ____________, complainant in this cause, is substantially the same as was
    found in her suit for legal malpractice against the respondent filed on ____________, 20___, and
    tried to a jury on ____________, 20___. The jury made findings entirely favorable to the defendant
    in that cause (respondent herein) and the court entered a judgment for the defendant and taxed
    all costs against the plaintiff (complainant herein) and said costs have yet to be paid.
    II.
    Copies of the plaintiff's pleadings, the defendant's answer, and a certified copy of the judgment in
    that cause are attached herewith as respondent's Exhibits "A", "B", and "C", and are herein
    incorporated
    for all purposes by reference.
    000527
    III.
    Respondent urges that virtually all issues presented to this committee were presented in
    ____________ court, and resolved by the rules of evidence and that the respondent was shown as
    a matter of law to have been guilty of no professional misconduct.
    IV.
    The complainant herein attempts a collateral attack upon that final judgment (Exhibit "C") which
    should not be permitted as a matter of law. Respondent respectfully urges that administrative
    hearings such as those held by the grievance committee may not attack facts conclusively established
    in court.
    V.
    Further, respondent respectfully submits that the grievance committee should not set itself up in a
    position above the courts and should not disregard the findings already made.
    WHEREFORE PREMISES CONSIDERED, respondent prays that this grievance be forthwith
    dismissed with prejudice and for all other further relief to which he may show himself to be justly
    entitled.
    [Date, subscription, and other formal parts omitted.]
    As a general rule, the committee is interested in hearing only from an attorney who has discovered
    unethical conduct, law enforcement authorities, the victim of the unethical conduct, but
    no others. In a surprisingly large number of cases, friends, neighbors or, particularly in divorce
    cases, relatives of the person they see as aggrieved will attempt to interpose their will. If tactfully
    handled, these cases can often be dismissed quite early.
    As a practical matter, there are no formal requirements for "standing." Anyone aware of unethical
    behavior may report it to the grievance committee. However, most committees receive complaints
    from third parties that generate unnecessary work for them, and, as a general rule, they are not
    sympathetic to interlopers. They wish to hear from the client or a person who claims to have been
    victimized by the attorney.
    MOTION TO DISMISS (LACK OF STANDING)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, respondent, by and through his attorney of record, and shows as
    follows:
    I.
    Respondent represented ____________, a citizen of Mexico, in litigation against ____________,
    a citizen of the United States. Respondent had an attorney/client relationship with ____________
    [plaintiff], and pursued the matter vigorously. Copies of the pleadings filed against the defendant
    in that case prepared by respondent are attached herewith as Exhibit "A" and incorporated for all
    purposes.
    II.
    The defendant in that case filed an answer, a copy of which is attached herewith as Exhibit "B"
    and incorporated herein for all purposes.
    III.
    Respondent proceeded to take depositions and to prepare for trial but, because of distances, was
    unable to maintain close contact with the plaintiff, his client.
    IV.
    The complainant in this cause is a friend of the plaintiff. The plaintiff often stayed at her home
    while visiting in the United States. Gradually the plaintiff seemed to lose interest in the litigation,
    000528
    and stopped paying attorney's fees to respondent. The complainant then attempted to usurp the
    perogatives of the plaintiff, at first by carrying messages to the respondent, then by taking
    independent
    action, and then by attempting to exercise her independent judgment as to how the case
    should be handled.
    V.
    In time, a dispute arose between the complainant, who had no legal right to interfere in the lawsuit,
    and the respondent, who respectfully suggested to her that he preferred to do business with
    his client only and that legal matters and questions of strategy should be left to the plaintiff and
    the respondent. To this, the complainant took great exception.
    VI.
    Respondent then filed a motion to withdraw, giving the plaintiff sufficient time to make other
    arrangements
    for counsel. The motion for and order permitting withdrawal as attorney of record is
    attached herewith as respondent's Exhibit "C," and incorporated herein for all purposes.
    VII.
    Nonetheless, the complainant continued to assert her wish to control the litigation and the obligation
    of the respondent to represent what had come to be, in her mind, her case. Respondent refused
    to communicate with her, and returned the file to his client in Mexico.
    VIII.
    Complainant refused to accept the court's order permitting withdrawal, and she has continued to
    call the respondent to insist upon a full accounting of all money expended, or an explanation as to
    why the case has not been tried.
    IX.
    Respondent has never had an attorney-client relationship with the complainant, and he respectfully
    suggests that she lacks standing to bring a complaint on charges of professional misconduct
    against him.
    WHEREFORE PREMISES CONSIDERED, the respondent in this case respectfully requests that
    the complaint of this complainant be dismissed with prejudice, and the further prays for all such
    relief, both general and equitable, to which he may show himself to be justly entitled.
    [Date, subscription, and other formal parts omitted.]
    31. Discovery
    [Cumulative Supplement]
    For a limited period following the filing of an answer, both bar counsel and the respondent should
    be afforded reciprocal discovery of matters not privileged.[60] During this period there should be a
    mutual exchange of (1) names and addresses of all persons having knowledge of relevant facts, (2)
    non-privileged information and evidence relevant to the charges or the respondent, and (3) other
    material
    that may be shown to be relevant and material. Protective orders should be available to prevent
    unwarranted discovery.[61]
    While many of the state bar enabling acts make no specific provision for discovery, as a general
    rule, a meeting with the investigating attorney will produce all the discovery necessary to prepare for
    the hearing. Furthermore, not only has the accused attorney an absolute right to a copy of the
    complaint
    lodged against him, and to all later amended complaints, but in most states, the accused has a
    right to a list of the witnesses who will appear against him, and in many states the bar rules provide
    000529
    that a summary must also be given of their expected testimony. The accused attorney also will have
    subpoena power to compel the attendance of witnesses, including hostile witnesses, police officers
    and court personnel.[62]
    In a particularly serious case, where the state rules of criminal procedure provide for little in the
    way of discovery, and if it appears that the loss of the accused attorney's law license is all but certain,
    the defense attorney may choose to make the tactical choice of using the grievance proceeding as a
    discovery tool for the upcoming criminal trial. This is particularly true when an indictment has been
    returned without the opportunity to conduct a preliminary hearing as provided by federal law, or an
    "examining trial" provided by a code of criminal procedure in most states.
    If such a move is made, the defense attorney will often choose to have his client invoke his Fifth
    Amendment rights, and he will not testify. He cannot be compelled to testify if there is criminal
    litigation
    pending. If a disbarment suit is pending, his deposition can usually be taken, and his refusal to
    be deposed can be used against him at the disbarment trial, but not at a criminal trial. The exercise of
    the Fifth Amendment right may not be used for impeachment.[63]
    If the defense attorney's strategy is along those lines, he should request that the committee postpone
    its decision until after the criminal trial is completed. Even though the request will seldom be
    granted, it can do no harm to ask. If the request for a delay of the grievance proceedings is granted
    until after the criminal trial, and there is an acquittal, this outcome should be brought to the attention
    of the committee immediately.
    In most jurisdictions, even though the investigating bar attorney may not have an absolute right to
    pre-hearing discovery, cooperation with him is usually best. However, such cooperation does not
    require
    the defense attorney to build the prosecution's case, and extensive cooperation may very well
    result in that being done. Thus, defense counsel must walk a fine line between proceeding so as to
    irritate
    the committee by refusing to turn over documents, or cooperating and hoping that the matter
    will not be prosecuted. It is always a difficult choice.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney was not entitled to invoke privilege against self-incrimination when ordered to file list
    of all monetary sanctions imposed against him by any federal court since sanctions were public orders
    and attorney did not explain how information could incriminate him. In re Maurice (1995, CA7)
    73 F3d 124.
    [FN31] See, Murphy, Grievance Counsel for the Public, 26 NY LS L Rev 221 (1981).
    [FN32] See 8.
    [FN33] Theoretically, the investigation is secret in virtually all jurisdictions, but a good deal
    of cooperation among law enforcement agencies always seems to take place if criminal allegations
    are made.
    Section 25 Footnotes:
    [FN34].
    See 59.
    [FN35].
    Bates v. State Bar of Arizona (1977) 433 US 350, 53 L Ed 2d 810, 97 S Ct 2691, 51 Ohio Misc 1,
    5 Ohio Ops 3d 60, 2 Media L R 2097, 1977-2 CCH Trade Cases 61573, reh den 434 US 881, 54
    L
    000530
    Ed 2d 164, 98 S Ct 242, Beasley v. Burt (1946) 201 Ga 144, 39 SE2d 51.
    Shadur, Attorneys' Guide 43 et seq.
    Section 26 Footnotes:
    [FN36] See 21.
    [FN37] See 28.
    [FN38] see 29.
    [FN39] See 32 34.
    [FN40] See 35.
    [FN41] See 31.
    [FN42] See 30.
    Section 28 Footnotes:
    [FN43] ABA Standards for Lawyer Discipline, Standard 8.8.
    [FN44] Id., Commentary.
    [FN45] ABA Standards for Lawyer Discipline, Standard 8.10(a)(c).
    [FN46] ABA Standards for Lawyer Discipline, Standard 8.9, 8.11.
    [FN47] ABA Standards for Lawyer Discipline, Standard 8.10(a).
    [FN48] ABA Standards for Lawyer Discipline, Standard 8.10(b).
    See 58.
    [FN49] ABA Standards for Lawyer Discipline, Standard 8.10(c).
    See 9, 60.
    [FN50] ABA Standards for Lawyer Discipline, Standard 8.10(e).
    [FN51] ABA Standards for Lawyer Discipline, Standard 8.10, Commentary.
    [FN52] ABA Standards for Lawyer Discipline, Standard 8.10(d). See also Standards
    8.178.20.
    [FN53] ABA Standards for Lawyer Discipline, Standard 8.218.23. Whatever action is taken,
    the respondent is entitled to notice of any disposition of the matter following the investigation.
    Standard 8.14.
    Notice of formal charges and hearing by grievance or other disciplinary tribunal, 2 Am. Jur.
    Pleading and Practice Forms, Attorneys at Law, Form 287290; order to show cause why attorney
    should not be disciplined, 2 Am. Jur. Pleading and Practice Forms, Attorneys at Law,
    Form 291294.
    [FN54] ABA Standards for Lawyer Discipline, Standard 8.248.25.
    [FN55] ABA Standards for Lawyer Discipline, Standard 8.26.
    Section 29 Footnotes:
    [FN56].
    ABA Standards for Lawyer Discipline, Standard 8.27.
    [FN57].
    Id., Commentary.
    The filing of a so-called 'general denial,' which is permitted in civil court in some jurisdictions
    such as Texas and Oklahoma, is not considered a meaningful answer by grievance committees. They
    want admissions of facts that are not in controversy, denials of ones not believed to be true, and
    statements
    of point of view.
    [FN58].
    ABA Standards for Lawyer Discipline, Standard 8.28.
    [FN59].
    000531
    See 3.
    Section 31 Footnotes:
    [FN60] ABA Standards for Lawyer Discipline, Standard 8.29.
    Discovery in attorney disciplinary proceedings, 7 Am. Jur. 2d, Attorneys at Law 93.
    Depositiondiscovery procedures in disciplinary proceeding against attorney, 92 A.L.R. 2d
    1328.
    For forms of interrogatories to attorney and for forms directing witness to answer interrogatories
    in disciplinary proceedings, see 2 Am. Jur. Pleading and Practice Forms, Attorneys at Law,
    Forms 295296, 298.1 (supp.).
    [FN61] Id., Commentary.
    [FN62] ABA Standards for Lawyer Discipline, Standard 8.35.
    [FN63] Due process considerations in attorney disciplinary proceedings, 7 Am. Jur. 2d, Attorneys
    at Law 91.
    Sincerely,
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    grievance and complaint against DDA Young and WCPD Dogan, Leslie,
    and Bosler
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 9/08/12 1:50 AM
    To: complaints@nvbar.org; complaint@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    1 attachment
    9 8 12 grievance against DDA Young Dogan Bosler and Leslie.pdf (88.9 KB)
    Zach Coughlin, Esq.
    PO Box 3961
    000532
    Reno, NV 89505
    Tel: 775 338 8118
    Fax: 949 667 7402
    ZachCoughlin@hotmail.com
    September 9th, 2012
    State Bar of Nevada
    complaint@nvbar.org
    complaints@nvbar.org
    DavidC@nvbar.org
    Dear Bar Counsel,
    Dear Bar Counsel,

    Please accept this correspondence as a formal grievance against both Washoe County Deputy District Attorney
    Zach Young, Esq. and Washoe County Public Defender Biray Dogan, Esq. for the reasons set forth herein, with
    the understanding that I plan to supplement this further in the near future.
    Mr. Dogan, despite RPC sections devoted to diligence, competence, and communciations with clients, you failed
    to copy me on (or even inform me of) DDA Young's attempt to amend the complaint in RCR2012-065630 to a
    misdemeanor that would require, if a conviction is garnered, Bar Counsel to file Petition seeking suspension of
    one's law license under SCR 111(6), given "obstructing a public officer" is specifically delineated as a "serious
    offense" therein. I have, in the past in writing and verbally, indicated to Dogan and his supervisors Jim Leslie
    and Jeremy Bosler, that I demand to be copied of every filing in any case for which they appear for me.
    Dogan made contradictory and untruthfull statements to me with regard to whether he ever gave me a copy of my
    file in this matter. At first, Dogan indicated he did himself, and that he was sure of that, then minutes later he
    stated he was sure that he was there to witness Jim Leslie give me the one copy the WCPD ever provided me.
    000533
    WCPD staff has admitted to me that there was a package available for me to pick up, after the date on which
    Dogan and Leslie allege they gave me my file, but that because I did not pick it up soon enough, it was withdrawn
    from the front desk. Thereafter Dogan and Leslie have maintained the position that I was provided that package,
    with varying, contradictory, evasive, and vague statements (and in Leslie's case, testimony) as to just how and
    when that occurred.

    Additionally, Dogan and Leslie persist in seeking to combine hearings in this case and the two cases Jim
    Leslie is attorney of record on (RCR2011-063341 and RCR2012-067980)with the case Dogan is attorney of
    record on (RCR2012-065630, and which Leslie alternately, when its convenient to him, maintains he is allowed to
    chip in on, or, alternately, maintain that he has not a connection thereto and thus any misconduct in connection
    with that case may not provide a basis for a conflict being found in RCR2011-063341), despite my express
    indication that Dogan and Leslie must refrain from doing so.

    Further, DDA Young is violating RPC 3.8 and other ethical rules. In seeking to attain some leverage in
    RCR2012-065630 by amending the Complaint to a charge that falls wtihin the purview of SCR 111(6) ("serious
    offense", etc), where the allegations do not provide probable cause for such a charge, DDA Young is violating
    RPC 3.8. Further, DDA Young has a duty to divulge to the Court the conflict inherent in his office's partnering
    with an entity that I am suing on a wrongful discharge/discrimination/retaliation basis, Washoe Legal Services,
    which is partnering with the WCDA in an Early Case Resolution program that is violative of the Sixth
    Amendment Right to Counsel.

    http://sixthamendment.org/?p=463

    Rule3.8.Special Responsibilities of a Prosecutor. The prosecutor in a criminal case shall:


    (a)Refrain from prosecuting a charge that the prosecutor knows is not supported by probable
    cause;
    (b)Make reasonable efforts to assure that the accused has been advised of the right to, and the
    procedure for obtaining, counsel and has been given reasonable opportunity to obtain counsel;
    (c)Not seek to obtain from an unrepresented accused a waiver of important pretrial rights, such as
    the right to a preliminary hearing;
    (d)Make timely disclosure to the defense of all evidence or information known to the prosecutor
    that tends to negate the guilt of the accused or mitigates the offense, and, in connection with sentencing, disclose
    to the defense and to the tribunal all unprivileged mitigating information known to the prosecutor, except when the
    prosecutor is relieved of this responsibility by a protective order of the tribunal;
    (e)Not subpoena a lawyer in a grand jury or other criminal proceeding to present evidence about a
    past or present client unless the prosecutor reasonably believes:
    (1)The information sought is not protected from disclosure by any applicable
    privilege;
    (2)The evidence sought is essential to the successful completion of an ongoing
    investigation or prosecution; and
    (3)There is no other feasible alternative to obtain the information;
    (f)Except for statements that are necessary to inform the public of the nature and extent of the
    prosecutors action and that serve a legitimate law enforcement purpose, refrain from making extrajudicial
    comments that have a substantial likelihood of heightening public condemnation of the accused and exercise
    reasonable care to prevent investigators, law enforcement personnel, employees or other persons assisting or
    associated with the prosecutor in a criminal case from making an extrajudicial statement that the prosecutor would
    be prohibited from making under Rule 3.6 or this Rule.

    DDA Young has continually sought to deny Coughlin his right to a legitimate pre-trial hearing in RCR2012-
    000534
    065630, in fact, Young needs to answer to whether or not RMC Judge Nash Holmes and he (as well as Dogan or
    anyone with the WCPD) met, on or about February 27th, 2012, minutes before Judge Nash Holmes entered her
    courtroom in 11 TR 26800 and shortly thereafter found Coughlin in "criminal contempt" in a traffic citation trial,
    seconds after Coughlin testified that RPD Sargent Carter lied in his testimony related to the three traffic citations
    he had issued on Coughlin incident to Richard Hill, Esq's refusal to return Coughlin his client's files or Coughlin's
    state issued identifcation. Additionally, please add to this grievance, Reno City attorney Allison Ormaas, for her
    lack for Candor to the Tribunal (RPC 3.3) in asserting that the word "retaliation" and the subject of retaliation did
    not appear in the police report for that November 15th, 2011 traffic citation when clearly, the report reveals that is
    does. The SCR 117 Petition Coughlin now faces is based in large part on Judge Nash Holme's Order and
    subsequent grievance filed with the State Bar in connection with a Trial in 11 TR 26800 on February 27th, 2012,
    set for 1:30 pm, and DDA Young and Dogan allegedly met on February 27th, 2012, at or around 1:00 pm, despite
    having noticed Coughlin that the Status Conference set for that time in RCR2012-065630 had been vacated. Judge
    Nash Holmes Judicial Assitant could not locate Judge Nash Holmes for nearly 45 minutes on that date when the
    time for Trial came around. WCPD Bosler and Dogan have refused to confrim or deny whether they had any
    communications with Judge Nash Holmes or anyone connected with the RMC on or around that date regarding
    Coughlin's alleged "competency" issues. Leslie has been extremely evasive in answering such questions. Court's
    have a duty to suspend proceedings if competency issues are raised, across departments, and arguably across the
    RJC to the RMC, particularly if Judge Nash Holmes was privy to the "secret" Status Conference that was held on
    February 27th, 2012, depsite the RJC having vacated it and Dogan having communicated as much to Coughlin
    after Coughlin pointed out the scheduling conflict with 11 TR 26800. I am formally requesting Bar Counsel to
    initiate an inquiry into whether Judge Nash Holmes was privy to the Order for Competency Evaluation orderd on
    February 27th, 2012 in RCR2012-065630, and if so, whether she violated any RPC's by continuing to hold the
    Trial in 11 TR 26800, especially in light of her subsequent grievance/Complaint with the SBN and Orders in that
    matter.
    DDA Young violated RPC 3.8 in seeking to have Coughlin returned to custody in September 5th, 2012. There was
    absolutely no basis for Young seeking to do so at that time other than to disadvantage Coughlin, ego trip, and
    impermissilby coerce Coughlin out of pursuing any civil remedies that he may have available given the police and
    prosecutorial misconduct that Coughlin has systematically been subjected to in the last year.
    On that note, the July 3rd, 2012 arrest in RMC 12 CR 12420 for "distrubing the peace", no "proof of insurance"
    and "failure to secure a load on a truck" led to Coughlin spending 21 days in jail after the RPD, in conjunction
    with Reno City Attorney Jill Drake advocated for RMC Judge Gardner to raise the $1,415 bondable bail to $3,000
    cash only, on a "public saferty and welfare basis" despite the only permissilbe rationale for bail under Nevada law
    being to insure the defendant's appearance at trial. Please accept this as a grievance against John Kadlic and Jill
    Drake, Esq. for violating RPC's, including RPC 3.8. It is telling that the disturbing the peace charge and proof of
    insurance charge were dropped on September 4th, 2012, but not before a Reno City Attorney (the signature is
    illegible) sought to violate Soldal v. Cook County and Wheeler v. Coss some more by adding a trespass complaint
    against Coughlin, whom had, at the time of the arrest, two valid leases at the property in question. If a Reno City
    attorney filed a trespass charge, it is a violation of the RPC, and I wish for this to be construedas a grievance and
    for further investigation to be undertaken. Certainly, Keith Loomis grievance of August 28th, 2012 looks more
    supportable
    Rule3.3.Candor Toward the Tribunal.
    (a)A lawyer shall not knowingly:
    (1)Make a false statement of fact or law to a tribunal or fail to correct a false
    statement of material fact or law previously made to the tribunal by the lawyer;
    (2)Fail to disclose to the tribunal legal authority in the controlling jurisdiction
    000535
    known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or
    (3)Offer evidence that the lawyer knows to be false. If a lawyer, the lawyers
    client, or a witness called by the lawyer, has offered material evidence and the lawyer comes to know of its falsity,
    the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal. A lawyer
    may refuse to offer evidence, other than the testimony of a defendant in a criminal matter, that the lawyer
    reasonably believes is false.
    (b)A lawyer who represents a client in an adjudicative proceeding and who knows that a person
    intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding sGhall
    take reasonable remedial measures, including, if necessary, disclosure to the tribunal.
    (c)The duties stated in paragraphs (a) and (b) continue to the conclusion of the proceeding, and
    apply even if compliance requires disclosure of information otherwise protected by Rule 1.6.
    (d)In an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the
    lawyer that will enable the tribunal to make an informed decision, whether or not the facts are adverse.

    DDA Young violated RPC 3.3 when, at trial in RCR2011-063341 on August 29th, 2012 he asserted to RJC Judge
    Sferrazza that Layton v State presented mandatory binding authority in Nevada preventing Judge Sferrazza from
    excercising any discretition with regard to whether Coughlin could appear as his own co-counsel. Certainly,
    Wheby and other cases prove otherwise. Yet, DDA Young was insistent and clear in his statements that there
    was "mandatory, binding authority" preventing any excercise of such discretion by the court to permit a co-
    counsel arrangement.

    DDA Young has continually sought to deny Coughlin his right to a legitimate pre-trial hearing in RCR2012-
    065630, in fact, Young needs to answer to whether or not RMC Judge Nash Holmes and he (as well as Dogan or
    anyone with the WCPD) met, on or about February 27th, 2012, minutes before Judge Nash Holmes entered her
    courtroom in 11 TR 26800 and shortly thereafter found Coughlin in "criminal contempt" in a traffic citation trial,
    seconds after Coughlin testified that RPD Sargent Carter lied in his testimony related to the three traffic citations
    he had issued on Coughlin incident to Richard Hill, Esq's refusal to return Coughlin his client's files or Coughlin's
    state issued identifcation. Additionally, please add to this grievance, Reno City attorney Allison Ormass, for her
    lack fo Candor to the Tribunal in asserting that the word "retaliation" and the subject of retaliation did not appear
    in the police report for that November 15th, 2011 traffic citation when clearly, the report reveals that is does.

    Rule 3.3 (formerly Supreme Court Rule 172) is the same as ABA Model Rule 3.3.

    Rule3.4.Fairness to Opposing Party and Counsel. A lawyer shall not:


    (a)Unlawfully obstruct another partys access to evidence or unlawfully alter, destroy or
    conceal a document or other material having potential evidentiary value. A lawyer shall not counsel or assist
    another person to do any such act;
    (b)Falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a
    witness that is prohibited by law;
    (c)Knowingly disobey an obligation under the rules of a tribunal except for an open refusal based
    on an assertion that no valid obligation exists;
    (d)In pretrial procedure, make a frivolous discovery request or fail to make reasonably diligent
    effort to comply with a legally proper discovery request by an opposing party;
    (e)In trial, allude to any matter that the lawyer does not reasonably believe is relevant or that will
    not be supported by admissible evidence, assert personal knowledge of facts in issue except when testifying as a
    witness, or state a personal opinion as to the justness of a cause, the credibility of a witness, the culpability of a
    civil litigant or the guilt or innocence of an accused; or
    (f)Request a person other than a client to refrain from voluntarily giving relevant information to
    another party unless:
    (1)The person is a relative or an employee or other agent of a client; and
    (2)The lawyer reasonably believes that the persons interests will not be
    000536
    adversely affected by refraining from giving such information.

    DDA Young, on July 16th, 2012, violated RPC 3.4 when he made the statement to the Court in RCR2011-
    063341, at Trial, that Coughlin caused the continuance that was necessitated that day by Joe Goodnight, Esq.
    (WCPD) sudden removal from the case. Coughlin pointed out that even he had not been given any rationale
    for Goodnight's sudden removal from a Monday Trial when Goodnight had met with Coughlin for trial prep the
    Friday before, tending to indicate that either Young was privy to information from the WCPD that Coughlin was
    not privy to, or Young was making arguments not based in fact or law or in line with RPD 3.4(e). DDA
    Young then sought to backtrack, making mincing statements about how he "assumed" this or that and how he had
    not actualy had impermissilbe communications with WCPD Bosler (who was filling in for Goodnight). RJC
    Judge Sferrazza rebuked DDA Young, pointing out that he should not "assume" anything.

    DDA Young continues to impermissibly seek to leverage another obstructing/resisting/making a "false" statement
    to a public officer charge in RCR2012-067980, despite his having been provided excuplatory videos and despite a
    lack of probable cause to support the complaint, the information pled therein being deficient as well. Additionally,
    Coughlin's June 26th and July 3rd, 2012 emails (see below) make clear that the RPD, Reno Justice Court, Washoe
    County Sheriff, et al were made aware well in advance of the deficiencies in the 5 day unlawful detainer notice
    drafted and served by Lew Taitel, Esq's apparent business partners, Nevada Court Services, who are committing
    the unauthorized practice of law in their "eviction consulting services" (please see my recent grievance in that
    regard). An attorney who initiates, causes to be initiated, or threatens to initiate a criminal prosecution for the
    purpose of influencing a civil matter is violating the rules of ethics. See Model Code of Profl Responsibility
    DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or Threatening to Initiate, Criminal
    Prosecution as Ground for Disciplining Counsel, 42 A.L.R.4th 1000 (2006). DDA Young and the WCDA may be
    violating the following: Attorney violated professional conduct rules prohibiting conduct prejudicial to the
    administration
    of justice and prohibiting a lawyer from threatening to present criminal charges
    solely to obtain an advantage in a civil matter, where attorney threatened a complainant with
    criminal prosecution and a defamation suit to prevent him from pressing forward with a disciplinary
    complaint. State Bar Articles of Incorporation, Art. 16, Rules of Prof.Conduct, Rules
    8.4(d, g), LSAR.S. foll. 37:222. In re Robinson, 46 So. 3d 662 (La. 2010). Additionally, a practitioner may be
    sanctioned, or even disbarred, for coercing any person connected to the case, for making false statements of
    material fact or law, or for frivolous behavior before the immigration courts. A Plaintiff that has been harassed,
    intimidated or treated in a bad faith manner by a Defendant has two recourses: Rule 11(b)(1) and Rule 11(b)(2).
    However, malicious prosecution actions are necessary to deter persons from procuring the arrest of another
    maliciously and without probable cause. Hunt v. Lawson, 2008 WL 4691052 (Ky. 2008), as corrected, (Oct. 24,
    2008). Merlet v. Rizzo, 64 Cal. App. 4th 53, 75 Cal. Rptr. 2d 83 (1st Dist. 1998).
    WCPD Jim Leslie has violated RPC 1.2 in RCR2011-063341 in attempting to withdraw from criminal defendant
    Coughlin one of the few inviolable rights a criminal defendant has. Leslie has refused to attempt to procure
    authentication or foundation for the admission of excuplatory videos of the arrest of August 20th, 2011 in that case
    from any of the witnesses in the case. Rather, Leslie has maintained that he will only put on such videos (whether
    as evidence or to refresh a witness recollection, and or for impeachment purposes) if Coughlin himself takes the
    stand and provides authentication and foundation for the videos, thereby exposing Coughlin to a waiver of his
    right to decide whether or not to testify, and opening the scope of cross examination impermissibly. Further,
    Leslie has refused to do or provide any legal research to determine the permissibility of only utilizing portions of
    000537
    any such video evidence. That is to say, Leslie insists that the videos must be submitted in toto, even portions that
    damage Coughlin's case. Leslie has a duty of diligence and competence, and his blase refusal to provide any legal
    citation for his contention that Coughlin's defense may not include picking an choosing which portions of such
    videos to utilize in Trial is violative of those duties, in addition to violating RPC 1.2's dictate that a "lawyer shall
    abide by a clients decision concerning the objectives of representation and, as required Rule 1.4, shall consult
    with the client as to the means by which they are to be pursued" and that "the lawyer shall abide by the client
    s decision, after consultation with the lawyer, as to a plea to be entered, whether to waive jury trial and
    whether the client will testify...".
    Rule1.2.Scope of Representation and Allocation of Authority Between Client and Lawyer.
    (a)Subject to paragraphs (c) and (d), a lawyer shall abide by a clients decision concerning the
    objectives of representation and, as required Rule 1.4, shall consult with the client as to the means by which they
    are to be pursued. A lawyer may take such action on behalf of the client as is impliedly authorized to carry out the
    representation. A lawyer shall abide by a clients decision whether to settle a matter. In a criminal case, the
    lawyer shall abide by the clients decision, after consultation with the lawyer, as to a plea to be entered,
    whether to waive jury trial and whether the client will testify.
    (b)A lawyers representation of a client, including representation by appointment, does not
    constitute an endorsement of the clients political, economic, social or moral views or activities.
    (c)A lawyer may limit the scope of the representation if the limitation is reasonable under the
    circumstances and the client gives informed consent.
    (d)A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer
    knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of
    conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity,
    scope, meaning or application of the law.
    Further, this grievance seeks to have an investigation undertaken to deterimine whether the circumstances detailed
    in the June 7th, 2012 email by Coughlin to davidc@nvbar.org, and the WCDA, wherein a battery via a lit cigarette
    projected at Coughlin at close range by Cory Goble was the subject of a grant of immunity by the WCDA, despite
    the extent to which such conduct is illegal and reasonable calculated to dissuade Coughlin from testiying in
    RCR2011-063341. Further inquiry is requested as to the permissibility of WCPD Jim Leslie refusing to even
    bring up the subject on cross examination of Goble, Zarate or Duralde in that matter.
    Compensatory Damages Topic Summary Correlation Table References 117. Injury to reputation West's Key
    Number Digest West's Key Number Digest, Malicious Prosecution k67 Compensatory damages in a malicious
    prosecution action may include harm to the plaintiff's reputation caused by the underlying action,[FN1] including
    the damage to one's reputation from the malicious institution of administrative proceedings.[FN2] Thus, the
    plaintiff in an action for malicious prosecution may recover damages for injury to his or her reputation,[FN3]
    including injury resulting from the publication of reports of the proceedings.[ FN4] Caution: Although a malicious
    prosecution is, at common law, assumed to be harmful to an individual's reputation, it is nonetheless necessary to
    make an objective showing of an individual's reputation before the malicious prosecution versus the damaged
    condition of his or her reputation afterwards to support an award of damages for injury to reputation.[FN5] The
    plaintiff's own testimony that he or she lost respect due to the malicious prosecution is not enough, without other
    objective evidence, to support such an award.[FN6] Evidence of a plaintiff's prior arrests is properly admitted in a
    malicious prosecution action if that evidence bears directly on the question of whether or not the plaintiff's arrest
    in fact damaged his or her reputation, in view of his or her previous arrests.[FN7] However, it has also been held
    that a trial court does not err in excluding such evidence, because it has no relevancy to the issue of compensatory
    damages.[FN8] [FN1] Bhatia v. Debek, 287 Conn. 397, 948 A.2d 1009 (2008); Sikora v. Gibbs, 132 Ohio App. 3d
    770, 726 N.E.2d 540, 111 A.L.R.5th 685 (10th Dist. Franklin County 1999); Wecht v. PG Pub. Co., 725 A.2d 788
    (Pa. Super. Ct. 1999). [FN2] Melvin v. Pence, 130 F.2d 423, 143 A.L.R. 149 (App. D.C. 1942). [FN3] Browning
    v. Ray, 1968 OK 52, 440 P.2d 721 (Okla. 1968). [FN4] Grimes v. Greenblatt, 47 Colo. 495, 107 P. 1111 (1910).
    000538
    As to proof of publicity given to prosecution, see 119. [FN5] Rodick v. City of Schenectady, 856 F. Supp. 105
    (N.D. N.Y. 1994) (applying New York law). [FN6] Rodick v. City of Schenectady, 856 F. Supp. 105 (N.D. N.Y.
    1994) (applying New York law). [FN7] Delchamps, Inc. v. Bryant, 738 So. 2d 824 (Ala. 1999). [FN8] Szarejko v.
    Amerling Volkswagen, Inc., 55 A.D.2d 801, 390 N.Y.S.2d 266 (3d Dep't 1976).

    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    confidentiality of grievances/bar complaints
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 9/05/12 1:12 PM
    To: davidc@nvbar.org
    Dear Mr. Clark,

    WCPD Jim Leslie just today, in full view of me, purported to communicate with someone with the
    State Bar of Nevada as to whether I had filed a bar complaint or grievance against him, and,
    apparently, in the course of that, Mr. Leslie was informed that I had filed one against Keith Loomis,
    Esq. Is such information not confidential? Should Mr. Leslie have been informed of that?

    On a similar note, Mr. King (in his SCR 117 Petition) has made allegations that I entered my former
    law office by "breaking and entereing" though he provides no support for that contention, and, upon
    information and belief, Mr. King was informed that the "basement" to that address was not secured
    with a lock of any sort.

    Further, Mr. King revealed to me a great deal of information about the particulars of Stephen Harris's
    case, what the money was being used on, how the self-reporting actually came about, etc., etc. I
    000539
    would imagine such information is actually confidential, and should not have been brought up,
    though I have not review the record in Mr. Harris's case that closely, yet.


    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    August 2rth, 2012 grievance against Jim Leslie, WCPD
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 9/05/12 12:11 PM
    To: davidc@nvbar.org; patrickk@nvbar.org; complaint@nvbar.org; complaints@nvbar.org
    Dear Bar Counsel,

    Please file this as a grievance or formal complaint.

    The WCPD has refused many reasonable requests I have made so far. Additionally, I
    believe there is a basis for moving for a dismissal in rcr2011-063341 given Mr. Goble's
    failure to show up at the last Trial Date in this matter. Mr. Leslie continues
    to refuse preserve the issues for appeal.
    I am that the WCPD has refused to respond in writing to my inquiries regarding any
    February 27th, 2012 communication with the Reno Municipal Court or Judge Nash
    Holmes. "...Also, please respond to my inquiries with respect to whether you or
    anyone with your office (including Biray Dogan) ever communicated with anyone with
    000540
    the Reno Municipal Court (including Judge Nash Holmes, especially on February 27th,
    2012 at or around 1:00pm, despite the fact that your client, me, was noticed that the
    Status Conference previously scheduled for that time was vacated....and despite the fact
    that on that very date your associate Biray Dogan and moved for a second competency
    evaluation ordered of me, apparently after meeting with DDA Young and another
    person or two....and neither you nor anyone with your office has responded to my
    inquiries in that regard, vis a vis, whether Judge Nash Holmes (whom could not be
    found by her staff in court at that time, which was the time schedule for the traffic trial
    in 11 TR 26800 on 2/27/12 at which I was found in criminal contempt and sentenced to
    5 days in jail, and for which I have had to report that conviction to the State Bar of
    Nevada and the USPTO). How is it that Mr. Dogan could get an Order signed
    requiring me to have a District Court competency hearing, yet I was permitted to stand
    trial in RMC 11 TR 26800? Mr. Leslie has continually jumped in on cases assigned
    to Joe Goodnight or Biray Dogan and indicated to me that his supervisory capacity
    allows him to do so. He has argued to the Court that my behavior in these various
    cases precluded a successful Faretta canvas, then argues his behavior for a conflict
    analysis is limited to just rcr2-11-0633441. That is not just. Now, if anyone with
    the RMC, particularly Judge Nash Holmes or anyone in communication with Her
    Honor, was present at or aware of the import of the February 27th, 2012 clandestine
    Status Conference between DDA Young and Deputy Public Defender Biray Dogan, I
    would like to know about it...
    On numerous occasions now I have requested, verbally and in writing, for the WCPD to
    provide me whatever part of my file in RCR11-065630 that I am permitted to have.
    Mr. Dogan, just recently made inconsistent statements to me regarding whether I was
    ever provided such materials. In the WCPD lobby, in person, Mr. Dogan at first
    indicated he was sure he himself provided me those materials, then scoffed at the idea
    of providing them again, if by chance I never actually received them. Then, Mr.
    Dogan shortly thereafter changed his account, and insisted Jim Leslie provided me
    those materials, in person no less..."
    Please note, I filed a grievance against Mr. Leslie on August 24th, 2012, and Mr. Leslie
    has had communication today with the State Bar of Nevada indicating the Bar is
    unaware of that, at least to some extent.
    That complaint or greivance read, in part:

    "Subject:WLS Let Taitel, conflict, professional misconduct, criminal misconduct
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/24/12 11:31 AM
    To: complaints@nvbar.org; complaint@nvbar.org
    000541
    Dear Bar Counsel, (omitted irrelevant material) ...Also, please add WCPD Jim Leslie to the
    complaint as he has continually refused to gather the audio cd from Milan Kreb's Protection Order
    extension hearing in the July 3rd, 2012 arrest matter RCR 2012-067980, in addition to failing to
    gather the July 16th, 2012 audio from the Trial in RCR 2012-063341 to determine whether the
    August 29th, 2012 court date is a hearing on pre-trial motions or, in fact, a Trial, in addition to the
    other misconduct Leslie has committed in my represenation, and add Biray Dogan, whom, along with
    Leslie apparently asserted to the RJC that I filed to show to a hearing in RCR2012-065630 on
    August 22th, 2012, despite WCPD staff Linda Gray admitting that she did not mail out the notice of
    the hearing to me as her office had marked my PO BOX 3961 Reno 89503 address as "no longer
    good" and, accordingly, failed to mail the notice, only to have Dogan assert that is was mailed, and
    provide a fax of the purported notice, baring the initials "LG" at the bottom, which Linda Gray
    confirmed was an indication that she prepared the letter. Dogan has refused to apprise the Court of
    his error and undue the prejudice to me brought by making me appear to be negligent and
    absentee. Further, Dogan and Leslie continue to try to combine hearings in these three cases to an
    impermissible extent."

    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    I don't get disbarred
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 8/30/12 9:40 AM
    To: davidc@nvbar.org
    Cc: patrickk@nvbar.org
    I don't get disbarred....I dis the Bar.
    Ah, you guys know I'm just funnin'...
    000542
    RE: NRS 649.020(1)...licensed as a bill collector?
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/24/12 7:41 PM
    To: rhill@richardhillaw.com; cdbaker@richardhillaw.com; complaints@nvbar.org; complaint@nvbar.org;
    davidc@nvbar.org; patrickk@nvbar.org
    Dear Mr. Hill and Mr. Baker,

    Page 18 of your recent 38 page Declarations point something important out:


    "While the law may allow you 10 judicial days to file your appeal, if you have been ordered to vacate
    the rental unit, you must take extra steps before the end of the 24 Hour eviction notice the
    constable/sheriff will give you in order to stay or stop the eviction."

    That is from one of the NV S. Ct forms, which I don't understand to be black letter law (as Mr. Hill
    seems to argue they are in underlying the passages about monetary penalties for frivolous appeals,
    etc...), but they may be instructive, I guess.

    What the above quotation indicates is that the WCSO/Constable must personally serve (well NRS
    40.253 mentions "receipt", and I have done lots of research on what "receipt" means and the only
    instructive examples hale from EEOC Right to Sue Letter filing deadline cases and DMV take away
    somebody's license/DUI cases....), but anyways, that quote above would imply at least 24 hours
    notice to the tenant after either, I don't know, reciept or "personal service" or "sheriff will give
    you"... for the tenant to vacate...what it doesn't say is that WCSO Deputy Machen can post the
    Lockout Order (allegedly) on the door and break in, then the RPD can later arrest one for criminal
    trespass:
    "Disciplinary Action Against Attorney for Aiding or Assisting Another Person in Unauthorized
    Practice of Law," 41 A.L.R.4th 361 (1985). Mr. HIll and Baker, your leveraging of Nevada
    Court Services "full service evictions", particularly to the extent you use them to criminally
    trespass behind an attorney's gated back yard and bang on windows, peer through blinds,
    shout threats and extortions and attempt to appear as though acting under color of law, etc....is
    questionable.
    An attorney who initiates, causes to be initiated, or threatens to initiate a criminal prosecution
    for the purpose of influencing a civil matter is violating the rules of ethics. See Model Code of
    Profl Responsibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or
    Threatening to Initiate, Criminal Prosecution as Ground for Disciplining Counsel, 42 A.L.R.4th
    000543
    1000 (2006). Additionally, a practitioner may be sanctioned, or even disbarred, for coercing any
    person connected to the case, for making false statements of material fact or law, or for
    frivolous behavior .

    Then there is Mr. Hill refusing to return my drivers license or wallet, much less my client files
    to me on November 15th, 2011, then having the Reno Police Department issue me three traffic
    citations, then Richard making jokes about my car's registration the next day when the only
    way Rich could have known about any issue there is by the RPD revealing privilege, private
    DMV information to Rich...

    Now, Mr. Hill, under Soldal v. Cook Co, you actually criminally trespassed given the void nature of
    any purported lockout (in light of yours and the WCSO failure to, under Aiken, strictly comply with
    procedural protections). Regardless, you point to forms for "Apartments", while, clearly, this was a
    commercial tenancy, and I didn't use forms to file the Tenant's Answer or Affidavit, and I did plead a
    commercial tenancy, while you failed to plead non-payment of rent, which, of course, makes this a
    wrong site surgery (of a legal services nature), wherein any eviction order is void under NRCP
    60(b)(4) for, among other things, lacking subject matter jurisdiction....as was the case, also, for the
    rent escrow deposit of $2,275 that the RJC ordered me to deposit and which I still did not have
    possession of at the time of my criminal trespass arrest. Mr. Hill, you may also want to consider
    how accurate and truthful your testimony was in RMC 11 CR 26405 vis a vis whether Coughlin
    failed to leave the premises upon any alleged demand by the RPD, and or whether the RPD identified
    themselves prior to, allegedly, Dr. Merliss kicking the door down. Then the Reno PD might want
    to consider Wheeler v Cross and whether probable cause was lacking for a custodial arrest,
    particularly where, allegedly, most, if not all of the elements of RMC 8.10.010 did not occur,
    allegdly, in the presence of the officer (meaning a custodial arrest was not an option). Then you
    might want to review the videos that you provided to the RMC prosecutors (including Merliss going
    through my medications and the "large collection of pills" that you and your contractor, Phil Stewart
    testified to in Affidavits (which on the video, are clearly vitamins, not "pills"). Then you will want
    to gather any evidence (and I mean anything at all, Mr. Hill) supporting yours or Mr. Baker's
    contention that a "crack pipe and bag of weed" was found at the former law office. I definitely
    anticipate you making some lame excuse that you didn't manage to photograph this "crack pipe and
    bag of weed", and that you absolute failure to have any proof thereof other than your own dubious
    personal attestations is not unusual, nor is your failure to alert the police of this contraband,
    particuularly considering the extent to which you have never failed previously to involved the police
    at the drop of a hat (to arrest me for jaywalking on January 13th, 2011, or to help you with your
    Temporary Protection Order on the same date from the RJC, which you promptly dropped at the
    extension hearing on January 31st, 2012 when you no longer had a need to prevent me from
    peaceably video taping your contractor throwing away non fungible property relevant to a wrongful
    000544
    eviction damages analysis, and evidence relevantt to the fact that amongst the several thousands of
    dollars of costs you claimed ina sworn memorandum, included $1,080 for "boarding up" the
    property, which, of course, your contractor did, in part, with my own plywood that was already there
    (Stewart used distinctive pieces of wood that I had gathered previoulsy, and I will let you guess
    whether I have media proof of my possession and ownership of it prior to the recordings and
    photographs of it being screwed to the boarch to "board the place up" despite yours and his failure to
    remove or affix in any real way window unit air conditioners. I notice the place is still not
    rented over one year later, and your client is, according to you, out $60,000 in attorney's fees for a
    house not worth $90,000, at this point.

    Then there is Baker and Hill arguing for $20K in attorney's fees for the summary eviction stage of
    the case in Justice Court, despite NRS 69.030 and JCRCP 3 forbidding it, with Baker citing to a
    manufacture of controlled sustance statute to support it. Then there is Baker and Hill moving for,
    and prevailing, on an attorney's fees during appeal motion, the $42,500 in fees largely built up my
    preparation for and attendance at hearings like the one on November 7th, 2011, which was
    necessitated in large part by Baker's "remixing" Judge Sferrazz'a Order of October 28th, 2011 to the
    tune of the "rent escorw" $2,275 not being mine, as Judge Sferrazza ruled it was (though he did say
    it would be held in the meantime as a bond on appeal), but rather, Baker "remixed" that Order as
    rendered to say the $2,275 was his clients....is that larceny? Is that a violation of the rules of
    professional conduct requiring candor to the tribulan and fairness and candor in dealings with the
    opposing party? Or NRCP 11 (and NRS 40.400 makes NRCP applicable to landlord tenant
    matters, such as NRCP 6(e), regarding the "service" (constructive or otherwise) of a Lockout
    Order. So, that makes it Hill and possibly Baker who criminally trespassed inside the former law
    office all the times they went in the property prior to the technical compliance with service of the
    Lockout Order (which, arguably, still has not occured, and given the legal nullity of the Lockout
    occurring prior to such service....). So, check out Soldal v. Cook Co.

    Sincerely,

    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    000545
    ZachCoughlin@hotmail.com

    From: rhill@richardhillaw.com
    To: zachcoughlin@hotmail.com; cdbaker@richardhillaw.com
    Subject: RE: NRS 649.020(1)...licensed as a bill collector?
    Date: Tue, 21 Feb 2012 08:14:18 -0800
    zach - is it that you don't read?
    is it that you don't understand what you read?
    or, is it that you read the statute, understood it, and just pump out these blatant mistatements of the law
    because you think that you can get away with it?

    tell me which it is
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Sunday, February 19, 2012 7:30 PM
    To: rhill@richardhillaw.com; cdbaker@richardhillaw.com
    Subject: NRS 649.020(1)...licensed as a bill collector?
    Dear Sirs,
    Given that you have apparently sent me bill collection notices, is your firm or either of
    you licensed as a bill collector? If so, please provide some proof thereof. Also, I
    would like my security deposit back please incident to the wrongful eviction by your
    client Matt Merliss from 121 River Rock St., Reno, NV 89501.
    Pursuant to NRS 649. 020(1), "[c]ollection agency" is defined as "all persons engaging, directly or indirectly, and
    as a primary or a secondary object, business or pursuit, in the collection of or in soliciting or obtaining in any
    manner the payment of a claim owed or due or asserted to be owed or due to another. " -5- 1 2. Pursuant to NRS
    649. 010, "[c]laim" is defined as "any obligation for the payment of 2 money or its equivalent that is past due."
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    WLS Let Taitel, conflict, professional misconduct, criminal misconduct
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/24/12 11:31 AM
    To: complaints@nvbar.org; complaint@nvbar.org
    Dear Bar Counsel,

    000546
    I would like to file a formal grievance against Lew Taitel, Washoe Legal Services, Joe Garin, and
    Nevada Court Services in connection with the matters set forth below, and my case against WLS is
    on appeal before the Nevada Supreme Court right now, with Garin moving to dismiss my appeal
    based upon a failure to timely file an Opening Brief caused by these two fraudulently procurred
    arrests. see N. S. Ct. case 60302.

    Also, please add WCPD Jim Leslie to the complaint as he has continually refused to gather the audio
    cd from Milan Kreb's Protection Order extension hearing in the July 3rd, 2012 arrest matter RCR
    2012-067980, in addition to failing to gather the July 16th, 2012 audio from the Trial in RCR 2012-
    063341 to determine whether the August 29th, 2012 court date is a hearing on pre-trial motions or, in
    fact, a Trial, in addition to the other misconduct Leslie has committed in my represenation, and add
    Biray Dogan, whom, along with Leslie apparently asserted to the RJC that I filed to show to a
    hearing in RCR2012-065630 on August 22th, 2012, despite WCPD staff Linda Gray admitting that
    she did not mail out the notice of the hearing to me as her office had marked my PO BOX 3961
    Reno 89503 address as "no longer good" and, accordingly, failed to mail the notice, only to have
    Dogan assert that is was mailed, and provide a fax of the purported notice, baring the initials "LG" at
    the bottom, which Linda Gray confirmed was an indication that she prepared the letter. Dogan has
    refused to apprise the Court of his error and undue the prejudice to me brought by making me appear
    to be negligent and absentee. Further, Dogan and Leslie continue to try to combine hearings in
    these three cases to an impermissible extent.

    From: zachcoughlin@hotmail.com
    To: jgarin@lipsonneilson.com
    Subject: WLS Let Taitel, conflict, professional misconduct, criminal misconduct
    Date: Fri, 24 Aug 2012 11:24:39 -0700

    "69 a.l.r. 4th 410" "negligence, inattention, or professional incompetence of attorney in criminal defense"
    "Disciplinary Action Against Attorney for Aiding or Assisting Another Person in Unauthorized Practice of
    Law," 41 A.L.R.4th 361 (1985).
    An attorney who initiates, causes to be initiated, or threatens to initiate a criminal prosecution for the
    purpose of influencing a civil matter is violating the rules of ethics. See Model Code of Profl
    Responsibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or Threatening to
    Initiate, Criminal Prosecution as Ground for Disciplining Counsel, 42 A.L.R.4th 1000 (2006). Additionally, a
    000547
    practitioner may be sanctioned, or even disbarred, for coercing any person connected to the case, for
    making false statements of material fact or law, or for frivolous behavior before the immigration courts.
    A Plaintiff that has been harassed, intimidated or treated in a bad faith manner by a Defendant has two
    recourses: Rule 11(b)(1) and Rule 11(b)(2).

    Taitel works for WLS now. Taitel's partners at Nevada Court Services, upon information and
    belief, recently had me arrested or contributed thereto (through R. Wray's perjured affidavit of
    personal service, attempted breaking and entering and attempted trespass and assault and NCS's and
    Jeff Chandlers unauthorized practice of law and other activities) on both June 28th, 2012 and July
    3rd, 2012.

    I want a written response from you and WLS explaining this to me and what steps have been taken to
    ameliorate this misconduct. Oh, Taitel also undertook to be my court appointed public defender in
    RMC case 11 cr 26405 for which I received a criminal trespass conviction on June 18th, 2012 and
    NCS criminally trespassed and assaulted me on numerous occasions through the eviction matter
    RJC Rev2011-001708 from which that criminal trespass conviction sprung. Taitel withdrew from
    the case without following RMC Rules regarding filign a written motion explaining the reasoning for
    seeking an Order granting withdrawal. I was suing NCS at the time Taitel took on my
    representation in that matter, while Taitel shared and office, staff, fax number with NCS and was
    listed on NCS's website as their "Staff Attorney" and "associated with" NCS. Taitel is now part of
    the ECR program run by WLS, in some connection with the WCDA (and the WCSO arrested me on
    July 3rd, 2012 with NCS in tow, NCS purporting to criminally trespass me from and entire
    Apartment Complex wherein I still had two valid leases and where the one eviction order was
    fraudulently procured by those committing the unauthorized practice of law (R. Wray lied about
    effecting personal service on my on June 14th, 2012 and the 5 day unlawful detainer notice was
    deficient listing Sparks Justice Court, as the appropriate forum to file a Tenant's Answer....then NCS
    received a Lockout Order from Reno Justice Court, despite my advance notice to both the RJC,
    WCSO, RPD and Sparks Justice Court regarding these jurisdictional defects and due process
    deficiencies.

    Sincerely,
    Zach Coughlin
    PO BOX 3961
    000548
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    a complaint and grievance against RMC appointed defenders and Reno
    City Attorney Prosecutors, and Richard Hill and Casey Baker
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 8/21/12 7:29 PM
    To: complaint@nvbar.org; complaints@nvbar.org; davidc@nvbar.org
    1 attachment
    complaint and grievance for bar counsel re rmc defenders and reno city attorney prosecutors.pdf
    (450.1 KB)
    Dear Bar Counsel,
    Please see attached, Respectfully Submitted with a hope that all of these matters will just be gotten past..
    Sincerely,

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    grievance and or complaint
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 8/21/12 7:21 PM
    To: complaints@nvbar.org; complaint@nvbar.org
    15 attachments
    final motion to dismiss 11 cr 26405 3 3 12.pdf (698.4 KB) , hill is lying about thinking I accidentally
    filed the wrong thing in carpentier case.pdf (45.4 KB) , 3 16 12 fax to wcso re eviction park terrace
    000549
    hill etc.pdf (1761.7 KB) , CV11-03628-2633891 (Reply...).pdf (164.9 KB) , CV11-03628-2625640
    (Mtn for TRO).pdf (153.5 KB) , 6.4.10 letter to Hall from Casey Baker describing same things
    Richard HIll does.pdf (57.1 KB) , CR11-2064-2676094 (Exhibit 2).pdf (130.1 KB) , CR11-2064-
    2676094 (Opposition to Mtn ...).pdf (171.6 KB) , CR11-2064-2682479 (Supplemental ...).pdf (153.7
    KB) , from nv supreme court website on eviction stay packet instructions.pdf (28.0 KB) , Eviction
    Procedure - Washoe County Sheriff's Office - 911 Parr Blvd, Reno, Nevada.pdf (80.9 KB) , CV11-
    03628_2750229 Machem up to his old tricks again.pdf (26.9 KB) , What Every Civil Litigator Needs
    to Know About Criminal Law.pdf (122.8 KB) , 3 7 12 11 TR 26800 rmc NOTICE OF APPEALS
    ETC MOTION.pdf (1301.3 KB) , JOHN TARTER TransparentNevada year city failed to report.pdf
    (25.7 KB)
    Against Richard Hill and RMC defenders and Reno City Prosecutors
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: glennm@nvbar.org; davidc@nvbar.org; patrickk@nvbar.org
    Subject: supplement to Richard Hill thing
    Date: Fri, 16 Mar 2012 15:14:01 -0700
    Dear Bar Counsel,

    Material in this supplement also serves to fulfill my own RPC 8.3 duty with respect to the
    misconduct of any other attorney's (or those who are licensed as attorneys but maybe are employed in
    some alternate capacity currently) whose conduct in these materials is so deserving. I will try to
    phone into Mr. King as he requested, though Judge Nash Holmes recently converted my phones to
    the Reno Municipal Court after they were booked into property at the Washoe County Jail, who
    thereafter made several contradictory statements as to whether the City of Reno Marshals came and
    took those and other items out of secured property or evidence and did what they may or whether
    such materials remained with the Jail and or whether the Jail actually even considers whether there
    might be a conflict of interest in releasing such property to these Marshals or the RMC. One thing
    I do know is that I did not offer those materials into evidence and am not sure Judge Nash Holmes
    should be doing so on my behalf, or on behalf of the prosecutor. When I say prosecutor, I should
    clarify, I mean Deputy City Attorney Ormaas, and not Judge Holmes.

    000550
    I have other materials I will be providing to supplement this and other grievances in short order.

    Sincerely,

    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    unauthorized practice of law in summary eviction proceedings
    grievance and complaint
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 8/21/12 6:16 PM
    To: davidc@nvbar.org; complaints@nvbar.org; zyoung@da.washoecounty.us;
    mkandaras@da.washoecounty.us; complaint@nvbar.org; patrickk@nvbar.org
    3 attachments
    THE FLORIDA BAR RE ADVISORY on upl in evictions.pdf (210.5 KB) , THE FLORIDA BAR v.
    MICKENS upl evictions.htm (13.5 KB) , complaint to bar counsel regarding eviction unauthorized
    practice of law.pdf (97.3 KB)

    Dear Bar Counsel and Washoe County District Attorney,


    Please accept this complaint and grievance against Jeff Chandler and Nevada Court Services, ACG-APMI.com,
    Northwind Apartments, Dwayne Jakob, Sue King and her company Western Nevada Management, and Gayle
    Kern, Esq., and the Park Terrace HOA. Just today I received a bill from Northwind Apartments for "legal work"
    done by their legal counsel from Nevada Court Services (which is apparently a business partner with an actuall
    attorney Lew Taitel, or otherwise "associated with" him, as he is their "Staff Attorney" according to their website,
    of a substantial amount for the legal work done by unlicensed non-attorneys. Regardless of the law of the case or
    res judiciate/claim preclusion effect of the various Orders that have been entered in the cases involving myself and
    Nevada Court Services or Northwind Apartments (doign business in 10 states as acg-apmi.com, and the FDCPA
    violations such a letter entails, this unauthorized practice of law has damaged me substantially. I have had phony
    protection orders taken out against me by a Northwind Maintenance Man, I have had Nevada Court Services
    purporting to trespass me from a location where I still had two valid leases, I have had the RPD violate Soldal v
    Cook County, etc., etc. and I have had NCS process servers trespass upon my former home law office with
    impunity, all while being arrested by RPD Officers for an alleged trespass of my own, which I reported to Bar
    Counsel in line with SCR 111. This unauthorize practice of law is hurting people, and I hope you will address this
    problem, even where some RJC Judges are interpreting NRS 40.253 in a way that goes far beyond the simple
    allowance to have an "agent" of the property owner (here is is a corporation, ie, not allowed to appear through a
    non attorney individual) serve a 5 day unlawful detainer notice, but to the point where NCS's Jeff Chandler et al
    are making complicated legal opinions for money on behalf of clients (is it a NRS 40.780 situation or a breach of
    lease 40.253?). This is particularly bad where NCS and Chandler are also getting paid to serve process in these
    same cases and where NCS's R. Wray lied about conducting personal service on me on June 14th, 2012 in a way
    that cut my time to file a Tenant's Answer short by three days (regardless, NCS's June 14th, 2012 5 day Notice
    was defective in that it listed to wrong forum for the tenant to file the Tenant's Answer-it listed Sparks Justice
    000551
    Court for a property located in Reno). I was arrested by the WCSO due to the confusion attendant to the Sheriff
    arriving three days early to perform an eviction (in light of the lies, in a sworn affidavit by NCS's R. Wray) that
    rested upon a Lockout Order from a different court than that which was listed as the appropriate forum to file the
    Tenant's Answer, (RJC versus SJC).
    In Nevada, a corporation may not proceed in proper person before this court. See id.; Guerin v. Guerin , 116 Nev.
    210, 214, 993 P.2d 1256, 1258 (2000). What is funny is that now Lew Taitel, whom is "associated with" NCS and
    listed as their "Staff Attorney" and whom accepted my case for representation when Richard Hill, Esq. got me
    convicted of criminal trespass from the same former law office where NCS trespassed behind my backyard gate
    and banged on windows and looked through blinds in teams of two, ringing door bells for 40 minutes at a time 3
    times a day (of course the RPD chose not to follow up on my police reports, natch)...Well, Taitel now works for
    Washoe Legal Services, even further cutting attorneys and the Sixth Amendment out of the game in some ECR
    deal WLS has been trying to get a piece of for years.
    Unger v. Landlords' Management Corp. 114 N.J. Eq. 68, 168 A. 229, In Naimo v. Fleming, 95 Nev. 13, 588 P.2d
    1025, the Supreme Court of Nevada upheld dismissal of a complaint filed in violation of NRCP 11, the Nevada
    rule equivalent of Rule 55.03(a). Out-of-state counsel signed the complaint and filed it in Nevada court but
    apparently did not serve defendants. Eighteen months later, plaintiff filed an amended complaint signed by a
    Nevada attorney. Defendants did not learn of the lawsuit until the amended complaint was filed. Further, the
    statute of limitation expired on the claims before the amended complaint was filed. The trial court dismissed
    plaintiffs claims upon defendants motion finding that plaintiffs out-of-state counsel deliberately
    violated the rules governing signing of pleadings and admission of out-ofstate attorneys in an effort to keep
    their lawsuit viable but avoid the cost of associating Nevada counsel. Id. at 1026. The trial court also held the
    case should be dismissed as the statute of limitations had run prior to the filing of the amended complaint which
    was signed by the Nevada attorney. The Nevada Supreme Court affirmed dismissal of plaintiffs claims.
    Basic Charging Statute for UPL The Unauthorized Practice of Law is governed by NRS 7.285 A person
    shall not practice law in this state if the personIs not an active member of the State Bar of Nevada or otherwise
    authorized to practice law in this State pursuant to the rules of the Supreme Court. First Offense = Misdemeanor
    Second Offense = Gross Misdemeanor Third Offense = Category E Felony, punishable by imprisonment of not
    less than 1 year and not more than 4 years, and a fine of not more than $5000. The State Bar of Nevada may bring
    a civil action to secure an injunction and any other appropriate relief.
    I have recently been involved in several landlord tenant matters in which I am a party, summary eviction
    proceedings. In those matters, the Reno Justice Court has allowed a property manager from Western Nevada
    Managment, Sue King, (RJC Rev2012-000374) to appear on behalf of Park Terrace Homeowners Associtation
    (prior to Gayle Kern's entry), and, in another matter, allowed Nevada Court Services to appear on behalf of
    Northwind Apartments (which is owned and operated by ACG-AMPI, Inc., which does business in ten states, as a
    corporation, which typically must retain an attorney to represent it in court.). Nevada Court Services is a process
    server company, though they list an attorney as a "Staff Attorney" on their website and as "associated with" their
    organization. However, in the summary eviction proceedings in which I was a party, NCS appeared on behalf of
    clients, crossing the bar and arguing in court, and, apparently, drafting filings, which they also serve and
    sometimes notarize, on behalf of clients. NCS's Jeff Chandler does not have a law license as far as I know, nor did
    he go to law school. However, his reckless abuse of court processes resulted in my recently spending 18 days in
    jail and being arrested twice in a 4 day period. On June 14th, 2012, a R. Wray from NCS attempted to break into
    my rental #29 at 1680 Sky Mountain Dr. in Reno at Northwind Apartments. He then field a sworn affidavit
    attesting to have effectuated personal service upon me at that time of a 5 day unlawful detainer notice. There is no
    way R. Wray could have possibly seen through a metal door and ascertained that someone of "suitable age and
    discretion" was there to receive that notice sufficient to effectuate "personal service" and thereby cut down the
    time to file a Tenant's Answer by 3 days (NRCP 6(e) accords three additional days for mailing in the computation
    of time to respond, etc.). Further, the 5 day notice that NCS prepared and posted (constructive or substituted
    service) was insufficient in that it mistakenly listed Sparks Justice Court as the appropriate forum for the tenant,
    myself, to file a Tenant's Answer under NRS 40.253(6).
    I confirmed with the Reno Justice Court that, even if I did need to file a Tenan'ts Affidavit in Reno Justice Court
    despite that insufficient notice, that, given the lack of personal service on June 14th, 2012, I would have until at
    000552
    least noon on June 28th, 2012 to file the Tenant's Affidavit. I submitted one for filing with the Sparks Justice
    Court and may have so submitted one with the Reno Justice Court (I need to do more research, etc...) but I know I
    further intended to fax file another Tenant's Affidavit with the RJC before noon on the June 28th, 2012 just to be
    sure. I am forwarding to you emails I sent the Sparks and Reno Justice Courts on june 26th, 2012 and July 2, 2012
    highlighting the insufficiency of notice on the 5 day unlawful detainer notice, etc...
    NRS 40.253(3), provides that:
    "3. A notice served pursuant to subsection 1 or 2 must:
    (a) Identify the court that has jurisdiction over the matter; and
    (b) Advise the tenant:
    (1) Of the tenants right to contest the matter by filing, within the time specified in subsection 1 for the
    payment of the rent or surrender of the premises, an affidavit with the court that has jurisdiction over the matter
    stating that the tenant has tendered payment or is not in default in the payment of the rent;"
    I am writing to request a formal opinion as to whether inidividuals who lack a law license (or someone like
    myself, who has one that is currently suspended) can represent parties in landlord tenant matters and otherwise
    perform legal work, draft filings, appear on behalf of landlords or tenants, etc., and if they may not, to file this
    written grievance against NCS, Richard G. Hill, Esq., and Casey Baker, Esq., and Western Nevada Management,
    Sue King, and Gayle Kern, Esq., and Lewis Taitel, Esq.
    Additionally, a basis for the grievance against Baker and Hill is that they sought $20,000 worth of attorney's fees
    in a summary eviction proceeding, despite NRS 69.030 precluding it and despite Baker's citing an attorney's fees
    statue that related to a complete non-issue, the manufacture of a controlled substance by an evicted tenant.
    Additionally, Baker and Hill have no managed to be awarded some $43,000 worth of attorney's fees on appeal
    despite the fact that much of that award was necessitated by the hearing and preparation for such a hearing and
    filign of documents related thereto, to undo the attorney's fee/cost award at the summary eviction proceeding level
    and Baker's submitting a proposed Order to Judge Sferrazza in RJC Rev2011-001708 that transferred the right to
    some $2,275 that I was forced to deposit into the RJC as rent escrow (despite the dictates against the Court
    so requiring found in NRS 40.253(6)) to their client, Matt Merliss, despite the fact that Judge Sferrazza's Order as
    rendered expressly stated that that money should be returned to me, subject to being helf for some time as an
    appeal bond.
    Justices in the Reno Justice Court have been allowing this from my experience, and I wish to know if I am able to
    perform such work while my license is suspended. While NRS 40.253 does seem to lend some support to the view
    that a "landlord's agent" is able to do some things (service notices, etc.), I find no support for the contention that
    such a "landlord's agent" non-attorney like Jeff Chandler of NCS is permitted to cross the bar and represent clients
    in summary eviction proceedings and otherwise draft legal filings (some of which wind up greatly damaging
    members of the public, such as myself in light of the two arrests I face, much less the civil damages and lost time
    incident to NCS's err in listing Sparks Justice Court as the forum under NRS 40.253(3)(a)-(b) and in their
    enabling their process server R. Wray to lie about effecting "personal service" on June 14th, 2012).
    Florida has a case on point: However, an exception exist for evictions. In those cases, a corporation may not
    appear pro se and must be represented by an attorney. Johnstown Properties Corp. v. Gabriel, 50 Fla. Supp. 138
    (Fla. Polk Cty. court 1980).
    Operating an eviction service by providing information to clients concerning eviction procedures (People v.
    Landlords Professional Services (1989) 215 Cal.App.3d 1599); Thus California today defines law practice as
    providing legal advice and legal instrument and contract preparation, whether or not these subjects were
    rendered in the course of litigation. Birbower, Montalban, Condo & Frank, P.C . v Superior Court., supra, at
    128. Providing legal advice or service is a violation of the State Bar Act if done by an unlicensed person, even if
    the advice or service does not relate to any matter pending before a court. (Mickel v. Murphy (1957) 147
    Cal.App.2d 718, 721.) This definition of law practice is broad and non-specific, but that policy choice is one
    which the California courts have made consciously. The California court of appeals has summarized the rationale
    for this broad approach as follows: [A]ny definition of legal practice is, given the complexity and variability of the
    subject, incapable of universal application and can provide only a general guide to whether a particular act or
    activity is the practice of law. To restrict or limit its applicability to situations in the interest of specificity would
    also limit its applicability to situations in which the public requires protection. 7 People v. Landlords Professional
    000553
    Services (1989) 215 Cal.App.3d 1599, 1609. In sum, California uses a broad standard for defining law practice to
    maximize its ability to protect its citizens from wrongs arising from the practice or counterfeited practice
    of law. It constitutes the unlicensed practice of law for a nonlawyer to represent a third party in an eviction.
    Generally speaking, a nonlawyer may not prepare evictions forms for another unless the nonlawyer is merely
    typing the information provided in writing by the individual or completing a Supreme Court Approved form with
    the factual information provided by the individual. An exception exists for property managers. In The Fla. Bar re:
    Advisory Opinion Nonlawyer Preparation of Landlord Uncontested Evictions, 605 So. 2d 868 (Fla. 1992),
    clarified, 627 So. 2d 485 (Fla. 1993) the Court held that a property manager may sign and file complaints for
    evictions and motions for default in uncontested residential evictions for nonpayment of rent as long as the
    property manager is using a Supreme Court Approved form.
    Jeff Chandler of NCS and Sue King of Western Nevada Management are going far beyond giving clients forms to
    fill out. Chandler is advising his clients on complicated legal distinctions between NRS 40.780 and NRS 40.253,
    in addition to suborning perjury by his process server R. Wray, as well as lying to tenants about the import of his
    "criminal trespass" warnings under NRS 207.200.
    At first Sue King decides to pursue an eviction under a No Cause Notice, but then the day comes to file the
    Landlord's Affidavit and she figure out it is more advantageous to pursue an eviction under a failure to pay rent
    theory. That is fraud where specific notice periods are required for each different type of Notice pursued.
    In the following cases involving allegations that a nonlawyer engaged in the unauthorized practice of law, the
    courts held, where it had been asserted that the defendant specifically engaged in conduct involving real estate
    matters, that the defendant was in contempt due to such conduct. A nonlawyer's actions, consisting of filing initial
    eviction complaints for residential landlords, counseling landlords about legal matters with regard to tenant
    eviction actions, typing or printing orally communicated information on tenant eviction forms set forth in a
    petition, and appearing in court at judicial proceedings for tenant eviction, constituted the "unauthorized practice
    of law" (former Fla. Stat. Ann. 83.001), punishable by contempt, the court held in The Florida Bar v. Mickens,
    505 So. 2d 1319 (Fla. 1987). The Florida Bar filed a petition charging a nonlawyer with the unauthorized practice
    of law and contempt of a previous order that enjoined the nonlawyer from the practice of law, the matter was
    referred to a referee for hearing, and the state supreme court, on review, approved the referee's recommended
    findings and discipline and held that the nonlawyer's actions constituted the "unauthorized practice of law," and
    that the unauthorized practice of law justified incarceration, a $1,000 fine, assessment of costs, and an injunction.
    Both NCS and Western Nevada Property Management appear to be going beyond using Nevada Supreme Court
    forms. Indeed, WNM serves a 30 day No Cause Notice then files a Landlord's Affidavit, apparently, that alleged
    failure to pay rent (and if the subtenant was a commercial tenant, then such an eviction is impermissible under
    NRS 40.253). Further NCS is seemingly providing legal counsel to Northwind Apartments, alternatively
    counseling it to pursue an eviction under NRS 40.253 under a breach of lease theory, only to subsequently file and
    pursue such an end under NRS 40.760.
    I reported by conviction for criminal trespass to the USPTO and Bar Counsel in Nevada in RMC 11 CR 26405. In
    the summary eviction matter incident to that case RJC Rev2011-001708, NCS, in my opinion, criminally
    trespassed into my former home law office's gated backyard on numerous occasions and otherwise harrassed me in
    attempting to effectuate personal service of various notices in the context of a summary eviction proceeding (one
    against a commercial tenant where the failure to pay rent was neither plead nor notice, in violation of the dictates
    of NRS 40.253). I realize some of these things slide in the day to day of a Justice Corut, but when a patent
    attorney's livelihood is taken away and it gets litigated on a federal level, as a result criminal conviction, the result
    may be different. Regardless, in that same criminal trespass case, the attorney who shares an office space with
    NCS, a fax number, apparently a receptionist, and is listed as "associate with" their organization and as their "Staff
    Attorney" on NCS's website, Lewis Taitel, Esq., was appointed as my public defender by the RMC in 11 CR
    26405, despite the fact that I had attempted to sue NCS just one month prior (apparently his conflicts check failed
    to catch that, and he subsequently failed to comply with RMC Rules related to disclosing via written motion to
    basis for seeking and Order grantign his withdrawal as attorney of record, only to pass the case to Roberto
    Puentes, Esq., whom subsequently admitted a close personal friendship with Taitel and business relationship with
    NCS).
    While Richard G. Hill and others apparently are able to file grievances with the State Bar that are accorded case
    000554
    numbers and Bar Counsel resources for months, the greivances I filed with respect to these matters have been
    rejected, and I would like an explanation of why if I may be provided one.
    Simply put, I am pretty sure I cannot hang out a shingle to perform heart surgeries tomorrow with impunity, and
    these non-lawyers should not be permitted to have such a dramatic effect on somethign so primary to the lives of
    members of the public, ie, the real property they rent for shelter, business purposes, or storage, etc.
    However, the Washoe County Sheriff's Office effecutated a lockout at 10 am on the morning of June 28th, 2012
    with an Order from the Reno Justice Court. Jeff Chandler of NCS was present at that time an attempted to serve
    me a notice informing me I was being "criminally trespassed" from the entire Northwind complex at that time.
    However, I still had two other valid rentals or lease agreements to units #71 and #45, and as such, do not believe a
    criminal trespass warning was possible with respect to the entire complex.
    Real estate relatedHeld in contempt
    [Cumulative Supplement]
    In the following cases involving allegations that a nonlawyer engaged in the unauthorized
    practice of law, the courts held, where it had been asserted that the defendant specifically engaged
    in conduct involving real estate matters, that the defendant was in contempt due to such
    conduct.
    A nonlawyer's actions, consisting of filing initial eviction complaints for residential landlords,
    counseling landlords about legal matters with regard to tenant eviction actions, typing
    or printing orally communicated information on tenant eviction forms set forth in a petition,
    and appearing in court at judicial proceedings for tenant eviction, constituted the "unauthorized
    practice of law" (former Fla. Stat. Ann. 83.001), punishable by contempt, the court held
    in The Florida Bar v. Mickens, 505 So. 2d 1319 (Fla. 1987). The Florida Bar filed a petition
    charging a nonlawyer with the unauthorized practice of law and contempt of a previous order
    that enjoined the nonlawyer from the practice of law, the matter was referred to a referee for
    hearing, and the state supreme court, on review, approved the referee's recommended findings
    and discipline and held that the nonlawyer's actions constituted the "unauthorized practice of
    law," and that the unauthorized practice of law justified incarceration, a $1,000 fine, assessment
    of costs, and an injunction.
    See New Jersey State Bar Ass'n v. Northern New Jersey Mortg. Associates, 22 N.J. 184,
    123 A.2d 498 (1956), where the court held that while the state supreme court has the power to
    punish for contempt those engaged in the unauthorized practice of law, here, though an abstract
    company was seemingly practicing law in some aspects of its operations, a record of injunction
    proceedings against the abstract company and its affiliate was inadequate to warrant a
    general peremptory determination against the defendant without a complete record of details
    of their method of doing business, buttressed by testimony and records relating thereto.
    The court held that one engaged in the business of preparing petitions and precepts in dispossess
    cases was practicing law unlawfully and was subject to punishment for contempt (
    N.Y. Jud. Law 750(7)) in In re Collins, 169 Misc. 234, 7 N.Y.S.2d 188 (Sup 1938).
    In a presentment charging a defendant with engaging in the unauthorized practice of law,
    the state supreme court held that the acts of the defendant, who, under debt pooling plans,
    gave advice in connection with, inter alia, the execution of a note and mortgage, and a conditional
    sale note, and who undertook to handle litigation against one of these individuals, constituted
    the unauthorized practice of law by the defendant, who was not licensed, and who
    would be held in contempt for such actions, the court held in In re Pilini, 122 Vt. 385, 173
    A.2d 828 (1961). By advising his clients in the instant matters, and in the manner as stated,
    the defendant invaded the field reserved for duly licensed attorneys, and his conduct in giving
    this legal advice constituted practicing law, the court declared. Such unauthorized practice of
    law is a criminal contempt in the court, and the instant defendant would therefore be adjudged
    guilty of contempt, the court concluded.
    See the following additional cases involving allegations that a nonlawyer engaged in the
    unauthorized practice of law, where the courts held, in cases in which it had been asserted that
    000555
    the defendant specifically engaged in conduct involving real estate matters, that the defendant
    was in contempt due to such conduct, where...
    Nevada
    Pioneer Title Ins. & Trust Co. v. State Bar of Nev., 326 P.2d 408 (Nev. 1958)
    As stated in Lowell Bar Ass'n v. Loeb, supra [315 Mass. 176, 52 N.E.2d 34], 'The actual practices of the
    community have an important bearing on the scope of the practice of law.'
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    MORE RELEVANT LAW
    Landlord's Corner - Evictions and Unauthorized Practice of Law
    A. Right to Proceed Pro Se
    In Ohio, a person can always represent himself in court. This is called appearing "pro se" and is a common
    (though unwise) practice where very little is at stake, such as in small claims courts around the state. Why is it
    unwise? The two main reasons are that attorneys who regularly perform evictions will be a great deal more
    familiar with the ins and outs of the law than the lay person. Secondly, an attorney will see the case objectively,
    and a dispassionate eye is a more effective observer of events than the landlord who may see things subjectively,
    having his vision clouded by emotions.
    B. Representing Other Persons or Entities
    But to represent another person or another entity (such as a company, a trust, or an LLC), you must be certified by
    the Ohio Supreme Court to practice law or you are engaging in the unauthorized practice of law. This rule affects
    landlords whose property is owned by a corporation or managed by a rental company. Owning a property in a
    corporate form has become very popular lately as a way of limiting the landlord's personal liability. This way, if
    the landlord is sued because of an injury at the property, the most he can lose is the value of the property
    (assuming his insurance isn't enough to cover it). His personal assets cannot be touched.
    000556
    In the past, some landlords tried to file evictions via their employees, or tried to file the actions themselves on
    behalf of the corporation owning the property. They reasoned that since they were the 100 percent owners of all
    the shares of the corporation, they should be able to represent it in court. The problem was that these employees
    and corporate shareholders were not attorneys.
    1. Ruling from the Ohio Supreme Court
    In the case of Cleveland Bar Association v. Picklo, (2002), 96 Ohio St.3d 195, Lynn Picklo had been filing
    complaints in the Cleveland Municipal Court, Housing Division, for forcible entry and detainer [evictions], as well
    as for the recovery of past due rents. Picklo was not licensed to practice law in the state of Ohio, but she
    nevertheless filed these claims and appeared in court on behalf of the property owner since she was the rental
    manager.
    Ms. Picklo argued that R.C. 1923.01(C)(2), which defines "landlord" for the purpose of invoking a county,
    municipal, or common pleas court's jurisdiction in most forcible entry and detainer actions as "the owner, lessor, or
    sublessor of the premises [or] the agent or person the landlord authorized to manage premises or to receive rent
    from a tenant under a rental agreement."
    She also cited R.C. 5321.01(B), which, with respect to landlord-tenant remedies in general, similarly defines
    "landlord" as "the owner, lessor, or sublessor of residential premises, the agent of the owner, lessor, or sublessor,
    or any person authorized by the owner, lessor, or sublessor to manage the premises or to receive rent from a tenant
    under a rental agreement." She argued that since she was the rental manager, she was the "landlord" and thus was
    entitled to bring the lawsuit on behalf of the owner of the property.
    It was a clever argument, but in the end, it would not wash with the Ohio Supreme Court. Under the Constitutional
    doctrine of Separation of Powers, the Ohio Supreme Court has the inherent power to determine who can practice
    law before the courts of Ohio. While it was true that the Ohio Legislature passed laws in conflict with the Ohio
    Constitution, the Ohio Constitution wins out in the case of such conflicts. The reason for this is because the Ohio
    Constitution is the document that set up the Ohio Legislature in the first place. The Ohio Legislature draws its
    ability to pass laws from the Ohio Constitution, and thus it cannot make laws contrary to the Ohio Constitution.
    So Ms. Picklo was found to be engaging in the unauthorized practice of law, and since that time, all evictions filed
    by persons not the owners of the property require the services of an attorney licensed to practice in the state of
    Ohio.
    000557
    II. Eviction Complexities
    There are other good reasons to hire an attorney to do evictions, even if the property is owned in the landlord's
    name (thus permitting pro se representation).
    A. Three Day Notice Requirement and Issues of Timing
    One is the three day notice requirement. Most landlords in Ohio realize that they must post a properly worded
    three day notice to vacate upon the rented property before they can file an eviction. But few landlords have a good
    grasp of the timing issues as they apply to the calculations of the three days.
    Firstly, the three days do not start to run on the day that the three day notice is posted. Secondly, any day in which
    the court is not open does not count as a day. Let's look at an example of how this works.
    1. Example of Three Day Notice Timing
    Larry Landlord has a tenant who has not paid his rent. On January 12, 2006, he posts a properly worded three day
    notice to vacate upon the door. The day of the posting does not count towards the three days. Friday, January 13,
    2006 will be the first day of the three day period which counts. Saturday and Sunday will not count. Monday,
    January 16, 2006 will not count either because it is Martin Luther King Day, a national holiday upon which the
    court is closed. So Tuesday, January 17, 2006 will be the second day, and Wednesday, January 18, 2006 will be
    the third day.
    If Larry Landlord has an attorney, that attorney will know that the eviction cannot be filed until the next Thursday,
    January 19, 2006, seven days later. But if Larry does the eviction alone, he might think that filing it on Tuesday,
    January 17, 2006 would be fine since more than three days will have passed.
    If, at the hearing, the error is pointed out by the tenant, the tenant's attorney, or noted by the court, the eviction
    000558
    action will have to be dismissed. All of the filing fees spent on the eviction will be lost, the eviction will have to
    be filed again, and the tenant will walk away from the first eviction hearing with a new found confidence that he
    can beat any eviction that the landlord throws at him. Better then to use an attorney and only have to handle the
    matter once.
    B. Thirty Day's Notice Sometimes Required.
    Another timing issue arises in relation to the type of breach that the landlord is alleging. If the landlord is alleging
    a breach of the rental contract, then all that is necessary to start the eviction process is the posting of a properly
    worded three day notice to vacate. But if the landlord is alleging that the tenant breached the tenant's duties under
    Ohio Revised Code Section 5321.05, then the landlord must first notify the tenant in writing of the problem and
    give the tenant 30 days to fix it. Only then can the three day notice be posted on the door to start the eviction
    process.
    Some landlords have tried to be too clever by half. They have inserted the text of Ohio Revised Code 5321.05's
    duties of the tenant into the lease agreement word for word, which enables the argument that any breach of R.C.
    5321.05 would also be a breach of the lease agreement. But Ohio courts have seen through this and ruled that if
    the violation is a breach of both the law and the lease, the landlord must still give the 30 day notice.
    Let's look at two examples.
    1. Unauthorized Dog
    Larry Landlord has a lease which prohibits the tenant from having a dog. Larry finds out that the tenant is
    violating this portion of the lease agreement. This is not a violation of Ohio Revised Code Section 5321.05 which
    says nothing about dogs. Thus, Larry Landlord does not need to give 30 day's notice before posting the three day
    notice to vacate.
    2. Unsanitary Conditions
    Larry Landlord has a lease agreement which says that the tenant shall keep all plumbing fixtures (sinks, toilets,
    000559
    --------------------------------------------------------------------------------
    tubs, etc.) in a clean and sanitary condition. During an inspection of the rented premises, Larry notices that the
    tenant is living like a complete pig, and that the plumbing fixtures are in an appallingly unsanitary condition. Larry
    would love to post the three day notice and get the eviction process going right away. But Ohio Revised Code
    Section 5321.05(A)(3) imposes a duty upon the tenant to "Keep all plumbing fixtures in the dwelling unit or used
    by him as clean as their condition permits . . .".
    Thus the tenant is violating both the lease and R.C. 5321.05(A)(3). Ohio Revised Code Section 5321.11(A)
    requires 30 days written notice from the landlord to the tenant to remedy any breach of the tenant's duties under
    Ohio Revised Code Section 5321.05. So Larry Landlord is going to have to give 30 days written notice to the
    tenant before he can post the three day notice to vacate. If the tenant remedies the problem within those thirty
    days, then the tenant will have a defense to the eviction.
    C. Tips for the Wise Landlord
    So the wise landlord hires an attorney to perform all of his or her evictions. In this way you can be more certain
    that the eviction will be done right and that possession will be returned to you as soon as possible.
    Where can you find such an attorney? There are several places. You can contact your local bar association and
    ask to be referred to an attorney who regularly performs evictions. If you call any large apartment complex, the
    rental managers there will more than likely refer you to the attorney they use. If you know an attorney personally,
    even if he or she does not conduct evictions, he or she will very likely know someone who does.
    Ethics Articles: The Unauthorized Practice of Law and Landlord Tenant Cases
    Focus on Professional Responsibility
    MBJ September, 1999
    000560
    By: Victoria V. Kremski, Assistant Counsel State Bar of Michigan
    The Unauthorized Practice of Law and Landlord Tenant Cases
    Landlord tenant cases comprise a large portion of the dockets of the District Courts in Michigan. Given the
    relatively rapid pace at which summary proceedings move and the important interests at stake for both parties
    involved, it is important to have a thorough understanding of the relationship between landlord-tenant actions and
    the unauthorized practice of law. Confusion sometimes arises regarding what types of landlords may file and
    litigate eviction cases on an in pro per basis, without engaging in the unauthorized practice of law.
    In Michigan, landlord-tenant law is governed by statute and specific court rules. In small claims actions, MCR
    4.302(B)(2) allows a corporation or partnership to appear and prosecute the proceeding through a lay
    representative. However, no statute or court rule exists in Michigan allowing corporations or other business entities
    to file and litigate matters on an in pro per basis in actions other than small claims court. Accordingly, the general
    body of case law addressing what constitutes the unauthorized practice of law applies to all landlord tenant
    proceedings.
    Individual, layperson landlords, i.e. those that own rental property in their individual capacity, may file and litigate
    eviction actions, in pro per, as they are acting on their own behalf and only their individual interests are affected
    by the proceeding. In contrast, Michigan law views corporations, partnerships and other legal entities as separate
    from their individual officers, shareholders, and partners. Lay officers, directors, partners and employees of
    corporate or partnership entities may not represent the entity in court proceedings or sign court documents without
    engaging in the unauthorized practice of law. Peters v. Desnick Broadcasting Co., 171 Mich App 283, 429 N.W.
    2d 654 (1988). Detroit Bar Association v. Union Guardian Trust Co., 282 Mich 707, 282 N.W.2d 432 (1938). See
    also Ginger v. Cohn, 426 F.2d 1385 (1970). Labato v. Pauline, 304 Mich 668 (1943), 8 N.W.2d 873. Yenglin v.
    Mazur, 121 Mich App 218, 328 N.W.2d 624 (1982).
    Michigan statutes are in accord with this case law. MCL 450.681, MSA 21.311 provides that corporations may not
    practice law or offer legal services. MCL 660.2051(2); MSA 27A 2051(2) recognizes partnerships as entities
    separate from their individual partners.
    The above restrictions do not prohibit lay employees of corporations and partnerships from drafting petitions,
    orders and other papers to be filed in court, provided the papers are filed under the name of, and by, an attorney
    000561
    who becomes personally responsible for the filings as if he or she had drafted them personally. Detroit Bar
    Association v. Union Guardian Trust Co., 282 Mich 707 (1938).
    Under current statutory and case law, a lay employee of a corporation or partnership cannot sign and file a
    complaint for termination of tenancy without engaging in the unauthorized practice of law. Further, any attempt to
    litigate the matter, by appearing in court on behalf of the business entity, leaves the individual open to prosecution
    for engaging in the unauthorized practice of law. MCL 600.916; MSA 27A916. The Supreme Court empowers the
    State Bar of Michigan, with authorization from its Board of Commissioners, to investigate and prosecute incidents
    of the unauthorized practice of law. Rule 16 of the Rules Concerning the State Bar.
    Michigan lawyers confronted with a non-lawyer appearing in court for a corporation or partnership have an ethical
    duty to bring the fact to the attention of the tribunal. Informal ethics opinion RI-10. The lawyer may also move for
    disqualification of the lay representative and to strike the pleadings.
    Likewise, Michigan judges are also under an ethical duty to prevent the unauthorized practice of law. Informal
    judicial ethics opinion JI-26 states, in part,
    "Administrative responsibilities of judges require them to instruct court personnel to regularly check pleadings
    filed with the court for signature and professional identification ("P" number) to assure the person representing a
    party is a member of the State Bar. Judges must instruct court staff to reject pleadings having no professional
    identification unless the person is appearing pro se.
    "When unauthorized practice of law activity occurs within the presence of a judge, the judge must stop the
    proceeding; place as much information on the record as possible; advise the party to seek the services of a licensed
    lawyer; and take other remedial action authorized by law."
    Given the important interests at stake for both parties in a landlord tenant proceeding, it is important for all
    involved to be sensitive to the unauthorized practice of law issue and how it may arise in such cases. A judge or
    lawyer who encounters unauthorized practice of law activity should report the incident to the State Bar of
    Michigan and its Committee on the Unauthorized Practice of law for investigation and possible prosecution.
    Unauthorized practice of law
    000562
    The judge cannot hear an eviction case if your landlord is a corporation unless the corporation is represented in
    court by a lawyer. The letters Inc. after the landlords name mean that it is a corporation. The corporate
    landlords case must be dismissed if someone who is not a lawyer prepared the complaint and summons.
    Unfortunately, some courts may bend the court rules and allow property managers, stockholders, and others who
    are not lawyers to act for the corporate landlord. This is improper under New Jersey law (except that a partner in a
    general partnership may file papers and appear pro se). Cite: Rule 6:10 and Rule 1:21-1(c).
    CLEVELAND BAR ASSOCIATION v. PICKLO. [Cite as Cleveland Bar Assn. v. Picklo, 96 Ohio St.3d 195,
    2002-Ohio-3995.] Unauthorized practice of law Person not licensed to practice law in Ohio filed complaints
    in the Cleveland Municipal Court, Housing Division, for forcible entry and detainer, as well as for recovery of past
    due rents on behalf of a property owner Engagement in the unauthorized practice of law enjoined.
    --Forwarded Message Attachment--
    THE FLORIDA BAR v. MICKENS
    505 So.2d 1319 (1987)
    THE FLORIDA BAR, Complainant,
    v.
    000563
    William K. MICKENS, Jr., etc., Respondent.
    No. 67687.
    Supreme Court of Florida.
    March 19, 1987.
    Rehearing Denied May 21, 1987.
    Joseph J. Reiter, President, West Palm Beach, Ray Ferrero, Jr., President-elect, Fort Lauderdale, John F.
    Harkness, Jr., Executive Director and John T. Berry, Staff Counsel, Tallahassee, James P. Hahn, Chairman,
    Standing Committee on Unauthorized Practice of Law, Lakeland, and Mary Ellen Bateman, UPL Counsel,
    Tallahassee, for The Florida Bar, complainant.
    Charles A. Gould, Jr., Miami Beach, for respondent.

    [ 505 So.2d 1320


    ]

    PER CURIAM.
    This unauthorized practice of law proceeding concerns a nonlawyer tenant eviction service and is
    before us on The Florida Bar's complaint and the referee's report. We have jurisdiction. Art. V, 15, Fla.
    Const.
    On March 16, 1983, The Florida Bar charged respondent with engaging in unauthorized practice of law
    by preparing legal documents in eviction proceedings involving commercial and residential landlords. As a
    consequence of the complaint, The Florida Bar and the respondent entered into a stipulation for settlement,
    in which respondent admitted actions forming the complaint's basis and agreed to refrain from engaging in
    unauthorized practice of law. On March 7, 1985, this Court approved the stipulation for settlement and
    permanently enjoined respondent from practice of law. The Florida Bar v. Mickens,465 So.2d 524 (Fla.
    1985).
    On September 24, 1985, The Florida Bar petitioned this Court, charging respondent with unauthorized
    practice of law and contempt of the March 7 order. After a hearing, the referee found that respondent, on
    June 10, 1985, received $170 from a landlord to file residential tenant eviction proceedings. Respondent
    filed these proceedings as president of Evictors of Florida, Inc. The referee further found:
    Chapter 83 restricts the role of a landlord's non-attorney agent in eviction actions exclusively to non-residential
    tenancies. In non-residential tenancies, Part I of the chapter permits the non-attorney agent to file the initial complaint
    for distress of rent or tenant eviction. In contrast, residential tenancies are governed by Part II of the chapter, which
    states that only the landlord may file a complaint for eviction. Because Part II does not reference the provision in Part I
    for filing eviction or distress of rent actions and only addresses actions filed by the landlord, 83.59(2), Florida
    Statutes, may be construed as excluding non-attorney agents from filing on behalf of a residential landlord.
    Further, in matters regarding tenant eviction actions, a landlord's non-attorney agent may not: (1) counsel the landlord
    about legal matters regarding tenant eviction actions, (2) appear in court or in any proceeding which is part of the
    tenant-eviction judicial process, or (3) type or print information on tenant eviction forms unless the landlord gives such
    information to its non-attorney agent in writing.
    The referee concluded:
    1.... [T]hat respondent, William K. Mickens, Jr., be found to have engaged in the unauthorized practice of law in
    contempt of the Supreme Court's order of March 7, 1986.
    2. That respondent be permanently restrained and enjoined from presenting himself as, or from using any accolation
    which expressly or impliedly suggests that he is, licensed to engage in the practice of law in the State of Florida.
    3. That respondent be permanently restrained and enjoined from conducting the following activities which constitute the
    unauthorized practice of law:
    A. Filing the initial complaints for residential landlords;
    B. Counseling landlords about legal matters regarding tenant eviction actions;
    C. Typing or printing information on the tenant eviction forms set forth in the petition where the landlord orally
    communicates such information to the respondent;
    D. Appearing in court or in any judicial proceeding which is part of the tenant eviction process.
    4. For the reasons that respondent has previously been found to have engaged in the unauthorized practice of law; that
    000564
    respondent offered no testimony in his defense in the instant proceeding; and further, that when given an opportunity to
    present a statement in mitigation of the sentence to be imposed, not only did respondent show no remorse but instead
    indicated that he would continue
    [ 505 So.2d 1321 ]
    to engage in the unauthorized practice of law, it is recommended that respondent be incarcerated in the Dade County
    Jail for a period of 20 days.
    5. That respondent be required to pay a fine in the amount of $1,000.00.
    6. That respondent be assessed the costs of this proceeding.
    We approve the referee's recommended findings and discipline. We reject respondent's contention that
    the proposed incarceration would be unduly harsh. As reflected in the referee's findings, respondent has
    shown no remorse and has indicated that he will continue to engage in the unauthorized practice of law.
    We restrain and enjoin the respondent, William K. Mickens, Jr., from representing, either expressly or
    impliedly, that he is licensed to engage in the practice of law in Florida, and from conducting the following
    activities: (a) filing the initial complaints for residential landlords; (b) counseling landlords about legal
    matters regarding tenant eviction actions; (c) typing or printing information on the tenant eviction forms set
    forth in the petition where the landlord orally communicates such information to the respondent; and (d)
    appearing in court or in any judicial proceeding which is part of the tenant eviction process.
    We direct that respondent, William K. Mickens, Jr., be immediately taken into custody and incarcerated
    in the Dade County jail for a period of twenty days. We further direct that he forthwith pay a fine of
    $1,000.00 to the Clerk of the Florida Supreme Court.
    Judgment for the costs in these proceedings in the amount of $536.24 is hereby entered against
    respondent, for which let execution issue.
    It is so ordered.
    OVERTON, EHRLICH, SHAW, BARKETT, GRIMES and KOGAN, JJ., concur.
    McDONALD, C.J., concurs in the referee's findings and imposition of a fine of $1,000.00, but dissents
    from the provision requiring incarceration.
    ATTORNEY GRIEVANCE OR COMPLAINT
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 8/21/12 5:15 PM
    To: complaint@nvbar.org
    1 attachment
    COMPLAINT TO BAR COUNSEL REGARDING WCPD 8 21 12 (146.8 KB)
    Dear Bar Counsel,

    Please see attached.

    Sincerely
    Zach Coughlin
    000565
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    ATTORNEY GRIEVANCE OR COMPLAINT
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 8/21/12 4:18 PM
    To: complaints@nvbar.org
    1 attachment
    COMPLAINT TO BAR COUNSEL REGARDING WCPD 8 21 12 (146.8 KB)
    Dear Bar Counsel,

    Please see attached.

    Sincerely
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    (No Subject)
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 8/20/12 11:59 PM
    To: davidc@nvbar.org
    1 attachment
    000566
    IMAG0709.jpg (2.6 MB)
    (No Subject)
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 8/20/12 11:56 PM
    To: davidc@nvbar.org
    1 attachment
    IMAG0709.jpg (2.6 MB)
    RE: Hearing date
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/17/12 6:26 PM
    To: Laura Peters (LauraP@nvbar.org)
    That works thanks Laura
    -----Original Message-----
    From: Laura Peters
    Sent: 17 Aug 2012 21:54:45 GMT
    To: 'Zach Coughlin'
    Subject: RE: Hearing date
    Zach:
    How about September 25th, work for you?
    - Laura
    -----Original Message-----
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, August 17, 2012 2:26 PM
    To: Laura Peters
    Subject: Hearing date
    Dear Ms. Peters,
    Please set the hearing date as soon as possible for any matter involving me that has been
    referred to the bar or the disciplinary panel.
    thanks
    Zach Coughlin
    000567
    Print Close
    Hearing date
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 8/17/12 2:26 PM
    To: laurap@nvbar.org
    Dear Ms. Peters,
    Please set the hearing date as soon as possible for any matter involving me that has been
    referred to the bar or the disciplinary panel.
    thanks
    Zach Coughlin
    please find enclosed my Petition under SCR 102(4)(d) and SCR 111(7)
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 8/13/12 6:24 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org
    1 attachment
    PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf (388.7 KB)
    Dear Sirs,
    Please find attached a courtesy e-copy of what I submitted for filing today:
    Petition for Dissolution of Temporary Suspension Pursuant to Supreme Court Rule 102(4); and/or alternatively, SCR 111(7) Petition to Show
    Good Cause For the Court To Set Aside Its Order Temporarily Suspending Attorney From the Practice of Law
    I hope to be able to engage the Board and the Bar in exploring the possibilities of some sort of negotiated
    agreement (I first need to see if the rules allow for such...), but in the meantime, just as a man, I don't want to be
    one of these lawyers who don't even file anything when their ticket gets pulled. It wasn't easy to get it, and
    while I abhor lawyers who subject their clients to a breach of the standard of care...I don't think it should be easy
    to have one's ticket taken away either. But that is just me, I am pro-lawyer. Hopefully the tone you will
    find in this filing (even if the brevity is still lacking) is a marked improvement from what you have seen out of me
    in the past year.
    Sincerely,
    000568
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    apology for taxing your fax machines and FW: Reno eviction noticed for
    Sparks Justice Court
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 8/09/12 2:38 PM
    To: davidc@nvbar.org; patrickk@nvbar.org; tsusich@nvdetr.org
    Dear Bar Counsel Clark, Assistant Bar Counsel King and Chairman Susich,

    I have been having some problems with my faxing service, it is an


    internet/computer based service and I am afraid one or more of you might
    have been faxed a long document more than once, and I apologize for the
    inconvenience or disruption this may have caused your fax machines.
    Additionally, in reviewing the Proofs of Service I filed and Notice of
    Electronic Filings in cases 60838 and 60975, I have noticed that Bar Counsel
    is not receiving service via electronic filing, and I believe I failed to mail
    copies of the documents served in light of my then belief that Bar Counsel
    were electronic filers (I am trying to ascertain whether Chairman Susich is
    an electronic filer at this point). Times are tight for me right now, and if
    you would consent to electronic service via email, I would certainly
    appreciate it, though I understand if you would prefer not to, and I am not
    certain whether or not that is even permissible. I am keen to comply with
    all the restrictions placed upon me in light of my suspension, and have
    000569
    noticed that the literature in that regard is somewhat mixed with regard to
    what constitutes the unauthorized practice of law, etc., and would appreciate
    any insight you may provide in that regard. I note that the Nevada
    Supreme Court's website has a power point presentation by Justice Hardesty
    in that regard, however it is geared towards, paralegals, and it seems that
    some jurisdictions accord a suspended attorney an even more broad
    definition of UPL than would be assigned to a non-attorney paralegal. It is
    my understanding that I am still an "attorney", but that my license is
    suspended (and that I have not been disbarred, thankfully, as those were
    made irrevocable in 2008 in Nevada).
    Again, I apologize for any overly burdensome taxing upon your fax
    machines and intend to file an amended proof of service to correct any
    failure on my part to appropriately serve you and to avoid any inference that
    you failed to respond to my filings.

    I either have or am attempting to complete the process of effectuating all the


    withdrawals as attorney of record for which I am required to perform. In
    my prior employment with Washoe Legal Services as a domestic violence
    attorney I was listed (and seem to still be listed) as attorney of record on a
    good deal of cases. It is my understanding that I do not need to move for
    an order granting my withdrawal in those matters, especially since the vast
    majority of them are no longer "open" cases and or have another WLS
    attorney associated with them at this point. Additionally, It is my
    understanding those matters for which I am listed as attorney of record, from
    my private private, but which have been "closed" cases for quite awhile now,
    do not require my obtaining such a withdrawal order. Would you
    informing me if my understanding of this is incorrect from the Bar's and the
    Board's viewpoint. Additionally, what is the position on representing
    clients in bankrupcty cases while one's state law license is suspended, or in
    federal courts for that matter, as well as in patent matters, including federal
    patent infringement litigation? I have gathered some authority on those
    matters and am providing it below in an attempt to demonstrate that I take
    000570
    this suspension seriously and the authority fo the Court, Bar Counsel and the
    Board, and wish to fully comply with all the restrictions place upon me
    during this suspension.

    The Reno Police Department, in my opinion, violated Soldal v. Cook


    County, 506 U.S. 56 (1992) in threatening to arrest me for criminal
    trespass if I went back to any part of the Northwind Apartments complex
    after the June 28th, 2012 lockout from unit #29. For the RPD to then
    arrest me for "Disturbing the Peace" would seem to further compound the
    wrongfullness of the situation in light of Wheeler v Coss, 344 Fed. Appx.
    420 (9th Cir. 2009). I do not wish to enter into a storm of litigation with
    all these powerful entities, but am merely trying to make a good faith effort
    to establish to Bar Counsel and the Disciplinary Board that I am attemptign
    to difuse these situations (it would be easier if I had more money available
    to me...) and do not wish to cause the Bar any embarassement. Hopefully
    you have found that many things that were once on the internet are no longer
    there and that some of these issues are resolving themselves.

    In light of my June 26th, 2012 email to the Washoe County Sheriff's Office
    and other advance notice I provided the relevant agencies, I beleive the
    WCSO made a wrongful arrest of me on June 28th, 2012. Further, on the
    record in court in RCP2012-000287, Northwinds Apartment maintenance
    Milan Krebs, on August 7th, 2011 seemingly admitted that the WCSO failed
    to appropriately identify itself after being asked whom was there just prior
    to the WCSO ordering or allowing Krebs to utilize a sawzall to cut open the
    metal door to unit #29. Asten v. City of Boulder, 652 F. Supp. 2d 1188
    (D. Colo. 2009), officers cannot escalate a situation or engage in deliberate
    and/or reckless conduct during a seizure that unreasonably creates and gives
    themselves a false basis for using such unreasonable 22 force; Knapps v.
    City of Oakland, 647 F. Supp. 2d 1129 (N.D. Cal. 2009), Officer Cardoza
    had an extremely hostile and unprofessional attitude toward the Plaintiff the
    minute he stepped out of his police vehicle and uttered a profanity at him.
    000571
    (These cases speak to the false utterance from Defendant Gomez about
    Preston fighting security escalating the situation from the way it was
    reported by 911 and their own dispatcher as it truly existed); Probable
    Cause: Wheeler v Coss, 344 Fed. Appx. 420 (9th Cir. 2009), Circuit
    affirmed Summary Judgment against qualified immunity in the arrest of
    Wheeler for harassment by police officer Brent Coss. "Probable cause to
    arrest exists when officers have knowledge or reasonably trustworthy
    information sufficient to lead a person of reasonable caution to believe that
    an offense has been or is being committed by the person being arrested." In
    establishing probable cause, officers may not solely rely upon the claim of a
    citizen witness that he was a victim of a crime, but must independently
    investigate the basis of the witness knowledge or interview other
    witnesses. Based on the totality of the circumstances that included Wheeler
    at the police substation on his own will asking the police for an escort home
    in order to keep the peace with his wife, & avoid violence. They never asked
    Wheeler if he had made any threatening statements earlier of an intent to
    harm or commit violence against his wife., see also, Williams v Sirmons,
    563 F. Supp. 2d 1315 (M.D. Fla. 2008); (Leverich, Herberner, & Gomez
    were aware of her lie that escalated the matter by making it appear to be a
    violent matter). Probable Cause: Wheeler v Coss, 344 Fed. Appx. 420 (9th
    Cir. 2009), Circuit affirmed Summary Judgment against qualified immunity
    in the arrest of Wheeler for harassment by police officer Brent Coss.
    "Probable cause to arrest exists when officers have knowledge or reasonably
    trustworthy information sufficient to lead a person of reasonable caution
    to believe that an offense has been or is being committed by the person
    being arrested." In establishing probable cause, officers may not solely rely
    upon the claim of a citizen witness that he was a victim of a crime, but must
    independently investigate the basis of the witness knowledge or
    interview other witnesses. Based on the totality of the circumstances that
    included Wheeler at the police substation on his own will asking the police
    for an escort home in order to keep the peace with his wife, & avoid
    violence. They never asked Wheeler if he had made any threatening
    statements earlier of an intent to harm or commit violence against his wife.,
    000572
    see also, Williams v Sirmons, 563 F. Supp. 2d 1315 (M.D. Fla. 2008);
    (Leverich, Herberner, & Gomez were aware of her lie that escalated the
    matter by making it appear to be a violent matter).

    I am including some of the research I have gathered below to demonstrate


    my efforts to ascertain the full import of the suspension of my license to
    practice law and to so comply with such conditions.
    Practicing law with federal license while state license is suspended or
    revoked
    Held or recognized not to be unauthorized practice of law
    The courts in the following cases held or recognized that, under the
    particular circumstances
    presented, attorneys whose licenses to practice law in the situs state were
    suspended or
    revoked did not engage in the unauthorized practice of law when they
    provided or offered to
    provide legal services.
    In U.S. v. Kirtley, 5 F.3d 1110 (7th Cir. 1993), the Seventh Circuit Court of
    Appeals recognized
    that attorneys admitted to practice before the federal bar do not engage in the
    unauthorized
    practice of law when they represent clients in bankruptcy actions while
    under suspension
    in the situs state. Although the court upheld the revocation of a probation of
    an attorney
    who otherwise continued to engage in the practice of law by handling a real
    estate transaction
    as an attorney while his license was suspended by the State of Illinois, it
    approved of the action
    taken by the U.S. District Court when it held that the attorney's bankruptcy
    000573
    activities did
    not constitute the unauthorized practice of law because he was still admitted
    in the federal bar.
    The only unauthorized practice of law committed by the attorney during the
    suspension period
    was his participation in unrelated real estate transactions as an attorney.
    Observation
    Although the Seventh Circuit's decision in U.S. v. Kirtley, 5 F.3d 1110 (7th
    Cir. 1993), is not
    accompanied by an analysis of the law affecting federally licensed attorneys
    who are suspended
    from practicing state law, the result is consistent with an earlier opinion
    from the circuit,
    U.S. v. Peterson, 550 F.2d 379 (7th Cir. 1977). In that case, the Seventh
    Circuit reversed a
    conviction for a claimed unauthorized practice of law while holding that
    state statutes regarding
    the unauthorized practice of law are not applicable to the practice of law in
    federal courts.
    As a result, it concluded in the Peterson case that a nonattorney could not be
    convicted in federal
    court of unauthorized practice of law for his efforts on behalf of criminal
    defendant in
    earlier prosecution in a United States District Court in Wisconsin.
    In The Florida Bar v. Penn, 421 So. 2d 497 (Fla. 1982), the Florida Supreme
    Court held
    that practicing law in a bankruptcy court as an attorney in Florida while
    under suspension by
    the Florida Supreme Court does not constitute the unauthorized practice of
    law. The court relied
    on In re Ruffalo, 390 U.S. 544, 88 S. Ct. 1222, 20 L. Ed. 2d 117 (1968),
    while saying
    that, although admission to practice before a federal court is derivative from
    000574
    membership in a
    state bar, suspension or disbarment by a state does not result in automatic
    suspension or disbarment
    by the federal court without some affirmative action by the federal court. It
    distinguished
    The Florida Bar v. Scussel, 240 So. 2d 153 (Fla. 1970), on the grounds that
    the individual
    in that case was neither a member of the Florida Bar nor of any federal
    court. It
    reasoned that, since the record clearly reflected that the attorney was still a
    member in good
    standing of the federal bar, he had made an appearance before a court which
    had authorized
    his practice of bankruptcy law.
    The court in In re Disciplinary Action Against Lallier, 555 N.W.2d 903
    (Minn. 1996), upheld
    a conclusion reached by a Minnesota referee in a state disciplinary
    proceedings that an
    attorney did not engage in the unauthorized practice of law when he
    practiced bankruptcy law
    in a U.S. District Court at a time when his license to practice law by the
    State of Minnesota
    was suspended. As observed by the court, the attorney's actions occurred at a
    time when his
    state license to practice law was suspended for nonpayment of attorney
    registration fees and at
    a time when he was on a restricted status for noncompliance with continuing
    legal education
    (CLE) requirements. The court also reasoned that the United States District
    Courts have a separate
    system for imposition of discipline and only require an attorney to report
    only public disciplinary
    actions. As a result, it said that the federal courts have reserved discretion to
    000575
    impose
    different discipline than that imposed by other jurisdictions. The court
    concluded that because
    the attorney had not been disciplined by the state so as to justify a
    suspension of his right to
    practice in the federal courts, the referee properly concluded that his practice
    in federal district
    court was not unauthorized.

    III. Lawyer
    A. While Lawyer's License to Practice Law Suspended or Revoked
    1. General Allegations
    25. General representations that defendant was attorney
    In the following cases involving allegations that a lawyer, whose license to
    practice law
    had been suspended or revoked, had engaged in the unauthorized practice of
    law, the courts
    determined, where it had been asserted that the defendant made general
    representations that he
    or she was, in fact, still a licensed attorney, whether the defendant was in
    contempt due to
    such conduct.[31]
    The sending of a letter addressed to the United States marshal, purporting to
    be signed by
    a disbarred attorney as "personal attorney" on a letterhead describing him as
    "lawyer" and
    threatening suit against the marshal by persons whom the disbarred attorney
    000576
    claimed to represent,
    constituted a representation that he was authorized to practice law in
    violation of a disbarment
    order, the court held in In re Fletcher, 107 F.2d 666 (App. D.C. 1939), a case
    in
    which the defendant was adjudged to be in contempt of court and sentenced
    to pay a fine or,
    on default thereof, to be committed to jail. The court, in so ruling, rejected
    the defendant's
    contention that, inter alia, the sending of the letter did not constitute a
    representation by him
    that he was authorized to practice law. The defendant also asserted, the court
    continued, that
    the contempt proceeding was void because not initiated by an affidavit,
    rather than by the report
    of the Grievance Committee. There is in the law governing contempts of this
    nature no
    affirmative requirement of an affidavit, the court indicated, and, aside from
    this, the answer of
    the defendant admitted the sending of the letter that was the subject of the
    Grievance Committee's
    report. With respect to the defendant's argument that the sentence of
    contempt was invalid
    because it failed to specify to whom the payment of the fine should be made,
    the court commented
    that the contempt was criminal, rather than civil, in nature, and that the fine
    000577
    was,
    therefore, payable to the United States, and, accordingly, to the clerk of the
    district court.
    Therefore, the court explained, the omission to specify to whom the fine
    should be paid was
    immaterial.
    In Danford v. Superior Court of Cal. in and for City and County of San
    Francisco, 49 Cal.
    App. 303, 193 P. 272 (1st Dist. 1920) (disapproved of on other grounds by,
    In re Stevens, 197
    Cal. 408, 241 P. 88 (1925)), a case in which the petitioner sought a writ of
    prohibition to restrain
    the superior court from entertaining proceedings instituted against him,
    charging him
    with contempt of court in holding himself out as entitled to practice law in
    the courts of the
    State, when he had no right to do so, the court commented that it appeared
    from the affidavit
    on which the contempt proceedings were based that several years prior to the
    proceedings he
    had been disbarred from practice in all courts of the State, and that 31/2
    years after his disbarment,
    the judge who had made the order of disbarment, acting upon his own
    motion, ordered
    the petitioner reinstated to the practice of the law in the superior court, and
    recommended full
    000578
    reinstatement to practice in all courts of the State by the district court of
    appeal. In accord
    with this order, the court continued, the petitioner took the oath to support
    the Constitution of
    the United States and of the State, and to discharge faithfully the duties of
    attorney and counselor
    at law. On March 24, 1913, the court elaborated, another judge sitting in the
    superior
    court in Los Angeles county set aside the order of reinstatement, on motion
    of an attorney representing
    the Bar Association of Los Angeles County, on the following grounds, as
    recited in
    the later order: "That said order was made without notice to the accuser in
    said disbarment
    proceedings, or any of the attorneys who prosecuted said proceedings; that
    said order was inadvertently
    and improvidently made; that at the time of the making of said order [the
    petition-
    er] had been convicted in said superior court of a felony, and had been
    sentenced to a term in
    the penitentiary of three years, and which sentence at the time of making
    said order had not
    expired, and that said court had no jurisdiction or power to reinstate or admit
    [the petitioner]
    as an attorney at law to said superior or any other court in the state of
    California." The court
    000579
    explained that the affidavit alleged that "at the present time, and for a
    considerable period of
    time, [the petitioner] has advertised and held himself out as practicing and
    entitled to practice
    law in the courts of this state," and that the petitioner maintained an office
    for that purpose in
    the city and county of San Francisco. The court held that the order for
    reinstatement was void,
    that the respondent was not exceeding its jurisdiction in entertaining the
    contempt proceedings,
    and that the writ for prohibition should be denied.
    A finding of the practice of law in contempt of an order of disbarment can
    be supported by
    testimony of a witness for whom the attorney has allegedly acted as an
    attorney, notwithstanding
    the disbarred attorney's assertions that he had never held himself out as an
    attorney and
    that the purported client was represented solely by attorneys authorized to
    practice law, the
    court held in In re Burton, 614 A.2d 46 (D.C. 1992). A disbarred attorney
    sought review of an
    order of a single judge of the court of appeals adjudging him in criminal
    contempt for violation
    of a disbarment order, and the court, on review, affirmed. The judge, though
    designated a
    member of the court, served as the trier of fact in adjudging the respondent
    000580
    in contempt, and
    in critical part, his findings rested upon an evaluation of the credibility of
    both the respondent
    and the client, the court indicated. The court, upon review of the record in
    light of the judge's
    carefully documented findings, concluded that they were well founded.
    While the respondent
    took repeated issue with the judge's decision to discredit his testimony and to
    credit that of the
    client, the court observed, that decision was based partly on what the judge
    found were implausible
    inferences the respondent asked to be drawn from his conduct, and partly on
    the corroboration
    afforded the client's testimony by other evidence in the case. The
    respondent's defense
    was that he never held himself out to the client as an attorney and that she
    was represented
    in the district court action solely by two attorneys authorized to practice law,
    the court
    continued, but there was ample support in the record for the judge's contrary
    finding that the
    respondent represented himself to the client as a lawyer and that, while the
    two attorneys may
    have formally signed court papers or entered their appearances for the client,
    they were no
    more than "marionettes on strings held by" the respondent. That is, the court
    000581
    concluded, it was
    the respondent who maneuvered and controlled their movements. Given the
    particular circumstances
    presented, the court sustained the sufficiency of the evidence of contempt.
    If a disbarred lawyer's alleged misconduct occurs after the lawyer has
    regained eligibility
    for licensure, but has not sought reinstatement, the disbarred lawyer is
    subject to an action for
    the unauthorized practice of law (Mich. Comp. Laws Ann. 600.916) or
    for contempt of
    court, if the lawyer practices or attempts to practice law without seeking
    reinstatement, or
    after being denied reinstatement, the court held in Grievance Adm'r v.
    Hibler, 457 Mich. 258,
    577 N.W.2d 449 (1998), the court noting that here, the attorney allegedly
    held himself out as
    an attorney after his disbarment. The statutory scheme (Mich. Comp. Laws
    Ann. 600.916)
    provides that it is unlawful for any person to practice law, or to engage in the
    law business, or
    in any manner whatsoever to lead others to believe that he or she is
    authorized to practice law
    or to engage in the law business, or in any manner whatsoever to represent
    or designate himself
    or herself as an attorney and counselor, attorney-at-law, or lawyer, unless the
    person so
    000582
    doing is regularly licensed and authorized to practice law in the State, the
    court instructed.
    Any person who violates the provisions of the code is guilty of contempt of
    the supreme court
    and of the circuit court of the county in which the violation occurred, and
    upon conviction is
    punishable as provided by law, the court elaborated. The statute, the court
    continued, does not
    apply to a person who is duly licensed and authorized to practice law in
    another state while
    temporarily in the state and engaged in a particular matter. The administrator
    may enforce a
    discipline order or an order granting or denying reinstatement by proceeding
    against a respondent
    for contempt of court, the court pointed out, and the proceeding must
    conform to established
    procedures, the court adding that the petition must be filed by the
    administrator in
    the circuit court in the county in which the alleged contempt took place, or
    in which the respondent
    resides, or has or had an office. Enforcement proceedings under the rule do
    not bar
    the imposition of additional discipline upon the basis of the same
    noncompliance with the discipline
    order, the court concluded.
    A suspended attorney who failed to change his listing in a telephone
    000583
    directory, who failed
    to advise a prospective client that he was not authorized to practice law and
    who allowed her
    to believe that he would write a letter or give other legal assistance, held
    himself out as entitled
    to practice law and thereby violated the order of suspension (Wash. Rev.
    Code Ann.
    2.48.180), the court held in In re Hawkins, 81 Wash. 2d 504, 503 P.2d 95
    (1972). In so ruling,
    the court instructed that Wash. Rev. Code Ann. 2.48.180 provides that
    any person who, not
    being an active member of the State Bar, or who after he or she has been
    disbarred or while
    suspended from membership in the State Bar, shall practice law, or hold
    himself or herself out
    as entitled to practice law, is guilty of a misdemeanor, provided, however,
    that nothing contained
    within the provision shall be held to in any way affect the power of the
    courts to grant
    injunctive relief or to punish as for contempt. The statute makes clear that
    holding oneself out
    as entitled to practice law constitutes contempt of an order of suspension, the
    court declared.
    Here, the court observed, the respondent took the position that no harm
    resulted from the incident
    under inquiry, since he rendered no services and charged no fee. However,
    000584
    the court
    stressed, this argument was untenable, for, pursuant to established rules, a
    lawyer shall not
    neglect a matter entrusted to him or her, the court adding that a lawyer owes
    entire devotion to
    the interest of the client, and the attorney should with reasonable dispatch
    and industry employ
    all honorable means available within the law to advance his or her client's
    interest and
    protect his or her client's rights. As such, continuing and protracted delay
    and procrastination
    in the performance of a lawyer's services and discharge of his or her duties,
    whether it be in
    advancing a cause in the courts or handling his affairs in the office, even if
    done without moral
    turpitude, do in one degree or another amount to a course of conduct that
    demonstrates, for
    the time being at least, a qualified lack of fitness to practice law, the court
    explained. The
    testimony of the prospective client demonstrated that the respondent's
    conduct did indeed produce
    an unfavorable impression upon the mind of that member of the public, and
    understandably
    so, and the frustration suffered by a client whose attorney procrastinates
    must indeed be
    magnified many times when the "client" learns that the "attorney" was, in
    000585
    fact, not authorized
    to practice law and never intended to render any legal services, the court
    declared. Having
    permitted and encouraged the "client" to believe that he was authorized to
    and would give her
    legal assistance, the respondent would not be heard to say that his conduct
    was excusable because
    he did not do that which he would have been obliged to do, under the
    circumstances,
    had he been authorized to practice law, the court concluded.
    26. Appearances at hearings, preparation and filing of pleadings,
    claims handling, and
    rendering general legal advice
    In the following cases involving allegations that a lawyer, whose license to
    practice law
    had been suspended or revoked, had engaged in the unauthorized practice of
    law, the courts
    determined, where it had been asserted generally that the defendant made
    appearances at hearings,
    prepared and filed pleadings, handled claims, and generally rendered legal
    advice,
    whether the defendant was in contempt due to engaging in such conduct.[32]
    A disbarred attorney's conduct in acting as an advocate on behalf of a
    plaintiff in a deposition
    proceeding and appearing as a representative for the plaintiff in a pretrial
    conference
    000586
    constituted the unauthorized practice of law, the court held in The Florida
    Bar v. Riccardi, 304
    So. 2d 444 (Fla. 1974), a proceeding brought by the Bar Association
    requesting an adjudication
    of contempt and a permanent injunction against the attorney. The court,
    given the particular
    circumstances presented, determined that the respondent was in contempt of
    the court, as a
    result of which he would be fined the sum of $500, together with the costs
    expended by the
    Florida Bar in accumulating the evidence and the presentation of the charge,
    the court further
    ordering that a permanent injunction restraining the respondent from
    engaging in the acts
    complained of, and from otherwise engaging in the practice of law in the
    State of Florida until
    eligible to do so as an authorized attorney, would be entered.
    A superior court order that, after a disbarred attorney had appeared in the
    court as an attorney
    for a defendant in a civil action, adjudged the attorney in contempt,
    sentenced him to confinement
    for five days, and imposed a $200 fine, was not unreasonable, was in
    furtherance of
    the administration of the court, and was not illegal or void, the court held in
    In re Boswell,
    000587
    148 Ga. App. 519, 251 S.E.2d 596 (1978).
    A disbarred attorney's conduct constituting the practice of law, in contempt
    of a disbarment
    order, warranted imprisonment for 90 days, in light of the attorney's willful
    and intentional
    disregard of the order, as evidenced by prior contemptuous conduct, the
    court held in
    Matter of Powell, 658 N.E.2d 572 (Ind. 1995), the court observing that the
    complained-of
    conduct involved the attorney's preparation of legal documents. The
    Disciplinary Commission
    charged a previously disbarred attorney with practicing law in contempt of a
    disbarment order,
    and, on order to appear and show cause and on the attorney's motion to have
    the license reinstated,
    the supreme court held that the attorney engaged in conduct constituting the
    practice of
    law, rendering the attorney guilty of indirect criminal contempt. In so ruling,
    the court pointed
    out that in the course of the representation under inquiry, the respondent
    prepared exemption
    forms in a small claims matter in which the client was a defendant, that,
    during the pursuit of
    a particular claim, the respondent prepared an affidavit on behalf of the
    client for presentation
    to a bank, and that he drafted a civil complaint against the bank for the
    000588
    client's signature. As
    such, the court related, the respondent engaged in the practice of law in
    violation of the court's
    order, as a result of which he would be held guilty of indirect criminal
    contempt of the court.
    The fact that a topic of law on which an attorney rendered legal advice was a
    federal immigration
    law matter, rather than a state law issue, did not preclude the supreme
    judicial court
    or a single justice of the court from exerting disciplinary authority over him
    in contempt proceedings
    for the attorney's alleged engaging in the unauthorized practice of law while
    under
    suspension, the court held in In re Moore, 449 Mass. 1009, 866 N.E.2d 897
    (2007). Contempt
    proceedings were initiated against an attorney, alleging that he had engaged
    in the unauthor-
    ized practice of law while under suspension, a single justice of the supreme
    judicial court
    found the attorney in contempt and barred him from applying for
    reinstatement for four years,
    the attorney appealed, and the court, on review, affirmed. In so ruling, the
    court commented
    that there was no merit to the respondent's assertion that neither the court nor
    a single justice
    may exert disciplinary authority over him because any legal advice he
    000589
    rendered involved a
    federal immigration law matter rather than a state law issue. The issue before
    the single justice
    on the contempt petition, however, was whether the respondent rendered
    legal services in violation
    of the judgment of suspension, such that, regardless of the specific topic of
    representation,
    on the record before her, the single justice was warranted in concluding that
    the respondent
    engaged in the unauthorized practice of law in the Commonwealth during
    the period of his
    suspension. Any lawyer or foreign legal consultant admitted to, or engaging
    in, the practice of
    law in the Commonwealth shall be subject to the court's exclusive
    disciplinary jurisdiction,
    the court explained. The remainder of the respondent's arguments primarily
    consisted of conclusory
    assertions that the conduct alleged in the contempt petition did not violate
    the terms of
    his suspension, the court indicated. The respondent did not answer the
    petition, did not appear
    at the show cause hearing as ordered by the single justice, and did not
    submit any evidence
    challenging the affidavits submitted by Bar counsel, from individuals who
    received legal advice
    from the respondent during the period of his suspension, the court
    000590
    elaborated. Given the
    particular circumstances presented, the court concluded that the single
    justice did not err in
    accepting the facts alleged in the uncontroverted affidavits, or in concluding
    that they established
    that the respondent had engaged in the unauthorized practice of law.
    A suspended attorney's practice of law as house counsel of a brokerage firm
    in which he
    had a controlling interest, registration as an attorney without indicating that
    he was limited to
    practice in federal courts and under state suspension, and appearance for the
    brokerage firm in
    a state court law suit, the provision of advice to the client, and the drafting of
    documents for
    his brokerage firm, would warrant disbarment, the court held in Matter of
    Olitt, 145 A.D.2d
    273, 538 N.Y.S.2d 537 (1st Dep't 1989), as a result of which a petition
    would be granted to
    the extent of disbarring the respondent and striking his name from the roll of
    attorneys and
    counselors-at-law, and finding the respondent to be guilty of both civil and
    criminal contempt,
    referring the contempt charges to a referee for the imposition of sanctions. It
    was the contention
    of the respondent that his practice as "house counsel" of a brokerage house,
    in which he
    000591
    had a controlling interest, his 1984 registration as an attorney with the New
    York State Office
    of Court Administration, pursuant to N.Y. Jud. Law 468-a, which did not
    indicate, in any
    way, that his practice was limited to federal courts or federal matters nor that
    he was under
    suspension, his appearance for the brokerage firm in a lawsuit in the
    Supreme Court, County
    of New York and filing of legal papers therein in his own name, his
    consultation with and giving
    advice to a client who had a claim against another broker, and his drafting
    contracts for
    the brokerage firm did not impinge upon his argument that he appeared only
    in arbitration
    proceedings before the New York Stock Exchange on behalf of a company
    in which he had an
    interest, the respondent considering the latter a pro se appearance, the court
    pointed out. It is
    well-settled that the practice of law by a suspended attorney is unlawful and
    warrants immediate
    disbarment, the court instructed. Accordingly, the court concluded, the
    respondent would
    be disbarred and his name struck from the roll of attorneys and counselors-
    at-law in the State
    of New York, and a referee would be appointed to hear and report with
    respect to the imposition
    000592
    of sanctions, the court adding that the respondent would be assessed $100
    for costs of the
    motions presented.
    The supreme court's finding that an attorney was in contempt due to the
    attorney's maintaining
    a law office in the Commonwealth, and advising at least one client during
    that time,
    while the attorney's license to practice law was suspended, did not violate
    the First Amendment,
    for the Commonwealth had the power to regulate the law, the supreme court
    had a compelling
    interest in regulating the practice of law within its borders, the prohibition
    was not designed
    to limit any First Amendment freedoms, and the restriction was no greater
    than absolutely
    necessary to further the government interest, the court held in Office Of
    Disciplinary
    Counsel v. Marcone, 579 Pa. 1, 855 A.2d 654 (2004).
    See the following additional cases involving allegations that a lawyer, whose
    license to
    practice law had been suspended or revoked, had engaged in the
    unauthorized practice of law,
    where the courts determined, in cases in which it had been asserted generally
    that the defendant
    made appearances at hearings, prepared and filed pleadings, handled claims,
    and generally
    000593
    rendered legal advice, whether the defendant was in contempt due to
    engaging in such conduct,
    where
    a disbarred attorney who appeared in another district and represented a
    client in a criminal
    proceeding and assured the court that he was a member of the District of
    Columbia Bar
    was held guilty of contempt. Bowles v. U. S., 50 F.2d 848 (C.C.A. 4th Cir.
    1931).
    following a hearing on an order to show cause, a defendant's former
    counsel, who continued
    to represent his client in settlement discussions after having been disbarred
    in Maryland
    and suspended in the District of Columbia, would be held in criminal
    contempt for violating
    Local Civil Rules (former U.S. Dist. Ct. Rules D.D.C., Rule 83.8(a) and
    Rule 83.9(a)) and for
    failing to appear at two previously scheduled show cause hearings in
    violation of the court's
    orders. Yohannes v. Republic Gardens, 217 F. Supp. 2d 91 (D.D.C. 2002).
    a former attorney instituted 25 actions in his own name as a plaintiff
    asking judgment
    for amounts claimed and attorney's fees for himself in each case, such cases
    having been allegedly
    assigned to an adjustment company owned by him, in seven of which he
    caused judgment
    000594
    by confession to be entered in his favor for the amount of the claims and
    attorney's fees,
    although there was nothing on the face of the instruments to show that they
    had been assigned
    to him, he was guilty of direct contempt for practicing law without a license.
    People ex rel.
    Chicago Bar Ass'n v. Barasch, 406 Ill. 253, 94 N.E.2d 148 (1950).
    a defendant's convictions on drug charges were affirmed by the
    intermediate appellate
    tribunal, a postconviction motion was filed alleging a denial of the
    constitutional right to
    counsel and effective assistance of counsel, the lower tribunal dismissed the
    petition without
    an evidentiary hearing, the defendant appealed, and the court, on review,
    reversed and remanded,
    the court holding, inter alia, that representation by a suspended attorney, who
    was not
    authorized to practice law in the State, violated the defendant's right to
    counsel under the
    Sixth Amendment, and that subjecting the attorney to the court's contempt
    power, without
    more, in no way would vitiate this constitutional deficiency. People v.
    Brigham, 208 Ill. App.
    3d 982, 153 Ill. Dec. 777, 567 N.E.2d 735 (2d Dist. 1991), judgment rev'd on
    other grounds,
    151 Ill. 2d 58, 175 Ill. Dec. 720, 600 N.E.2d 1178 (1992).
    000595
    a Disciplinary Commission filed a motion for order to show cause why
    an attorney
    should not be held in contempt of a prior supreme court disciplinary order,
    which had accepted
    the attorney's resignation from the State Bar, the state supreme court,
    following a hearing,
    held, inter alia, that the attorney did not engage in the unauthorized practice
    of law when he
    appeared on behalf of his employer at a meeting of the county planning
    commission, but that
    he had engaged in the unauthorized practice of law when he filed complaints
    in circuit court
    on behalf of his employer and partnership, the court adding that the attorney
    improperly held
    himself out as an attorney in the capacity of a legal advisor, such that a fine
    was an appropriate
    penalty for the attorney's contempt of court. Matter of Contempt of the
    Supreme Court of
    Indiana, 673 N.E.2d 755 (Ind. 1996).
    upon a referee's recommendation of disbarment, repeatedly engaging in
    law practice
    while suspended warranted the respondent's disbarment, as well as orders of
    contempt; in so
    ruling, the court pointed out that deliberate violations of the court's orders
    simply cannot be
    000596
    condoned, the court adding that a principle purpose of the exercise of
    disciplinary authority is
    to assure respect for the orders of the court by attorneys, who, as much as
    judges, are responsible
    for the orderly administration of justice in Minnesota. Matter of Discipline
    of Jorissen,
    391 N.W.2d 822 (Minn. 1986).
    engaging in the practice of law subsequent to disbarment, including the
    representation
    of a defendant in a matter in the supreme court and accepting a retainer from
    a client in connection
    with a personal injury claim, warranted a fine of $250 as a contempt
    sanction against
    the attorney. Matter of Louison, 143 A.D.2d 62, 531 N.Y.S.2d 616 (2d Dep't
    1988).
    a disbarred attorney who nonetheless filed pleadings on behalf of a client
    violated the
    order striking his name from the roll of attorneys and counselors at law and
    ordering him to
    desist from the practice of law was in contempt of court; the court noted that
    the respondent,
    after the order striking his name and commanding him to desist from the
    practice of law and
    forbidding him from accepting compensation for legal services, appearing as
    an attorney, or
    giving an opinion as to the law, in contravention to the provisions of the
    000597
    order, obtained a retainer
    and fee by representing himself to be an attorney-at-law and entitled to
    practice as such,
    and agreed to bring an action for the client, after which he prepared a paper
    purporting to be a
    summons and complaint in an action in the supreme court using the name of
    another attorney,
    without the latter's knowledge or consent, and caused the pleading to be
    served. In re Szendy,
    244 A.D. 49, 278 N.Y.S. 199 (1st Dep't 1935).
    a disbarred attorney who had appeared as an attorney for a defendant in
    trial of a cause
    in circuit court, willfully and without justifiable cause, was punishable for
    contempt of court
    for violation of an order of disbarment. In re Sullivan, 64 S.D. 165, 265
    N.W. 601 (1936).
    Sincerely,
    Zach Coughlin
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    000598
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    From: zachcoughlin@hotmail.com
    To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov;
    stuttle@washoecounty.gov; rsilva@washoecounty.us;
    stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com;
    info@acg-apmi.com; rjcweb@wasoecounty.us; jboles@callatg.com;
    apminfo@acg.com
    Subject: FW: Reno eviction noticed for Sparks Justice Court
    Date: Mon, 2 Jul 2012 17:21:54 -0700
    NOrthwind and Nevada Court Services served and "amended 5 day notice of
    unlawful detainer on July 29th, 2012"...giving me five days to get my stuff
    out of unit 29 (the one the subject of Judge Schroeer's Eviction Order, which
    was effectively rescinded by their serving a new 5 day unlawful detainer
    notice....) as well as units 71 and 45...whicih are two units to which i still
    have valide lease agreements, ie, I cannot be trespassing for accessing them
    000599
    (the Reno PD has indicated they will arrest me for criminal trespass for
    accessing any units in the complex, including those to which I still have a
    valid possessory or property interest, in violation of 42 usc 1983).

    why does Sargent Miller have to give me a hard time? Isn't it enough for
    him to have his "Denzel" good looks and a much higher paying job than I
    will ever have? What up wit that?

    Northwind and Nevada Court Services (which is practicing eviction law


    without a license) screwed up and put "Sparks Justice Court on Greenbrae"
    as the place for the tenant to file a Tenan'ts Answer or Affidavit. Doing so
    will make the RJC Order by Judge Schroeder null and void (Karen Stancil,
    Chief Civil Clerk at RJC admits this, but really, the fault lies with NCS and
    Northwind, not the committed professional at the RJC).
    The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a).
    ONe cannot be trespassing in a placwe where they have a valid reason for
    being or a lawful right to be. NRS 207.200, RMC 8.10.040.

    In Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli
    construed the
    predecessor statute to NRS 40.2516 to mean that the alternative five (5) day
    notice must be given
    before the tenants can be dispossed and a lease can be validly terminated.
    The court stated that this
    five (5) day notice requirement " ... neither can be waved nor neglected." 91
    Nev. at 748.
    ttp://www.constitution.org/ussc/506-056a.htm
    6
    000600

    U.S. Supreme Court
    SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
    506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
    CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
    THE
    SEVENTH CIRCUIT
    No. 91-6516
    Argued October 5, 1992
    Decided December 8, 1992
    While eviction proceedings were pending, Terrace Properties and Margaret
    Hale forcibly evicted petitioners, the Soldal family, and their mobile home
    from a Terrace Properties' mobile home park. At Hale's request, Cook
    County, Illinois, Sheriff's Department deputies were present at the eviction.
    Although they knew that there was no eviction order and that Terrace
    Properties' actions were illegal, the deputies refused to take Mr. Soldal's
    complaint for criminal trespass or otherwise interfere with the eviction.
    Subsequently, the state judge assigned to the pending eviction proceedings
    ruled that the eviction had been unauthorized, and the trailer, badly damaged
    during the eviction, was returned to the lot. Petitioners brought an action in
    the Federal District Court under 42 U.S.C. 1983, claiming that Terrace
    Properties and Hale had conspired with the deputy sheriffs to unreasonably
    seize and remove their home in violation of their Fourth and Fourteenth
    Amendment rights. The court granted defendants' motion for summary
    judgment, and the Court of Appeals affirmed. Acknowledging that what had
    occurred was a "seizure" in the literal sense of the word, the court reasoned
    that it was not a seizure as contemplated by the Fourth Amendment because,
    inter alia, it did not invade petitioners' privacy.
    Held:
    The seizure and removal of the trailer home implicated petitioners' Fourth
    Amendment rights. Pp. 61-72.
    000601
    (a) A "seizure" of property occurs when "there is some meaningful
    interference with an individual's possessory interests in that
    property." United States v. Jacobsen, 466 U.S. 109, 113 . The
    language of the Fourth Amendment - which protects people from
    unreasonable searches and seizures of "their persons, houses, papers,
    and effects" - cuts against the novel holding below, and this Court's
    cases unmistakably hold that the Amendment protects property even
    where privacy or liberty is not implicated. See, e.g., ibid.; Katz v.
    United States, 389 U.S. 347, 350 . This Court's "plain view"
    decisions also make untenable the lower court's construction of the
    Amendment. If the Amendment's boundaries were defined
    exclusively by rights of privacy, "plain view" seizures, rather than
    being scrupulously subjected to Fourth Amendment inquiry,
    Arizona v. Hicks, 480 U.S. 321, 326 -327, would not implicate that
    constitutional provision at all. Contrary to the Court of Appeals'
    [506 U.S. 56, 57] position, the Amendment protects seizure even
    though no search within its meaning has taken place. See, e.g.,
    Jacobsen, supra, at 120-125. Also contrary to that court's view,
    Graham v. Connor, 490 U.S. 386 , does not require a court, when it
    finds that a wrong implicates more than one constitutional
    command, to look at the dominant character of the challenged
    conduct to determine under which constitutional standard it
    should be evaluated. Rather, each constitutional provision is
    examined in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp.
    61-71.
    (b) The instant decision should not foment a wave of new litigation
    in the federal courts. Activities such as repossessions or attachments,
    if they involve entering a home, intruding on individuals' privacy, or
    interfering with their liberty, would implicate the Fourth
    Amendment even on the Court of Appeals' own terms. And
    numerous seizures of this type will survive constitutional scrutiny
    on "reasonableness" grounds. Moreover, it is unlikely that the police
    will often choose to further an enterprise knowing that it is contrary
    000602
    to the law, or proceed to seize property in the absence of objectively
    reasonable grounds for doing so. Pp. 71-72.
    942 F.2d 1073, reversed and remanded.
    WHITE, J., delivered the opinion for a unanimous Court.
    John L. Stainthorp argued the cause and filed briefs for petitioners.
    Kenneth L. Gillis argued the cause for respondents. With him on the brief
    were Jack O'Malley, Renee G. Goldfarb, and Kenneth T. McCurry. [*]
    [ Footnote *] James D. Holzhauer, Timothy S. Bishop, John A. Powell,
    Steven R. Shapiro, Harvey M. Grossman, and Alan K. Chen filed a brief for
    the American Civil Liberties Union et al. as amici curiae urging reversal.
    Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad
    filed a brief for the National League of Cities et al. as amici curiae urging
    affirmance.
    JUSTICE WHITE delivered the opinion of the Court.
    I
    Edward Soldal and his family resided in their trailer home, which was
    located on a rented lot in the Willoway Terrace mobile [506 U.S. 56, 58]
    home park in Elk Grove, Illinois. In May 1987, Terrace Properties, the
    owner of the park, and Margaret Hale, its manager, filed an eviction
    proceeding against the Soldals in an Illinois state court. Under the Illinois
    Forcible Entry and Detainer Act, Ill.Rev.Stat., ch. 110, 9-101 et seq. (1991),
    a tenant cannot be dispossessed absent a judgment of eviction. The suit was
    dismissed on June 2, 1987. A few months later, in August 1987, the owner
    brought a second proceeding of eviction, claiming nonpayment of rent. The
    case was set for trial on September 22, 1987.
    Rather than await judgment in their favor, Terrace Properties and Hale,
    contrary to Illinois law, chose to evict the Soldals forcibly two weeks prior
    to the scheduled hearing. On September 4, Hale notified the Cook County's
    Sheriff's Department that she was going to remove the trailer home from the
    park, and requested the presence of sheriff deputies to forestall any possible
    resistance. Later that day, two Terrace Properties employees arrived at the
    000603
    Soldals' home accompanied by Cook County Deputy Sheriff O'Neil. The
    employees proceeded to wrench the sewer and water connections off the side
    of the trailer home, disconnect the phone, tear off the trailer's canopy and
    skirting, and hook the home to a tractor. Meanwhile, O'Neil explained to
    Edward Soldal that "`he was there to see that [Soldal] didn't interfere with
    [Willoway's] work.'" Brief for Petitioner 6.
    By this time, two more deputy sheriffs had arrived at the scene, and Soldal
    told them that he wished to file a complaint for criminal trespass. They
    referred him to deputy Lieutenant Jones, who was in Hale's office. Jones
    asked Soldal to wait outside while he remained closeted with Hale and other
    Terrace Properties employees for over 20 minutes. After talking to a district
    attorney and making Soldal wait another half hour, Jones told Soldal that he
    would not accept a complaint because "`it was between the landlord and the
    tenant ... [and] they were going to go ahead and continue to move [506 U.S.
    56, 59] out the trailer.'" Id., at 8. 1 Throughout this period, the deputy
    sheriffs knew that Terrace Properties did not have an eviction order and that
    its actions were unlawful. Eventually, and in the presence of an additional
    two deputy sheriffs, the Willoway workers pulled the trailer free of its
    moorings and towed it onto the street. Later, it was hauled to a neighboring
    property.
    On September 9, the state judge assigned to the pending eviction
    proceedings ruled that the eviction had been unauthorized, and ordered
    Terrace Properties to return the Soldals' home to the lot. The home,
    however, was badly damaged.
    [2]
    The Soldals brought this action under 42
    U.S.C. 1983, alleging a violation of their rights under the Fourth and
    Fourteenth Amendments. They claimed that Terrace Properties and Hale had
    conspired with Cook County deputy sheriffs to unreasonably seize and
    remove the Soldals' trailer home. The District Judge granted defendants'
    motion for summary judgment on the grounds that the Soldals had failed to
    adduce any evidence to support their conspiracy theory and, therefore, the
    existence of state action necessary under 1983.
    [3]

    The Court of Appeals for the Seventh Circuit, construing the facts in
    petitioners' favor, accepted their contention that there was state action.
    000604
    However, it went on to hold that [506 U.S. 56, 60] the removal of the
    Soldals' trailer did not constitute a seizure for purposes of the Fourth
    Amendment or a deprivation of due process for purposes of the Fourteenth.
    On rehearing, a majority of the Seventh Circuit, sitting en banc, reaffirmed
    the panel decision.
    [4]
    Acknowledging that what had occurred was a
    "seizure" in the literal sense of the word, the court reasoned that, because it
    was not made in the course of public law enforcement, and because it did not
    invade the Soldals' privacy, it was not a seizure as contemplated by the
    Fourth Amendment. 942 F.2d 1073, 1076 (1991). Interpreting prior cases of
    this Court, the Seventh Circuit concluded that, absent interference with
    privacy or liberty, a "pure deprivation of property" is not cognizable under
    the Fourth Amendment. Id., at 1078-1079. Rather, petitioners' property
    interests were protected only by the Due Process Clauses of the Fifth and
    Fourteenth Amendments.
    [5]

    We granted certiorari to consider whether the seizure and removal of the


    Soldals' trailer home implicated their Fourth Amendment rights, 503 U.S.
    918 (1992), and now reverse.
    [6]
    [506 U.S. 56, 61]
    II
    The Fourth Amendment, made applicable to the States by the Fourteenth,
    Ker v. California, 374 U.S. 23, 30 (1963), provides in pertinent part that the
    "right of the people to be secure in their persons, houses, papers, and effects,
    against unreasonable searches and seizures, shall not be violated... ."
    A "seizure" of property, we have explained, occurs when "there is some
    meaningful interference with an individual's possessory interests in that
    property." United States v. Jacobsen, 466 U.S. 109, 113 (1984). In addition,
    we have emphasized that "at the very core" of the Fourth Amendment
    "stands the right of a man to retreat into his own home." Silverman v.
    United States, 365 U.S. 505, 511 (1961). See also Oliver v. United States,
    466 U.S. 170, 178 -179 (1984); Wyman v. James, 400 U.S. 309, 316 (1971);
    Payton v. New York, 445 U.S. 573, 601 (1980).
    As a result of the state action in this case, the Soldals' domicile was not only
    000605
    seized, it literally was carried away, giving new meaning to the term "mobile
    home." We fail to see how being unceremoniously dispossessed of one's
    home in the manner alleged to have occurred here can be viewed as anything
    but a seizure invoking the protection of the Fourth Amendment. Whether the
    Amendment was in fact [506 U.S. 56, 62] violated is, of course, a different
    question that requires determining if the seizure was reasonable. That
    inquiry entails the weighing of various factors, and is not before us.
    The Court if Appeals recognized that there had been a seizure, but concluded
    that it was a seizure only in a "technical" sense, not within the meaning of
    the Fourth Amendment. This conclusion followed from a narrow reading of
    the Amendment, which the court construed to safeguard only privacy and
    liberty interests, while leaving unprotected possessory interests where
    neither privacy nor liberty was at stake. Otherwise, the court said,
    "a constitutional provision enacted two centuries ago [would] make
    every repossession and eviction with police assistance actionable
    under - of all things - the Fourth Amendment[, which] would both
    trivialize the amendment and gratuitously shift a large body of
    routine commercial litigation from the state courts to the federal
    courts. That trivializing, this shift, can be prevented by recognizing
    the difference between possessory and privacy interests." 942 F.2d,
    at 1077.
    Because the officers had not entered Soldal's house, rummaged through his
    possessions, or, in the Court of Appeals' view, interfered with his liberty in
    the course of the eviction, the Fourth Amendment offered no protection
    against the "grave deprivation" of property that had occurred. Ibid.
    We do not agree with this interpretation of the Fourth Amendment. The
    Amendment protects the people from unreasonable searches and seizures of
    "their persons, houses, papers, and effects." This language surely cuts
    against the novel holding below, and our cases unmistakably hold that the
    Amendment protects property as well as privacy.
    [7]
    This much [506 U.S.
    56, 63] was made clear in Jacobsen, supra, where we explained that the first
    Clause of the Fourth Amendment
    000606
    "protects two types of expectations, one involving "searches," the
    other "seizures." A "search" occurs when an expectation of privacy
    that society is prepared to consider reasonable is infringed. A
    "seizure" of property occurs where there is some meaningful
    interference with an individual's possessory interests in that
    property." 466 U.S., at 113 (footnote omitted).
    See also id., at 120; Horton v. California, 496 U.S. 128, 133 (1990); Arizona
    v. Hicks, 480 U.S. 321, 328 (1987); Maryland v. Macon, 472 U.S. 463, 469
    (1985); Texas v. Brown, 460 U.S. 730, 747 -748 (1983) (STEVENS, J.,
    concurring in judgment); United States v. Salvucci, 448 U.S. 83, 91 , n. 6
    (1980). Thus, having concluded that chemical testing of powder found in a
    package did not compromise its owner's privacy, the Court in Jacobsen did
    not put an end to its inquiry, as would be required under the view adopted by
    the Court of Appeals and advocated by respondents. Instead, adhering to the
    teachings of United States v. Place, 462 U.S. 696 (1983), it went on to
    determine whether the invasion of the owners' "possessory interests"
    occasioned by the destruction of the powder was reasonable under the
    Fourth Amendment. Jacobsen, supra, at 124-125. In Place, although we
    found that subjecting luggage to a "dog sniff" did not constitute a search for
    Fourth Amendment purposes because it did not compromise any privacy
    interest, taking custody of Place's suitcase was deemed an unlawful seizure,
    for it unreasonably infringed "the suspect's possessory interest in his
    luggage." 462 U.S., at 708 . 8 Although lacking a privacy component, the
    property rights in both instances nonetheless were not [506 U.S. 56, 64]
    disregarded, but rather were afforded Fourth Amendment protection.
    Respondents rely principally on precedents such as Katz v. United States,
    389 U.S. 347 (1967), Warden, Maryland Penitentiary v. Hayden, 387 U.S.
    294 (1967), and Cardwell v. Lewis, 417 U.S. 583 (1974), to demonstrate that
    the Fourth Amendment is only marginally concerned with property rights.
    But the message of those cases is that property rights are not the sole
    measure of Fourth Amendment violations. The Warden opinion thus
    observed, citing Jones v. United States, 362 U.S. 257 (1960), and Silverman
    000607
    v. United States, 365 U.S. 505 (1961), that the "principal" object of the
    Amendment is the protection of privacy, rather than property, and that "this
    shift in emphasis from property to privacy has come about through a subtle
    interplay of substantive and procedural reform." 387 U.S., at 304 . There was
    no suggestion that this shift in emphasis had snuffed out the previously
    recognized protection for property under the Fourth Amendment. Katz, in
    declaring violative of the Fourth Amendment the unwarranted overhearing
    of a telephone booth conversation, effectively ended any lingering notions
    that the protection of privacy depended on trespass into a protected area. In
    the course of its decision, the Katz Court stated that the Fourth Amendment
    can neither be translated into a provision dealing with constitutionally
    protected areas nor into a general constitutional right to privacy. The
    Amendment, the Court said, protects individual privacy against certain kinds
    of governmental intrusion, "but its protections go further, and often have
    nothing to do with privacy at all." 389 U.S., at 350 .
    As for Cardwell, a plurality of this Court held in that case that the Fourth
    Amendment did not bar the use in evidence of paint scrapings taken from
    and tire treads observed on the defendant's automobile, which had been
    seized in a parking lot and towed to a police lockup. Gathering this evidence
    was not deemed to be a search, for nothing from the [506 U.S. 56, 65]
    interior of the car and "no personal effects, which the Fourth Amendment
    traditionally has been deemed to protect" were searched or seized. 417 U.S.,
    at 591 (opinion of BLACKMUN, J.). No meaningful privacy rights were
    invaded. But this left the argument, pressed by the dissent, that the evidence
    gathered was the product of a warrantless, and hence illegal, seizure of the
    car from the parking lot where the defendant had left it. However, the
    plurality was of the view that, because, under the circumstances of the case,
    there was probable cause to seize the car as an instrumentality of the crime,
    Fourth Amendment precedent permitted the seizure without a warrant. Id., at
    593. Thus, both the plurality and dissenting Justices considered the
    defendant's auto deserving of Fourth Amendment protection even though
    privacy interests were not at stake. They differed only in the degree of
    protection that the Amendment demanded.
    000608
    The Court of Appeals appeared to find more specific support for confining
    the protection of the Fourth Amendment to privacy interests in our decision
    in Hudson v. Palmer, 468 U.S. 517 (1984). There, a state prison inmate sued,
    claiming that prison guards had entered his cell without consent and had
    seized and destroyed some of his personal effects. We ruled that an inmate,
    because of his status, enjoyed neither a right to privacy in his cell nor
    protection against unreasonable seizures of his personal effects. Id., at 526-
    528, and n. 8; id., at 538 (O'CONNOR, J., concurring). Whatever else the
    case held, it is of limited usefulness outside the prison context with respect
    to the coverage of the Fourth Amendment.
    We thus are unconvinced that any of the Court's prior cases supports the
    view that the Fourth Amendment protects against unreasonable seizures of
    property only where privacy or liberty is also implicated. What is more, our
    "plain view" decisions make untenable such a construction of the
    Amendment. Suppose, for example, that police officers lawfully enter a
    house, by either complying with the warrant requirement or satisfying one of
    its recognized exceptions - [506 U.S. 56, 66] e.g., through a valid consent
    or a showing of exigent circumstances. If they come across some item in
    plain view and seize it, no invasion of personal privacy has occurred.
    Horton, 496 U.S., at 133 -134; Brown, supra, at 739 (opinion of
    REHNQUIST, J.). If the boundaries of the Fourth Amendment were defined
    exclusively by rights of privacy, "plain view" seizures would not implicate
    that constitutional provision at all. Yet, far from being automatically upheld,
    "plain view" seizures have been scrupulously subjected to Fourth
    Amendment inquiry. Thus, in the absence of consent or a warrant permitting
    the seizure of the items in question, such seizures can be justified only if
    they meet the probable-cause standard, Arizona v. Hicks, 480 U.S. 321, 326
    -327 (1987), 9 and if they are unaccompanied by unlawful trespass, Horton,
    496 U.S., at 136 -137. 10 That is because, the absence of a privacy interest
    notwithstanding, "[a] seizure of the article ... would obviously invade the
    owner's possessory interest." Id., at 134; see also Brown, 460 U.S., at 739
    (opinion of REHNQUIST, J.). The plain-view doctrine "merely reflects an
    application of the Fourth Amendment's central requirement of
    000609
    reasonableness to the law governing seizures of property." Ibid.; Coolidge v.
    New Hampshire, 403 U.S. 443, 468 (1971); id., at 516 (WHITE, J.,
    concurring and dissenting).
    The Court of Appeals understandably found it necessary to reconcile its
    holding with our recognition in the plain-view cases that the Fourth
    Amendment protects property as such. In so doing, the court did not
    distinguish this case on the ground that the seizure of the Soldals' home took
    place in a [506 U.S. 56, 67] noncriminal context. Indeed, it acknowledged
    what is evident from our precedents - that the Amendment's protection
    applies in the civil context as well. See O'Connor v. Ortega, 480 U.S. 709
    (1987); New Jersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v.
    Tyler, 436 U.S. 499, 504 -506 (1978); Marshall v. Barlow's, Inc., 436 U.S.
    307, 312 -313 (1978); Camara v. Municipal Court of San Francisco, 387
    U.S. 523, 528 (1967). 11
    Nor did the Court of Appeals suggest that the Fourth Amendment applied
    exclusively to law enforcement activities. It observed, for example, that the
    Amendment's protection would be triggered "by a search or other entry into
    the home incident to an eviction or repossession," 942 F.2d, at 1077. 12
    Instead, the court sought to explain why the Fourth Amendment protects
    against seizures of property in the plain-view context, but not in this case, as
    follows:
    "[S]eizures made in the course of investigations by police or other
    law enforcement officers are almost always, as in the plain view
    cases, the culmination of searches. The police search in order to
    seize, and it is the search [506 U.S. 56, 68] and ensuing seizure that
    the Fourth Amendment, by its reference to "searches and seizures,"
    seeks to regulate. Seizure means one thing when it is the outcome of
    a search; it may mean something else when it stands apart from a
    search or any other investigative activity. The Fourth Amendment
    may still nominally apply, but, precisely because there is no
    invasion of privacy, the usual rules do not apply." Id., at 1079
    (emphasis in original).
    000610
    We have difficulty with this passage. The court seemingly construes the
    Amendment to protect only against seizures that are the outcome of a search.
    But our cases are to the contrary, and hold that seizures of property are
    subject to Fourth Amendment scrutiny even though no search within the
    meaning of the Amendment has taken place. See, e.g., Jacobsen, 466 U.S., at
    120 -125; Place, 462 U.S., at 706 -707; Cardwell, 417 U.S., at 588 -589. 13
    More generally, an officer who happens to come across an individual's
    property in a public area could seize it only if Fourth Amendment standards
    are satisfied - for example, if the items are evidence of a crime or
    contraband. Cf. Payton v. New York, [506 U.S. 56, 69] 445 U.S., at 587 .
    We are also puzzled by the last sentence of the excerpt, where the court
    announces that the "usual rules" of the Fourth Amendment are inapplicable
    if the seizure is not the result of a search or any other investigative activity
    "precisely because there is no invasion of privacy." For the plain-view cases
    clearly state that, notwithstanding the absence of any interference with
    privacy, seizures of effects that are not authorized by a warrant are
    reasonable only because there is probable cause to associate the property
    with criminal activity. The seizure of the weapons in Horton, for example,
    occurred in the midst of a search, yet we emphasized that it did not "involve
    any invasion of privacy." 496 U.S., at 133 . In short, our statement that such
    seizures must satisfy the Fourth Amendment and will be deemed reasonable
    only if the item's incriminating character is "immediately apparent," id., at
    136-137, is at odds with the Court of Appeals' approach.
    The Court of Appeals' effort is both interesting and creative, but, at bottom,
    it simply reasserts the earlier thesis that the Fourth Amendment protects
    privacy, but not property. We remain unconvinced, and see no justification
    for departing from our prior cases. In our view, the reason why an officer
    might enter a house or effectuate a seizure is wholly irrelevant to the
    threshold question whether the Amendment applies. What matters is the
    intrusion on the people's security from governmental interference. Therefore,
    the right against unreasonable seizures would be no less transgressed if the
    seizure of the house was undertaken to collect evidence, verify compliance
    with a housing regulation, effect an eviction by the police, or on a whim, for
    000611
    no reason at all. As we have observed on more than one occasion, it would
    be "anomalous to say that the individual and his private property are fully
    protected by the Fourth Amendment only when the individual is suspected
    of criminal behavior." Camara 387 U.S., at 530 ; see also O'Connor, 480
    U.S., at 715 ; T.L.O., 469 U.S., at 335 . [506 U.S. 56, 70]
    The Court of Appeals also stated that, even if, contrary to its previous
    rulings, "there is some element or tincture of a Fourth Amendment seizure, it
    cannot carry the day for the Soldals." 942 F.2d, at 1080. Relying on our
    decision in Graham v. Connor, 490 U.S. 386 (1989), the court reasoned that
    it should look at the "dominant character of the conduct challenged in a
    section 1983 case [to] determine the constitutional standard under which it is
    evaluated." 942 F.2d, at 1080. Believing that the Soldals' claim was more
    akin to a challenge against the deprivation of property without due process
    of law than against an unreasonable seizure, the court concluded that they
    should not be allowed to bring their suit under the guise of the Fourth
    Amendment.
    But we see no basis for doling out constitutional protections in such fashion.
    Certain wrongs affect more than a single right, and, accordingly, can
    implicate more than one of the Constitution's commands. Where such
    multiple violations are alleged, we are not in the habit of identifying, as a
    preliminary matter, the claim's "dominant" character. Rather, we examine
    each constitutional provision in turn. See, e.g., Hudson v. Palmer, 468 U.S.
    517 (1984) (Fourth Amendment and Fourteenth Amendment Due Process
    Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth Amendment and
    Fourteenth Amendment Due Process Clause). Graham is not to the contrary.
    Its holding was that claims of excessive use of force should be analyzed
    under the Fourth Amendment's reasonableness standard, rather than the
    Fourteenth Amendment's substantive due process test. We were guided by
    the fact that, in that case, both provisions targeted the same sort of
    governmental conduct and, as a result, we chose the more "explicit textual
    source of constitutional protection" over the "more generalized notion of
    `substantive due process.'" 490 U.S., at 394 -395. Surely, Graham does not
    bar resort in this case to the Fourth Amendment's specific protection for
    000612
    "houses, papers, [506 U.S. 56, 71] and effects," rather than the general
    protection of property in the Due Process Clause.
    III
    Respondents are fearful, as was the Court of Appeals, that applying the
    Fourth Amendment in this context inevitably will carry it into territory
    unknown and unforeseen: routine repossessions, negligent actions of public
    employees that interfere with individuals' right to enjoy their homes, and the
    like, thereby federalizing areas of law traditionally the concern of the States.
    For several reasons, we think the risk is exaggerated. To begin, our decision
    will have no impact on activities such as repossessions or attachments if they
    involve entry into the home, intrusion on individuals' privacy, or interference
    with their liberty, because they would implicate the Fourth Amendment even
    on the Court of Appeals' own terms. This was true of the Tenth Circuit's
    decision in Specht, with which, as we previously noted, the Court of Appeals
    expressed agreement.
    More significantly, "reasonableness is still the ultimate standard" under the
    Fourth Amendment, Camara, supra, at 539, which means that numerous
    seizures of this type will survive constitutional scrutiny. As is true in other
    circumstances, the reasonableness determination will reflect a "careful
    balancing of governmental and private interests." T.L.O., supra, at 341.
    Assuming, for example, that the officers were acting pursuant to a court
    order, as in Specht v. Jensen, 832 F.2d 1516 (CA10 1987), or Fuentes v.
    Shevin, 407 U.S. 67 , (1972), and, as often would be the case, a showing of
    unreasonableness on these facts would be a laborious task indeed. Cf. Simms
    v. Slacum, 3 Cranch 300, 301 (1806). Hence, while there is no guarantee
    against the filing of frivolous suits, had the ejection in this case properly
    awaited the state court's judgment, it is quite unlikely that the federal court
    would have been bothered with a 1983 action alleging a Fourth Amendment
    violation. [506 U.S. 56, 72]
    Moreover, we doubt that the police will often choose to further an enterprise
    knowing that it is contrary to the law, or proceed to seize property in the
    absence of objectively reasonable grounds for doing so. In short, our
    000613
    reaffirmance of Fourth Amendment principles today should not foment a
    wave of new litigation in the federal courts.
    IV
    The complaint here alleges that respondents, acting under color of state law,
    dispossessed the Soldals of their trailer home by physically tearing it from
    its foundation and towing it to another lot. Taking these allegations as true,
    this was no "garden variety" landlord-tenant or commercial dispute. The
    facts alleged suffice to constitute a "seizure" within the meaning of the
    Fourth Amendment, for they plainly implicate the interests protected by that
    provision. The judgment of the Court of Appeals is, accordingly, reversed,
    and the case is remanded for further proceedings consistent with this
    opinion.
    So ordered.
    Footnotes
    [1] Jones' statement was prompted by a district attorney's advice that no
    criminal charges could be brought because, under Illinois law, a criminal
    action cannot be used to determine the right of possession. See Ill.Rev.Stat.
    ch. 110, 9-101 et seq. (1991); People v. Evans, 163 Ill.App. 3d 561, 114
    Ill.Dec. 662, 516 N.E.2d 817 (1st Dist. 1987).
    [2] The Soldals ultimately were evicted per court order in December 1987.
    [3] Title 42 U.S.C. 1983 provides that:
    "Every person who, under color of any statute, ordinance,
    regulation, custom or usage, of any State ... subjects, or causes to be
    subjected, any citizen of the United States ... to the deprivation of
    any rights, privileges, or immunities secured by the Constitution and
    laws, shall be liable to the party injured in an action at law, suit in
    equity, or other proper proceeding for redress."
    [4] The court reiterated the panel's conclusion that a conspiracy must be
    000614
    assumed on the state of the record and, therefore, that the case must be
    treated in its current posture "as if the deputy sheriffs themselves seized the
    trailer, disconnected it from the utilities, and towed it away." 942 F.2d 1073,
    1075 (CA7 1991) (en banc).
    [5] The court noted that, in light of the existence of adequate judicial
    remedies under state law, a claim for deprivation of property without due
    process of law was unlikely to succeed. Id., at 1075-1076. See Parratt v.
    Taylor, 451 U.S. 527 (1981). In any event, the Soldals did not claim a
    violation of their procedural rights. As noted, the Seventh Circuit also held
    that respondents had not violated the Soldals' substantive due process rights
    under the Fourteenth Amendment. Petitioners assert that this was error, but,
    in view of our disposition of the case, we need not address the question at
    this time.
    [6] Under 42 U.S.C. 1983, the Soldals were required to establish that the
    respondents, acting under color of state law, deprived them of a
    constitutional right, in this instance, their Fourth and Fourteenth Amendment
    freedom from unreasonable seizures by the State. See Monroe v. Pape, [506
    U.S. 56, 61] 365 U.S. 167, 184 (1961). Respondents request that we
    affirm on the ground that the Court of Appeals erred in holding that there
    was sufficient state action to support a 1983 action. The alleged injury to the
    Soldals, it is urged, was inflicted by private parties for whom the county is
    not responsible. Although respondents did not cross-petition, they are
    entitled to ask us to affirm on that ground if such action would not enlarge
    the judgment of the Court of Appeals in their favor. The Court of Appeals
    found that, because the police prevented Soldal from using reasonable force
    to protect his home from private action that the officers knew was illegal,
    there was sufficient evidence of conspiracy between the private parties and
    the officers to foreclose summary judgment for respondents. We are not
    inclined to review that holding. See Adickes v. S.H. Kress & Co., 398 U.S.
    144, 152 -161 (1970).
    [7] In holding that the Fourth Amendment's reach extends to property as
    such, we are mindful that the Amendment does not protect possessory
    interests in all kinds of property. See, e.g., Oliver v. United States, 466 U.S.
    000615
    170, 176 -177 (1984). This case, however, concerns a house, which the
    Amendment's language explicitly includes, as it does a person's effects.
    [8] Place also found that to detain luggage for 90 minutes was an
    unreasonable deprivation of the individual's "liberty interest in proceeding
    with his itinerary," which also is protected by the Fourth Amendment. 462
    U.S., at 708 -710.
    [9] When "operational necessities" exist, seizures can be justified on less
    than probable cause. 480 U.S., at 327 . That in no way affects our analysis,
    for even then it is clear that the Fourth Amendment applies. Ibid; see also
    United States v. Place, 462 U.S. 696 , at 703 (1983).
    [10] Of course, if the police officers' presence in the home itself entailed a
    violation of the Fourth Amendment, no amount of probable cause to believe
    that an item in plain view constitutes incriminating evidence will justify its
    seizure. Horton, 496 U.S., at 136 -137.
    [11] It is true that Murray's Lessee v. Hoboken Land & Improvement Co.,
    18 How. 272 (1856), cast some doubt on the applicability of the Amendment
    to noncriminal encounters such as this. Id., 18 How. at 285. But cases since
    that time have shed a different light, making clear that Fourth Amendment
    guarantees are triggered by governmental searches and seizures "without
    regard to the use to which [houses, papers, and effects] are applied."
    Warden, Maryland Penitentiary v. Hayden, 387 U.S. 294, 301 (1967).
    Murray's Lessee's broad statement that the Fourth Amendment "has no
    reference to civil proceedings for the recovery of debt" arguably only meant
    that the warrant requirement did not apply, as was suggested in G.M.
    Leasing Corp. v. United States, 429 U.S. 338, 352 (1977). Whatever its
    proper reading, we reaffirm today our basic understanding that the protection
    against unreasonable searches and seizures fully applies in the civil context.
    [12] This was the view expressed by the Court of Appeals for the Tenth
    Circuit in Specht v. Jensen, 832 F.2d 1516 (1987), remanded on unrelated
    grounds, 853 F.2d 805 (1988) (en banc), with which the Seventh Circuit
    expressly agreed. 942 F.2d, at 1076.
    [13] The officers in these cases were engaged in law enforcement, and were
    looking for something that was found and seized. In this broad sense, the
    000616
    seizures were the result of "searches," but not in the Fourth Amendment
    sense. That the Court of Appeals might have been suggesting that the plain-
    view cases are explainable because they almost always occur in the course
    of law enforcement activities receives some support from the penultimate
    sentence of the quoted passage, where the court states that the word
    "seizure" might lose its usual meaning "when it stands apart from a search or
    any other investigative activity." Id., at 1079 (emphasis added). And, in the
    following paragraph, it observes that, "[o]utside of the law enforcement area,
    the Fourth Amendment retains its force as a protection against searches,
    because they invade privacy. That is why we decline to confine the
    amendment to the law enforcement setting." Id., at 1079-1080. Even if the
    court meant that seizures of property in the course of law enforcement
    activities, whether civil or criminal, implicate interests safeguarded by the
    Fourth Amendment, but that pure property interests are unprotected in the
    non-law-enforcement setting, we are not in accord, as indicated in the body
    of this opinion. [506 U.S. 56, 73]

    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    000617
    From: zachcoughlin@hotmail.com
    To: chansen@washoecounty.us
    Subject: Reno eviction noticed for Sparks Justice Court
    Date: Tue, 26 Jun 2012 09:10:14 -0700
    Dear Civil Supervisor Hansen
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Dear Sparks Justice Court,
    I called and received permission to file this by fax...I am indigent and
    request a fee waiver, and failing that, an opportunity to cure any filing fee
    deficiency.
    From: zachcoughlin@hotmail.com
    To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us;
    kstancil@washoecounty.us; chansen@washoecounty.us; milllerr@reno.gov
    Subject: Reno eviction noticed for Sparks Justice Court
    Date: Tue, 26 Jun 2012 07:58:36 -0700
    Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
    000618
    I have received (though not personally served) what appears to be an
    eviction notice (5 day unlawful detainer?) for rentals located at 1680 Sky
    Mountain Drive, Reno, 89523, but the notice indicates that I must file a
    Tenant's Answer with the Sparks Justice Court.
    Am I mistaken in viewing this matter to be outside the jurisdiction of the
    Sparks Justice Court, and rather, a matter to be handled in Reno Justice
    Court?
    Given Sparks Justice Court is open 5 days a week (closes at noon on
    Fridays) and Reno Justice Court has 4 judicial days a week, the deadline for
    filing a special appearance (to contest jurisdiction) and or a Tenant's Answer
    of Affidavit is difficult to measure.
    I spoke with a Reno Police Department who identified himself as Sargent
    Miller last week and he indicated the WCSO planned to come effectuate an
    eviction on this date, June 26, 2012. I believe that would be premature, as
    Nevada Landlord Tenant law provides for filing a Tenant's Answer or
    Affidavit by noon after the fifth full day (judicial days) and Fridays in
    Sparks Justice Court are not full days in that sense, and regardless, Sparks
    Justice Court, I believe, is not the appropriate forum where, as here, the situs
    is located in Reno (Ward 1-nap?)
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    tel 775 338 8118
    fax 949 667 7403
    000619
    Civil Division
    630 Greenbrae Drive
    Sparks, Nevada 89431
    (775)353.7603 Phone
    (775)352.3004 Fax
    Civil Department Supervisor
    Chris Hansen
    chansen@washoecounty.us
    The Civil Division of Sparks Justice Court is made up of three major
    functions:
    Civil
    Civil Complaints for damages in excess of $5000 or if a suit involves a
    breach of contract, punitive damages, an action to obtain possession of
    property, a writ of restitution, or other like actions, legal counsel is
    suggested for these types of actions.
    Evictions
    An act or process of legally dispossessing a person of land or rental property.
    Small Claims
    An action filed in order to obtain a monetary judgment. Claims must not
    exceed $5000. A small claims action may be filed with the Sparks Justice
    Court if one of the following applies to the defendant:
    1. They reside within the boundaries of the Sparks Township;
    2. They are employed within the boundaries of the Sparks Township;
    and/or,
    3. They do business within the boundaries of the Sparks Township.
    filings in In re Coughlin 60838 and 60975
    000620
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 8/09/12 1:34 AM
    To: tsusich@nvdetr.org; patrickk@nvbar.org; davidc@nvbar.org
    1 attachment
    in re coughlin filings 60838 and 60975.pdf (3.1 MB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com

    12-19902 SCR 115 Affidavit In Re Coughlin 60838


    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 8/08/12 1:47 AM
    To: davidc@nvbar.org; patrickk@nvbar.org
    1 attachment
    12-19902 SCR 115 Affidavit In Re Coughlin 60838.pdf (64.6 KB)
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    000621
    ZachCoughlin@hotmail.com
    Matrix
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 8/01/12 3:30 PM
    To: davidc@nvbar.org
    1 attachment
    20120725_111719.jpg (472.6 KB)
    Dear Bar Counsel,
    In case smartphone failed to send earlier. is my board heading not limited to the jurisdiction set forth in the June 7
    2012 Order? I would like a hearing as soon as I am entitled to one. If I am suspended more than Stephen
    Harris's 3 months, I don't want it be because I didn't request a hearing or signed to a scr 117 deal, although I did
    request for my admission case to be submitted at the end of the September 03 deferral period, though it was
    not...for over another 12 months.
    Respectfully,
    Zach Coughlin
    Matrix
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 8/01/12 3:09 PM
    To: davidc@nvbar.org
    1 attachment
    20120725_111726.jpg (516.4 KB)
    000622
    Message-ID: <BAY148-W5731D7CBA666FD11CD8139C2C40@phx.gbl>
    Content-Type: multipart/alternative;
    boundary="_b86d7598-d95e-45bb-85c3-3d4d8e1b2ac1_"
    X-Originating-IP: [75.14.195.227]
    From: Zach Coughlin <zachcoughlin@hotmail.com>
    To: <zyoung@da.washoecounty.us>, <mkandaras@da.washoecounty.us>,
    <keithloomis@earthlink.net>, <jleslie@washoecounty.us>, <kadlicj@reno.gov>,
    <christensend@reno.gov>, <chaset@reno.gov>, <patrickk@nvbar.org>,
    <davidc@nvbar.org>, <stuttle@washoecounty.us>, <askrpd@reno.gov>
    Subject: request for consideration of global resolution
    Date: Tue, 31 Jul 2012 18:58:52 -0700
    Importance: Normal
    MIME-Version: 1.0
    --_b86d7598-d95e-45bb-85c3-3d4d8e1b2ac1_
    Content-Type: text/plain; charset="iso-8859-1"
    Content-Transfer-Encoding: quoted-printable
    Dear Madams and Sirs.
    =20
    I hope you not find it untoward for me to contact you in this manner. I do =
    not know to what extent it is permissible to mix discussions of potential c=
    ivil causes of actions with=20
    "pending or still subject to being set aside under something like a NRCP 60=
    (b) analysis" criminal matters...if doing so is impermissible=2C then I do =
    not wish to engage any of you in that regard=2C and my apologies.
    =20
    I am deeply humbled by all the various charges and sanctions I have incurre=
    d this year=2C and realize I have made big mistakes=2C only to compound the=
    m with bigger mistakes and ever more greater showings of ill advised instra=
    nsigence. I apologize for those actions.
    =20
    I am doing my best to make sure I do not go back to jail or otherwise upset=
    anyone in the judicial branch or l I realize the DA=2C WCSO=2C or the Ren=
    o City Attorney or the RPD may find it laughable to think that I would have=
    any reasonable basis for bringing suit....but for whatever it is worth=2C =
    I would jump at an opportunity to sign away any such potential claims shoul=
    d it assist me in resolving my outstanding criminal charges (in the RJC=2C =
    there is a misuse of 911 services charge from January 14th=2C 2012 before J=
    udge Pearson=2C the iPhone petty larceny matter from August 20th=2C 2011 be=
    fore Judge Sferrazza=2C and this new obstructing/resisting charge incident =
    to a misunderstanding related to an eviction on June 27th=2C 2012=3B in the=
    Reno Municipal Court there remains a jaywalking charge from January 12th=
    =2C 2012 and a traffic "failure to come to a complete stop" charge from Nov=
    ember 15th=2C 2011=2C both before Judge Nash Holmes=2C the latter of which =
    resulted in an accusation or even=2C perhaps=2C a conviction of summary con=
    tempt=2C perhaps even criminal summary contempt incident to the still suspe=
    nded Trial that was held on February 27th=2C 2012=2C and lastly=2C before J=
    udge Dilworth is the "disturbing the peace" charge stemming from my July 3r=
    d=2C 2012 arrest by the RPD). =20
    =20
    Additionally=2C two convictions of criminal law violations were entered aga=
    inst me in the last year. One in RMC 11CR22176 by Judge Howard for petty l=
    arceny of a candy bar and cough drops from Wal-Mart incident to a September=
    9th=2C 2011 arrest=2C folliwng the November 30th=2C 2011 Trial in that mat=
    ter=2C and=2C two=2C a criminal trespass conviction in 11CR26405 from a Nov=
    ember 12th=2C 2011 arrest=2C following the Trial on June 18th=2C 2012.=20
    =20
    With respect to the two criminal convictions and the appeals thereto=2C as =
    well as the summary eviction proceeding and appeal of that matter (RJC rev2=
    011-001708 and CV11-03628) I have some 60(b) Motions filed the WDC=2C RMC=
    =2C and RJC=2C and should they be granted and these convictions=2C sanction=
    s=2C etc. be set aside=2C then under SCR 111(7)-(8)=2C that may auger towar=
    ds my having a more probable path to regaining my law license.
    =20
    I realize many of you may feel that I lack any leverage here=2C and that ma=
    y well be true=2C regardless of the import of cases like Glazier or Lippis =
    v Justice Court=2C Soldal v Cook County=2C Wheeler v Cross=2C etc.=2C etc.
    =20
    I cannot find anything very clear on whether it is permissible to seek a "g=
    lobal resolution" that may=2C to some extent=2C implicate the resolution of=
    both criminal and civil matters=2C and should that be tantamount to an eth=
    ical violation=2C I do not wish to do so here=2C and=2C in that case=2C ple=
    ase forget I mentioned anything in that regard. =20
    As a side note=2C that criminal trespass conviction stemmed from my being a=
    t the location of my former home law office after an Order of Summary Evict=
    ion was signed (but perhaps not appropriately served prior to any lockout i=
    000623
    n accordance with NRCP 6(e)=2C considering NRS 40.400's mandate that the NR=
    CP apply to landlord tenant mattters=2C and therefore vitiating any such lo=
    ckout. Further=2C the validity of that Order of Summary Eviction in RJC R=
    ev2011-001708 (subsequently appealed to the District Court in CV11-03628 an=
    d resulting in $42=2C500 in attorney's fees being awarded against me=2C for=
    which I am personally responsible) is perhaps up for debate given some of =
    the jurisdictional bars to such an order (please see attached Motions)
    =20
    There are a few 60b type basis for setting aside the Wal-Mart candy bar/cou=
    gh drops petty theft conviction in 11 cr 22176:
    newly discovered proof that a drivers license was provided to the arresting=
    officer (jail property intake form and Wal-mart video shows Coughlin provi=
    ding his drivers license=2C however=2C the RSIC Officer testfied that Cough=
    lin's failure to provide his license was the basis for effectuating a custo=
    dial arrest=2C and therefore=2C a search incident to arrest=2C which result=
    ed in a finding of some cough drops=2C allegedly. However=2C the testimony=
    of both the Wal-Mart LP associate and the RSIC Officers (ie=2C that a upc =
    for such cough drops did not appear on Coughlin's receipt) was expressly co=
    ntradicted by the receipt provided by Coughlin (clear error=2C failure to m=
    eet burden?)=3B additionaly the failure to provide counsel required by the =
    Sixth Amendement=2C where even the merest possibility of jail time exists=
    =2C may provide a void for lack of jurisdiciton basis for setting aside the=
    candy bar/cough drop conviction...if it is set aside=2C I don't want to su=
    e Wal-Mart or anybody else=2C I just want to try to get my license back=2C =
    mend some fences=2C and move on with life while taking care to learn from m=
    y mistakes=2C and asking for foregiveness.
    =20
    Mr. Loomis pointed out the argument that the Notice of Appeal I filed in th=
    e eviction matter Rev2011-001708 likely divesting the RJC of jurisdiciton t=
    o enter the summary eviction Order=2C and therefore=2C the criminal trespas=
    s case conviction may similarly be vulnerable to a set aside=2C as both cas=
    e involve my former home law office (and occured shortly after what was ess=
    entially a divorce from a 5 year relationship).
    =20
    Thank you for any consideration you may give this writing.
    =20
    I am fairly opposed to resolutions of the criminal matters that include any=
    "obey all laws" and "180 days suspended sentence" types of conditions=2C n=
    ot because I think the prosecutors or the system is unreasonable=2C but...w=
    ell=2C I have upset a good number of members of law enforcement and I may w=
    ish to leave the area for an extended time (only if legally allowed to do s=
    o)=2C and for the same reasons (and because I already have two convictions)=
    I would prefer not to go into Mental Health Court (though I greatly respec=
    t Judge Breen)=2C in addition to some other more personal reasons that rela=
    te to my father=2C whom I love. However=2C my whole life has been somewhat=
    of a Mental Health Court or diversion program with my Dad in it=2C as he h=
    as been involved in physician diversion programs for those with mental hea=
    lth problems and substance abuse issues=2C and that has resulted in a tough=
    love approach for years=2C taken to an extreme=2C which=2C at times=2C has=
    seemed to complicate=2C if not derail entirely=2C my attempts to address t=
    he various issues that I face. =20
    =20
    Sincerely=2C
    =20
    Zach Coughlin=20
    PO BOX 3961=20
    Reno=2C NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com =
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    <body class=3D'hmmessage'><div dir=3D'ltr'>
    <FONT size=3D4 face=3D"Times New Roman"><BR id=3DecxFontBreak></FONT>
    000624
    <DIV dir=3Dltr>Dear Madams and Sirs.<BR>&nbsp=3B<BR>I hope you not find it =
    untoward for me to contact you in this manner.&nbsp=3BI do not know to what=
    extent it is permissible to mix discussions of potential civil&nbsp=3Bcaus=
    es of actions with <BR>"pending or still subject to being set aside&nbsp=3B=
    under something like a NRCP 60(b) analysis" criminal matters...if&nbsp=3Bdo=
    ing so is impermissible=2C then I do not wish to engage any of you in that =
    regard=2C and&nbsp=3Bmy apologies.<BR>&nbsp=3B<BR>I am deeply humbled by al=
    l the various charges and sanctions I have incurred this year=2C and realiz=
    e I have made big mistakes=2C only to compound them with bigger mistakes an=
    d ever more greater showings of ill advised instransigence.&nbsp=3B I apolo=
    gize for those actions.<BR>&nbsp=3B<BR>I am doing my best to make sure I do=
    not go back to jail or otherwise upset anyone in the judicial branch or l&=
    nbsp=3B I realize the DA=2C WCSO=2C or the Reno City Attorney or the RPD ma=
    y find it laughable to think that I would have any reasonable basis for bri=
    nging suit....but for whatever it is worth=2C I would jump at an opportunit=
    y to sign away any such potential claims should it assist me in resolving m=
    y outstanding criminal charges (in the RJC=2C there is a misuse of 911 serv=
    ices charge from&nbsp=3BJanuary 14th=2C 2012&nbsp=3Bbefore Judge Pearson=2C=
    the iPhone petty larceny matter from&nbsp=3BAugust 20th=2C 2011&nbsp=3Bbef=
    ore Judge Sferrazza=2C and this new obstructing/resisting charge incident t=
    o a misunderstanding related to an eviction on June 27th=2C 2012=3B&nbsp=3B=
    in the Reno Municipal Court there remains a jaywalking charge from January =
    12th=2C 2012 and a traffic "failure to come to a complete stop" charge from=
    November 15th=2C 2011=2C both before Judge Nash Holmes=2C the latter of wh=
    ich resulted in an accusation or even=2C perhaps=2C a conviction of summary=
    contempt=2C perhaps even criminal summary contempt incident to the still s=
    uspended Trial that was held on February 27th=2C 2012=2C and lastly=2C befo=
    re Judge Dilworth is the "disturbing the peace" charge stemming from my Jul=
    y 3rd=2C 2012 arrest by the RPD).&nbsp=3B <BR>&nbsp=3B<BR>Additionally=2C t=
    wo convictions of criminal law violations were entered against me in the la=
    st year.&nbsp=3B One in RMC 11CR22176 by Judge Howard for petty larceny of =
    a candy bar and cough drops from Wal-Mart incident to a September 9th=2C 20=
    11 arrest=2C folliwng the November 30th=2C 2011 Trial in that matter=2C and=
    =2C two=2C a criminal trespass conviction in 11CR26405 from a November 12th=
    =2C 2011 arrest=2C following the Trial on June 18th=2C 2012.&nbsp=3B</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>With respect to the two criminal convictions and the appeals=
    thereto=2C as well as the summary eviction proceeding and appeal of that m=
    atter (RJC rev2011-001708 and CV11-03628) I have some 60(b) Motions filed&n=
    bsp=3Bthe WDC=2C RMC=2C&nbsp=3Band RJC=2C and should they be granted and th=
    ese convictions=2C sanctions=2C etc. be set aside=2C then under SCR 111(7)-=
    (8)=2C that may auger towards my having a more probable path&nbsp=3Bto rega=
    ining my law license.</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>I realize many of you may feel that I lack any leverage here=
    =2C and that may&nbsp=3Bwell be true=2C regardless of the import of cases l=
    ike Glazier or Lippis v Justice Court=2C Soldal v Cook County=2C Wheeler v =
    Cross=2C etc.=2C etc.</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>I cannot find anything very clear on whether it is permissib=
    le to seek a "global resolution" that may=2C to some extent=2C implicate th=
    e resolution of both criminal and civil matters=2C and should that be tanta=
    mount to an ethical violation=2C I do not wish to do so here=2C and=2C in t=
    hat case=2C please forget I mentioned anything in that regard.&nbsp=3B </DI=
    V>
    <DIV dir=3Dltr><BR>As a&nbsp=3Bside note=2C that criminal trespass convicti=
    on stemmed from my being at the location of my former home law office after=
    an Order of Summary Eviction was signed (but perhaps not appropriately ser=
    ved prior to any lockout&nbsp=3Bin accordance with NRCP 6(e)=2C&nbsp=3Bcons=
    idering NRS 40.400's mandate that the NRCP apply to landlord tenant mattter=
    s=2C and therefore vitiating any such lockout.&nbsp=3B&nbsp=3B Further=2C t=
    he validity of that Order of Summary Eviction in RJC Rev2011-001708 (subseq=
    uently appealed to the District Court in CV11-03628 and resulting in $42=2C=
    500 in attorney's fees being awarded against me=2C for which I am personall=
    y responsible)&nbsp=3Bis perhaps up for debate given some of the jurisdicti=
    onal bars to such an order (please see attached Motions)</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>There are a few 60b type basis for setting aside the Wal-Mar=
    t candy bar/cough drops petty theft conviction in 11 cr 22176:</DIV>
    <DIV dir=3Dltr>newly discovered proof that a drivers license was provided t=
    o the arresting officer (jail property intake form and Wal-mart video shows=
    Coughlin providing his drivers license=2C however=2C the RSIC Officer test=
    fied that Coughlin's failure to provide his license was the basis for effec=
    tuating a custodial arrest=2C and therefore=2C a search incident to arrest=
    =2C which resulted in a finding of some cough drops=2C allegedly.&nbsp=3B H=
    owever=2C the testimony of both the Wal-Mart LP associate and the RSIC Offi=
    cers (ie=2C that a upc for such cough drops did not appear on Coughlin's re=
    ceipt) was expressly contradicted by the receipt provided by Coughlin (clea=
    r error=2C failure to meet burden?)=3B additionaly the failure to provide c=
    ounsel required by the Sixth Amendement=2C where even the merest possibilit=
    y of jail time exists=2C may provide a void for lack of jurisdiciton basis =
    000625
    for setting aside the candy bar/cough drop conviction...if it is set aside=
    =2C I don't want to sue Wal-Mart or anybody else=2C I just want to try to g=
    et my license back=2C mend some fences=2C and move on with life while takin=
    g care to learn from my mistakes=2C and asking for foregiveness.</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>Mr. Loomis pointed out the argument that the Notice of Appea=
    l I filed in the eviction matter Rev2011-001708 likely divesting the RJC of=
    jurisdiciton to enter the summary eviction Order=2C and therefore=2C the c=
    riminal trespass case conviction may similarly be vulnerable to a set aside=
    =2C as both case involve my former home law office (and occured shortly aft=
    er what was essentially a divorce from a 5 year relationship).</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>Thank you for any consideration you may give this writing.</=
    DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>I am fairly opposed to resolutions of the criminal matters t=
    hat include any "obey all laws" and "180 days suspended sentence" types of =
    conditions=2C not because I think the prosecutors or the system is unreason=
    able=2C but...well=2C I have upset a good number of members of law enforcem=
    ent and I may wish to leave the area for an extended time (only if legally =
    allowed to do so)=2C and for the same reasons (and because I already have t=
    wo convictions) I would prefer not to go into Mental Health Court (though I=
    greatly respect Judge Breen)=2C in addition to some other more personal re=
    asons that relate to my father=2C whom I love.&nbsp=3B However=2C my whole =
    life has been somewhat of a Mental Health Court or diversion program with m=
    y Dad in it=2C as he has&nbsp=3B been involved in physician diversion progr=
    ams for those with mental health problems and substance abuse issues=2C and=
    that has resulted in a tough love approach for years=2C taken to an extrem=
    e=2C which=2C at times=2C has seemed to complicate=2C if not derail entirel=
    y=2C my attempts to address the various issues that I face.&nbsp=3B&nbsp=3B=
    &nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B </DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>Sincerely=2C</DIV>
    <DIV dir=3Dltr>&nbsp=3B</DIV>
    <DIV dir=3Dltr>Zach Coughlin </DIV>
    <P style=3D"MARGIN-BOTTOM: 0in" dir=3Dltr>PO BOX 3961 </P>
    <P style=3D"MARGIN-BOTTOM: 0in" dir=3Dltr>Reno=2C NV 89505</P>
    <P style=3D"MARGIN-BOTTOM: 0in" dir=3Dltr>Tel 775 338 8118</P>
    <P style=3D"MARGIN-BOTTOM: 0in" dir=3Dltr>Fax 949 667 7402</P>
    <P style=3D"MARGIN-BOTTOM: 0in" dir=3Dltr>ZachCoughlin@hotmail.com</P> =
    </div></body>
    </html>=
    --_b86d7598-d95e-45bb-85c3-3d4d8e1b2ac1_--
    000626
    Print Close
    resending this FW: Apology and Zach Coughlin prescription
    medications information
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 7/31/12 1:39 PM
    To: patrickk@nvbar.org
    1 attachment
    Zach Coughlin rx history since February 2008.pdf (1163.3 KB)
    Dear Mr. King,
    I am resending this too you just in case it went into your "junk mail" folder the first time I sent it (given
    that it was addressed to numerous people, as sometimes results in an email being declared "junk mail"
    by one's email server)....Its admittedly fairly rambling, but I believe it does demonstrate a willingness to
    look within for a cause of the problems I have encountered in the last year.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: tcoughlinmd@hotmail.com; davidc@nvbar.org; patrickk@nvbar.org; glennm@nvbar.org;
    marybarkbark@yahoo.com
    Subject: Apology and Zach Coughlin prescription medications information
    Date: Mon, 14 May 2012 12:37:17 -0700
    Dear Dad, Bar Counsel, Mom and Melissa,
    I am sorry for all the hurtful things I have said and done in the last
    year. I haven't been on my Wellbutrin/Buproprion antidepressant
    000627
    Page: 1
    M E D I C A L EX P E N S E S
    COUGZA1
    Patient: COUGHLIN, ZACH
    Resppty:
    DC!! 1422 E 9TH ST #2
    REO
    Birth: 09/27/1976
    Prescriptions:
    ,N 89512
    LastFill R # Drug Name
    01/30/08 6405827 BUDEPRION X 300 M
    02/01/08 2401067 MTHYL IN 20M
    03/01/08 6405827 BUEPRION X 300 MG
    03/03/08 2401357 VVANSE 70 MG
    03/30/08 2401611 VYVANSE 70 M
    04/02/08 6413703 BUPROPION 300 MG X
    05/01/08 2401932 VYVASE 70 M
    05/05/08 6416295 BUPROPION 300 MG X
    06/02/08 2402229 VYVASE 70 M
    06/02/08 6416295 BUPROPION 300 M X
    06/27/08 2402484 VYVANSE 70 MG
    07/03/08 6416295 BUPROPION 300 MG X
    08/01/08 2402852 VYVANSE 70 M
    08/04/08 6422989 BUPROPION 300 M X
    08/30/08 2403149 VYVANSE 70 MG
    09/06/08 6422989 BUPROPION 300 MG X
    09/30/08 2403415 VANSE 70 M
    09/30/08 6422989 BUPROPION 300 M X
    10/30/08 2403418 VYVANSE 70 M
    10/30/08 6430436 BUPROPION 300 MG X
    11/30/08 2403419 VYANSE 70 M
    11/30/08 6430436 BUPROPION 300 M X
    12/19/08 6434447 GUAFACINE 1MG
    12/28/08 2404354 VYVASE 70 MG
    12/28/08 6434452 BUPROPION 300 MG XL
    01/24/09 2404356 VYASE 70 M
    01/24/09 6434452 BUPROPION 300 M X
    02/17/09 6430436 BUPROPION 300 M XL
    02/18/09 2404355 VASE 70 MG
    03/18/09 2405234 VASE 70 MG
    03/18/09 6441680 GUAFACINE 1M
    03/18/09 6441682 BUPROPION 300 M X
    03/20/09 6441898 VIAGR 50MG
    04/17/09 2405236 VYVANSE 70 MG
    05/04/09 6441682 BUPROPION 300 MG XL
    05/18/09 2405237 VYVANSE 70 MG
    06/05/09 6441682 BUPROPION 300 M X
    06/13/09 2406368 AMPHETAMINE 30MG
    07/17/09 2406369 AMHETAMINE 30MG
    07/17/09 6452048 BUPROPION 300 MG X
    08/11/09 2407073 VNSE 70 M
    08/11/09 6452048 BUPROPION 300 M X
    09/10/09 6456472 BUPROPION 300 MG XL
    10/16/09 2407500 VANSE 70 MG
    10/16/09 6456472 BUPROPION 300 MG XL
    11/15/09 2407501 VYVANSE 70 MG
    11/23/09 6463678 BUPROPION 150M SR
    12/31/09 6463678 BUPROPION 150MG SR
    01/17/10 6468474 OMPRZOLE 20M
    01/22/10 2409075 AMPHETAMINE 20MG
    02/02/10 6463678 BUPROPION 150MG SR
    Pharmacy: SAVE MART PHACY #556
    195 W. PLU LE
    RENO N 89509
    RPh: TAYLOR, JACKIE/TOMY
    Date: 01/01/2008 TO 05/01/2012
    Qty Physician Name
    30 Dr.RASUL
    60 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    5 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.COUGHLIN
    90 Dr.RASUL
    60 Dr.RASUL
    T/P
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    Price RPh
    25.00
    22.23
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    25.00
    73.41
    25.00
    25.00
    160.48
    92.72
    52.68
    52.68
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    5.00
    5.00
    34.67
    5.00
    J
    TZ2
    JT5
    JH2
    JH5
    JT3
    JH3
    JT1
    JT3
    JT3
    JT6
    JT4
    K06
    TZ7
    TZ5
    JT6
    KC2
    KC2
    JRT
    JT1
    JT6
    JT6
    JT3
    JT4
    JT8
    TZ5
    TZ5
    JT5
    TZ5
    TZ2
    JT3
    JT3
    TZ5
    JT8
    M
    JT
    TNZ
    TNZ
    J9
    JG6
    JG3
    JT1
    JT5
    JG5
    JG5
    JG6
    JT1
    JG5
    JT5
    JG3
    JG3
    .L EXPENSES
    Pago:
    Pharmacy: SAVE MART PHARMACY 15
    115 W. PLUMB LANE
    RENO NV 81509
    RPh: TAYLOR. JACKIErOMMY
    NV 89512
    Dato: 0110112000 TO 0510112012
    .gNamo Oty PhysicianNam TIP Prico "Ph
    90 D'.RASUL 34.67 JGJ
    60 Dr.RASUL CPB 5.00 JGJ
    60 DI.RASUL CPB 15.00 JGO
    40 Dr.PARRon APN CPB 4.87 JGJ
    180 Dr.RASUL CPB 25.00 JGJ
    60 Or.RASUL CPO 5.00 JTS
    6Or.RASUL CPO 15.00 LOO
    6O,.RASUL CPB 5.00 J.S
    60 Or.RASUL CPO 15.00 M'
    00 Or.RASUL CPO 15.00 JMG
    6Or.RASUL CPO 5.00 Z1.4
    6 Or.RASUL CPB 15.00 JT4
    6 Or.RASUL CPO 5.00 LB.
    60 Or.RASUL 32.05 JG5
    6Or.YASAR 32.95 JT4
    60 Or.YASAR 32.95 LB4
    120 Dr.YASAR 32.48 JGI
    00 Or.YASAR 32.95 JT6
    60 Dr.YAMR 32.95 G'J
    60 Dr.YASAR 32.46 JG'
    00 Dr.YASAR 32.95 G13
    6 Dr.YASAR 32.46 JG'
    8Dr.YASAR 32.95 JT8
    60 Dr.YASAR 32.46 JT8
    60 Dr.YASAR 32.95 2MO
    6 Or.YASAR 32.46 J.J
    60 Dr.YASAR 26.79 JTO
    60 Dr.YASAR 37.39 JT6
    6 Dr.YASAR 32.05 JG3
    6Dr.YASAR 37.39 JTS
    60 Dr.YASAR 26.79 JT6
    60Dr.YASAR 36.89 2M2
    8Dr.YASAR 20.23 ZM,I
    6Dr.YASAR 15.46 118
    60 Dr.YASAR 60.00 Z11
    60 Dr.YASAR 60.00 Mt.f
    60 Dr.YASAR 60.00 JTS
    60 Dr.VASAR 69.19 MM4
    60 Dr.YASAR 69.19 JT1
    60 Dr.YASAR 60.19 MM7
    6Or.VASAR 61.01 195
    Roport Dalo: 05101/2012 $2.720.3"
    AI1os10d To By: )
    oglO 01 m '"
    M EDI C A L EXPEN S E S
    Pago:
    COUGZAI
    allonl: COUGHLIN. ZACH Pharmacy: SAVE MART PHARMACY 11556
    :ospPty: 195 W. PLUMB LANE
    D:: 1422 E 9TH ST 1 RENO NV 89509
    RPh: TAYLOR. JACKIEffOMMY
    RENO NV 89512
    Ilflh: 09127/1076
    'roscriptlons: Oato: 01101/2000 TO 0510112012
    O..g Namo Oy Physician N;lmo TIP Prico RPh
    METHYLIN 20MG 60 OLRASUL 22.23 JHl
    I VYVANSE 70 MG 30 Or.RASUL OPU JT3
    SUOEPRION XL 300 MG 30 Or.RA5UL CPB 25.00 JWH
    METHYLIN lOMG 6Df.RASUL 22.23 TZ2
    IUDEPRION XL 300 MG 30 Or.RASUL CPB 25.00 JT5
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JH2
    I VYVANSE 70 MC 30 Dr.RASUL CPB 25.00 JI-IS
    BUPROPION 300 MG XL 300r.RASUL cpa 25.00 JT3
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JH3
    SUPROPION 300 MG XL 30 OLRASUL CPB 25.00 JTI
    VYVANSE 70 MG 30 Or.RASUL cpa 2S.00 JT3
    BUPROPION 300 tAG XL 30 Or.RASUL CPB 25.00 JT3
    VYVANSE 70 MG 30 OLRASUL CPS 25.00 JTO
    BUPROPION 300 MG XL 30 Or.RASUL cpa JT4
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 K06
    OUPROPION 300 MG XL 30 Or.RASUL cpa 25.00 TZ7
    VYVANSE 70 MG 30 Or.RASUI. CPB 25.00 TZ5
    BUPROPION 300 MG XL 30 Dr.RASUL CPB 25.00 JT6
    I VYVANSE 70 MG 30 Or.RASUL CPB 25.00 KCZ
    BUPROPION 300 MG XL 30Dr.RASUL cpa 25.00 KCZ
    I VYVANSE 70 MG 30 Or.RASUI. cpa 25.00 JRT
    IUPIOPION 300 MG XL 30 Or.RASUI. CPB 2S.00 JTI
    VYVANSE 70 MG 3 Dr.RASUL CPB 25.00 JTO
    BUPROPION 300 MG XL 30 Or.RASUL cpa 25.00 JTO
    GUANFACINE 1 MG 60 Or.RASUL cpa 5.00 JT3
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JT4
    BUPROPION 300 MG XL 300r.RASUL CPB 25.00 JTO
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 TZ5
    OUPROPION 300 MG XL 300r.RASUL CPB 25.00 TZ,
    IlUPROPION 300 MG XL 30Dr.RASUL cpa 25.00 JT5
    VYVANSE 70 MG 300r.RASUl CPB 25.00 TZS
    VYVANSE 70 MG 30 Or.RASUL cpa 25.00 T22
    GUANFACINE 1MG 6Or.RASUl CPB 5.00 JT3
    nUPROPION 300 MG XL 300r.RASUI. CPB 25.DO JT3
    VIAGRA SOMG 50r.RASUl CPB 73.41 TZ'
    VYVANSE 70 tAG 30 Or.RASUl cpa 25.00 JTO
    tlUPROPION 3 MGXl 300r.RASUL CPB 2S.00 "VB
    VYVANSE 70 AG 30 Or.RASUl 100.48 JRT
    BUPROPION 300 MGXL 300r.RASUL 02.72 TNZ
    AMPHETAMINE 30MG 600l.RASUl 52.68 TNZ
    AMPHETAMINE 30MG 600r.RASUL 52.68 JTO
    BUPROPION 300 MGXL 30 OI.RASUl CPB 25.00 JGO
    VYVANSE 70 MG 30 Dr.RASUL cpa 25.00 JG3
    BUPROPION 300 1.1G Xl 30 Dr.RASUL CPB 25.00 JTI
    BUPROPION 300 MGXl 30 Or.RASUl CPB 2S.00 JT'
    VYVANSE 70 MG 30 Or.RASUL cpe 25.00 JG5
    eUPROPION 300 MG Xl 30 Or.RASUl CPS 25.00 JGS
    VYVANSE 70 MG 300r.RASUL CPB 25.00 JGO
    BUPROPION ISOMG SR 6 Or.RASUL CPB S.OO JTI
    BUPROPION 150MG SR 60 Or.RASUl CPB 5.00 JGS
    OMEPRAZOlE 20MG 60 Or.COUGHLIN CPB 5.00 JTS
    M E D I C A L
    COUGZA1
    Patient: COUGHLIN, ZACH
    Resppty:
    DC!! 1422 E 9TH ST #2
    RENO
    Birth: 09/27/1976
    prescriptions:
    ,N 89512
    LastFill R # Drug Name
    02/19/10 2409405 ADDERALL X 30MG
    02/24/10 6471901 MTOCLOPRAM 5M
    03/18/10 6472900 CAMRAL 333MG
    03/19/10 6474257 BUPROPION 150MG SR
    03/20/10 2409769 ADDERLL X 30MG
    04/19/10 6474257 BUPROPION 150M SR
    04/21/10 2409770 ADERALL X 30M
    OS/22/10 2409771 ADDERALL X 30M
    06/03/10 6474257 BUPROPION 150M SR
    06/17/10 2410853 ADDERALL X 30M
    07/12/10 6484763 BUPROPION 150MG SR
    08/02/10 2411503 AMPHETAMINE 30MG
    09/02/10 2411881 APHETAMINE 30M
    10/02/10 2411974 APHETAMINE 30MG
    10/06/10 6492514 BUPROPION 75MG
    11/01/10 2411973 AMHETAMINE 30M
    12/02/10 2412940 AMPHETAMINE 30M
    12/02/10 6489816 BUPROPION 150M SR
    12/18/10 2413141 APHETAMINE 30M
    12/23/10 6489816 BUPROPION 150MG SR
    01/31/11 2413142 AMPHETAMINE 30MG
    01/31/11 6489816 BUPROPION 150M SR
    03/03/11 2413143 AMPHETAMINE 30M
    03/03/11 6505746 BUPROPION 150M SR
    04/04/11 2413144 AMPHETAMINE 30MG
    04/04/11 6505746 BUPROPION 150MG SR
    04/22/11 2414647 AMPHETAMINE 30M
    OS/21/11 6511008 BUPROPION 150M SR
    06/03/11 2414644 APHETAMINE 30M
    06/25/11 6511008 BUPROPION 150M SR
    06/29/11 2414645 AMPHETAMINE 30MG
    09/12/11 2416340 AMHETAMINE 30MG
    10/13/11 2416349 AMHETAMINE 30M
    11/17/11 2416350 AMPHETAMINE 30M
    12/26/11 2416351 AMPHETAMINE 30M
    01/26/12 2417915 AMPHETAMINE 30MG
    02/27/12 2417919 AMHETAMINE 30MG
    04/02/12 2417920 AMPHETAMINE 30MG
    04/28/12 6521924 BUPROPN HCL 150MG X
    Report Date: 05/01/2012
    Attested To By:
    E X P E N S E S
    Pharmacy: SAVE MRT PHACY #556
    195 W. PLUM LE
    RENO N 89509
    Page: 2
    RPh: TAYLOR, JACKIE/TOM
    Date: 01/01/2008 TO 05/01/2012
    Qty Physician Name T/P Price RPh
    60 Dr.RASUL
    40 Dr.PARROTT APN
    180 Dr .RASUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RSUL
    60 Dr .RSUL
    60 Dr .RASUL
    60 Dr.RSUL
    60 Dr.YASAR
    60 Dr.YASAR
    120 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASA
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    15.00
    4.87
    25.00
    5.00
    15.00
    5.00
    15.00
    15.00
    5.00
    15.00
    5.00
    32.95
    32.95
    32.95
    32.46
    32.95
    32.95
    32.46
    32.95
    32.46
    32.95
    32.46
    32.95
    32.46
    26.79
    37.39
    32.95
    37.39
    26.79
    36.S9
    20.23
    45.46
    60.00
    60.00
    60.00
    69.19
    69.19
    69.19
    61. 01
    $2, 707.11
    JG6
    JG3
    JG3
    JT5
    LB6
    J15
    AF
    J
    ZM4
    JT4
    LEI
    JG5
    JT4
    LE4
    JG1
    JT6
    G13
    JG1
    G13
    JG4
    JT8
    JTS
    ZM6
    J13
    JT6
    JT6
    JG3
    JT5
    JT6
    ZM2
    ZM4
    M8
    Zl1
    M7
    JT5
    M4
    JT7
    M7
    BB5
    for quite awhile (I pulled my pharmacy records recently to try to
    learn from some things). I have taken anti-depressants since I was
    18 years old. I wasn't on either my Wellbutrin or Adderall for all of
    August 2011 until September 14, 2011. I was arrested on August
    20th, 2011 and September 9th, 2011. The Walmart arrest involved
    chocolate and cough drops. The cough drops have
    dextromethorphan in them, which is a dissociative in high enough
    doses. Chocolate (sugar) is, of course, an old time palliative. The
    banned cough drop (the melt or dissolve very quickly and contain
    30 mg in each one...so rather than powering through a whole bottle
    of cough syrup to take 300 mg of DM, one could eat 10 cough drop
    melts rather easily and quickly). These drops were pulled from
    shelfs for awhile when they first came out a few years ago, I believe
    because of the abuse potential or dangers of being able to ingest
    that high a quantity of a powerful dissociative so quickly (the cough
    syrup version of dextromethorpan is extremely difficult to just drink
    a whole bottle of, whereas the sugary cough melts are pretty much
    similar to candy). I went off the Adderall on approximately
    August 2, 2011. I went of the Wellbutrin in July 2011, right after
    the breakup of a four and half year. Okay, I went and found the
    records and am attaching them to this email. I wondered whether
    the switch from Vyvanse to Adderall coincided with my getting
    fired from Washoe Legal Services, but actually, it does not appear
    to have. I was suspended on April 20th, 2009 from WLS. Then,
    my termination date was May 12th, 2009. I only started taking
    Adderall instead of Vyvanse on June 13th, 2009. I was wondering
    if I became more irritable upon starting Adderall instead of
    Vyvanse and though maybe that cause the problems with the family
    court Judge during the March 2009 trial and then with Washoe
    000628
    Legal Services. I am actually kind of relieved to see their does not
    appear to be a causal connection given the chronology. I think I
    just felt WLS was a bit of a dead end job for me, was ruining my
    work ethic and motivation, and was, perhaps, an environment where
    white males had to conform to a certain prototype to fit in, one
    which I was not entirely at home with.
    You can see I filled one for Campral. See this forum
    for evidence that tolerance to Adderall is sometimes thought to be
    counteracted by a class of medications that includes Campral,
    Dextormethorphan (DM is also being used to treat chronic pain
    patients in some experimental studies), etc.:
    http://addforums.com/forums/showthread.php?t=36078
    http://www.ncbi.nlm.nih.gov/pubmed/10875724
    I recall researching this in an attempt to be ultra cautious in
    my use of Adderall.
    My chronic pain levels seem to be much, much, more manageable
    when I am taking Wellbutrin and Adderall. I believe that the
    chronic upper back pain I dealt with for years was due, in part, to
    emotional/mental stress related to not appropriately addressing my
    ADHD and the spotty use of antidepressants I exhibited during
    those years (if my Dad and I were getting along, I would get
    Wellbutrin from him for free, if we weren't, I would rarely secure
    my own health insurance or pay out of pocket for that
    antidepressant, but would rather "rough it" to save money). When I
    went off the Wellbutrin and Adderall, the chronic pain returned,
    plus, I was basically in the early stages of a "divorce" from Melissa
    (whom I dated and lived with since April-ish 2007 until May 17th,
    000629
    2011. Melissa and I had been fighting since we moved into the
    home/office on River Rock on February 20th, 2010. From probably
    June 2010 until she moved out on May 17th, 2011, we fought
    almost daily, sometimes in a fairly hostile way (I was never
    physically violent with her, but she got a bit with me). I was
    existing on $400 a week in unemployment benefits, receiving them
    for 99 weeks. I actually worked quite hard the entire time. I
    learned a lot about a lot of different things, including some things
    related to the business of law, practice management, employment
    law, computers, software, hardware, cars, home improvement, I did
    focus on music for about 6 months straight (though I always
    continued to apply for jobs and send out resumes during this 99
    weeks...Washoe County had 15% unemployment during those 3
    years and jobs were in short supply and starting my own law
    practice seemed overly risky), and I was basically Melissa's maid
    and helper with proofreading her schoolwork for a couple years (in
    my mind at least, of course she may have a vastly different view of
    things). She worked a significant amount of hours and was in
    school full time and was irritable, extremely emotional, and
    stretched pretty thin. I implemented the "I pay for dinner one time,
    then you pay for dinner one time" rule for going out to dinner, and,
    of course, that took a lot of the romance out of things. I think I
    became very insecure about money and my career and getting fired
    from WLS was very, very discouraging. But, I worked their for 18
    months. Previous to that my longest tenure of employment at any
    job whatsoever was literally 4 months at Hale Lane. I am talking
    ANY job, my whole life. I realize my father has concerns about
    someone in recovery taking a controlled substance like Adderall,
    but I have exhibited symptoms consistent with a strong case of
    000630
    ADHD my entire life, and feel to potential for substance abuse
    inherent to untreated ADHD presents a great risk than does taking
    Adderall, though, admittedly, it is something that one must watch
    and realize that it can effect one's behavior and mood, sometimes in
    good ways, sometimes in bad ways. But so can drinking or not
    drinking water. So can taking or not taking insulin. Same with
    coffee. So, in some ways I consider adding the Adderall to the
    Wellbutrin a success and feel that I may have purposefully gotten
    fired from WLS because the malaise there and institutional politics
    were tough to deal with. Plus, it just occurred to me there that I
    could work there forever, it was an incredibly easy job, but their
    was not a pension, the pay was like $55K, they didn't give me the
    $5K raise after a year they promised (it seems small, but watching
    them heat half and empty building for months on end to 84 degrees
    round the clock because the office manager couldn't figure out how
    to fix the thermostat was just irritating), and that the law just held a
    different destiny for me than to be a legal aid domestic violence
    attorney for years and years, as honorable and admirable as that
    may be. Interestingly, a couple of the people I had the most
    problems with appear to have been fired from WLS after me.
    Previously, the Executive Director basically would not fire anyone
    unless they embezzled. It appears I changed his approach and got
    him to implement firing people as a management tool. He fired that
    office manager, RK, and he also fired ZL (I believe, though she
    might have just left, though I cannot imagine that because what
    other job would allow her to call in sick, with full pay, 30 Fridays a
    year and be accountable to absolutely no one and call herself a
    paralegal with no apparent legal training at all? Plus she, allegedly,
    had borrowed money from various employees without paying them
    000631
    back, so...).
    Speaking of borrowing money, when we broke up, Melissa stayed
    at Mom's for awhile (Mom now says Melissa "uses her tears to her
    advantage" and that she "feels a bit used by Melissa"), and Mom
    bought her a $500 mattress from Costco (we had two very nice
    memory foam beds I build with spare foam from Mills End fabrics
    and all bought with my $400 a week and thrift, and I just didn't
    want to give Melissa one when I felt she had been so unappreciative
    of things just like my building those beds and doing the research,
    etc.). We both agreed though that Melissa being an insulin
    dependent diabetic undoubtedly presents challenges to her in
    regulating her mood and emotions and that Melissa has
    demonstrated extraordinary courage and resolve in meeting those
    challenges. Then, Mom just admitted to me that Carly loaned
    Melissa several hundred dollars. Apparently Carly is pissed
    because Melissa is in New York City right now and still hasn't paid
    Carly or Mom back (she also went in September 2011, and we were
    supposed to go in July 2011, bought the tickets and everything
    $450, but her Aunt decided to change her travel to Ireland dates, so
    I basically lost that $450 due to the change fees Delta and American
    charge-Melissa bought the tickets and did not think to utilize
    Southwest...). Melissa also made off with at least one and possibly
    two months of my rent contribution that I gave her to give the
    landlord, plus, she didn't pay the landlord her contribution for May
    2011, June 2011, etc. However, as in all 4.5 year relationships,
    things get blurry, etc., and she is a wonderful person.
    SOMETHING PRETTY INTERESTING:
    000632
    One thing I note from the prescription history is I filled a
    Buproprion (note, I am using the terms Buproprion and
    Wellbutrin interchangeably) script on 3/18/09, then did not fill
    another one until 5/4/09...meaning a period of some 16 days
    or so where I was either out of Buproprion or did not take it
    or took less than my typical dose. I was suspended from
    WLS on 4/20/09. My final termination date was 5/12/09.
    That is pretty interesting. I seem to recall sometimes when
    my script for Buproprion ran out and there could be some lag
    time getting the doctor to fax a renewal to the pharmacy, and
    I believe at one point during the past couple years I
    complained to the pharmacy and the doctors office about an
    extended delay in getting my prescription renewed and filled
    and I specifically took them to task about the dangers of
    patients suddenly going of there antidepressants and recall
    being upset about what I perceived to be the doctor's office's
    or pharmacies negligence in so renewing the prescriptions. I
    do not believe I was blame shifting and avoiding my own
    responsibilities in that regard, but it is possible I should have
    done more in advance of running out of my Buproprion to
    renew the prescription and or should have followed up more
    on the failure to so renew after I made the renewal
    request....I believe this was during that 5/4/11 to 5/21/11
    period, but am not sure at this point, but I recall being upset
    that somethign like 3 weeks went by and my prescription was
    not ready...or I may have been late in making the request.
    seem to undervalue what Bupropion does for my mood and
    behavior, I recall often thinking they were just "sugar pills"
    and it was all in my mind, any benefit....But, I didn't always
    believe that, sometimes finding the efficacy apparent.
    I
    000633
    Looks like I went off Buproprion between 5/21/20 and
    6/17/10 as well. I went off Buproprion again between 8/12/10
    and 10/6/10....I notice that my copays stopped around
    7/12/10, which was went I stopped getting the reduced Cobra
    premiums under the Obama bailout, and had to start paying
    out of pocket (though it was essentially a wash, because the
    Cobra was $180 a month, plus $20 in copays, whereas, out of
    pocket was probably less overall, though it was $105 ever 3
    months for the psychiatrist and the prices of Adderall and
    Wellbutrin (I dropped Adderal XR probably because it cost
    more) spiked somewhat during that time). Then again from
    11/6/10 to 12/2/10, though its possible that I used that
    10/6/10 prescription, which consisted of 120 of the 75mg
    Buproprion generic versions to try to effect a discount by
    taking less Buproprion per day, ie, stretch one month of a
    script out 3 months or so by only taking 150 mg or 75 mg or
    something, I do remember trying to save money like that. I
    am very startled to see that from 5/4/11 to 5/21/11 I would
    have been out of Wellbutrin/Buproprion. Melissa and I broke
    up and she moved out on 5/17/11. I did have trouble with
    the ignition cylinder turning the key to start the car when
    trying to go to Melissa's graduation party on 5/15/11, and
    was at least 45 minutes late, causing her embarassment and
    pain. However, despite the fact that the key would not turn
    the cylinder causing me some delay, I believe it did not cause
    that much of a delay in finding some other way to get to the
    graduation party, but rather, my ADHD and depression led
    me to trying to do to many other things that day, misjudging
    time and the ability to get a reasonable amount of things
    000634
    done (I was probably trying to finish fixing Melissa's car or
    something else that was no where near as important as
    showing up to that party on time....but that is typical of
    people with depression and ADHD, the prioritizing and
    misjudging time, lateness, etc....). I do recall saying very
    mean things to Melissa during that 3 week stretch in May
    2011...however, both she and I were stressed out preparing
    for her graduation and final exams, having a great deal of her
    out of town family coming into town, my fighting with my Dad
    starting on 4/28/11 and having a bad argument about
    something rather small and minor, etc., and my
    unemployment benefits stopping right about late April 2011
    (99 weeks from May 21, 2009 start date would mean my
    unemployment ran out in early April 2011, I believe).
    I switched to the cheaper generic version of Adderall from the
    perhaps more steady consistent Adderall XR in June 2010.
    Melissa and I fought constantly from June 2010 until our
    breakup in June 2011....There were news reports of the price
    of Adderall XR skyrocketing out of the blue at about this time
    and there was a fair amount of controversy about Shire
    retaining the rights to make the generic and the generic
    version being essentially, garbage, according to many
    patients.
    http://www.addforums.com/forums/showthread.php?
    t=112229
    It is pretty crappy when you think about it, these drug
    companies increasing the copay from $29 on a mental health
    medication once month to $180 the next...and artificially
    000635
    forcing people to avoid the generic by retaining the rights to
    the generic and purposefully making the generic lack efficacy.
    http://www.drugs.com/answers/why-has-the-price-of-
    adderall-generic-30-mg-gone-455000.html
    http://motherboard.vice.com/2012/2/16/anatomy-of-the-
    great-adderall-drought
    http://www.thefix.com/content/pay-attention-adderall-add-
    big-pharma7004
    I then went off my Wellbutrin/Buproprion from 7/25/11 until
    4/28/ 12..From filling the Buproprion at a cost of $20 in June
    of 2011 until recently filling the prescription in late April 2012,
    the cost has gone up 300%. That medication has been off
    patent for some 20 years now, it should not be rising in price,
    especially during a period where the economy has struggled
    so mightily. Interestingly, the cost of those cough drop melts
    with 30 mg of Dextromethorphan per melt rose form around
    $6.50 a box in 2007 or so to $8.88 in September 2011 for the
    exact same quantity/dosage. I simply could not afford it
    though on at least two occasions I called up Northern Nevada
    Adult Mental Health and inquired about the possibility of
    getting the cost paid for by the state or subsidized. In
    evaluating the time and relinquishment of my privacy rights
    (there is a fair amount of shame and worry about one's
    professional reputation and how those in recovery or AA will
    view one's taking these medications associated with taking
    ADHD and Major Depressive Disorder medications) that I felt
    000636
    it would require to achieve the savings of around $125 a
    month for these two prescriptions, I never decided it was
    worth it to go to NAMS, but rather just stopped paying for the
    Buproprion (again, I sometimes viewed it as a sugar pill,
    whereas the Adderall I felt had an effect, both for controlling
    ADHD and for the supplemental uses as a treatment resistant
    antidepressant and the off label use for the control of OCD.
    In that time period I was put in jail 8 times and, essentially
    evicted 3 times and fought with and alienated myself from my
    entire family, lived a very secluded, reclusive life, etc...
    exhibited poor impulse control, a temper, and symptoms
    consistent with untreated Major Depressive Disorder (MDD)
    and perhaps some type of hoarding behavior or Obsessive
    Compulsive Disorder, including tiling the River Rock home
    office, collecting car seats, recarpeting the entire home office
    with scraps in a patchwork, and tiling the crumbling front
    steps, and putting green carpet on the dirt lawn.
    I was arrested on:
    8/20/11 for petit larceny (the lost mislaid iPhone thing where
    the finder said he would "throw it in the river if someone
    doesn't claim it right away"). 7 days in jail.
    9/9/11 for petit larceny at Wal-Mart of a chocolate bar and
    two boxes of the cough medication drops/melts with
    Dextromethorphan 30 mg per melt. 1 day in jail.
    11/12/11 for criminal trespass at my former home law office
    (i was issued 3 traffic citations days later when I went to the
    opposing attorney who signed the criminal trespass
    complaints office to retrieve my wallet and driver's license and
    was told to leave by the RPD. While driving away the RPD
    000637
    pulled me over and charged me with a "California Roll"/failure
    to come to a complete stop and a couple fix it tickets, that
    were ultimately fixed). 3 days in jail
    11/30/11 for summary contempt during the trial for the Wal-
    Mart chocolate bar and cough medication drops Trial before
    Judge Howard in RMC 11 CR 22176. 1 day in jail.
    1/12/12 for jaywalking while filming personal property at my
    former home law office being placed in a dump truck for
    hauling to the dump. 1 day in jail
    1/14/12 for "misuse of 911 where no actual or perceived
    emergency exists), a gross misdemeanor incident to the
    domestic violence I was victimized by on E. 9th St. by my
    housemates. 3 days in jail
    2/27/12 for summary contempt during the trial for the
    11/15/11 traffic citations "California Roll"/failure to come to a
    complete stop at stop sign deal....5 days in jail
    4/19/12 for contempt, I believe, for failing to fully participate
    (concern for privacy rights, shame, etc) in the ordered
    competency evaluation that Judge Elliot ordered I undergo
    with the Lake's Crossing doctors. I spent 7 days in jail.
    I am feeling better and better since starting to take my
    antidepressant, Wellbutrin again, and now realize I need to be
    much more diligent in filling that prescription in a timely
    manner and making preparations for situations where I might
    not be able to afford it. I plan to write many apology letters,
    including to judges, bar counsel, opposing counsel, etc. I
    always fought and worked hard for my clients though for an
    extremely competitive price.
    000638
    Sincerely,
    Zach Coughlin, Esq.
    reporting convictions and suspension of law license to USPTO
    OED
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 7/31/12 1:32 PM
    To: patrickk@nvbar.org; oedonline@uspto.gov; sue.hines-laboy@uspto.gov
    Cc: davidc@nvbar.org
    1 attachment
    uspto_report_letter_of_conviction_Coughlin.pdf (25.4 KB)
    Hi Mr. King and USPTO OED,
    Mr. King, Thanks for taking the time to sit down with my last Friday. I am copying you on a couple
    things here. I want to bet sure to do my best to comply with the reporting requirements of SCR 111
    and the similar requirements with the United States Patent and Trademark Office (USPTO, I am licensed
    with the USPTO, I suppose formerly as a patent attorney, but given my current suspension of my
    Nevada law license, I am unsure whether that makes me a patent agent with the USPTO or if that
    license will be effected to a greater extent.
    One thing that I am trying to figure out is whether a civil "summary contempt" finding, as I believe
    Judge Howard found me guilty of in Reno Municipal Court Case 11 CR 22176 and or what appears to be
    a criminal "summary contempt" finding, as Judge Nash Holmes ruled in RMC 11 TR 26800 are
    "convictions" subjecting to the reporting requirments of the Nevada Supreme Court's SCR 111 and the
    USPTO's reporting requirements, ie, (37 C.F.R. 11.25(a), etc..." Persons who are required to report
    crimes include registered patent attorneys, registered patent agents, and any attorney practicing before
    the Trademark Office or representing an employee of the USPTO in any non-patent or non-trademark
    matter. A crime is defined by 37 C.F.R. 11.1 as any offense declared to be a felony or
    misdemeanor by Federal or State law in the jurisdiction where the act occurs. Traffic offenses such as
    000639
    a DUI, a hit and run, or vehicular homicide, are considered crimes under the rule.
    State law violations under the category of reciprocal discipline fall under suspension or disbarment from practice on
    ethical grounds by a state under 37 C.F.R. 10.23(c)(5), or conviction under a state law offense involving moral
    turpitude under 37 C.F.R. 10.23(c)(1). Examples of conduct in the category involving criminal convictions include:
    assault with a deadly weapon; engaging in sexually explicit conversation with a minor over the internet; hit and run and
    DUI; sexual assault; encouraging an illegal alien to come to the United States; insider trading; wire fraud; and possession
    and trafficking of a controlled substance.7 A few examples of state convictions that involved matters before the USPTO
    not covered under other USPTO rules provisions other than under 37 C.F.R. 10.23(c)(5).
    Additionally, I believe I may have been found in summary contempt in CR12-0376 in the Second Judicial District Court
    in and for Washoe County.
    With regard to any failure on my part to report any such "summary contempt" (a la NRS 22.010 or 22.030) "convictions",
    I must say that I believe I simply did not understand such rulings to be "convictions" of "crimes" given the summary
    nature of the rulings and that I believe they were civil only in nature. I only just in the last couple weeks received for the
    first time an Order by Judge Nash Holmes werein the "criminal summary contempt" language was contained therein.
    That Order was mailed to my former address on E. 9th St. despite the fact that, I believe, I had both updated the RMC
    with my new address at that point, in addition to my having filed an Official Change of Address with the USPS.
    I believe you will find that I am taking, or in the process of taking, every step possible to apologize to those I have
    offended, right my wrongs, and diffuse these situations where possible by taking a much more conciliatory tact.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: oedonline@uspto.gov; sue.hines-laboy@uspto.gov
    CC: davidc@nvbar.org
    Subject: reporting convictions and suspension of law license to USPTO OED
    Date: Thu, 26 Jul 2012 11:09:28 -0700
    Zach Coughlin, Esq
    PO BOX 3961
    000640
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    Registration Number: 53905
    Nevada Bar No: 9473 (suspended)
    ZachCoughlin@hotmail.com
    Director Office of Enrollment and Discipline
    Mail Stop OED
    U.S. Patent and Trademark Office
    PO Box 1450 Alexandria, Virginia 22313-1450
    Phone: 571-272-4097
    FAX: 571-273-0074
    July 26, 2012
    Dear OED,
    I am writing in an attempt to comply with the reporting requirement that I just became aware of today. While I may not be
    timely reporting this, there may be a basis for tolling the running of the 30 day reporting period such that, under one
    interpretation, I would be viewed as timely reporting this. I was in jail from July 3
    rd
    to July 21, 2012 and was not able to mail
    any materials or do any research.
    OED online User ID: OED17396
    Zachary B Coughlin
    Registration Number: 53905
    Reciprocal Discipline with State
    The high number of total violations in this category is likely due to 37 C.F.R. 11.24 and 11.25 requiring practitioners
    to report to the USPTO public censure, public reprimand, probation, disbarment or suspension by another jurisdiction,
    and disciplinary criminal violations after a conviction. Only violations of state law not provided for in other USPTO
    000641
    disciplinary rules in this category were counted. Had violations of other USPTO disciplinary rules been included in this
    category that first were prosecuted by a state, the number of violations in this category would have far outnumbered all
    other violations.
    Under self-reporting rules that went into effect on September 15, 2008, practitioners must notify the OED Director in
    writing within thirty days of being disbarred or suspended by another jurisdiction (37 C.F.R. 11.24), and must notify
    the OED Director within thirty days of conviction of any crime (37 C.F.R. 11.25(a)). Persons who are required to report
    crimes include registered patent attorneys, registered patent agents, and any attorney practicing before the Trademark
    Office or representing an employee of the USPTO in any non-patent or non-trademark matter. A crime is defined by
    37 C.F.R. 11.1 as any offense declared to be a felony or misdemeanor by Federal or State law in the jurisdiction where
    the act occurs. Traffic offenses such as a DUI, a hit and run, or vehicular homicide, are considered crimes under the
    rule.
    State law violations under the category of reciprocal discipline fall under suspension or disbarment from practice on
    ethical grounds by a state under 37 C.F.R. 10.23(c)(5), or conviction under a state law offense involving moral
    turpitude under 37 C.F.R. 10.23(c)(1). Examples of conduct in the category involving criminal convictions include:
    assault with a deadly weapon; engaging in sexually explicit conversation with a minor over the internet; hit and run and
    DUI; sexual assault; encouraging an illegal alien to come to the United States; insider trading; wire fraud; and possession
    and trafficking of a controlled substance.7 A few examples of state convictions that involved matters before the USPTO
    not covered under other USPTO rules provisions other than under 37 C.F.R. 10.23(c)(5) include: where a practitioner
    used information relating to the representation of a client to provoke an interference with a patent application that the
    practitioner had previously filed with the USPTO on behalf of the client (this, as well as other misconduct, resulted in the
    practitioner being disbarred in Arizona and excluded from practice before the USPTO); and where a practitioner filed a
    patent application naming himself and a former client as inventors, and when the former client requested the practitioner
    assign the application, the practitioner demanded $2.6 million dollars plus royalties (resulting in a two-year suspension
    from practice in Virginia and before the USPTO). In re Watkins, D2006-04; In re Lynt, D2005-08.
    I was convicted of petty larceny in the Reno Municipal Court in 11 CR 22176 on November 30
    th
    , 2011. I was
    unaware of the USPTO reporting requirement, but realize I should have taken steps to learn about it and follow it.
    I was also convicted of criminal trespass in Reno Municipal Court case 11 CR 26405 on June 18
    th
    , 2012. I
    appealed the petty larceny conviction, but it was affirmed. I am appealing the criminal trespass conviction as
    well. I am not sure the criminal trespass conviction requires reporting but I am doing so in an abundance of
    caution.
    The Nevada Supreme Court entered an Order on June 7
    th
    , 2012 temporarily suspending my license pending a
    hearing before the Northern Nevada Disciplinary Board (one has yet to be scheduled).
    Sincerely,
    Zach Coughlin, Esq.
    Licensed in Nevada (temporarily suspended June 7
    th
    , 2012)
    000642
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    000643
    Print Close
    a question
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 7/26/12 11:48 AM
    To: davidc@nvbar.org
    Dear Mr. Clark,
    I just cc'd you on my letter to the USPTO wherein I reported my two criminal convictions and the
    temporary suspension of my law license. I am not sure whether that will result in the suspension or
    disbarment of my license before the USPTO, but, in the event it does not, I have a question. Would
    my license to practice patent law before the USPTO satisfy the requirment of SCR 72.1(1), and,
    potentially (subject to a SCR 51 determination and other requirements) make it possible for me to
    practice law for a legal services entity while my Nevada law license is suspended (per the Court's
    June 7th, 2012 Order)?
    Rule 72.1. Admission of legal services members.
    1. Requirements. Notwithstanding the provisions of Rule 49, an attorney who is admitted to
    practice law in any other jurisdiction, and who becomes employed by or associated with an organized
    legal services program funded from state, federal or recognized charitable sources and providing legal
    assistance to indigents in civil matters, may be admitted to practice before all courts of this state
    subject to the conditions of this rule and to such further conditions as the court may hereafter direct.
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlin@hotmail.com
    Matrix
    000644
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 7/25/12 12:32 PM
    To: davidc@nvbar.org
    1 attachment
    20120725_111723.jpg (438.7 KB)
    Scr 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 7/24/12 9:08 AM
    To: davidc@nvbar.org
    I was convicted of trespass on June 18 2012 in 11cr26405 and unable to report while in jail recently
    though I asked Loomis and Giles to
    Zach Coughlin po box 3961 reno nv 89505 tel 775 338 8118 fax 949 667 7402
    000645
    FW: Reno eviction noticed Ior Sparks Justice Court
    Zach Coughlin (zachcoughlinhotmail.com)7/02/12
    To: kbrownnvbar.org, milllerrreno.gov, millerrreno.gov, stuttlewashoecounty.gov,
    rsilvawashoecounty.us, stuttlewashoecounty.us, jamchenwashoecounty.us, 037nor4acg.com,
    inIoacg-apmi.com, rjcwebwasoecounty.us, jbolescallatg.com, apminIoacg.com
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Mon 7/02/12 5:21 PM
    To: kbrownnvbar.org; milllerrreno.gov; millerrreno.gov; stuttlewashoecounty.gov;
    rsilvawashoecounty.us; stuttlewashoecounty.us; jamchenwashoecounty.us; 037nor4acg.com;
    inIoacg-apmi.com; rjcwebwasoecounty.us; jbolescallatg.com; apminIoacg.com
    Outlook Active View
    2 attachments (total 1164.6 KB)
    coughlin v northwind 16TenantsAIIidavitDeclarationOtherPrivateHousing other than nonpayment
    oI rent.pdIDownload
    combined northwind v coughlin eviction Iilings.pdIDownload
    Download all as zip
    NOrthwind and Nevada Court Services served and "amended 5 day notice oI unlawIul detainer on July
    29th, 2012"...giving me Iive days to get my stuII out oI unit 29 (the one the subject oI Judge Schroeer's
    Eviction Order, which was eIIectively rescinded by their serving a new 5 day unlawIul detainer
    notice....) as well as units 71 and 45...whicih are two units to which i still have valide lease agreements,
    ie, I cannot be trespassing Ior accessing them (the Reno PD has indicated they will arrest me Ior
    criminal trespass Ior accessing any units in the complex, including those to which I still have a valid
    possessory or property interest, in violation oI 42 usc 1983).
    why does Sargent Miller have to give me a hard time? Isn't it enough Ior him to have his "Denzel"
    good looks and a much higher paying job than I will ever have? What up wit that?
    Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed up
    and put "Sparks Justice Court on Greenbrae" as the place Ior the tenant to Iile a Tenan'ts Answer or
    AIIidavit. Doing so will make the RJC Order by Judge Schroeder null and void (Karen Stancil, ChieI
    Civil Clerk at RJC admits this, but really, the Iault lies with NCS and Northwind, not the committed
    proIessional at the RJC).
    The Notice must identiIy the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in
    a placwe where they have a valid reason Ior being or a lawIul right to be. NRS 207.200, RMC
    8.10.040.
    In Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
    predecessor statute to NRS 40.2516 to mean that the alternative Iive (5) day notice must be given
    1/12
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    6
    beIore the tenants can be dispossed and a lease can be validly terminated. The court stated that this
    Iive (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
    ttp://www.constitution.org/ussc/506-056a.htm
    U.S. Supreme Court
    SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
    506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
    CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
    SEVENTH CIRCUIT
    No. 91-6516
    Argued October 5, 1992
    Decided December 8, 1992
    While eviction proceedings were pending, Terrace Properties and Margaret Hale Iorcibly evicted
    petitioners, the Soldal Iamily, and their mobile home Irom a Terrace Properties' mobile home park. At
    Hale's request, Cook County, Illinois, SheriII's Department deputies were present at the eviction.
    Although they knew that there was no eviction order and that Terrace Properties' actions were illegal,
    the deputies reIused to take Mr. Soldal's complaint Ior criminal trespass or otherwise interIere with the
    eviction. Subsequently, the state judge assigned to the pending eviction proceedings ruled that the
    eviction had been unauthorized, and the trailer, badly damaged during the eviction, was returned to the
    lot. Petitioners brought an action in the Federal District Court under 42 U.S.C. 1983, claiming that
    Terrace Properties and Hale had conspired with the deputy sheriIIs to unreasonably seize and remove
    their home in violation oI their Fourth and Fourteenth Amendment rights. The court granted deIendants'
    motion Ior summary judgment, and the Court oI Appeals aIIirmed. Acknowledging that what had
    occurred was a "seizure" in the literal sense oI the word, the court reasoned that it was not a seizure as
    contemplated by the Fourth Amendment because, inter alia, it did not invade petitioners' privacy.
    Held:
    The seizure and removal oI the trailer home implicated petitioners' Fourth Amendment rights. Pp. 61-
    72.
    (a) A "seizure" oI property occurs when "there is some meaningIul interIerence with an individual's
    possessory interests in that property." United States v. Jacobsen, 466 U.S. 109, 113 . The language oI
    the Fourth Amendment - which protects people Irom unreasonable searches and seizures oI "their
    persons, houses, papers, and eIIects" - cuts against the novel holding below, and this Court's cases
    unmistakably hold that the Amendment protects property even where privacy or liberty is not
    implicated. See, e.g., ibid.; Katz v. United States, 389 U.S. 347, 350 . This Court's "plain view"
    decisions also make untenable the lower court's construction oI the Amendment. II the Amendment's
    boundaries were deIined exclusively by rights oI privacy, "plain view" seizures, rather than being
    scrupulously subjected to Fourth Amendment inquiry, Arizona v. Hicks, 480 U.S. 321, 326 -327, would
    not implicate that constitutional provision at all. Contrary to the Court oI Appeals' |506 U.S. 56, 57|
    position, the Amendment protects seizure even though no search within its meaning has taken place.
    See, e.g., Jacobsen, supra, at 120-125. Also contrary to that court's view, Graham v. Connor, 490 U.S.
    386 , does not require a court, when it Iinds that a wrong implicates more than one constitutional
    command, to look at the dominant character oI the challenged conduct to determine under which
    2/12
    000647
    constitutional standard it should be evaluated. Rather, each constitutional provision is examined in turn.
    See, e.g., Hudson v. Palmer, 468 U.S. 517 . Pp. 61-71.
    (b) The instant decision should not Ioment a wave oI new litigation in the Iederal courts. Activities such
    as repossessions or attachments, iI they involve entering a home, intruding on individuals' privacy, or
    interIering with their liberty, would implicate the Fourth Amendment even on the Court oI Appeals'
    own terms. And numerous seizures oI this type will survive constitutional scrutiny on "reasonableness"
    grounds. Moreover, it is unlikely that the police will oIten choose to Iurther an enterprise knowing that
    it is contrary to the law, or proceed to seize property in the absence oI objectively reasonable grounds
    Ior doing so. Pp. 71-72.
    942 F.2d 1073, reversed and remanded.
    WHITE, J., delivered the opinion Ior a unanimous Court.
    John L. Stainthorp argued the cause and Iiled brieIs Ior petitioners.
    Kenneth L. Gillis argued the cause Ior respondents. With him on the brieI were Jack O'Malley, Renee
    G. GoldIarb, and Kenneth T. McCurry. |*|
    | Footnote *| James D. Holzhauer, Timothy S. Bishop, John A. Powell, Steven R. Shapiro, Harvey M.
    Grossman, and Alan K. Chen Iiled a brieI Ior the American Civil Liberties Union et al. as amici curiae
    urging reversal.
    Richard Ruda, Carter G. Phillips, Mark D. Hopson, and Mark E. Haddad Iiled a brieI Ior the National
    League oI Cities et al. as amici curiae urging aIIirmance.
    JUSTICE WHITE delivered the opinion oI the Court.
    I
    Edward Soldal and his Iamily resided in their trailer home, which was located on a rented lot in the
    Willoway Terrace mobile |506 U.S. 56, 58| home park in Elk Grove, Illinois. In May 1987, Terrace
    Properties, the owner oI the park, and Margaret Hale, its manager, Iiled an eviction proceeding against
    the Soldals in an Illinois state court. Under the Illinois Forcible Entry and Detainer Act, Ill.Rev.Stat.,
    ch. 110, # 9-101 et seq. (1991), a tenant cannot be dispossessed absent a judgment oI eviction. The suit
    was dismissed on June 2, 1987. A Iew months later, in August 1987, the owner brought a second
    proceeding oI eviction, claiming nonpayment oI rent. The case was set Ior trial on September 22, 1987.
    Rather than await judgment in their Iavor, Terrace Properties and Hale, contrary to Illinois law, chose to
    evict the Soldals Iorcibly two weeks prior to the scheduled hearing. On September 4, Hale notiIied the
    Cook County's SheriII's Department that she was going to remove the trailer home Irom the park, and
    requested the presence oI sheriII deputies to Iorestall any possible resistance. Later that day, two
    Terrace Properties employees arrived at the Soldals' home accompanied by Cook County Deputy
    SheriII O'Neil. The employees proceeded to wrench the sewer and water connections oII the side oI the
    trailer home, disconnect the phone, tear oII the trailer's canopy and skirting, and hook the home to a
    tractor. Meanwhile, O'Neil explained to Edward Soldal that "`he was there to see that |Soldal| didn't
    interIere with |Willoway's| work.'" BrieI Ior Petitioner 6.
    By this time, two more deputy sheriIIs had arrived at the scene, and Soldal told them that he wished to
    Iile a complaint Ior criminal trespass. They reIerred him to deputy Lieutenant Jones, who was in Hale's
    oIIice. Jones asked Soldal to wait outside while he remained closeted with Hale and other Terrace
    Properties employees Ior over 20 minutes. AIter talking to a district attorney and making Soldal wait
    another halI hour, Jones told Soldal that he would not accept a complaint because "`it was between the
    landlord and the tenant ... |and| they were going to go ahead and continue to move |506 U.S. 56, 59|
    out the trailer.'" Id., at 8. 1 Throughout this period, the deputy sheriIIs knew that Terrace Properties did
    not have an eviction order and that its actions were unlawIul. Eventually, and in the presence oI an
    additional two deputy sheriIIs, the Willoway workers pulled the trailer Iree oI its moorings and towed it
    onto the street. Later, it was hauled to a neighboring property.
    3/12
    000648
    On September 9, the state judge assigned to the pending eviction proceedings ruled that the eviction
    had been unauthorized, and ordered Terrace Properties to return the Soldals' home to the lot. The home,
    however, was badly damaged. |2| The Soldals brought this action under 42 U.S.C. 1983, alleging a
    violation oI their rights under the Fourth and Fourteenth Amendments. They claimed that Terrace
    Properties and Hale had conspired with Cook County deputy sheriIIs to unreasonably seize and remove
    the Soldals' trailer home. The District Judge granted deIendants' motion Ior summary judgment on the
    grounds that the Soldals had Iailed to adduce any evidence to support their conspiracy theory and,
    thereIore, the existence oI state action necessary under 1983. |3|
    The Court oI Appeals Ior the Seventh Circuit, construing the Iacts in petitioners' Iavor, accepted their
    contention that there was state action. However, it went on to hold that |506 U.S. 56, 60| the removal oI
    the Soldals' trailer did not constitute a seizure Ior purposes oI the Fourth Amendment or a deprivation
    oI due process Ior purposes oI the Fourteenth.
    On rehearing, a majority oI the Seventh Circuit, sitting en banc, reaIIirmed the panel decision. |4|
    Acknowledging that what had occurred was a "seizure" in the literal sense oI the word, the court
    reasoned that, because it was not made in the course oI public law enIorcement, and because it did not
    invade the Soldals' privacy, it was not a seizure as contemplated by the Fourth Amendment. 942 F.2d
    1073, 1076 (1991). Interpreting prior cases oI this Court, the Seventh Circuit concluded that, absent
    interIerence with privacy or liberty, a "pure deprivation oI property" is not cognizable under the Fourth
    Amendment. Id., at 1078-1079. Rather, petitioners' property interests were protected only by the Due
    Process Clauses oI the FiIth and Fourteenth Amendments. |5|
    We granted certiorari to consider whether the seizure and removal oI the Soldals' trailer home
    implicated their Fourth Amendment rights, 503 U.S. 918 (1992), and now reverse. |6| |506 U.S. 56,
    61|
    II
    The Fourth Amendment, made applicable to the States by the Fourteenth, Ker v. CaliIornia, 374 U.S.
    23, 30 (1963), provides in pertinent part that the "right oI the people to be secure in their persons,
    houses, papers, and eIIects, against unreasonable searches and seizures, shall not be violated... ."
    A "seizure" oI property, we have explained, occurs when "there is some meaningIul interIerence with
    an individual's possessory interests in that property." United States v. Jacobsen, 466 U.S. 109, 113
    (1984). In addition, we have emphasized that "at the very core" oI the Fourth Amendment "stands the
    right oI a man to retreat into his own home." Silverman v. United States, 365 U.S. 505, 511 (1961). See
    also Oliver v. United States, 466 U.S. 170, 178 -179 (1984); Wyman v. James, 400 U.S. 309, 316
    (1971); Payton v. New York, 445 U.S. 573, 601 (1980).
    As a result oI the state action in this case, the Soldals' domicile was not only seized, it literally was
    carried away, giving new meaning to the term "mobile home." We Iail to see how being
    unceremoniously dispossessed oI one's home in the manner alleged to have occurred here can be
    viewed as anything but a seizure invoking the protection oI the Fourth Amendment. Whether the
    Amendment was in Iact |506 U.S. 56, 62| violated is, oI course, a diIIerent question that requires
    determining iI the seizure was reasonable. That inquiry entails the weighing oI various Iactors, and is
    not beIore us.
    The Court iI Appeals recognized that there had been a seizure, but concluded that it was a seizure only
    in a "technical" sense, not within the meaning oI the Fourth Amendment. This conclusion Iollowed
    Irom a narrow reading oI the Amendment, which the court construed to saIeguard only privacy and
    liberty interests, while leaving unprotected possessory interests where neither privacy nor liberty was at
    stake. Otherwise, the court said,
    "a constitutional provision enacted two centuries ago |would| make every repossession and eviction
    with police assistance actionable under - oI all things - the Fourth Amendment|, which| would both
    4/12
    000649
    trivialize the amendment and gratuitously shiIt a large body oI routine commercial litigation Irom the
    state courts to the Iederal courts. That trivializing, this shiIt, can be prevented by recognizing the
    diIIerence between possessory and privacy interests." 942 F.2d, at 1077.
    Because the oIIicers had not entered Soldal's house, rummaged through his possessions, or, in the Court
    oI Appeals' view, interIered with his liberty in the course oI the eviction, the Fourth Amendment
    oIIered no protection against the "grave deprivation" oI property that had occurred. Ibid.
    We do not agree with this interpretation oI the Fourth Amendment. The Amendment protects the people
    Irom unreasonable searches and seizures oI "their persons, houses, papers, and eIIects." This language
    surely cuts against the novel holding below, and our cases unmistakably hold that the Amendment
    protects property as well as privacy. |7| This much |506 U.S. 56, 63| was made clear in Jacobsen,
    supra, where we explained that the Iirst Clause oI the Fourth Amendment
    "protects two types oI expectations, one involving "searches," the other "seizures." A "search" occurs
    when an expectation oI privacy that society is prepared to consider reasonable is inIringed. A "seizure"
    oI property occurs where there is some meaningIul interIerence with an individual's possessory
    interests in that property." 466 U.S., at 113 (Iootnote omitted).
    See also id., at 120; Horton v. CaliIornia, 496 U.S. 128, 133 (1990); Arizona v. Hicks, 480 U.S. 321,
    328 (1987); Maryland v. Macon, 472 U.S. 463, 469 (1985); Texas v. Brown, 460 U.S. 730, 747 -748
    (1983) (STEVENS, J., concurring in judgment); United States v. Salvucci, 448 U.S. 83, 91 , n. 6
    (1980). Thus, having concluded that chemical testing oI powder Iound in a package did not
    compromise its owner's privacy, the Court in Jacobsen did not put an end to its inquiry, as would be
    required under the view adopted by the Court oI Appeals and advocated by respondents. Instead,
    adhering to the teachings oI United States v. Place, 462 U.S. 696 (1983), it went on to determine
    whether the invasion oI the owners' "possessory interests" occasioned by the destruction oI the powder
    was reasonable under the Fourth Amendment. Jacobsen, supra, at 124-125. In Place, although we Iound
    that subjecting luggage to a "dog sniII" did not constitute a search Ior Fourth Amendment purposes
    because it did not compromise any privacy interest, taking custody oI Place's suitcase was deemed an
    unlawIul seizure, Ior it unreasonably inIringed "the suspect's possessory interest in his luggage." 462
    U.S., at 708 . 8 Although lacking a privacy component, the property rights in both instances
    nonetheless were not |506 U.S. 56, 64| disregarded, but rather were aIIorded Fourth Amendment
    protection.
    Respondents rely principally on precedents such as Katz v. United States, 389 U.S. 347 (1967),
    Warden, Maryland Penitentiary v. Hayden, 387 U.S. 294 (1967), and Cardwell v. Lewis, 417 U.S. 583
    (1974), to demonstrate that the Fourth Amendment is only marginally concerned with property rights.
    But the message oI those cases is that property rights are not the sole measure oI Fourth Amendment
    violations. The Warden opinion thus observed, citing Jones v. United States, 362 U.S. 257 (1960), and
    Silverman v. United States, 365 U.S. 505 (1961), that the "principal" object oI the Amendment is the
    protection oI privacy, rather than property, and that "this shiIt in emphasis Irom property to privacy has
    come about through a subtle interplay oI substantive and procedural reIorm." 387 U.S., at 304 . There
    was no suggestion that this shiIt in emphasis had snuIIed out the previously recognized protection Ior
    property under the Fourth Amendment. Katz, in declaring violative oI the Fourth Amendment the
    unwarranted overhearing oI a telephone booth conversation, eIIectively ended any lingering notions
    that the protection oI privacy depended on trespass into a protected area. In the course oI its decision,
    the Katz Court stated that the Fourth Amendment can neither be translated into a provision dealing with
    constitutionally protected areas nor into a general constitutional right to privacy. The Amendment, the
    Court said, protects individual privacy against certain kinds oI governmental intrusion, "but its
    protections go Iurther, and oIten have nothing to do with privacy at all." 389 U.S., at 350 .
    As Ior Cardwell, a plurality oI this Court held in that case that the Fourth Amendment did not bar the
    5/12
    000650
    use in evidence oI paint scrapings taken Irom and tire treads observed on the deIendant's automobile,
    which had been seized in a parking lot and towed to a police lockup. Gathering this evidence was not
    deemed to be a search, Ior nothing Irom the |506 U.S. 56, 65| interior oI the car and "no personal
    eIIects, which the Fourth Amendment traditionally has been deemed to protect" were searched or
    seized. 417 U.S., at 591 (opinion oI BLACKMUN, J.). No meaningIul privacy rights were invaded. But
    this leIt the argument, pressed by the dissent, that the evidence gathered was the product oI a
    warrantless, and hence illegal, seizure oI the car Irom the parking lot where the deIendant had leIt it.
    However, the plurality was oI the view that, because, under the circumstances oI the case, there was
    probable cause to seize the car as an instrumentality oI the crime, Fourth Amendment precedent
    permitted the seizure without a warrant. Id., at 593. Thus, both the plurality and dissenting Justices
    considered the deIendant's auto deserving oI Fourth Amendment protection even though privacy
    interests were not at stake. They diIIered only in the degree oI protection that the Amendment
    demanded.
    The Court oI Appeals appeared to Iind more speciIic support Ior conIining the protection oI the Fourth
    Amendment to privacy interests in our decision in Hudson v. Palmer, 468 U.S. 517 (1984). There, a
    state prison inmate sued, claiming that prison guards had entered his cell without consent and had
    seized and destroyed some oI his personal eIIects. We ruled that an inmate, because oI his status,
    enjoyed neither a right to privacy in his cell nor protection against unreasonable seizures oI his personal
    eIIects. Id., at 526-528, and n. 8; id., at 538 (O'CONNOR, J., concurring). Whatever else the case held,
    it is oI limited useIulness outside the prison context with respect to the coverage oI the Fourth
    Amendment.
    We thus are unconvinced that any oI the Court's prior cases supports the view that the Fourth
    Amendment protects against unreasonable seizures oI property only where privacy or liberty is also
    implicated. What is more, our "plain view" decisions make untenable such a construction oI the
    Amendment. Suppose, Ior example, that police oIIicers lawIully enter a house, by either complying
    with the warrant requirement or satisIying one oI its recognized exceptions - |506 U.S. 56, 66| e.g.,
    through a valid consent or a showing oI exigent circumstances. II they come across some item in plain
    view and seize it, no invasion oI personal privacy has occurred. Horton, 496 U.S., at 133 -134; Brown,
    supra, at 739 (opinion oI REHNQUIST, J.). II the boundaries oI the Fourth Amendment were deIined
    exclusively by rights oI privacy, "plain view" seizures would not implicate that constitutional provision
    at all. Yet, Iar Irom being automatically upheld, "plain view" seizures have been scrupulously subjected
    to Fourth Amendment inquiry. Thus, in the absence oI consent or a warrant permitting the seizure oI the
    items in question, such seizures can be justiIied only iI they meet the probable-cause standard, Arizona
    v. Hicks, 480 U.S. 321, 326 -327 (1987), 9 and iI they are unaccompanied by unlawIul trespass,
    Horton, 496 U.S., at 136 -137. 10 That is because, the absence oI a privacy interest notwithstanding,
    "|a| seizure oI the article ... would obviously invade the owner's possessory interest." Id., at 134; see
    also Brown, 460 U.S., at 739 (opinion oI REHNQUIST, J.). The plain-view doctrine "merely reIlects an
    application oI the Fourth Amendment's central requirement oI reasonableness to the law governing
    seizures oI property." Ibid.; Coolidge v. New Hampshire, 403 U.S. 443, 468 (1971); id., at 516
    (WHITE, J., concurring and dissenting).
    The Court oI Appeals understandably Iound it necessary to reconcile its holding with our recognition in
    the plain-view cases that the Fourth Amendment protects property as such. In so doing, the court did
    not distinguish this case on the ground that the seizure oI the Soldals' home took place in a |506 U.S.
    56, 67| noncriminal context. Indeed, it acknowledged what is evident Irom our precedents - that the
    Amendment's protection applies in the civil context as well. See O'Connor v. Ortega, 480 U.S. 709
    (1987); New Jersey v. T.L.O., 469 U.S. 325, 334 -335 (1985); Michigan v. Tyler, 436 U.S. 499, 504
    -506 (1978); Marshall v. Barlow's, Inc., 436 U.S. 307, 312 -313 (1978); Camara v. Municipal Court oI
    6/12
    000651
    San Francisco, 387 U.S. 523, 528 (1967). 11
    Nor did the Court oI Appeals suggest that the Fourth Amendment applied exclusively to law
    enIorcement activities. It observed, Ior example, that the Amendment's protection would be triggered
    "by a search or other entry into the home incident to an eviction or repossession," 942 F.2d, at 1077. 12
    Instead, the court sought to explain why the Fourth Amendment protects against seizures oI property in
    the plain-view context, but not in this case, as Iollows:
    "|S|eizures made in the course oI investigations by police or other law enIorcement oIIicers are almost
    always, as in the plain view cases, the culmination oI searches. The police search in order to seize, and
    it is the search |506 U.S. 56, 68| and ensuing seizure that the Fourth Amendment, by its reIerence to
    "searches and seizures," seeks to regulate. Seizure means one thing when it is the outcome oI a search;
    it may mean something else when it stands apart Irom a search or any other investigative activity. The
    Fourth Amendment may still nominally apply, but, precisely because there is no invasion oI privacy,
    the usual rules do not apply." Id., at 1079 (emphasis in original).
    We have diIIiculty with this passage. The court seemingly construes the Amendment to protect only
    against seizures that are the outcome oI a search. But our cases are to the contrary, and hold that
    seizures oI property are subject to Fourth Amendment scrutiny even though no search within the
    meaning oI the Amendment has taken place. See, e.g., Jacobsen, 466 U.S., at 120 -125; Place, 462 U.S.,
    at 706 -707; Cardwell, 417 U.S., at 588 -589. 13 More generally, an oIIicer who happens to come
    across an individual's property in a public area could seize it only iI Fourth Amendment standards are
    satisIied - Ior example, iI the items are evidence oI a crime or contraband. CI. Payton v. New York,
    |506 U.S. 56, 69| 445 U.S., at 587 . We are also puzzled by the last sentence oI the excerpt, where the
    court announces that the "usual rules" oI the Fourth Amendment are inapplicable iI the seizure is not
    the result oI a search or any other investigative activity "precisely because there is no invasion oI
    privacy." For the plain-view cases clearly state that, notwithstanding the absence oI any interIerence
    with privacy, seizures oI eIIects that are not authorized by a warrant are reasonable only because there
    is probable cause to associate the property with criminal activity. The seizure oI the weapons in Horton,
    Ior example, occurred in the midst oI a search, yet we emphasized that it did not "involve any invasion
    oI privacy." 496 U.S., at 133 . In short, our statement that such seizures must satisIy the Fourth
    Amendment and will be deemed reasonable only iI the item's incriminating character is "immediately
    apparent," id., at 136-137, is at odds with the Court oI Appeals' approach.
    The Court oI Appeals' eIIort is both interesting and creative, but, at bottom, it simply reasserts the
    earlier thesis that the Fourth Amendment protects privacy, but not property. We remain unconvinced,
    and see no justiIication Ior departing Irom our prior cases. In our view, the reason why an oIIicer might
    enter a house or eIIectuate a seizure is wholly irrelevant to the threshold question whether the
    Amendment applies. What matters is the intrusion on the people's security Irom governmental
    interIerence. ThereIore, the right against unreasonable seizures would be no less transgressed iI the
    seizure oI the house was undertaken to collect evidence, veriIy compliance with a housing regulation,
    eIIect an eviction by the police, or on a whim, Ior no reason at all. As we have observed on more than
    one occasion, it would be "anomalous to say that the individual and his private property are Iully
    protected by the Fourth Amendment only when the individual is suspected oI criminal behavior."
    Camara 387 U.S., at 530 ; see also O'Connor, 480 U.S., at 715 ; T.L.O., 469 U.S., at 335 . |506 U.S. 56,
    70|
    The Court oI Appeals also stated that, even iI, contrary to its previous rulings, "there is some element or
    tincture oI a Fourth Amendment seizure, it cannot carry the day Ior the Soldals." 942 F.2d, at 1080.
    Relying on our decision in Graham v. Connor, 490 U.S. 386 (1989), the court reasoned that it should
    look at the "dominant character oI the conduct challenged in a section 1983 case |to| determine the
    constitutional standard under which it is evaluated." 942 F.2d, at 1080. Believing that the Soldals' claim
    7/12
    000652
    was more akin to a challenge against the deprivation oI property without due process oI law than
    against an unreasonable seizure, the court concluded that they should not be allowed to bring their suit
    under the guise oI the Fourth Amendment.
    But we see no basis Ior doling out constitutional protections in such Iashion. Certain wrongs aIIect
    more than a single right, and, accordingly, can implicate more than one oI the Constitution's
    commands. Where such multiple violations are alleged, we are not in the habit oI identiIying, as a
    preliminary matter, the claim's "dominant" character. Rather, we examine each constitutional provision
    in turn. See, e.g., Hudson v. Palmer, 468 U.S. 517 (1984) (Fourth Amendment and Fourteenth
    Amendment Due Process Clause); Ingraham v. Wright, 430 U.S. 651 (1977) (Eighth Amendment and
    Fourteenth Amendment Due Process Clause). Graham is not to the contrary. Its holding was that claims
    oI excessive use oI Iorce should be analyzed under the Fourth Amendment's reasonableness standard,
    rather than the Fourteenth Amendment's substantive due process test. We were guided by the Iact that,
    in that case, both provisions targeted the same sort oI governmental conduct and, as a result, we chose
    the more "explicit textual source oI constitutional protection" over the "more generalized notion oI
    `substantive due process.'" 490 U.S., at 394 -395. Surely, Graham does not bar resort in this case to the
    Fourth Amendment's speciIic protection Ior "houses, papers, |506 U.S. 56, 71| and eIIects," rather than
    the general protection oI property in the Due Process Clause.
    III
    Respondents are IearIul, as was the Court oI Appeals, that applying the Fourth Amendment in this
    context inevitably will carry it into territory unknown and unIoreseen: routine repossessions, negligent
    actions oI public employees that interIere with individuals' right to enjoy their homes, and the like,
    thereby Iederalizing areas oI law traditionally the concern oI the States. For several reasons, we think
    the risk is exaggerated. To begin, our decision will have no impact on activities such as repossessions
    or attachments iI they involve entry into the home, intrusion on individuals' privacy, or interIerence
    with their liberty, because they would implicate the Fourth Amendment even on the Court oI Appeals'
    own terms. This was true oI the Tenth Circuit's decision in Specht, with which, as we previously noted,
    the Court oI Appeals expressed agreement.
    More signiIicantly, "reasonableness is still the ultimate standard" under the Fourth Amendment,
    Camara, supra, at 539, which means that numerous seizures oI this type will survive constitutional
    scrutiny. As is true in other circumstances, the reasonableness determination will reIlect a "careIul
    balancing oI governmental and private interests." T.L.O., supra, at 341. Assuming, Ior example, that the
    oIIicers were acting pursuant to a court order, as in Specht v. Jensen, 832 F.2d 1516 (CA10 1987), or
    Fuentes v. Shevin, 407 U.S. 67 , (1972), and, as oIten would be the case, a showing oI
    unreasonableness on these Iacts would be a laborious task indeed. CI. Simms v. Slacum, 3 Cranch 300,
    301 (1806). Hence, while there is no guarantee against the Iiling oI Irivolous suits, had the ejection in
    this case properly awaited the state court's judgment, it is quite unlikely that the Iederal court would
    have been bothered with a 1983 action alleging a Fourth Amendment violation. |506 U.S. 56, 72|
    Moreover, we doubt that the police will oIten choose to Iurther an enterprise knowing that it is contrary
    to the law, or proceed to seize property in the absence oI objectively reasonable grounds Ior doing so.
    In short, our reaIIirmance oI Fourth Amendment principles today should not Ioment a wave oI new
    litigation in the Iederal courts.
    IV
    The complaint here alleges that respondents, acting under color oI state law, dispossessed the Soldals oI
    their trailer home by physically tearing it Irom its Ioundation and towing it to another lot. Taking these
    allegations as true, this was no "garden variety" landlord-tenant or commercial dispute. The Iacts
    alleged suIIice to constitute a "seizure" within the meaning oI the Fourth Amendment, Ior they plainly
    implicate the interests protected by that provision. The judgment oI the Court oI Appeals is,
    8/12
    000653
    accordingly, reversed, and the case is remanded Ior Iurther proceedings consistent with this opinion.
    So ordered.
    Footnotes
    |1| Jones' statement was prompted by a district attorney's advice that no criminal charges could be
    brought because, under Illinois law, a criminal action cannot be used to determine the right oI
    possession. See Ill.Rev.Stat. ch. 110, # 9-101 et seq. (1991); People v. Evans, 163 Ill.App. 3d 561, 114
    Ill.Dec. 662, 516 N.E.2d 817 (1st Dist. 1987).
    |2| The Soldals ultimately were evicted per court order in December 1987.
    |3| Title 42 U.S.C. 1983 provides that:
    "Every person who, under color oI any statute, ordinance, regulation, custom or usage, oI any State ...
    subjects, or causes to be subjected, any citizen oI the United States ... to the deprivation oI any rights,
    privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an
    action at law, suit in equity, or other proper proceeding Ior redress."
    |4| The court reiterated the panel's conclusion that a conspiracy must be assumed on the state oI the
    record and, thereIore, that the case must be treated in its current posture "as iI the deputy sheriIIs
    themselves seized the trailer, disconnected it Irom the utilities, and towed it away." 942 F.2d 1073,
    1075 (CA7 1991) (en banc).
    |5| The court noted that, in light oI the existence oI adequate judicial remedies under state law, a claim
    Ior deprivation oI property without due process oI law was unlikely to succeed. Id., at 1075-1076. See
    Parratt v. Taylor, 451 U.S. 527 (1981). In any event, the Soldals did not claim a violation oI their
    procedural rights. As noted, the Seventh Circuit also held that respondents had not violated the Soldals'
    substantive due process rights under the Fourteenth Amendment. Petitioners assert that this was error,
    but, in view oI our disposition oI the case, we need not address the question at this time.
    |6| Under 42 U.S.C. 1983, the Soldals were required to establish that the respondents, acting under
    color oI state law, deprived them oI a constitutional right, in this instance, their Fourth and Fourteenth
    Amendment Ireedom Irom unreasonable seizures by the State. See Monroe v. Pape, |506 U.S. 56, 61|
    365 U.S. 167, 184 (1961). Respondents request that we aIIirm on the ground that the Court oI Appeals
    erred in holding that there was suIIicient state action to support a 1983 action. The alleged injury to the
    Soldals, it is urged, was inIlicted by private parties Ior whom the county is not responsible. Although
    respondents did not cross-petition, they are entitled to ask us to aIIirm on that ground iI such action
    would not enlarge the judgment oI the Court oI Appeals in their Iavor. The Court oI Appeals Iound that,
    because the police prevented Soldal Irom using reasonable Iorce to protect his home Irom private
    action that the oIIicers knew was illegal, there was suIIicient evidence oI conspiracy between the
    private parties and the oIIicers to Ioreclose summary judgment Ior respondents. We are not inclined to
    review that holding. See Adickes v. S.H. Kress & Co., 398 U.S. 144, 152 -161 (1970).
    |7| In holding that the Fourth Amendment's reach extends to property as such, we are mindIul that the
    Amendment does not protect possessory interests in all kinds oI property. See, e.g., Oliver v. United
    States, 466 U.S. 170, 176 -177 (1984). This case, however, concerns a house, which the Amendment's
    language explicitly includes, as it does a person's eIIects.
    |8| Place also Iound that to detain luggage Ior 90 minutes was an unreasonable deprivation oI the
    individual's "liberty interest in proceeding with his itinerary," which also is protected by the Fourth
    Amendment. 462 U.S., at 708 -710.
    |9| When "operational necessities" exist, seizures can be justiIied on less than probable cause. 480
    U.S., at 327 . That in no way aIIects our analysis, Ior even then it is clear that the Fourth Amendment
    applies. Ibid; see also United States v. Place, 462 U.S. 696 , at 703 (1983).
    |10| OI course, iI the police oIIicers' presence in the home itselI entailed a violation oI the Fourth
    Amendment, no amount oI probable cause to believe that an item in plain view constitutes
    9/12
    000654
    incriminating evidence will justiIy its seizure. Horton, 496 U.S., at 136 -137.
    |11| It is true that Murray's Lessee v. Hoboken Land & Improvement Co., 18 How. 272 (1856), cast
    some doubt on the applicability oI the Amendment to noncriminal encounters such as this. Id., 18 How.
    at 285. But cases since that time have shed a diIIerent light, making clear that Fourth Amendment
    guarantees are triggered by governmental searches and seizures "without regard to the use to which
    |houses, papers, and eIIects| are applied." Warden, Maryland Penitentiary v. Hayden, 387 U.S. 294, 301
    (1967). Murray's Lessee's broad statement that the Fourth Amendment "has no reIerence to civil
    proceedings Ior the recovery oI debt" arguably only meant that the warrant requirement did not apply,
    as was suggested in G.M. Leasing Corp. v. United States, 429 U.S. 338, 352 (1977). Whatever its
    proper reading, we reaIIirm today our basic understanding that the protection against unreasonable
    searches and seizures Iully applies in the civil context.
    |12| This was the view expressed by the Court oI Appeals Ior the Tenth Circuit in Specht v. Jensen, 832
    F.2d 1516 (1987), remanded on unrelated grounds, 853 F.2d 805 (1988) (en banc), with which the
    Seventh Circuit expressly agreed. 942 F.2d, at 1076.
    |13| The oIIicers in these cases were engaged in law enIorcement, and were looking Ior something that
    was Iound and seized. In this broad sense, the seizures were the result oI "searches," but not in the
    Fourth Amendment sense. That the Court oI Appeals might have been suggesting that the plain-view
    cases are explainable because they almost always occur in the course oI law enIorcement activities
    receives some support Irom the penultimate sentence oI the quoted passage, where the court states that
    the word "seizure" might lose its usual meaning "when it stands apart Irom a search or any other
    investigative activity." Id., at 1079 (emphasis added). And, in the Iollowing paragraph, it observes that,
    "|o|utside oI the law enIorcement area, the Fourth Amendment retains its Iorce as a protection against
    searches, because they invade privacy. That is why we decline to conIine the amendment to the law
    enIorcement setting." Id., at 1079-1080. Even iI the court meant that seizures oI property in the course
    oI law enIorcement activities, whether civil or criminal, implicate interests saIeguarded by the Fourth
    Amendment, but that pure property interests are unprotected in the non-law-enIorcement setting, we
    are not in accord, as indicated in the body oI this opinion. |506 U.S. 56, 73|
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlinhotmail.com
    From: zachcoughlinhotmail.com
    To: chansenwashoecounty.us
    Subject: Reno eviction noticed Ior Sparks Justice Court
    Date: Tue, 26 Jun 2012 09:10:14 -0700
    Dear Civil Supervisor Hansen
    10/12
    000655
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    ZachCoughlinhotmail.com
    Dear Sparks Justice Court,
    I called and received permission to Iile this by Iax...I am indigent and request a Iee waiver, and Iailing
    that, an opportunity to cure any Iiling Iee deIiciency.
    From: zachcoughlinhotmail.com
    To: sheriIIwebwashoecounty.us; lstuchellwashoecounty.us; kstancilwashoecounty.us;
    chansenwashoecounty.us; milllerrreno.gov
    Subject: Reno eviction noticed Ior Sparks Justice Court
    Date: Tue, 26 Jun 2012 07:58:36 -0700
    Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
    I have received (though not personally served) what appears to be an eviction notice (5 day unlawIul
    detainer?) Ior rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the notice indicates that I
    must Iile a Tenant's Answer with the Sparks Justice Court.
    Am I mistaken in viewing this matter to be outside the jurisdiction oI the Sparks Justice Court, and
    rather, a matter to be handled in Reno Justice Court?
    Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court
    has 4 judicial days a week, the deadline Ior Iiling a special appearance (to contest jurisdiction) and or a
    Tenant's Answer oI AIIidavit is diIIicult to measure.
    I spoke with a Reno Police Department who identiIied himselI as Sargent Miller last week and he
    indicated the WCSO planned to come eIIectuate an eviction on this date, June 26, 2012. I believe that
    would be premature, as Nevada Landlord Tenant law provides Ior Iiling a Tenant's Answer or AIIidavit
    by noon aIter the IiIth Iull day (judicial days) and Fridays in Sparks Justice Court are not Iull days in
    that sense, and regardless, Sparks Justice Court, I believe, is not the appropriate Iorum where, as here,
    the situs is located in Reno (Ward 1-nap?)
    Sincerely,
    Zach Coughlin
    PO BOX 3961
    Reno, NV 89505
    tel 775 338 8118
    Iax 949 667 7403
    11/12
    000656
    Civil Division
    630 Greenbrae Drive
    Sparks, Nevada 89431
    (775)353.7603 Phone
    (775)352.3004 Fax
    Civil Department Supervisor
    Chris Hansen
    chansenwashoecounty.us
    The Civil Division oI Sparks Justice Court is made up oI three major Iunctions:
    Civil
    Civil Complaints Ior damages in excess oI $5000 or iI a suit involves a breach oI contract, punitive
    damages, an action to obtain possession oI property, a writ oI restitution, or other like actions, legal
    counsel is suggested Ior these types oI actions.
    Evictions
    An act or process oI legally dispossessing a person oI land or rental property.
    Small Claims
    An action Iiled in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims
    action may be Iiled with the Sparks Justice Court iI one oI the Iollowing applies to the deIendant:
    They reside within the boundaries oI the Sparks Township;
    They are employed within the boundaries oI the Sparks Township; and/or,
    They do business within the boundaries oI the Sparks Township.
    12/12
    000657
    Message-ID: <BAY148-W7B876C2F5336EA0BBCBB0C2010@phx.gbl>
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    boundary="_57ed7ee9-81fd-474d-97dc-a1ccb35ebe2c_"
    X-Originating-IP: [64.134.224.188]
    From: Za oughlin <zachcoug
    To:
    @yahoo.com>,
    <patrickk@nvbar.org>, <davidc@nvbar.org>, <glennm@nvbar.org>
    Subject: I have to file something in Opposition...I think...
    Date: Fri, 25 May 2012 02:48:20 -0700
    Importance: Normal
    MIME-Version: 1.0
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    Dear Sirs=2C
    Here is a proposed Opposition to Bar Counsel's Petition for a Temporary Sus=
    pension of Law License. Any feedback is appreciated.
    Sincerely=2C
    Zach Coughlin =
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    <font style=3D"font-size: 16pt=3B" face=3D"Times New Roman" size=3D"4">Dear=
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    ><br><br>Sincerely=2C<br><br>Zach Coughlin<br id=3D"ecxFontBreak"></font> =
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    000658
    Print Close
    update for In Re Coughlin SCR 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 5/22/12 11:31 PM
    To: patrickk@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel,
    I am sorry for how I conducted myself in my dealings with you over the last few
    months. Below, please find some updates on my progress.
    Sincerely,
    Zach Coughlin, Esq.
    PO BOX 3961
    Reno, NV 89505
    Tel 775 338 8118
    Fax 949 667 7402
    From: zachcoughlin@hotmail.com
    To: geofgiles@hotmail.com; judgemcgee@aol.com; keith@leelawoffice.net; coe@gbis.com
    Subject: RE: In Re Coughlin SCR 111 petition to avoid temporary petition from practice of law FW
    Date: Tue, 22 May 2012 23:26:14 -0700
    Hi Geof and Judge McGee,
    Thanks for the note you wrote below. Somehow, I missed it until now. I was moving
    everything I own and unpacking it from about 5/5/12 until just a couple days ago, so
    things have been difficult. I moved everything with a honda accord. I am talking many
    trips, by myself, roping things to my roof, everything.
    Geof, I am disappointed that I didn't get you something better for the Thursday filing
    you wrote of last week vis a vis the foreclosure trustee actions as void due to the lack of
    a debt collectors license...you deserved better, sorry. But, I did collect and previously
    send you a lot of stuff on that issue, some scanned (rats) and some in digital ocr ready
    format from the s ct law library....I just need to distill it more, and that didn't get done in
    time.
    000659
    Judge McGee, sorry I missed the Thursday group last week. I am amazed that I didn't
    go, but I just didn't. I had a very emotional day and week last week and 6pm rolled
    around and I was just spent. 10 months off my antidepressants (not by choice, but
    because I simply couldn't afford them), then starting back up on them on 4 28 12
    resulted in a flooding of emotions and grief over my divorce, family problems, career
    dumpster fire, etc. I am exercising again daily after about 18 months of not doing so (I
    have always exercised to regulate my mood) and am experiencing benefits from that.
    I don't know if all this can be undone, but I am making progress each day, and that has
    always been the recipe for me to get back on track, ie, to eat the whale one spoonful at
    a time, one day at a time, etc.
    I want to get together some apology letters or something for Judges Nash Holmes
    (though I did apologize at my last hearing before her), Judge Adams, Judge Elliot,
    Judge Sferrazza (although he and I seem to have a pretty good rapport, I believe...he
    made a joke about me being part of the "roller derby" the case before me involved), and
    probably many others....
    The thing about this Wal-Mart petit larceny of a chocolate bar and some cough
    medication drops/melts is that I did not go into the store and grab those items and
    leave. The Wal-Mart associate said I ate the chocolate bar (and that they saw me take it
    off the shelf in the candy isle) while I was shopping for any paid for $90 of other
    groceries. However, the UPC of the chocolate bar shows it was an ice cream bar,
    meaning it wouldn't have been in the candy isle, but rather the refrigerated isle. Then,
    the Wal-Mart witness admitted he could not hear whether or not I told the cashier
    ringing me up whether I had a quantity of 3 of the cough medication drops/melts and
    the Walmart and Indian Colony Officer testified that on the receipt for the items I did
    pay for, the UPC of the type of cough medication melts they say I stole did not appear.
    Also, amazingly, the Wal-Mart loss prevention associate testified that he could glean,
    from 30 yeards away, each and every item the cashier rung up for me and that those
    items did not include such a box of the cough medication melts.
    However, I showed in court and in exhibits that the receipt for the items I purchased did
    have one item with the same UPC as the exact type of cough medication melts (they
    have dextromethorphan in them and if you take enough of that stuff it will make you
    forget about the effects of coming of antidepressants too rapidly, processing a divorce
    000660
    from 4.5 year relationship, a father physician who can have difficulties recognizing
    boundaries vis a vis his son's health care and mental health care, and who can, at times,
    seem a bit of a saboteur to his son's life in the pursuit of serving him the
    "incomprehensible demoralization" the he feels so necessary to the process, etc....plus
    getting fairly whacked out on cough syrup doesn't carry quite the same shame of a
    relapse the street drugs and alcohol would to some... ). So the Wal-Mart loss
    prevention associate admitted neither he nor anyone at Wal-Mart could say that they
    could hear whether I told the cashier a quantity to ring up for the cough medication melt
    box with the same UPC as the ones Wal-Mart alleges were stolen or consumed while
    shopping....
    Further, the Indian Colony Officer testified that he only arrested me and conducted a
    search incident to arrest because I didn't provide me driver's license to him. However,
    the video of the Wal-Mart interrogation room interview clearly shows me giving the
    officer my driver's license and him radioing it in to his dispatch and him taking down
    the DL number and other information off of it. Further, the receipt from the $90 of
    groceries I paid for contains an entry with the UPC of the exact type of cough
    medication melts that the officer found in my pocket upon conducting the search
    incident to arrest. The Wal-Mart associate and Indian Colony Officer both testified that
    the receipt did not contain an entry for the cough drops, but the copy of the receipt in
    the police report and discovery and a review of the UPC and subsequnetly looking up
    the item assigned that Universal Parcel Code clearly shows that a box of those cough
    medication melts were, in fact, included on that receipt.
    I am all for owning up to things but this wasn't a "walked into the store, grabbed some
    stuff, tucked under one's shirt, and dashed away" type situation. Plus Wal-Mart's loss
    prevention staff had told me just weeks before they would retaliate against me by
    having me banned from all their stores for arguing with their customer service
    personnel about a curious practice wherein Wal-mart staff and managers seem to
    "forget" the terms of their store's return policy and or claim that policy is a "courtesy"
    rather than a bargained for term included in a contract for the sale of goods:
    http://www.enotes.com/consumer-issues-reference/purchases-and-returns
    About a week ago I sent Bar Counsel a printout of all my prescription
    medication history since February 2008 and it showed some interesting things
    vis a vis that Wal-Mart arrest and my firing from Washoe Legal Services in
    May of 2009. At both times I was out of my antidepressant, Wellbutrin. In
    May of 2009 there was something like a 21 day delay with the pharmacy and
    000661
    my doctors office in getting my refill done. At the time of the September 2011
    Wal-Mart petit larceny arrest I had stopped taking my antidepressant because
    I didn't have the money to pay for it out of pocket. My dad wouldn't give me
    any samples of it or a loan or whatever to get a temporary supply. I get it, I
    am a grown man, need to pay for my own stuff or figure something out.
    However, that same logic should probably prevent my Dad from calling up
    State Bars and the Deans of law schools and my girlfriends and seemingly
    trying to arrange for some "incomprehensible demoralization" to be delivered
    to me, but it often doesn't. I love my Dad to death and think the world of
    him, but he and I have a bit of obsessive compulsive disorder sometimes and
    he just has real problems staying out of my mental health care, particularly
    where it may involve taking a medication he would prefer I not take.
    Hopefully, Bar Counsel will appreciate my forwarding my certified prescription
    history to them, but I have no idea if they will or not.
    Its funny, both my sisters have divorces from alcoholics in the last 2 years and
    everybody tells them they need Al-Anon. I have a divorce from an alcoholic
    type-1 diabetic who starts drinking again right after leaving me (after stealing
    two months of rent from me by not forwarding my contribution to the
    landlord, in addition to getting a grand in loans and gifts from my mother,
    sisters, and other family members that she still hasn't started to pay back,
    leaving just 2 days after finally graduating from UNR with a degree in
    journalism that I contributed lots of money and sweat to...) and my family
    decides I am a jerk off, won't loan me a dime, my dad won't chip me off a
    box of Wellbutrin antidepressant samples that he gets for free and which he
    started me on when I was 17. What, don't I need Al-Anon? Ah...shoot, its
    this type of comparison thinking that got me suing Washoe Legal Services. I
    am a whiny little bitch sometimes.
    Judge McGee, I hope your hip is coming along and I will be there for sure Thursday
    night.
    I am upset about how this year has gone for me and disappointed in myself in many
    ways and know I have to do better and have to make amends.
    Sincerely,
    Zach Coughlin
    000662
    From: geofgiles@hotmail.com
    To: zachcoughlin@hotmail.com; judgemcgee@msn.com; judgemcgee@aol.com; keith@leelawoffice.net;
    coe@gbis.com
    Subject: RE: In Re Coughlin SCR 111 petition to avoid temporary petition from practice of law FW
    Date: Wed, 9 May 2012 02:01:17 +0000
    I am having trouble following this. The assistant bar counsel filed a petition for a temporary
    suspension, and I assume you wish to contest this. However you eMail says you want to do a 'show
    cause as to why you shouldn't be suspended', is this a typo or are you offering to stipulate to that? If
    you wish to get things back on track, you need to speak with someone who knows the 'ins and outs' of
    Supreme Court practice. That's not me, though I have managed to follow the rules all these years.
    May I suggest David Hamilton who is tops in this, but pretty obnoxious, If he thinks you've gotten a
    raw deal, he might help you out. I dont know, under his rough exterior he really does care about
    justice. Or you could call Cal Dunlap, who has represented many professionals before administrative
    agencies. I have a feeling that he will be expensive. If you insist on doing this yourself, please call
    me in the morning as I am free until noon. I give you this 'advise' as a friend and not your counsel. I
    hope you can distance yourself from your problems, but the first step in that direction is to
    acknowledge you have them. Geof Giles
    From: zachcoughlin@hotmail.com
    To: geofgiles@hotmail.com; judgemcgee@msn.com; judgemcgee@aol.com; keith@leelawoffice.net;
    coe@gbis.com
    Subject: In Re Coughlin SCR 111 petition to avoid temporary petition from practice of law FW: Adverse
    ruling on foreclosure from Judge Kosach
    Date: Tue, 8 May 2012 15:31:31 -0700
    Dear Judge McGee and Mr. Giles, Mr. Lee, and Mr. Swobe,
    I hope yoru surgery goes well today, Judge Mcgee, best wishes for that and a speedy recuperation.
    Mr. Giles, I am disappointed to see the result in LaBrosse, but know you did the best work anybody
    could have done, and that, hopefully, cases like Meluzio and In re Johnson:
    http://www.jdsupra.com/post/documentViewer.aspx?fid=0441f3d3-291e-4275-aafe-11e212f6fc97
    http://law.justia.com/cases/north-carolina/court-of-appeals/2009/081263-1.html
    I hate to write either of you about this at this time, but time is of the essence. I am preparing a
    motion to Show Cause why I should not be temporarily suspended from the practice of law in light of
    the Petition of Bar Counsel for Temporary Suspension From The Practice of Law Pursuant to SCR 111
    that is attached, and was filed on May 3, 2012. I feel I need to get something filed with the Nevada
    Supreme Court in the next 3 days or so to avoid a situation where such an Order suspending me from
    the practice of law is entered prior to me having a chance to say my peace. I feel I am innocent of
    this charge, and that my going off my antidepressants suddently because I could not afford them
    because my girlfriend stole two months of rent from me played a large role in this conviction. This was
    my live in girlfriend of 4 and half years whom I helped finish her final 3 years of college. She had four
    years of sobrierty (we met in AA) before breaking up with me two days after graduating from UNR and
    starting to drink again. The break up had a real divisive result in terms of my relationship with my
    family, particularly my father, as much of my family seemed to really "side" with my girlfriend in the
    breakup (both of my sisters had divorces in the last 18 months and it seemed to create somewhat of an
    anti-male sentiment in my extended family). I know I have my faults and a role in all of this, and am
    renewing my recovery efforts. However, I feel that those who may be able to watch a condensed
    movie of the last, say, 10 months of my life may be somewhat impressed at the dedication I have
    displayed to my clients and the practice of law and the resilience and tenacity I have demonstrated in
    overcoming some tough obstacles, including a summary eviction from my former home law office where
    000663
    the nonpayment of rent was not plead, something expressly prohibited by NRS 40.253, on top of a "rent
    escrow" deposit of $2,300 being demanded by the Reno Justice Court, despite the law of a corollary to
    Las Vegas Justice Court Rule 44 in the Reno Justice Court, and the dictates of JCRCP 84 requiring that
    any such rule be published and signed off on by the Nevada Supreme Court prior to its implentation.
    Rules like JCRCP Rule 44 exact quite a tole on communities, and are only warranted, if ever, in the
    most unique of circumstances (such as in a town like Las Vegas) and really do not have a place in
    communities like Reno, in my opinion.
    Further, I believe police and prosecutorial misconduct played some role and that the Reno Municipal
    Court was remiss in not contemplating mental health court in any way, or otherwise alerting me to the
    possibility thereof, especially where I was denied my Sixth Amendment Right to Counsel, particularly
    where I feel I established my indigency, and was wrongfully evicted from my former home law office
    less than one month prior to the trial date, for which my request for a continuance was denied, despite
    my indicating to the court that opposing counsel in the eviction matter was applying an unlawful rent
    distraint under NRS 118A.520 to exculpatory materials. Additionally, Judge Elliot's Order seems to
    apply a civil standard to the issue of whether the RMC was to create transcripts of the Trial in my
    appeal (an bill me later, rather, Judge Elliot's Order cites a civil statute that allows the court to not even
    begin making the transcripts until they have been paid for, however, this is a criminal matter, and this,
    in conjunction with my being denied my right to counsel, incarcerated for three days under a summary
    contempt ruling, and mental health court not being broached in any way, may provide some avenue for
    arguing that a temporary suspension from the practice of law is not warranted).
    I reported this arrest to my psychiatrist, Dr. Yassar, of Ascent Neurobehavioral Insitute, and he
    confirmed that I called and cancelled my August 2, 2011 appointment and indicated I would not be
    filling my prescriptions (and I have pharmacy records indicating that I did not so fill those prescriptions
    during this August-September period...the arrest was on September 9, 2011 for the conviction resulting
    from RMC 11 CR 22176... I filed a 60b motion for relief from judgement in that matter at the trial court
    level, while the case was on appeal before Judge Elliot, on March 23, 2012...but I have not filed a
    Request for Submission of that Motion yet...but should it be overturned by Judge Howard, that may
    help with avoiding a suspension from the practice of law. I would appreciate any input as to how I
    might proceed with that 60(b) motion before Judge Howard and any other input you might offer).
    I have a diagnosis of Major Depressive Disorder on file with Dr. Yassar and the Mental Health Court has
    agreed to accept me and I would like to see about getting the conviction in RMC 11 CR 22176
    overturned and placed into Mental Health Court in that regard. I do not know whether I am allowed to
    contact Judge Breen (he swore me in with Keith Lee and Coe Swobe in attendance) about this and
    would appreciate your input. Hopefully, the fact that Judge Cherry was sworn in as Chief Justice
    recently will help in managing to get the Court to take a rehabilitative view towards this matter.
    Any help you can offer is much appreciate, of course, though I know the work you are doing is so
    important that I am hesitant to ask you to associate with this situation, but I do feel I am innocent
    here, and further, I am not sure consuming a chocolate bar and or cough drops while shopping for and
    payign for $90 of other merchandise is tantamount to "theft" in the sense that word is used in SCR
    111. Further, while paying for those items, items of the same UPC number were purchased, and at
    trial, the Wal-Mart witness did admit that it is an established practice at Wal-Mart, when items are
    being rung up, to indicate a quantity of one item to the cashier, whom would type that quantity in
    rather than scanning, say, three boxes of cough drops.
    Additionally, the Reno Sparks Indian Colony Officer testified that he made a custodial arrest, and
    conducted a search incident to arrest in light of my refusal to provide my driver's license...however, the
    video from Wal-mart interrogation room provided by Reno City Attorney Pam Roberts clearly shows me
    giving my driver's license to the officer, and further shows him radioing the number off of it in, thereby
    undermining his rationale for failing to issue a citation, but rather conduct a search incident to arrest,
    wherein a cough drop was found in my pocket. The receipt from the $90 of items I paid for has an
    entry for the UPC of that very type of cough drops.
    Sincerely,
    000664
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: geofgiles@hotmail.com
    To: attcbf@cox.net; mark@markmausertlaw.com; mcl3303@aol.com; zachcoughlin@hotmail.com;
    tahoephil@gmail.com; t2@kqswproductions.com
    Subject: Adverse ruling on foreclosure from Judge Kosach
    Date: Tue, 8 May 2012 21:11:07 +0000
    Well, here is an order that just came down from Dept 8. It was a hard fought and well briefed case, I
    am considering an appeal but doubt that I will do it, unless you see something glaring. I used all the
    latest techniques in hopes that I could get a better result than I am getting in federal court, but to no
    avail. It's a long case, so if you don't have time, I understand. Geof
    Apology and Zach Coughlin prescription medications
    information
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 5/14/12 12:37 PM
    To: tcoughlinmd@hotmail.com; davidc@nvbar.org; patrickk@nvbar.org; glennm@nvbar.org;
    marybarkbark@yahoo.com
    1 attachment
    Zach Coughlin rx history since February 2008.pdf (1163.3 KB)
    Dear Dad, Bar Counsel, Mom and Melissa,
    I am sorry for all the hurtful things I have said and done in the last
    year. I haven't been on my Wellbutrin/Buproprion antidepressant
    for quite awhile (I pulled my pharmacy records recently to try to
    learn from some things). I have taken anti-depressants since I was
    18 years old. I wasn't on either my Wellbutrin or Adderall for all of
    August 2011 until September 14, 2011. I was arrested on August
    20th, 2011 and September 9th, 2011. The Walmart arrest involved
    chocolate and cough drops. The cough drops have
    dextromethorphan in them, which is a dissociative in high enough
    doses. Chocolate (sugar) is, of course, an old time palliative. The
    banned cough drop (the melt or dissolve very quickly and contain
    000665
    30 mg in each one...so rather than powering through a whole bottle
    of cough syrup to take 300 mg of DM, one could eat 10 cough drop
    melts rather easily and quickly). These drops were pulled from
    shelfs for awhile when they first came out a few years ago, I believe
    because of the abuse potential or dangers of being able to ingest
    that high a quantity of a powerful dissociative so quickly (the cough
    syrup version of dextromethorpan is extremely difficult to just drink
    a whole bottle of, whereas the sugary cough melts are pretty much
    similar to candy). I went off the Adderall on approximately
    August 2, 2011. I went of the Wellbutrin in July 2011, right after
    the breakup of a four and half year. Okay, I went and found the
    records and am attaching them to this email. I wondered whether
    the switch from Vyvanse to Adderall coincided with my getting
    fired from Washoe Legal Services, but actually, it does not appear
    to have. I was suspended on April 20th, 2009 from WLS. Then,
    my termination date was May 12th, 2009. I only started taking
    Adderall instead of Vyvanse on June 13th, 2009. I was wondering
    if I became more irritable upon starting Adderall instead of
    Vyvanse and though maybe that cause the problems with the family
    court Judge during the March 2009 trial and then with Washoe
    Legal Services. I am actually kind of relieved to see their does not
    appear to be a causal connection given the chronology. I think I
    just felt WLS was a bit of a dead end job for me, was ruining my
    work ethic and motivation, and was, perhaps, an environment where
    white males had to conform to a certain prototype to fit in, one
    which I was not entirely at home with.
    You can see I filled one prescription for Campral. See this forum
    for evidence that tolerance to Adderall is sometimes thought to be
    000666
    counteracted by a class of medications that includes Campral,
    Dextormethorphan (DM is also being used to treat chronic pain
    patients in some experimental studies), etc.:
    http://addforums.com/forums/showthread.php?t=36078
    http://www.ncbi.nlm.nih.gov/pubmed/10875724
    I recall researching this in an attempt to be ultra cautious in
    my use of Adderall.
    My chronic pain levels seem to be much, much, more manageable
    when I am taking Wellbutrin and Adderall. I believe that the
    chronic upper back pain I dealt with for years was due, in part, to
    emotional/mental stress related to not appropriately addressing my
    ADHD and the spotty use of antidepressants I exhibited during
    those years (if my Dad and I were getting along, I would get
    Wellbutrin from him for free, if we weren't, I would rarely secure
    my own health insurance or pay out of pocket for that
    antidepressant, but would rather "rough it" to save money). When I
    went off the Wellbutrin and Adderall, the chronic pain returned,
    plus, I was basically in the early stages of a "divorce" from Melissa
    (whom I dated and lived with since April-ish 2007 until May 17th,
    2011. Melissa and I had been fighting since we moved into the
    home/office on River Rock on February 20th, 2010. From probably
    June 2010 until she moved out on May 17th, 2011, we fought
    almost daily, sometimes in a fairly hostile way (I was never
    physically violent with her, but she got a bit with me). I was
    existing on $400 a week in unemployment benefits, receiving them
    for 99 weeks. I actually worked quite hard the entire time. I
    learned a lot about a lot of different things, including some things
    related to the business of law, practice management, employment
    000667
    law, computers, software, hardware, cars, home improvement, I did
    focus on music for about 6 months straight (though I always
    continued to apply for jobs and send out resumes during this 99
    weeks...Washoe County had 15% unemployment during those 3
    years and jobs were in short supply and starting my own law
    practice seemed overly risky), and I was basically Melissa's maid
    and helper with proofreading her schoolwork for a couple years (in
    my mind at least, of course she may have a vastly different view of
    things). She worked a significant amount of hours and was in
    school full time and was irritable, extremely emotional, and
    stretched pretty thin. I implemented the "I pay for dinner one time,
    then you pay for dinner one time" rule for going out to dinner, and,
    of course, that took a lot of the romance out of things. I think I
    became very insecure about money and my career and getting fired
    from WLS was very, very discouraging. But, I worked their for 18
    months. Previous to that my longest tenure of employment at any
    job whatsoever was literally 4 months at Hale Lane. I am talking
    ANY job, my whole life. I realize my father has concerns about
    someone in recovery taking a controlled substance like Adderall,
    but I have exhibited symptoms consistent with a strong case of
    ADHD my entire life, and feel to potential for substance abuse
    inherent to untreated ADHD presents a great risk than does taking
    Adderall, though, admittedly, it is something that one must watch
    and realize that it can effect one's behavior and mood, sometimes in
    good ways, sometimes in bad ways. But so can drinking or not
    drinking water. So can taking or not taking insulin. Same with
    coffee. So, in some ways I consider adding the Adderall to the
    Wellbutrin a success and feel that I may have purposefully gotten
    fired from WLS because the malaise there and institutional politics
    000668
    were tough to deal with. Plus, it just occurred to me there that I
    could work there forever, it was an incredibly easy job, but their
    was not a pension, the pay was like $55K, they didn't give me the
    $5K raise after a year they promised (it seems small, but watching
    them heat half and empty building for months on end to 84 degrees
    round the clock because the office manager couldn't figure out how
    to fix the thermostat was just irritating), and that the law just held a
    different destiny for me than to be a legal aid domestic violence
    attorney for years and years, as honorable and admirable as that
    may be. Interestingly, a couple of the people I had the most
    problems with appear to have been fired from WLS after me.
    Previously, the Executive Director basically would not fire anyone
    unless they embezzled. It appears I changed his approach and got
    him to implement firing people as a management tool. He fired that
    office manager, RK, and he also fired ZL (I believe, though she
    might have just left, though I cannot imagine that because what
    other job would allow her to call in sick, with full pay, 30 Fridays a
    year and be accountable to absolutely no one and call herself a
    paralegal with no apparent legal training at all? Plus she, allegedly,
    had borrowed money from various employees without paying them
    back, so...).
    Speaking of borrowing money, when we broke up, Melissa stayed
    at Mom's for awhile (Mom now says Melissa "uses her tears to her
    advantage" and that she "feels a bit used by Melissa"), and Mom
    bought her a $500 mattress from Costco (we had two very nice
    memory foam beds I build with spare foam from Mills End fabrics
    and all bought with my $400 a week and thrift, and I just didn't
    want to give Melissa one when I felt she had been so unappreciative
    000669
    of things just like my building those beds and doing the research,
    etc.). We both agreed though that Melissa being an insulin
    dependent diabetic undoubtedly presents challenges to her in
    regulating her mood and emotions and that Melissa has
    demonstrated extraordinary courage and resolve in meeting those
    challenges. Then, Mom just admitted to me that Carly loaned
    Melissa several hundred dollars. Apparently Carly is pissed
    because Melissa is in New York City right now and still hasn't paid
    Carly or Mom back (she also went in September 2011, and we were
    supposed to go in July 2011, bought the tickets and everything
    $450, but her Aunt decided to change her travel to Ireland dates, so
    I basically lost that $450 due to the change fees Delta and American
    charge-Melissa bought the tickets and did not think to utilize
    Southwest...). Melissa also made off with at least one and possibly
    two months of my rent contribution that I gave her to give the
    landlord, plus, she didn't pay the landlord her contribution for May
    2011, June 2011, etc. However, as in all 4.5 year relationships,
    things get blurry, etc., and she is a wonderful person.
    SOMETHING PRETTY INTERESTING:
    One thing I note from the prescription history is I filled a
    Buproprion (note, I am using the terms Buproprion and
    Wellbutrin interchangeably) script on 3/18/09, then did not fill
    another one until 5/4/09...meaning a period of some 16 days
    or so where I was either out of Buproprion or did not take it
    or took less than my typical dose. I was suspended from
    WLS on 4/20/09. My final termination date was 5/12/09.
    That is pretty interesting. I seem to recall sometimes when
    my script for Buproprion ran out and there could be some lag
    000670
    time getting the doctor to fax a renewal to the pharmacy, and
    I believe at one point during the past couple years I
    complained to the pharmacy and the doctors office about an
    extended delay in getting my prescription renewed and filled
    and I specifically took them to task about the dangers of
    patients suddenly going of there antidepressants and recall
    being upset about what I perceived to be the doctor's office's
    or pharmacies negligence in so renewing the prescriptions. I
    do not believe I was blame shifting and avoiding my own
    responsibilities in that regard, but it is possible I should have
    done more in advance of running out of my Buproprion to
    renew the prescription and or should have followed up more
    on the failure to so renew after I made the renewal
    request....I believe this was during that 5/4/11 to 5/21/11
    period, but am not sure at this point, but I recall being upset
    that somethign like 3 weeks went by and my prescription was
    not ready...or I may have been late in making the request. I
    seem to undervalue what Bupropion does for my mood and
    behavior, I recall often thinking they were just "sugar pills"
    and it was all in my mind, any benefit....But, I didn't always
    believe that, sometimes finding the efficacy apparent.
    Looks like I went off Buproprion between 5/21/20 and
    6/17/10 as well. I went off Buproprion again between 8/12/10
    and 10/6/10....I notice that my copays stopped around
    7/12/10, which was went I stopped getting the reduced Cobra
    premiums under the Obama bailout, and had to start paying
    out of pocket (though it was essentially a wash, because the
    Cobra was $180 a month, plus $20 in copays, whereas, out of
    pocket was probably less overall, though it was $105 ever 3
    000671
    months for the psychiatrist and the prices of Adderall and
    Wellbutrin (I dropped Adderal XR probably because it cost
    more) spiked somewhat during that time). Then again from
    11/6/10 to 12/2/10, though its possible that I used that
    10/6/10 prescription, which consisted of 120 of the 75mg
    Buproprion generic versions to try to effect a discount by
    taking less Buproprion per day, ie, stretch one month of a
    script out 3 months or so by only taking 150 mg or 75 mg or
    something, I do remember trying to save money like that. I
    am very startled to see that from 5/4/11 to 5/21/11 I would
    have been out of Wellbutrin/Buproprion. Melissa and I broke
    up and she moved out on 5/17/11. I did have trouble with
    the ignition cylinder turning the key to start the car when
    trying to go to Melissa's graduation party on 5/15/11, and
    was at least 45 minutes late, causing her embarassment and
    pain. However, despite the fact that the key would not turn
    the cylinder causing me some delay, I believe it did not cause
    that much of a delay in finding some other way to get to the
    graduation party, but rather, my ADHD and depression led
    me to trying to do to many other things that day, misjudging
    time and the ability to get a reasonable amount of things
    done (I was probably trying to finish fixing Melissa's car or
    something else that was no where near as important as
    showing up to that party on time....but that is typical of
    people with depression and ADHD, the prioritizing and
    misjudging time, lateness, etc....). I do recall saying very
    mean things to Melissa during that 3 week stretch in May
    2011...however, both she and I were stressed out preparing
    for her graduation and final exams, having a great deal of her
    out of town family coming into town, my fighting with my Dad
    000672
    starting on 4/28/11 and having a bad argument about
    something rather small and minor, etc., and my
    unemployment benefits stopping right about late April 2011
    (99 weeks from May 21, 2009 start date would mean my
    unemployment ran out in early April 2011, I believe).
    I switched to the cheaper generic version of Adderall from the
    perhaps more steady consistent Adderall XR in June 2010.
    Melissa and I fought constantly from June 2010 until our
    breakup in June 2011....There were news reports of the price
    of Adderall XR skyrocketing out of the blue at about this time
    and there was a fair amount of controversy about Shire
    retaining the rights to make the generic and the generic
    version being essentially, garbage, according to many
    patients.
    http://www.addforums.com/forums/showthread.php?
    t=112229
    It is pretty crappy when you think about it, these drug
    companies increasing the copay from $29 on a mental health
    medication once month to $180 the next...and artificially
    forcing people to avoid the generic by retaining the rights to
    the generic and purposefully making the generic lack efficacy.
    http://www.drugs.com/answers/why-has-the-price-of-
    adderall-generic-30-mg-gone-455000.html
    http://motherboard.vice.com/2012/2/16/anatomy-of-the-
    great-adderall-drought
    000673
    http://www.thefix.com/content/pay-attention-adderall-add-
    big-pharma7004
    I then went off my Wellbutrin/Buproprion from 7/25/11 until
    4/28/ 12..From filling the Buproprion at a cost of $20 in June
    of 2011 until recently filling the prescription in late April 2012,
    the cost has gone up 300%. That medication has been off
    patent for some 20 years now, it should not be rising in price,
    especially during a period where the economy has struggled
    so mightily. Interestingly, the cost of those cough drop melts
    with 30 mg of Dextromethorphan per melt rose form around
    $6.50 a box in 2007 or so to $8.88 in September 2011 for the
    exact same quantity/dosage. I simply could not afford it
    though on at least two occasions I called up Northern Nevada
    Adult Mental Health and inquired about the possibility of
    getting the cost paid for by the state or subsidized. In
    evaluating the time and relinquishment of my privacy rights
    (there is a fair amount of shame and worry about one's
    professional reputation and how those in recovery or AA will
    view one's taking these medications associated with taking
    ADHD and Major Depressive Disorder medications) that I felt
    it would require to achieve the savings of around $125 a
    month for these two prescriptions, I never decided it was
    worth it to go to NAMS, but rather just stopped paying for the
    Buproprion (again, I sometimes viewed it as a sugar pill,
    whereas the Adderall I felt had an effect, both for controlling
    ADHD and for the supplemental uses as a treatment resistant
    antidepressant and the off label use for the control of OCD.
    In that time period I was put in jail 8 times and, essentially
    evicted 3 times and fought with and alienated myself from my
    000674
    entire family, lived a very secluded, reclusive life, etc...
    exhibited poor impulse control, a temper, and symptoms
    consistent with untreated Major Depressive Disorder (MDD)
    and perhaps some type of hoarding behavior or Obsessive
    Compulsive Disorder, including tiling the River Rock home
    office, collecting car seats, recarpeting the entire home office
    with scraps in a patchwork, and tiling the crumbling front
    steps, and putting green carpet on the dirt lawn.
    I was arrested on:
    8/20/11 for petit larceny (the lost mislaid iPhone thing where
    the finder said he would "throw it in the river if someone
    doesn't claim it right away"). 7 days in jail.
    9/9/11 for petit larceny at Wal-Mart of a chocolate bar and
    two boxes of the cough medication drops/melts with
    Dextromethorphan 30 mg per melt. 1 day in jail.
    11/12/11 for criminal trespass at my former home law office
    (i was issued 3 traffic citations days later when I went to the
    opposing attorney who signed the criminal trespass
    complaints office to retrieve my wallet and driver's license and
    was told to leave by the RPD. While driving away the RPD
    pulled me over and charged me with a "California Roll"/failure
    to come to a complete stop and a couple fix it tickets, that
    were ultimately fixed). 3 days in jail
    11/30/11 for summary contempt during the trial for the Wal-
    Mart chocolate bar and cough medication drops Trial before
    Judge Howard in RMC 11 CR 22176. 1 day in jail.
    1/12/12 for jaywalking while filming personal property at my
    former home law office being placed in a dump truck for
    hauling to the dump. 1 day in jail
    000675
    1/14/12 for "misuse of 911 where no actual or perceived
    emergency exists), a gross misdemeanor incident to the
    domestic violence I was victimized by on E. 9th St. by my
    housemates. 3 days in jail
    2/27/12 for summary contempt during the trial for the
    11/15/11 traffic citations "California Roll"/failure to come to a
    complete stop at stop sign deal....5 days in jail
    4/19/12 for contempt, I believe, for failing to fully participate
    (concern for privacy rights, shame, etc) in the ordered
    competency evaluation that Judge Elliot ordered I undergo
    with the Lake's Crossing doctors. I spent 7 days in jail.
    I am feeling better and better since starting to take my
    antidepressant, Wellbutrin again, and now realize I need to be
    much more diligent in filling that prescription in a timely
    manner and making preparations for situations where I might
    not be able to afford it. I plan to write many apology letters,
    including to judges, bar counsel, opposing counsel, etc. I
    always fought and worked hard for my clients though for an
    extremely competitive price.
    Sincerely,
    Zach Coughlin, Esq.
    000676
    Page: 1
    M E D I C A L EX P E N S E S
    COUGZA1
    Patient: COUGHLIN, ZACH
    Resppty:
    DC!! 1422 E 9TH ST #2
    REO
    Birth: 09/27/1976
    Prescriptions:
    ,N 89512
    LastFill R # Drug Name
    01/30/08 6405827 BUDEPRION X 300 M
    02/01/08 2401067 MTHYL IN 20M
    03/01/08 6405827 BUEPRION X 300 MG
    03/03/08 2401357 VVANSE 70 MG
    03/30/08 2401611 VYVANSE 70 M
    04/02/08 6413703 BUPROPION 300 MG X
    05/01/08 2401932 VYVASE 70 M
    05/05/08 6416295 BUPROPION 300 MG X
    06/02/08 2402229 VYVASE 70 M
    06/02/08 6416295 BUPROPION 300 M X
    06/27/08 2402484 VYVANSE 70 MG
    07/03/08 6416295 BUPROPION 300 MG X
    08/01/08 2402852 VYVANSE 70 M
    08/04/08 6422989 BUPROPION 300 M X
    08/30/08 2403149 VYVANSE 70 MG
    09/06/08 6422989 BUPROPION 300 MG X
    09/30/08 2403415 VANSE 70 M
    09/30/08 6422989 BUPROPION 300 M X
    10/30/08 2403418 VYVANSE 70 M
    10/30/08 6430436 BUPROPION 300 MG X
    11/30/08 2403419 VYANSE 70 M
    11/30/08 6430436 BUPROPION 300 M X
    12/19/08 6434447 GUAFACINE 1MG
    12/28/08 2404354 VYVASE 70 MG
    12/28/08 6434452 BUPROPION 300 MG XL
    01/24/09 2404356 VYASE 70 M
    01/24/09 6434452 BUPROPION 300 M X
    02/17/09 6430436 BUPROPION 300 M XL
    02/18/09 2404355 VASE 70 MG
    03/18/09 2405234 VASE 70 MG
    03/18/09 6441680 GUAFACINE 1M
    03/18/09 6441682 BUPROPION 300 M X
    03/20/09 6441898 VIAGR 50MG
    04/17/09 2405236 VYVANSE 70 MG
    05/04/09 6441682 BUPROPION 300 MG XL
    05/18/09 2405237 VYVANSE 70 MG
    06/05/09 6441682 BUPROPION 300 M X
    06/13/09 2406368 AMPHETAMINE 30MG
    07/17/09 2406369 AMHETAMINE 30MG
    07/17/09 6452048 BUPROPION 300 MG X
    08/11/09 2407073 VNSE 70 M
    08/11/09 6452048 BUPROPION 300 M X
    09/10/09 6456472 BUPROPION 300 MG XL
    10/16/09 2407500 VANSE 70 MG
    10/16/09 6456472 BUPROPION 300 MG XL
    11/15/09 2407501 VYVANSE 70 MG
    11/23/09 6463678 BUPROPION 150M SR
    12/31/09 6463678 BUPROPION 150MG SR
    01/17/10 6468474 OMPRZOLE 20M
    01/22/10 2409075 AMPHETAMINE 20MG
    02/02/10 6463678 BUPROPION 150MG SR
    Pharmacy: SAVE MART PHACY #556
    195 W. PLU LE
    RENO N 89509
    RPh: TAYLOR, JACKIE/TOMY
    Date: 01/01/2008 TO 05/01/2012
    Qty Physician Name
    30 Dr.RASUL
    60 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RASUL
    30 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    5 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RASUL
    30 Dr.RSUL
    30 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.COUGHLIN
    90 Dr.RASUL
    60 Dr.RASUL
    T/P
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    Price RPh
    25.00
    22.23
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    25.00
    73.41
    25.00
    25.00
    160.48
    92.72
    52.68
    52.68
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    25.00
    5.00
    5.00
    5.00
    34.67
    5.00
    J
    TZ2
    JT5
    JH2
    JH5
    JT3
    JH3
    JT1
    JT3
    JT3
    JT6
    JT4
    K06
    TZ7
    TZ5
    JT6
    KC2
    KC2
    JRT
    JT1
    JT6
    JT6
    JT3
    JT4
    JT8
    TZ5
    TZ5
    JT5
    TZ5
    TZ2
    JT3
    JT3
    TZ5
    JT8
    M
    JT
    TNZ
    TNZ
    J9
    JG6
    JG3
    JT1
    JT5
    JG5
    JG5
    JG6
    JT1
    JG5
    JT5
    JG3
    JG3
    .L EXPENSES
    Pago:
    Pharmacy: SAVE MART PHARMACY 15
    115 W. PLUMB LANE
    RENO NV 81509
    RPh: TAYLOR. JACKIErOMMY
    NV 89512
    Dato: 0110112000 TO 0510112012
    .gNamo Oty PhysicianNam TIP Prico "Ph
    90 D'.RASUL 34.67 JGJ
    60 Dr.RASUL CPB 5.00 JGJ
    60 DI.RASUL CPB 15.00 JGO
    40 Dr.PARRon APN CPB 4.87 JGJ
    180 Dr.RASUL CPB 25.00 JGJ
    60 Or.RASUL CPO 5.00 JTS
    6Or.RASUL CPO 15.00 LOO
    6O,.RASUL CPB 5.00 J.S
    60 Or.RASUL CPO 15.00 M'
    00 Or.RASUL CPO 15.00 JMG
    6Or.RASUL CPO 5.00 Z1.4
    6 Or.RASUL CPB 15.00 JT4
    6 Or.RASUL CPO 5.00 LB.
    60 Or.RASUL 32.05 JG5
    6Or.YASAR 32.95 JT4
    60 Or.YASAR 32.95 LB4
    120 Dr.YASAR 32.48 JGI
    00 Or.YASAR 32.95 JT6
    60 Dr.YAMR 32.95 G'J
    60 Dr.YASAR 32.46 JG'
    00 Dr.YASAR 32.95 G13
    6 Dr.YASAR 32.46 JG'
    8Dr.YASAR 32.95 JT8
    60 Dr.YASAR 32.46 JT8
    60 Dr.YASAR 32.95 2MO
    6 Or.YASAR 32.46 J.J
    60 Dr.YASAR 26.79 JTO
    60 Dr.YASAR 37.39 JT6
    6 Dr.YASAR 32.05 JG3
    6Dr.YASAR 37.39 JTS
    60 Dr.YASAR 26.79 JT6
    60Dr.YASAR 36.89 2M2
    8Dr.YASAR 20.23 ZM,I
    6Dr.YASAR 15.46 118
    60 Dr.YASAR 60.00 Z11
    60 Dr.YASAR 60.00 Mt.f
    60 Dr.YASAR 60.00 JTS
    60 Dr.VASAR 69.19 MM4
    60 Dr.YASAR 69.19 JT1
    60 Dr.YASAR 60.19 MM7
    6Or.VASAR 61.01 195
    Roport Dalo: 05101/2012 $2.720.3"
    AI1os10d To By: )
    oglO 01 m '"
    M EDI C A L EXPEN S E S
    Pago:
    COUGZAI
    allonl: COUGHLIN. ZACH Pharmacy: SAVE MART PHARMACY 11556
    :ospPty: 195 W. PLUMB LANE
    D:: 1422 E 9TH ST 1 RENO NV 89509
    RPh: TAYLOR. JACKIEffOMMY
    RENO NV 89512
    Ilflh: 09127/1076
    'roscriptlons: Oato: 01101/2000 TO 0510112012
    O..g Namo Oy Physician N;lmo TIP Prico RPh
    METHYLIN 20MG 60 OLRASUL 22.23 JHl
    I VYVANSE 70 MG 30 Or.RASUL OPU JT3
    SUOEPRION XL 300 MG 30 Or.RA5UL CPB 25.00 JWH
    METHYLIN lOMG 6Df.RASUL 22.23 TZ2
    IUDEPRION XL 300 MG 30 Or.RASUL CPB 25.00 JT5
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JH2
    I VYVANSE 70 MC 30 Dr.RASUL CPB 25.00 JI-IS
    BUPROPION 300 MG XL 300r.RASUL cpa 25.00 JT3
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JH3
    SUPROPION 300 MG XL 30 OLRASUL CPB 25.00 JTI
    VYVANSE 70 MG 30 Or.RASUL cpa 2S.00 JT3
    BUPROPION 300 tAG XL 30 Or.RASUL CPB 25.00 JT3
    VYVANSE 70 MG 30 OLRASUL CPS 25.00 JTO
    BUPROPION 300 MG XL 30 Or.RASUL cpa JT4
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 K06
    OUPROPION 300 MG XL 30 Or.RASUL cpa 25.00 TZ7
    VYVANSE 70 MG 30 Or.RASUI. CPB 25.00 TZ5
    BUPROPION 300 MG XL 30 Dr.RASUL CPB 25.00 JT6
    I VYVANSE 70 MG 30 Or.RASUL CPB 25.00 KCZ
    BUPROPION 300 MG XL 30Dr.RASUL cpa 25.00 KCZ
    I VYVANSE 70 MG 30 Or.RASUI. cpa 25.00 JRT
    IUPIOPION 300 MG XL 30 Or.RASUI. CPB 2S.00 JTI
    VYVANSE 70 MG 3 Dr.RASUL CPB 25.00 JTO
    BUPROPION 300 MG XL 30 Or.RASUL cpa 25.00 JTO
    GUANFACINE 1 MG 60 Or.RASUL cpa 5.00 JT3
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 JT4
    BUPROPION 300 MG XL 300r.RASUL CPB 25.00 JTO
    VYVANSE 70 MG 30 Or.RASUL CPB 25.00 TZ5
    OUPROPION 300 MG XL 300r.RASUL CPB 25.00 TZ,
    IlUPROPION 300 MG XL 30Dr.RASUL cpa 25.00 JT5
    VYVANSE 70 MG 300r.RASUl CPB 25.00 TZS
    VYVANSE 70 MG 30 Or.RASUL cpa 25.00 T22
    GUANFACINE 1MG 6Or.RASUl CPB 5.00 JT3
    nUPROPION 300 MG XL 300r.RASUI. CPB 25.DO JT3
    VIAGRA SOMG 50r.RASUl CPB 73.41 TZ'
    VYVANSE 70 tAG 30 Or.RASUl cpa 25.00 JTO
    tlUPROPION 3 MGXl 300r.RASUL CPB 2S.00 "VB
    VYVANSE 70 AG 30 Or.RASUl 100.48 JRT
    BUPROPION 300 MGXL 300r.RASUL 02.72 TNZ
    AMPHETAMINE 30MG 600l.RASUl 52.68 TNZ
    AMPHETAMINE 30MG 600r.RASUL 52.68 JTO
    BUPROPION 300 MGXL 30 OI.RASUl CPB 25.00 JGO
    VYVANSE 70 MG 30 Dr.RASUL cpa 25.00 JG3
    BUPROPION 300 1.1G Xl 30 Dr.RASUL CPB 25.00 JTI
    BUPROPION 300 MGXl 30 Or.RASUl CPB 2S.00 JT'
    VYVANSE 70 MG 30 Or.RASUL cpe 25.00 JG5
    eUPROPION 300 MG Xl 30 Or.RASUl CPS 25.00 JGS
    VYVANSE 70 MG 300r.RASUL CPB 25.00 JGO
    BUPROPION ISOMG SR 6 Or.RASUL CPB S.OO JTI
    BUPROPION 150MG SR 60 Or.RASUl CPB 5.00 JGS
    OMEPRAZOlE 20MG 60 Or.COUGHLIN CPB 5.00 JTS
    M E D I C A L
    COUGZA1
    Patient: COUGHLIN, ZACH
    Resppty:
    DC!! 1422 E 9TH ST #2
    RENO
    Birth: 09/27/1976
    prescriptions:
    ,N 89512
    LastFill R # Drug Name
    02/19/10 2409405 ADDERALL X 30MG
    02/24/10 6471901 MTOCLOPRAM 5M
    03/18/10 6472900 CAMRAL 333MG
    03/19/10 6474257 BUPROPION 150MG SR
    03/20/10 2409769 ADDERLL X 30MG
    04/19/10 6474257 BUPROPION 150M SR
    04/21/10 2409770 ADERALL X 30M
    OS/22/10 2409771 ADDERALL X 30M
    06/03/10 6474257 BUPROPION 150M SR
    06/17/10 2410853 ADDERALL X 30M
    07/12/10 6484763 BUPROPION 150MG SR
    08/02/10 2411503 AMPHETAMINE 30MG
    09/02/10 2411881 APHETAMINE 30M
    10/02/10 2411974 APHETAMINE 30MG
    10/06/10 6492514 BUPROPION 75MG
    11/01/10 2411973 AMHETAMINE 30M
    12/02/10 2412940 AMPHETAMINE 30M
    12/02/10 6489816 BUPROPION 150M SR
    12/18/10 2413141 APHETAMINE 30M
    12/23/10 6489816 BUPROPION 150MG SR
    01/31/11 2413142 AMPHETAMINE 30MG
    01/31/11 6489816 BUPROPION 150M SR
    03/03/11 2413143 AMPHETAMINE 30M
    03/03/11 6505746 BUPROPION 150M SR
    04/04/11 2413144 AMPHETAMINE 30MG
    04/04/11 6505746 BUPROPION 150MG SR
    04/22/11 2414647 AMPHETAMINE 30M
    OS/21/11 6511008 BUPROPION 150M SR
    06/03/11 2414644 APHETAMINE 30M
    06/25/11 6511008 BUPROPION 150M SR
    06/29/11 2414645 AMPHETAMINE 30MG
    09/12/11 2416340 AMHETAMINE 30MG
    10/13/11 2416349 AMHETAMINE 30M
    11/17/11 2416350 AMPHETAMINE 30M
    12/26/11 2416351 AMPHETAMINE 30M
    01/26/12 2417915 AMPHETAMINE 30MG
    02/27/12 2417919 AMHETAMINE 30MG
    04/02/12 2417920 AMPHETAMINE 30MG
    04/28/12 6521924 BUPROPN HCL 150MG X
    Report Date: 05/01/2012
    Attested To By:
    E X P E N S E S
    Pharmacy: SAVE MRT PHACY #556
    195 W. PLUM LE
    RENO N 89509
    Page: 2
    RPh: TAYLOR, JACKIE/TOM
    Date: 01/01/2008 TO 05/01/2012
    Qty Physician Name T/P Price RPh
    60 Dr.RASUL
    40 Dr.PARROTT APN
    180 Dr .RASUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.RASUL
    60 Dr.RSUL
    60 Dr.RASUL
    60 Dr.RSUL
    60 Dr .RSUL
    60 Dr .RASUL
    60 Dr.RSUL
    60 Dr.YASAR
    60 Dr.YASAR
    120 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASA
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    60 Dr.YASAR
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    CPB
    15.00
    4.87
    25.00
    5.00
    15.00
    5.00
    15.00
    15.00
    5.00
    15.00
    5.00
    32.95
    32.95
    32.95
    32.46
    32.95
    32.95
    32.46
    32.95
    32.46
    32.95
    32.46
    32.95
    32.46
    26.79
    37.39
    32.95
    37.39
    26.79
    36.S9
    20.23
    45.46
    60.00
    60.00
    60.00
    69.19
    69.19
    69.19
    61. 01
    $2, 707.11
    JG6
    JG3
    JG3
    JT5
    LB6
    J15
    AF
    J
    ZM4
    JT4
    LEI
    JG5
    JT4
    LE4
    JG1
    JT6
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    G13
    JG4
    JT8
    JTS
    ZM6
    J13
    JT6
    JT6
    JG3
    JT5
    JT6
    ZM2
    ZM4
    M8
    Zl1
    M7
    JT5
    M4
    JT7
    M7
    BB5
    FW: release of information to my attorney
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 5/02/12 4:29 PM
    To: jgoodnight@washoecounty.us; keithloomis@earthlink.net; keith@leelawoffice.net;
    patrickk@nvbar.org; coe@gbis.com; zyoung@da.washoecounty.us; judgemcgee@msn.com;
    kadlicj@reno.gov; geofgiles@hotmail.com; hazlett-stevensc@reno.gov; sooudib@reno.gov;
    robertsp@reno.gov; ormaasa@reno.gov
    3 attachments
    patrick o. king citations.pdf (1070.1 KB) , loomis allcases.pdf (624.7 KB) , giles allcases.pdf
    (1426.7 KB)
    Dear Mr. Loomis and Mr. Goodnight, et al,
    I am writing response to your putting for the idea of a global resolution. If any global resolution could
    be achieved it would mean a great deal to me. I believe I am doing better now and this has been an
    enormously difficult time with a great deal of damage done to my family relationships, reputation,
    finances, privacy rights, lost opportunities, etc.
    I ask that you pursue, if possible including the conviction of 11 30 12 before Judge Howard on some
    Rule 60 relief from judgment basis. I believe I filed a Rule 60 in that petit theft conviction in 11 TR
    22176, however, I am not sure if the RMC filed it, etc., etc. as sometimes there have been issues with
    having my filings accepted. I am just trying to move on with my life and pick up the pieces. Of course,
    I wish I had handled some things better and am plenty willing to grovel for foregiveness before
    whomever if it will help get these matters resolved without a conviction, and especially if it will get the
    conviction in 11 TR 22176 set aside or undone, etc. I did report that conviction to Bar Counsel (from
    RMC 11 TR 22176 before Judge Howard) under SCR 111, however, I believe a global resolution wherein
    that conviction is overturned would hel me retain my law license and avoid a significant suspension. If
    that could be achieved it would be very easy for me to just move on and forget about seeking recourse
    for the various things that have happened. Further, my main goal is to avoid a suspension of my law
    license or being forced into a SCR 117 disability petition. I love the practice of law and take it very
    seriously. I have very few clients right now because I know that is necessary to afford me that which I
    need to provide them services in a professional manner and to meet all standards of care. I could be
    making more money right now, but I know the prudent thing is to not take on too many clients and to
    do good work for those clients I do have. I attempt to mirror the approach of Geof Giles, whom could
    have a great deal more foreclosure defense clients and clients in general than he currently does, but
    chooses to keep that roster relatively trim in order to attempt to get the best precedent on the books
    as possible. Mr. Giles is doing work that is extremely important to Nevadans right now in the
    foreclosure defense setting, including fighting the big removal and preemption fights. I have been
    lucky to get to do a little research for him once in awhile, though I dont think I have found him any
    materials he did not already have or otherwise get him anything useful, but at least
    I get to see some of this exciting foreclosure battle up close.
    Mr. Goodnight, please work with Mr. Loomis, he is the former District Attorney for Lyon County and is
    extremely well respected in our profession. I am attaching a collection of his Westlaw profiler results.
    Mr. Loomis, Joe is a National Merit Finalist whom I have known since I moved to Reno in 7th
    000677
    grade after sending 2 years in Dayton, Ohio before that I slit time between Gardnerville 9 months a
    year with my mom and summers with my Dad in Reno. Also, if permissible, please work with
    Bar Counsel Patrick King, whom Coe Swobe speaks highly of and who has been pretty patient with me
    throughout my recent issues. I am attaching a collection of the signficant cases he has appeared on as
    well.
    Coe Swobe, Esq. former state senator, and recipient of a commendation from President Reagan for his
    work in forming the TRPA, and Keith Lee, Esq., whom started the Character and Fitness Committee,
    was student body president at UNR may be willing to provide some insight into this situation. I will be
    attending Lawyers Concerned For Lawyers on Thursday nights, though an extremely heavy deadline
    collection of late has been tough of late...
    Basically, I was doing pretty well for some time, but creative differences at Washoe Legal Services
    resulted in our parting ways in May 2009, though I still have an enormous deal of respect for Paul
    Elcano and the rest of Washoe Legal Services, and in some ways owe him more than I am comfortable
    admitting for his insane decision to hire me in August 2007. After leaving WLS, the economy turned
    sour, and the next 2 years were a combination of seeking employment and doing the scut work of
    preparing to enter private practice. I can build a computer from the ground up and know what thermal
    paste is for a processor. I am getting better with rules based calendaring software and the rest of all
    that is involved in practicing law these days.
    However, my live-in girlfriend of four and a half years and I broke up in June 2011. As confirmed by
    the landlord in RJC Rev2011-001708, my girlfriend took a couple months worth of my rent contributions
    and instead of forwarding it on to the landlord, she secretly used it to get a new apartment, etc. She
    also took my beloved Pomeranian, Palin.
    I was running low on money in early August 2011 and decided to take a 'medication holiday', which is
    an accepted practice, especially considering the cost of the medication has skyrocketed somewhat in
    the last year or so. My psychiatrist, Dr. Yassar's office will confirm that they have a record of my calling
    to cancel my August 2, 2011 appointment and that I would have run out and did not refill my
    prescription by that date. I did not receive another prescription or otherwise fill one until September
    12, 2011.
    I did not find out about the missing rent until mid August 2011 as the landlord had a practice of not
    even cashing rent checks for months at a time....naturally, as he is a neurosurgeon who probably is not
    living paycheck to paycheck. Richard G. Hill, Esq. entered the picture for the landlord on August 16th,
    2011. I was arrested on the iphone in the skate plaza possession of lost or mislaid property matter on
    August 20th, 2011 and the eviction Notice is dated August 22nd...and I sent 7 days in jail waiting for an
    OR. Then, on September 9th, 2011 I was arrested on the eating a candy bar, etc, at WalMart while
    shopping for an paying for $90 worth of groceries. I do not believe I committed theft in either of the
    petit larceny cases, the arrests for which occurred during a 19 day period wherein I had ceased taking a
    medication prescribed by my pscyhiatrist that I have been on for years and years, mostly due to the
    cost of the medication skyrocketing lately, my girlfriend breaking up with me and making off with my
    share of the rent, a tough economy, etc., etc. I believe my personality was made prickly from going off
    the medication abruptly and that resulted in two arrests in situations where an arrest would not typically
    be made. I got back on one of my medications immediately following my release from jail on
    September 12th, 2011. I still could not afford my other medication until I finally filled it on April 28th,
    2011. My dad is a physician and gave me this medication when I was a teenager.
    The eviction Order by Judge Sferrazza (that Mr. Loomis made a brilliant argument against in the
    criminal trespass matter related to the RJC being divested of jurisdiction to enter that Order considering
    a Notice of Appeal was filed by me in the interim between the two hearings) called for the lockout to
    take place on November 1, 2011. I was arrested for criminal trespass on November 13th, 2011.
    Despite NRS 40.253 expressly forbidding it, Judge Sferrazza forced me to deposit my last $2,300 into
    the RJC's rent escrow account in order to preserve my right to litigate habitability. Even after the
    eviction Order was rendered on October 27th, 2011 and for nearly 10 days thereafter, the RJC
    000678
    continued to hold on to that $2,300 of mine. What was I supposed to live on? Plus, the way the law is
    being applied currently, a tenant is forced to deposit such an escrow amount, then, prepare for a
    hearing, then if the tenant loses, be ready for a Sheriff to be opening their door with his gun drawn
    after a locksmith gained access to the rental just hours after the hearing itself. I do not get Section 8
    housing benefits, do not get welfare or food stamps, no medicaid, etc. Further, Richard G. Hill and
    Casey Baker actually got Judge Sferrazza to sign the Order of 10/27/11 with a ruling wherein the $2,300
    was awarded to the neurosurgeon, despite the Order as rendered in open court having said no such
    thing. Simply put, they hand the court an Order that the court directed them to prepare based on what
    was announced in open court, and rather than faithfully reproducing the same, they remix it to be what
    they had hoped the Order would be in the first place, forcing Judge Sferrazza and I to correct
    their perfidy...just kidding, sort of... I had to file a JCRCP Motion to Alter or Amend just to correct that
    and get that rent escrow deposit back. In Las Vegas, the Justice Court had to get Rule 44 passed off
    on by the Nevada Supreme Court just to be able to force such rent escrow deposits, as required by
    JCRCP 83. I think Judge Sferrazza just misread the statute, which is damn confusing and complex.
    Such forced rent escrow deposits in the context of the speedy nature of these ultra quick summary
    eviction proceedings have a vast societal cost, as seen here. The Reno Police Department has gotten a
    little disparage in this. Officer's have. My reputation will never be the same...the RJC took some
    lums.....and Richard G. Hill, Esq. got over $50,000 in fees to litigate a summary eviction from a
    commercial law office where the only notice served failed to allege nonpayment of rent. NRS 40. 253
    expressly forbids utilizing summary eviction proceedings against commercial tenants unless non-
    payment of rent is alleged. My Lease Agreement allowed for the commercial law office use for which
    the property was being utilized, in express, written terms. Richard G. Hill, Esq. committed a wrong site
    surgery of a legal nature for his neurosurgeon client.
    So, I was subject to a custodial arrest incident to Richard G. Hill, Esq. signing a criminal trespass
    complaint on November 13th, 2011. I spent three days in jail and more money on bail and got out on
    November 16th, 2011, then Thanksgiving week and many deadlines in other cases took place... Then,
    on November 30th, 2011 the trial in RMC 11 TR 22176 in the candy bar case took place and Judge
    Howard denied my request for a continuance, even where Richard G. Hill was subjecting exculpatory
    materials to an unlawful rent distrain under NRS 118A.520 that I felt necessary to my defense of a
    matter for which a conviction would require reporting under SCR 111. I was convicted and did report
    that to Bar Counsel. I was denied an attorney, yet sentenced to 3 days in jail for summary contempt.
    It is my hope that there is some permissible manner for that conviction to be overturned and to avoid a
    SCR 117 disability petition. I spent four years on the sidelines from 2001 to 2005 waiting to get a law
    license. I have not had a relapse. Staying busy has always been the best thing for me, and a
    suspension, I believe, would have a negative effect in that regard, and actually not benefit me or
    otherwise provide time for me to address any problems anyone feels I might have. Simply put, I just
    want to practice law. I do not want to get into protracted wranglings and fighting city hall, etc. while
    waiting out a suspension or worse. I know I have upset a good number of people and will be making
    amends for that in the years to come.
    I appreciate anything any of you can do to assist me here in achieving my stated goals and promise you
    I would pay it forward in our profession in the future. There has been a silver lining in all this for me,
    however. I have been able to meet and watch practice a number of fine attorneys and people,
    including Deputy City Attorneys Roberts, who had some very crafty moves in the appeal of the candy
    bar case, Ormaas, Hazlett-Stevens, and Sooudi, as well as Deputy District Attorney Zach Young. And
    RJC Chief Bailiff Sexton and Bailiff English and I were able to joke the other day after a hearing wherein
    my arguments were roundly smited about how I actually won the hearing because I did not have to go
    to jail at the conclusion of it, and how its those little victories that one must build on in seeking to
    navigate in the legal profession while learning to practice law. And I may not have ever received a
    license in the first place if it was not for Reno City Attorney John Kadlic writing me a letter of
    recommendation to the State Bar of Nevada and Nevada Supreme Court back in 2004 where I was
    languishing in Moral Character application purgatory, or were it not for Keith Lee taking on my case pro
    bono when it seemed bleakest, or had Judge McGee and Coe not been there to laugh with.
    Sincerely,
    000679
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000680
    Print Close
    Update and a Request
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 4/27/12 12:12 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org; coe@gbis.com;
    keith@leelawoffice.net
    Dear Bar Counsel,
    I was never afforded an informal meeting or an opportunity to view the materials
    submitted in conjunction with the various grievances or other types of complaints
    against me, nor was I given a deadline to respond for any such matters outside the
    deadline related only to the Hill "grievance". I ask that the process be paused and that
    those procedural safeguards be afforded me. Further, I have met with Coe Swobe
    recently and discussed this matter and ask that all avenues available to me be held
    available, until I have had a a legitimate chance to explore them. I apologize for what
    may seem an overly adversarial tone so far on my behalf and pledge to work with you
    from hereon in addressing these matters of concern.
    Sincerely,
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: Mr. King's assertion in his 3/16/12 letter
    Date: Thu, 19 Apr 2012 21:29:10 +0000
    April 19, 2012
    Zach Coughlin
    Dear Mr. Coughlin,
    000681
    A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the
    grievances filed against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be
    preparing a formal Complaint.
    I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at
    Wal-Mart and that you should not have been found in contempt of Court. However, it must concern you that you were
    found in contempt of Court by more than one Judge in two different trials. You wanted to know how I learned of or
    obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent to me by the clerk of the court at
    my request, pursuant to my investigation.
    It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and
    why you were held in contempt of Court. You may be well served to explain what remedial measures you are taking to
    make sure you do not repeat the conduct complained about. I cannot give you legal advice. However I can suggest you
    cooperate with Bar counsels investigation and that you respond specifically to the allegations contained in Judge
    Holmes and Richard Hills grievance letters to the office of Bar Counsel.
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 5:41 PM
    To: Patrick King; David Clark; Glenn Machado
    Subject: Mr. King's assertion in his 3/16/12 letter
    Dear Bar Counsel,
    One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months
    worth of my portion of our rent from me (our arrangement was I would give her the money, she would forward it on to the
    landlord) in the period between May-July 2011. I sacrificed a great deal and paid lots of her tuition, and she broke up with me
    and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her graduation from UNR. I
    did not know about her stealing my portion of the rent or failing to pay her own portion until August 2011, as the landlord was
    on an extended vacation and failed to communicate any deficiency in the rent until mid-August, 2011, and the eviction in RJC
    REV2011-001708 from my former home law office ensued within less than a week of his communicating this deficiency. He
    and his counsel, Richard G. Hill, Esq. and Casey Baker pursued a No Cause Notice of Eviction because there was a wealth of
    support for me contention that habitability issues, fix and deduct, and the landlord's failure to cure, in addition to personal
    property damage done by the landlord's landscaping crew and a provision in the lease holding the landlord liable for such,
    indicated it would "be the path of least resistance" to simply seek a No Cause Eviction. The only problem in their attempt to
    circumvent the law (even though they still threatened to seek back rent in another forum after getting their No Cause,
    000682
    summary eviction) was the fact that the Lease Agreement specifically allowed for me to have a commercial law office there, and
    NRS 40.253 makes impermissible a summary eviction against a commercial tenant unless the non-payment of rent is Notice,
    which, of course Baker and Hill chose not to do....and it was about the time that Hill started to understand that his "wrong site
    surgery" for his neurosurgeon landlord client might subject Hill and his firm to some malpractice liability, that Hill started
    writing letters to bar counsel attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable
    when Gessin was Hill's client and Hill was milking over $20K from Gessin) for "ghostwriting" even though I was listed as
    Attorney of Record on several different Gessin cases, etc., etc.
    Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has filed a
    grievance or complaint and also with respect to any criminal charge against me, including that which resulted in a conviction in
    11 CR 22176, which, I think will ultimately reveal was replete with prosecutorial misconduct, lying by the Wal-Mart loss
    prevention associate, and lying by the two RSIC police officers, in additional to abuse of discretion and other errors by Judge
    Howard.
    I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent. The postmark on
    that 3/16/12 letter from Assistant Bar Counsel King (please see attached picture of the letter and envelope) indicates it was
    mailed 3/16/12, and the letter indicates it was not faxed to me (despite my numerous written requests that such a practice be
    done in consideration of the problems I have encountered in the USPS violations of the Federal Torts Claims Act and incident to
    the domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which included interference with my mail).
    I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the Golden
    Valley USPS Station and the Downtown Reno Post Office in and attempt to make every diligent effort to receive my mail. I
    have been threatened by and lied to by the supervisors of the Golden Valley Station USPS Station. I had a hearing related to a
    landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12 letter that I was living in my car
    at that time rather suspect, given my home law office was located at the property which was the subject of that hearing and
    which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no attribution for such hearsay in her
    extremely reckless assertion) in RJC REV2012-00374 (the matter for which Gayle Kern sent a property manager who lacked
    even a law license to litigate on her behalf, or on that of the HOA which Kern has now decided to appear for, despite her being
    listed a the PTTHOA Resident Agent for sometime and despite Kern being a named party in the lawsuit in RJC Rev2012-
    000374.
    My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time to
    respond to it. Additionally, I note that Mr. King, in that 3/16/12 letter, writes "I am enclosing with this letter copies of a
    grievance letter, from the Municipal Court and a copy of an Order from District court....I will make available for your review and
    inspection the supporting documents and audio recordings."
    However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting
    documents and audio recordings". I wish to have a copy of all such "supporting documents and audio recordings", and failing a
    copy being provided, I wish to be allowed the access to conduct a "review and inspection" of "the supporting documents and
    audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such access. In addition, Mr.
    King now informs me that he has opened a grievance on behalf of Judge Linda M. Gardner, incident to a Order for Sanctions
    she entered in April 2009. Mr. King has refused to indicate to me who submitted this Order for Sanctions or otherwise provided
    it to Bar Counsel as a Complaint or Grievance or otherwise. I believe someone necessarily must file the complaint or
    grievance. Further, I believe I am entitled to know whom that is, and when such was filed. Additionally, Mr. King has, so failed
    to provide a copy or any access to any purported complaint by the City of Reno Marshal's division incident to my accessing
    justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided as much.
    I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord
    tenant hearing set for March 15th, 2012, and further, in response to hostility, retaliation, lies, and threats made by the USPS
    Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12 letter to me,
    was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other, on it by the USPS),
    however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me, but rather, apparently,
    returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for Judge Nash Holmes 3/14/12
    letter to Mr. King, as such, I have no idea what Judge Nash Holmes is referring to when she describes difficulty contacting me
    000683
    (the attempts by Judge Nash Holmes and the RMC apparently did not included either email or fax or a phone call, however....).
    There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from the
    RMC dated 3/14/12) and which mailings it ultimately forwarded on to me (at my then PO BOX 60952, please note, I have a
    new PO BOX, that I intened to keep for a substantial period of time, it is PO BOX 3961, Reno 89505...), such as a 3/13/12
    mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope has 3 yellow
    stickers stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then next sticker
    indicating a hold, and the final sticker atop the stack indicating a forwarding date of 3/28/12....).
    I stayed in a weekly motel for an extended period of time following my November 2011 No Cause eviction from my former
    home law office, and there was difficulties in filing a Change of Address incident to that given that the Address being changed
    from was permanently assigned to a business, a motor lodge. Further, some problem cause Bank of America to temporarily
    deny my attempts to change my address on file online, and rather require that I mail Bank of America a signed letter
    requesting as much, all the way to Florida. That resulted in delays in filing an online Change of Address with the USPS, given
    the USPS demands the online changes be made with one's own debit card, and that they debit card bare the same billing
    address as the location one is filing a change of address from, or else, the USPS, will process such a request, but it will add 7-
    10 days to tohe processing time. I chose that option given mailign a letter to Bank of America in Florida would have taken
    just as long. IN the interim I went to the Golden Valley USPS Station and explained these circumstances and the supervisor,
    beyond calling me a "squatter" in advance of the hearing in RJC REv2011-000374 (and refusing to divulge whom had been
    providing information to them resulting in such a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed
    me that while my Change of Address to my then PO Box 60952 was being processed, my mail would be held at the Golden
    Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the following days, a supervisor
    named Buck Hyde literally assaulted me, and he and two other supervisors there, Terri James and "Ms. Passot" informed me
    they were "Feds" and didn't have to put up with any crap from an attorney related to state laws like NRS 118A.190, though
    they couldn't cite specifically to any section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my
    former home law office at 1422 E. 9th St. #2.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH
    COUGHLIN, ESQ.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 4/17/12 12:42 PM
    To: suzannew@nvbar.org
    Ms. Walters,
    I guess I just don't really understand what that "referral" category is? Is that for the address of
    someone I would refere business to other than myself, or an address for me to have prospective
    clients referred to by the LRIS?
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000684
    From: SuzanneW@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Date: Tue, 17 Apr 2012 19:28:01 +0000
    Hi Zach,
    Did you mean to list your P.O. Box address in 3 areas? If not, please login and update your
    profile again.
    Thanks
    From: Suzanne Walters
    Sent: Tuesday, April 17, 2012 8:03 AM
    To: 'zachcoughlin@hotmail.com'
    Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Not a problem Zach. I will have the website update this week.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 3:55 PM
    To: Suzanne Walters; Patrick King; David Clark; Glenn Machado
    Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Dear Suzanne,
    Thanks...I check the portal and notice that too, sorry I meant to write you back and say
    "nevermind"...I am sorry to have had to change my address so much recently, I know it
    is probably more work for the Bar.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: SuzanneW@nvbar.org
    000685
    To: zachcoughlin@hotmail.com
    Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Date: Mon, 16 Apr 2012 21:44:47 +0000
    That is what we have Zach
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 2:39 PM
    To: Suzanne Walters; support@baralliance.com; renodirect@reno.gov; courtadmin@washoecourts.us;
    courttech@washoecourts.us; joey.hastings@washoecourts.us; joey.orduna@washoecourts.us; craig.franden@washoecourts.us;
    kstancil@washoecounty.us; stuttle@washoecounty.us; rbaker@washoecounty.us
    Subject: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Dear State Bar of Nevada, 2nd Judicial District Court, Reno Justice Court, et al,
    Please let me clarify and or change my recent communication. In my last
    correspondence I made a misstatement based upon my misreading of SCR
    79. Please allow me to correct that. My preferred mailing address and my
    SCR 79 address should be the same, as listed directly below:
    Zach Coughlin, Esq.
    PO BOX 3961
    Reno, NV 89505
    Tel: 775 338 8118
    Fax: 949 667 7402
    email: ZachCoughlin@hotmail.com
    website: www.ZachCoughlinEsq.wordpress.com
    please make all the above information my preferred mailing address and
    publicly available.
    As for any alternate mailing address, please change that to:
    Zach Coughlin, Esq.
    945 W. 12th St.
    Reno, NV 89503
    I will attempt to make these changes myself at the "portal" found at
    www.nvbar.org in the member section, however, I am contacting you now in
    an abundance of caution.
    000686
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax:
    949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    Mr. King's assertion in his 3/16/12 letter
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/16/12 5:41 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Dear Bar Counsel,
    One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years
    stole about 2 months worth of my portion of our rent from me (our arrangement was I would give her
    the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed
    a great deal and paid lots of her tuition, and she broke up with me and moved out on or around May
    18th, 2011, about 3 days after we hosted her entire family for her graduation from UNR. I did not
    know about her stealing my portion of the rent or failing to pay her own portion until August 2011, as
    the landlord was on an extended vacation and failed to communicate any deficiency in the rent until
    mid-August, 2011, and the eviction in RJC REV2011-001708 from my former home law office ensued
    within less than a week of his communicating this deficiency. He and his counsel, Richard G. Hill, Esq.
    and Casey Baker pursued a No Cause Notice of Eviction because there was a wealth of support for me
    contention that habitability issues, fix and deduct, and the landlord's failure to cure, in addition to
    personal property damage done by the landlord's landscaping crew and a provision in the lease holding
    the landlord liable for such, indicated it would "be the path of least resistance" to simply seek a No
    Cause Eviction. The only problem in their attempt to circumvent the law (even though they still
    threatened to seek back rent in another forum after getting their No Cause, summary eviction) was the
    fact that the Lease Agreement specifically allowed for me to have a commercial law office there, and
    NRS 40.253 makes impermissible a summary eviction against a commercial tenant unless the non-
    payment of rent is Notice, which, of course Baker and Hill chose not to do....and it was about the time
    that Hill started to understand that his "wrong site surgery" for his neurosurgeon landlord client might
    subject Hill and his firm to some malpractice liability, that Hill started writing letters to bar counsel
    attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable when
    Gessin was Hill's client and Hill was milking over $20K from Gessin) for "ghostwriting" even though I
    was listed as Attorney of Record on several different Gessin cases, etc., etc.
    Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and
    whoever else has filed a grievance or complaint and also with respect to any criminal charge against
    me, including that which resulted in a conviction in 11 CR 22176, which, I think will ultimately reveal
    was replete with prosecutorial misconduct, lying by the Wal-Mart loss prevention associate, and lying by
    the two RSIC police officers, in additional to abuse of discretion and other errors by Judge Howard.
    000687
    I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was
    sent. The postmark on that 3/16/12 letter from Assistant Bar Counsel King (please see attached picture
    of the letter and envelope) indicates it was mailed 3/16/12, and the letter indicates it was not faxed to
    me (despite my numerous written requests that such a practice be done in consideration of the
    problems I have encountered in the USPS violations of the Federal Torts Claims Act and incident to the
    domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which included
    interference with my mail).
    I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances
    at both the Golden Valley USPS Station and the Downtown Reno Post Office in and attempt to make
    every diligent effort to receive my mail. I have been threatened by and lied to by the supervisors of
    the Golden Valley Station USPS Station. I had a hearing related to a landlord tenant dispute on 3/15/12
    (which makes Judge Nash Holmes assertion, in her 3/14/12 letter that I was living in my car at that
    time rather suspect, given my home law office was located at the property which was the subject of
    that hearing and which I was still located at on 3/14/12...of course, Judge Nash Holmes provides no
    attribution for such hearsay in her extremely reckless assertion) in RJC REV2012-00374 (the matter for
    which Gayle Kern sent a property manager who lacked even a law license to litigate on her behalf, or
    on that of the HOA which Kern has now decided to appear for, despite her being listed a the PTTHOA
    Resident Agent for sometime and despite Kern being a named party in the lawsuit in RJC Rev2012-
    000374.
    My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am
    requesting more time to respond to it. Additionally, I note that Mr. King, in that 3/16/12 letter, writes
    "I am enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an
    Order from District court....I will make available for your review and inspection the supporting
    documents and audio recordings."
    However, as I have previously written, Mr. King has not made "available for (my) review and inspection
    the supporting documents and audio recordings". I wish to have a copy of all such "supporting
    documents and audio recordings", and failing a copy being provided, I wish to be allowed the access to
    conduct a "review and inspection" of "the supporting documents and audio recordings" that Mr. King
    promised to afford me. At no time has Mr. King ever allowed me such access. In addition, Mr. King
    now informs me that he has opened a grievance on behalf of Judge Linda M. Gardner, incident to a
    Order for Sanctions she entered in April 2009. Mr. King has refused to indicate to me who submitted
    this Order for Sanctions or otherwise provided it to Bar Counsel as a Complaint or Grievance or
    otherwise. I believe someone necessarily must file the complaint or grievance. Further, I believe I am
    entitled to know whom that is, and when such was filed. Additionally, Mr. King has, so failed to provide
    a copy or any access to any purported complaint by the City of Reno Marshal's division incident to my
    accessing justice, or attempting to, on March 22nd, 2012. I am again requesting that I be so provided
    as much.
    I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address
    incident to a landlord tenant hearing set for March 15th, 2012, and further, in response to hostility,
    retaliation, lies, and threats made by the USPS Golden Valley Station supervisors Buck Hyde, Terri
    James, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12 letter to me, was eventually forwarded
    to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other, on it by the USPS),
    however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me, but
    rather, apparently, returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC
    in time for Judge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what Judge Nash
    Holmes is referring to when she describes difficulty contacting me (the attempts by Judge Nash Holmes
    and the RMC apparently did not included either email or fax or a phone call, however....).
    There has been little rhyme or reason as to what mailings the USPS simply returned to the sender
    (such as a mailing from the RMC dated 3/14/12) and which mailings it ultimately forwarded on to me
    (at my then PO BOX 60952, please note, I have a new PO BOX, that I intened to keep for a substantial
    period of time, it is PO BOX 3961, Reno 89505...), such as a 3/13/12 mailing from the Reno Justice
    Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope has 3 yellow stickers
    000688
    stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then
    next sticker indicating a hold, and the final sticker atop the stack indicating a forwarding date of
    3/28/12....).
    I stayed in a weekly motel for an extended period of time following my November 2011 No Cause
    eviction from my former home law office, and there was difficulties in filing a Change of Address
    incident to that given that the Address being changed from was permanently assigned to a business, a
    motor lodge. Further, some problem cause Bank of America to temporarily deny my attempts to
    change my address on file online, and rather require that I mail Bank of America a signed letter
    requesting as much, all the way to Florida. That resulted in delays in filing an online Change of
    Address with the USPS, given the USPS demands the online changes be made with one's own debit
    card, and that they debit card bare the same billing address as the location one is filing a change of
    address from, or else, the USPS, will process such a request, but it will add 7-10 days to tohe
    processing time. I chose that option given mailign a letter to Bank of America in Florida would have
    taken just as long. IN the interim I went to the Golden Valley USPS Station and explained these
    circumstances and the supervisor, beyond calling me a "squatter" in advance of the hearing in RJC
    REv2011-000374 (and refusing to divulge whom had been providing information to them resulting in
    such a prejudicial view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my
    Change of Address to my then PO Box 60952 was being processed, my mail would be held at the
    Golden Valley Station and that I could retrieve it there for the next 7-10 days. When I returned in the
    following days, a supervisor named Buck Hyde literally assaulted me, and he and two other supervisors
    there, Terri James and "Ms. Passot" informed me they were "Feds" and didn't have to put up with any
    crap from an attorney related to state laws like NRS 118A.190, though they couldn't cite specifically to
    any section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former
    home law office at 1422 E. 9th St. #2.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH
    COUGHLIN, ESQ.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/16/12 3:55 PM
    To: suzannew@nvbar.org; patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Dear Suzanne,
    Thanks...I check the portal and notice that too, sorry I meant to write you back and say
    "nevermind"...I am sorry to have had to change my address so much recently, I know it
    is probably more work for the Bar.
    Sincerely,
    000689
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: SuzanneW@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Date: Mon, 16 Apr 2012 21:44:47 +0000
    That is what we have Zach
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 16, 2012 2:39 PM
    To: Suzanne Walters; support@baralliance.com; renodirect@reno.gov; courtadmin@washoecourts.us;
    courttech@washoecourts.us; joey.hastings@washoecourts.us; joey.orduna@washoecourts.us; craig.franden@washoecourts.us;
    kstancil@washoecounty.us; stuttle@washoecounty.us; rbaker@washoecounty.us
    Subject: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHLIN, ESQ.
    Dear State Bar of Nevada, 2nd Judicial District Court, Reno Justice Court, et al,
    Please let me clarify and or change my recent communication. In my last
    correspondence I made a misstatement based upon my misreading of SCR 79. Please
    allow me to correct that. My preferred mailing address and my SCR 79 address should
    be the same, as listed directly below:
    Zach Coughlin, Esq.
    PO BOX 3961
    Reno, NV 89505
    Tel: 775 338 8118
    Fax: 949 667 7402
    email: ZachCoughlin@hotmail.com
    website: www.ZachCoughlinEsq.wordpress.com
    please make all the above information my preferred mailing address and publicly
    available.
    As for any alternate mailing address, please change that to:
    Zach Coughlin, Esq.
    945 W. 12th St.
    000690
    Reno, NV 89503
    I will attempt to make these changes myself at the "portal" found at
    www.nvbar.org in the member section, however, I am contacting you now in
    an abundance of caution.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949
    667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH
    COUGHLIN, ESQ.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/16/12 2:38 PM
    To: suzannew@nvbar.org; support@baralliance.com; renodirect@reno.gov;
    courtadmin@washoecourts.us; courttech@washoecourts.us; joey.hastings@washoecourts.us;
    joey.orduna@washoecourts.us; craig.franden@washoecourts.us; kstancil@washoecounty.us;
    stuttle@washoecounty.us; rbaker@washoecounty.us
    Dear State Bar of Nevada, 2nd Judicial District Court, Reno Justice Court, et al,
    Please let me clarify and or change my recent communication. In my last
    correspondence I made a misstatement based upon my misreading of SCR 79. Please
    allow me to correct that. My preferred mailing address and my SCR 79 address should
    be the same, as listed directly below:
    Zach Coughlin, Esq.
    PO BOX 3961
    Reno, NV 89505
    Tel: 775 338 8118
    Fax: 949 667 7402
    email: ZachCoughlin@hotmail.com
    000691
    website: www.ZachCoughlinEsq.wordpress.com
    please make all the above information my preferred mailing address and publicly
    available.
    As for any alternate mailing address, please change that to:
    Zach Coughlin, Esq.
    945 W. 12th St.
    Reno, NV 89503
    I will attempt to make these changes myself at the "portal" found at
    www.nvbar.org in the member section, however, I am contacting you now in
    an abundance of caution.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949
    667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    official change of address form attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 4/14/12 2:13 PM
    To: suzannew@nvbar.org
    1 attachment
    scr 79 state bar change of address form for suzannew@nvbar.org.pdf (57.2 KB)
    Dear Suzanne,
    Please find attached my SCR 79 form.
    Sincerely,
    000692
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    Please see attached
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 4/13/12 3:46 PM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    1 attachment
    4 12 12 fax to Bar Counsel State Bar of Nevada.pdf (147.3 KB)
    Zach Coughlin, Esq.
    Nevada Bar No: 9473
    PO Box 3961
    RENO, NV 89505
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    PLEASE NOTE THE NEW CHANGE OF ADDRESS ABOVE
    THIS IS A FREEDOM OF INFORMATION ACT REQUEST (FOIA) AND
    A REQUEST MADE PURSUANT TO THE NEVADA OPEN RECORDS
    LAW UNDER NRS 239
    http://sunshinereview.org/index.php/Nevada_FOIA_procedures
    TO: David Clark, Esq., Patrick King, Esq., Glenn Machado, Esq.
    State Bar of Nevada Bar Counsel
    sent via email to: PatrickK@nvbar.org, GlennM@nvbar.org, and ClarkD@nvbar.org
    and via fax, ATTN BAR COUNSEL to 702 385 2878 and 775 329 0522
    000693
    PLEASE NOTE THE NEW CHANGE OF ADDRESS ABOVE
    April 12, 2012
    Dear Bar Counsel,
    I am writing to formally request a copy of the materials provided to the State Bar of Nevada in connection with
    any and all grievances filed against me. I believe I have a right to all materials submitted in connection with any
    grievance, not just excerpts of the materials. Further, these grievances, particularly that filed by Judge Nash
    Holmes, are complicating currently pending court proceedings, particularly to the extent that Judge Nash Holmes
    purports to speak on behalf of all three other RMC judges, in addition to judge pro tempores (I have no idea whom
    she is referring to in that regard). Further Judge William Gardner of the RMC is the brother of Judge Linda
    Gardner of the Second Judicial District Court. While in court last week, Judge William Gardner indicated he
    could not recall if he had seen Judge Nash Holmes' grievance letter relating to me, which she supplied to the State
    Bar of Nevada. Judge William Gardner's memory did serve him to relate that, indeed, his sister, Judge Linda
    Gardner, recently forward to him, which he forwarded to the other RMC Judges, a copy of Judge Linda Gardner's
    Order for Sanctions against me in April of 2009. Bar Counsel Patrick King has refused to indicate to me whom
    submitted to the State Bar of Nevada Judge Linda Gardner's Order for Sanctions, and therefore, it is entirely
    unclear as to how an entire grievance, with its own case number could be opened respecting Judge Linda
    Gardner's Order for Sanctions, particularly given I have been supplied no grievance letter purporting to open a
    complaint or grievance in relation to that April 2009 Order for Sanctions.
    Please note I have a new SCR 79 Public Address and a new PO BOX that I have identified as my preferred
    mailing address. I have attempted to make these changes via the Portal at www.nvbar.org, but the
    website is not allowing me to make them. Please accept this writing as a communication meant to effect such
    changes.
    My SCR 79 Address should be:
    Zach Coughlin, Esq.
    945 W. 12
    th
    St.
    Reno, NV 89503
    My preferred mailing address and PO BOX address should be:
    Zach Coughlin, Esq.
    PO Box 3961
    Reno, NV 89505
    My publicly listed telephone number should be 775 338 8118.
    My publicly listed fax should be 949 667 7402.
    I would like a complete, signed, copy of all the grievances filed against me, and any other similar style written or
    oral complaints (including those Mr. King eludes to from March 22, 2012 of the Reno Marshals for the RMC). I
    am requesting a complete copy of any an all material submitted along with those grievances or complaints, again.
    I would like an indication, in writing, from Bar Counsel as to when I must respond to each of the various
    complaints and or grievances by. I do not believe Hill's grievance should be treated as official at this point given
    he failed to sign it and further, he lacks standing to make the complaints that he makes. Additionally, Judge Nash
    000694
    Holmes lacks standing to purport to speak on behalf of all other RMC Judges, in addition to unnamed Judge Pro
    Tempores. I ask for a written indication from Bar Counsel as to whether or not such deficiencies prevent any such
    correspondences from appropriately being deemed grievances calling for any response on my part.
    Judge William Gardner has now refused to recuse himself from a case wherein I am a party, despite receiving
    materials about me from his sister, despite his being employed by the Reno City Attorney's office as recently as
    2010 (I have currently pending litigation against the Reno City Attorney's Office and or litigation which is
    reasonably likely to arise in the near future), and despite Judge Nash Holmes filing a grievance with the State Bar
    of Nevada (apparently in response to prompting from Bar Counsel Patrick King, as she apologies for "taking two
    days to get you the materials you requested" in a letter to Mr. King) wherein Judge Nash Holmes purports to file
    that grievance on behalf of, amongst others, RMC Judge William Gardner.
    I have submitted both a FOIA and a Nevada Open Records Law request to the State Bar of Nevada for copies of
    all materials supplied to the State Bar and Bar Counsel in connection with these "grievances" and have had my
    requests denied and or they have gone unresponded to. Further,returned to me only 7 days after the RMC's
    3/30/12 Order requiring as much (meaning my personal property, including a cell phone, a smart phone, an
    electric shaver, and a 32gb micro sd card) by way of the WCSO, with all data deleted or otherwise made
    inaccesible was a 32gb micro sd card that Judge Nash Holmes and the City of Reno Marshal seized from me
    incident to what certainly appears to be a pretextual arrest allowing them to conductd a search incident to arrest in
    connection with my cross examination of Reno Police Department Sargent Tarter concerning RPD Officer Chris
    Carter admitting that Richard G. Hill, Esq. was bribing him (Hill filed the initial bar grievance against me and Bar
    Counsel King, despite have a published decision of the Nevada Supreme Court in Carstarphen v. Milsner from
    March 2012 in which Mr. Hill was opposing counsel and despite Mr. King's previous shared employment with
    current Reno City Attorney Dan Wong (Wong and King worked for the Attorney General's Office at the same
    time, despite all that Mr. King failed to disclose any such potential conflict and apparently remains on this matter)
    http://law.justia.com/cases/nevada/supreme-court/2012/51631.html
    I have been provided no date by which I must file my response to any of these grievances, save perhaps a date for
    responding to the Hill grievance However, the Hill grievance purported to implicate matters which necessitated
    seeking clarification from Bar Counsel with regard to whether the pendency of a criminal proceeding or prior
    reporting to other Bar Counsel divested Mr. King of jurisdiction to conduct an inquiry. Mr. King failed to respond
    to such request.
    I have currently pending or anticipated litigation against the United States Postal Service in connection with the
    malfeasance of Golden Valley Station Postal Supervisors Terri James, Buck Hyde, and "Ms." Passot and their
    violations of the Federal Tort Claims Act. I have filed an Official USPS Change of Address and have received
    some mail to the PO BOX 60952. However, Judge Nash Holmes and Judge Gardner recently have informed me in
    court that the RMC received returned as undeliverable several orders the RMC had attempted to send me Buck
    Hyde, a woman whose last name is Passot, and Terri James of the Golden Valley Station USPS post office made
    threatening and retaliation commentary to me with regard to my mail, maintaining that they are feds and
    therefore need not put up with your garbage, in response to my inquiries related to the access to the mailbox at
    1422 E. 9
    th
    St. #2, a place where I was lawfully entitled to be located at. Gayle Kern, Esq., is not violating NRCP
    Rule 11 in REV RJC 2012-000374 by attempting to classify me as a squatter there (something these USPS
    employees were saying prior to any judicial determination in that regard), despite the fact that the property
    management company that Ms. Kern's client, Park Terrace Townhomes Association employes, Western Nevada
    000695
    Management, was forced to admit under oath that the individuals whom entered a rental agreement with me, and
    against whom I have been awarded Orders of Protection in FV12-00188, and FV12-00187, Christopher Allaback
    and Laura Foreshee, were, in fact, given express approval to inhabit that townhome by both Robyn Batalado, then
    a manager at Western Nevada management and by the Park Terrace Townhome's Home Owner's Association
    (PTTHOA), in exchange for carpentry work, keeping on the utilities, and the benefit of a lessened insurance
    premium attendant to such a unit not being vacant. Whether or not those individuals entered a subtenancy with
    me, or whether any lease they entered with me (118A.160 holds that leases, in Nevada, may be either written or
    oral, but don't tell that to the USPS Golden Valley Station supervisors, as they are feds and don't have to follow
    your stupid state laws, duh) was entered into on behalf of either Western Nevada management or PTTHOA or
    Gayle Kern, LTD, is a matter for the justice courts to determine, unless the amount in controversy exceeds
    $10,000, in which case, the Justice Court and the District Court have jurisdictional disputes that seem to lack a
    clear resolution at this point.
    Regardless, Ms. Kern's recent argument in her Opposition to my Motion to Alter or Amend the Order of
    Summary Eviction in RJC Rev2012-000374, deserve a bar grievance. Ms. Kern and or her client PTTHOA sent
    an individual without a law license, Sue King, owner and manager of Western Nevada Management to two
    different hearings to practice law on behalf of Gayle Kern, LTD and PTTHOA, in addition to on behalf of
    Western Nevada management. This is the unauthorized practice of law. Further, Ms. Kern is held to know what
    her own agents, the secretary for the PTTHOA (Becci, I believe is her name) and Sue King, Owner and Operator
    of Western Nevada Management testified to as to the express approval provided to my former housemates and
    domestic abusers Christoper Erin Ervin Allaback and Laura Foreshee (ne Petrone, and more recently, ne
    Harrison) allowing them to inhabit that particular townhome for over 8 months prior to my moving in to it.
    Further, Kern is now persisting with this eviction under an eviction Notice that was No Cause, only to, the day of
    the hearing, file an affidavit that indicates it was a Non Payment of Rent eviction. This is clearly an attempt to get
    around the prohibition against using summary eviction procedures against a commercial tenant (which I was,
    given the location was my home law office, a permissible professional home office use exception to any
    applicable zoning laws) and the delay which would have been attendant to correcting the deficient original
    Eviction Notice. This letter constitutes and official grievance and complaint against Gayle Kern, Esq., and Gayle
    Kern, LTD. Robyn Batalado, was the PTTHOA for Western Nevada management whom received express approval
    form the PTTHOA Board of Directors to have Allaback and Foreshee inhabit that townhome in exchange for
    some form of consideration. To the extent the consideration was not a monetary rental payment, the summary
    eviction procedures under NRS 40.253 are impermissibly applied in like of the Glazier v Justice Court ruling of
    the Nevada Supreme Court. Both Kern and Hill have violated RPC 3.4. Further, Hill purposefully filed what he
    believes to be my social security number is a very short filing with the RJC (something for which Hill and Baker
    actually received sanctions on John Gessin's behalf in the cases involving Glade Hall, Esq.). This is a violation of
    state law and clearly a hostile act by Richard Hill.
    Hill's allegation with respect to any service issues, and and inability of Bar Counsel or the Court's to send mail to
    me, or for me to receive such mail, necessarily implicates those matters, in addition to the interference with my
    mail by those against whom I was awarded Orders of Protection in FV12-00188 and FV12-00187, my former
    housemates. I demonstrated a great deal of diligence in attempting to maintain a viable mailing address, inform
    courts and Bar Counsel of these issues, and maintain client contact. I have proof of my filing official Changes of
    Address and alerting opposing counsel and the court's of the same.
    I suspect Bar Counsel King is coyly refusing to tell me if he has received any mail as "undeliverable" or some
    other similar designation that he has attempted to send to me.
    000696
    I
    I am formally requesting that Bar Counsel inform me, in writing, via fax or email (at the email and fax listed
    below and on my official contact information page as listed at www.nvbar.org) as to the existence of
    any undelivered mail that the State Bar of Nevada has had returned to it after sending it to me.
    wish to pick such mail up immediately and to retain all of my rights to respond to any such
    grievance or notice of the State Bar of Nevada. PLEASE NOTE MY NEW PO BOX CHANGE OF
    ADDRESS ATOP THIS LETTER. PLEASE SEND ANY PAST MAILINGS THAT WERE
    RETURNED AS UNDELIVERABLE TO THAT ADDRESS, IN ADDITION TO COPYING ME
    ON THEM VIA FAX AND EMAIL AND PLEASE SEND ALL FUTURE MAILINGS TO THIS
    NEW PO BOX ATOP THIS CORRESPONDENCE.
    In the following cases the courts took the view that, under the particular disciplinary rules
    of the jurisdiction, the attorney's failure to co-operate with disciplinary authorities does not
    constitute an independent ground for disciplining counsel. Okla State ex rel. Oklahoma Bar Ass'n v Adams (1995,
    Okla) 895 P2d 701
    Although rejecting an attorney's assertion in a disciplinary proceeding that the constitutional
    privilege not to be a witness against himself applied since the attorney made no assertion
    that his response to a question in the proceeding could be used against him in a criminal
    prosecution, the court, in Re Geurts (1980) 290 Or 241, 620 P2d 1373, held that the accused's
    failure to respond to the bar's inquiries did not constitute grounds for discipline where the bar
    did not show what legal or disciplinary rule the accused violated by failing to respond to the
    bar's inquiry. The disciplinary review board had found that the accused's only response to
    three letters requesting a response to a client's complaint was a telephone call stating that he
    had mailed a reply and would send a copy of it. When no copy was received, the bar appoin-
    ted an investigator who was informed by the accused that he would furnish him with either a
    copy of the original letter or a new letter outlining the substance of the original letter. As the
    investigator would not accept a new letter and the accused testified that he did not keep office
    copies of his letters, the attorney stated that he felt there was no purpose in replying to the investigator
    and hence did not reply. Stating that it did not imply approval of nonco-operation
    with the process of investigation into complaints about a lawyer's professional conduct, the
    court reasoned that if nonco-operation itself is to be made a ground for imposing a disciplinary
    penalty, the rules of professional discipline must give fair notice of the terms and limits of
    the obligation and that they did not do so at the present time.
    Although the disciplinary review board recommended a 30-day suspension based on the
    000697
    attorney's neglecting a legal matter entrusted to him by failing to proceed in a dissolution of
    marriage and failing to respond to the bar's inquiries, the court, in Re Conduct of Rudie (1981)
    290 Or 471, 622 P2d 1098, held that the appropriate discipline was a public reprimand where
    notwithstanding the court's express disapproval of the attorney's failure to respond to the bar's
    inquiries, that failure was not itself clearly condemned by a disciplinary rule, independent of
    what bearing it might have on the matter under inquiry. It noted that the attorney failed to respond
    to inquiries from the bar in four disciplinary matters, and that he stipulated to the accusations
    subject to the extenuating reason that his parents were killed in an airplane crash leaving
    him too preoccupied with family affairs and emotionally incapacitated to function effectively
    in his practice.
    In a later proceeding involving the same attorney disciplined in Re Conduct of Rudie
    (1981) 290 Or 471, 622 P2d 1098, supra, recognizing that although the failure to respond by
    making an answer or appearance to disciplinary charges may not have been a violation of the
    disciplinary rules, the court held, in Re Conduct of Rudie (1983) 294 Or 740, 662 P2d 321,
    that it demonstrated a lack of an important element of professionalism and that the disciplinary
    review board did not draw an unwarranted inference from the accused's failure to appear
    in the disciplinary proceedingsthat is, that it showed that the accused's problems with being
    able to accord his conduct with the requirements of the code of professional conduct were of a
    "more serious nature." The court ordered that the attorney be suspended for 7 months and until
    reinstatement on an affirmative showing of fitness to be readmitted where he was found to
    have, inter alia, conducted representation of his clients without preparation adequate under the
    circumstances, intentionally failed to carry out a contract of employment, and neglected a legal
    matter.
    Holding that an attorney's refusal to co-operate with the ethics committee cannot be used
    as an independent assignment of cause of discipline, the court, in Committee on Legal Ethics
    of West Virginia State Bar v Mullins (1976) 159 W Va 647, 226 SE2d 427, ordered the indefinite
    suspension of an attorney who failed to perform the services for which he had been employed
    and misled his clients as to his activities in their behalf, but rejected the committee's
    determination that his lack of co-operation with the ethics committee should be interjected as
    000698
    a charge against him. The committee had found that he failed to respond to all communications
    from the offices of the executive director of the state bar and the chairman of the committee
    on legal ethics and failed to appear, answer, or otherwise respond to the charges against
    him. The court stated that the attorney in a disciplinary proceeding has an absolute right to react
    to charges against him as to be considered uncooperativethat is, he may make a defense,
    employ counsel, testify, or refuse to do any of the former. The court noted that such unco-
    operative attitude toward the ethics committee is undertaken at the attorney's peril, and may
    compel the committee to accept as true all allegations of fact on which a complaint is based.
    However, the court observed that an attorney may conduct himself in a disciplinary proceeding
    in a manner that he deems to be proper, and his manner of doing so cannot be used as an
    independent basis for discipline.
    CUMULATIVE SUPPLEMENT
    Cases:
    Allegations in petition by Director of Office of Lawyers Professional Responsibility for
    temporary suspension of attorney's license to practice law, which alleged that attorney had
    failed to cooperate with Director's further investigation and that attorney's failure to cooperate
    had prevented Director from implementing probation, were deemed admitted, and thus temporary
    suspension of attorney who had previously been placed on probation was warranted,
    where attorney failed to answer Director's petition for temporary suspension. 52 M.S.A., Lawyers
    Prof. Resp., Rule 16(c). In re Disciplinary Action Against Jellinger, 632 N.W.2d 640
    (Minn. 2001).
    Attorney could not be sanctioned for failure to cooperate with county bar association's disciplinary
    processes, where attorney was not member of voluntary county bar association and
    state attorney general had not requested assistance by association. State ex rel. Oklahoma Bar
    Ass'n v Bolton (1994, Okla) 880 P2d 339.
    In disciplinary proceeding, attorney's failure to cooperate with grievance committee in its
    investigative procedures concerning filed complaints received from individual citizens was
    not separate, independent ground for disciplinary action, but could be considered in determining
    000699
    punishment. State v Malone (1985, Tex App Beaumont) 692 SW2d 888, later app (Tex
    App Beaumont) 720 SW2d 842.
    Attorney's neglect of multiple clients' immigration matters, including failing to file applications
    and failing to keep clients informed of status of cases, together with his failing to
    promptly furnish a written response to disciplinary counsel requests, warranted two-year suspension
    from the practice of law; aggravating factors were not sufficiently egregious, nor were
    mitigating factors sufficiently compelling to justify departure from presumptive sanction of
    disbarment, but presumptive sanction of disbarment was disproportionate to misconduct in
    light of prior disciplinary decisions involving similar misconduct. RPC 1.3, 1.4(a, b), 1.5(a),
    1.15(d); RLD 2.8. In re Disciplinary Proceeding Against Anschell, 141 Wash. 2d 593, 9 P.3d
    193 (2000).
    Rule that disciplinary action may not be ordered for invoking right against selfincrimination
    [Cumulative Supplement]
    In the following cases the court held or recognized that disbarment or other disciplinary
    action against an attorney may not be ordered for properly invoking the attorney's right
    against self-incrimination.US
    Spevack v Klein (1967) 385 US 511, 17 L Ed 2d 574, 87 S Ct 625
    Del
    Re Kennedy (1982, Del Sup) 442 A2d 79
    Ill
    Re Zisook (1981) 88 Ill 2d 321, 58 Ill Dec 786, 430 NE2d 1037, 30 ALR4th 228, cert
    den 457 US 1134, 73 L Ed 2d 1352, 102 S Ct 2962 (apparently recognizing rule)
    Mich
    Sternberg v State Bar of Michigan (1971) 384 Mich 588, 185 NW2d 395 (recognizing
    rule)
    Miss
    Mississippi State Bar v Attorney-Respondent in Disciplinary Proceedings (1979, Miss)
    367 So 2d 179 (recognizing rule)
    000700
    Wis
    State v Postorino (1972) 53 Wis 2d 412, 193 NW2d 1 (recognizing rule)
    Thus, reversing an order of disbarment, the United States Supreme Court held, in Spevack
    v Klein (1967) 385 US 511, 17 L Ed 2d 574, 87 S Ct 625, that an attorney who, in reliance on
    the privilege against self-incrimination, refused to testify and refused to produce records demanded
    at a proceeding to discipline him for professional misconduct is not subject to disbarment,
    since the self-incrimination clause of the Fifth Amendment forbids the imposition of
    disbarment as the penalty for remaining silent. The court noted that the self-incrimination
    clause of the Fifth Amendment applies to the states, and therefore to state proceedings,
    through the Fourteenth Amendment. It explained that under the self-incrimination clause of
    the Fifth Amendment, a person has the right to remain silent without suffering any penalty for
    such silence, stating that "penalty" in this context means the imposition of any sanction that
    makes assertion of the Fifth Amendment privilege "costly." The court observed that the threat
    of disbarment and a loss of professional reputation and standing are powerful forms of compulsion
    to make a lawyer relinquish the privilege against self-incrimination. It added that lawyers
    are not excepted from the words "no person shall be compelled in any criminal case to be
    a witness against himself."[17]
    In Mississippi State Bar v Attorney-Respondent in Disciplinary Proceedings (1979, Miss)
    367 So 2d 179, although recognizing the rule in Spevack v Klein (1967) 385 US 511, 17 L Ed
    2d 574, 87 S Ct 625, supra, that an attorney may not be disbarred simply because he made a
    valid assertion of the privilege against self-incrimination, the court held that a disciplinary
    proceeding does not require blanket immunity as in a criminal case, but nevertheless, having
    taken the witness stand, the attorney may, on a question-by-question basis, make valid assertion
    of the Fifth Amendment privilege as to those questions that would tend to incriminate
    him of a state or federal criminal offense. The court reasoned that a disciplinary proceeding,
    while concededly having penal elements, is not a criminal case and that an attorney, unlike in
    a criminal case, may be compelled to appear and take the witness stand.
    CUMULATIVE SUPPLEMENT
    000701
    Cases:
    Privilege against self-incrimination extends to attorneys, and attorney may not be disbarred
    for invoking privilege in Bar disciplinary proceedings. U.S.C.A. Const. Amend. 5.
    State v. Spiegel, 710 So. 2d 13 (Fla. Dist. Ct. App. 3d Dist. 1998), reh'g denied, (June 10,
    1998) and review denied (Fla. Nov. 18, 1998).
    One-year suspension was warranted for attorney who failed to pursue legal matter on behalf
    of client and failed to respond to disciplinary authorities. State Bar Rules and Regulations,
    Rule 4102(b), Standards 44, 68. In re Zoota, 272 Ga. 496, 532 S.E.2d 107 (2000).
    Protection against self-incrimination did not apply to, and thus did not excuse, attorney's
    failure to comply with request by State Lawyers Assistance Committee (SLAC) that attorney,
    his personal physician, and SLAC member meet to develop alcohol dependency treatment
    plan for attorney; no incrimination would have occurred, as participation in alcohol dependency
    treatment would not be admissible in attorney disciplinary proceeding, and such proceeding
    would not be criminal proceeding. U.S.C.A. Const. Amend. 5; Const. Art. 1, 12;
    ORS 9.545; Code of Prof. Resp., DR 1-103(F). In re Conduct of Wyllie, 326 Or. 622, 956
    P.2d 951 (1998).
    Defending Lawyers in Disciplinary Proceedings, 31 AMJUR TRIALS 633:
    24. The role of retained counsel; in generalNegotiations with bar counsel
    Quite often bar counsel will be a well-known practicing attorney with a large, prominent law
    firm, that is, an attorney who can afford to take time off for bar-related activities. He is likely to be
    middle-aged, wealthy, conservative, and quite busy with his own private practice. He is also unlikely
    to be sympathetic to an unrepresented accused attorney, and will find it difficult to understand the
    problems of young, sole practitioner, for he customarily represents corporate clients, insurance
    companies,
    and banks. He will probably do no divorce or criminal work, and he is likely to be highly specialized
    in his own practice.[31] His goal will be to dispose of the matter as painlessly and as quickly
    as possible, and he will resent lack of cooperation or a hostile attitude. By the time retained counsel
    enters the case, the accused attorney may have had two or three bitter confrontations with this
    attorney,
    and he may have given him no cooperation nor shown any contrition. The attitude of the investigating
    attorney is likely to be guarded, if not hostile.[32]
    The considerable powers of bar counsel should be understood: he has the authority to file formal
    charges and set the case for hearing, or he may dispose of it without further investigation. He may sit
    on a case indefinitely, or he can see that it is thoroughly prosecuted, even getting assistance of the
    attorney
    000702
    general's office or the local district attorney. Indeed, occasionally bar counsel may coordinate
    his efforts with the local United States Attorney or district attorney for the purpose of prosecuting a
    particular attorney for perjury or for some breach of fiduciary duty. He may even suggest to the
    district
    attorney that the case be presented to a grand jury.
    It is therefore obvious that early in the case, retained counsel must communicate, in a friendly
    way with the committee's attorney. He should first determine whether the client has offended him and
    make necessary apologies, although this courtesy will not always fall on receptive ears. If bar counsel
    is irreversibly opposed to the client because of personal animosity, however, he may be amenable to
    replacement by another attorney. This should be requested in a tactful way.
    As a general rule, the committee's counsel will be pleased to suggest prompt methods of settlement.
    If he makes specific suggestions, they should be complied with if at all possible. This is true
    even where they resolve doubts in matters of equity in favor of the complainant. The investigator has
    the power to see that his wishes are enforced. Concrete steps should be proposed and efforts made to
    determine the bar counsel's attitude toward possible rehabilitation through Alcoholics Anonymous or
    psychotherapy treatment or whatever is appropriate of a medical or educational nature.
    Everything that should obviously be done should be done promptly. For example, if a refund of a
    few hundred dollars is clearly in order, it should be done speedily. It is wise to coordinate such
    efforts
    with the committee's staff personnel.
    Sometimes a proposed written agreement for an immediate specific refund, or attendance at ethics
    seminars or remedial courses, to be completed within a given period of time, will be favorably
    received.
    Trickery or failing to live up to agreements made are almost certain to have bad results.
    Therefore it is particularly important that any restitution promised be promptly paid. Occasionally,
    the curative action is simplicity itself, and a request for a letter of apology to the complainant or the
    immediate turning over of a file to substitute counsel should be promptly complied with. However,
    the most important points to make with the investigating bar attorney, where there is no defense
    under
    the facts of the case, are contrition, cooperation, and corrective measures.
    There will be cases, however, where the client has committed no wrongful act and is innocent. It
    should be explained to the bar attorney that innocence will be the defense and that it will be
    vigorously
    pursued. Weaknesses in the complainant's case, his or her past criminal or psychiatric history
    should be pointed out, and an inquiry made as to what steps are necessary to settle the matter under
    those circumstances.
    In some jurisdictions, the investigating bar attorney is a full-time employee of the state bar
    association,
    the attorney general's office or an employee of the local judicial district. The approach in that
    case will probably be somewhat different. Whereas the committee member participating in the
    investigation
    is seldom compensated for his work, counsel employed by a state bar association or the attorney
    general's office always is. The only exception would be a "special prosecutor" appointed to
    handle a particular, and usually quite spectacular, case. This is rare, but when it does occur, it usually
    involves a political figure or a judge.
    An investigating attorney who is employed full time to investigate and prosecute grievances will
    000703
    be harder to deal with. He is less likely to be sympathetic to the accused attorney, particularly if he
    has a record of prior disciplinary action. Nonetheless, most of these grievance committee prosecutors
    have more than enough work, and they tend to concentrate their efforts on the worst offenders, those
    who have been least cooperative, or those who have offended them.
    Retained counsel can expect closer cooperation with federal criminal or state and local district
    attorney
    investigators if the investigating committee attorney is a state or bar association employee.
    Committee counsel acts as the prosecutor, and he may have had considerable experience working
    with the Internal Revenue Service, the Federal Bureau of Investigation or comparable state office,
    and he may have been a former prosecutor himself. If such an investigating attorney is handling the
    matter, a quick determination must be made of the probability of criminal prosecution, and possibly
    serious, adverse tax consequences.[33]
    Regardless of whether the investigating attorney is a committee member or a state bar or attorney
    general's employee, the duty of all investigating or prosecuting attorneys is the same: to do justice.
    They are bound by the code of professional responsibility just as others are. Regrettably, they do not
    seem to enjoy hearing that from defense counsel, and reminding them of their ethical duties will be
    irritating. Nonetheless, most of these investigating attorneys have a heavy workload, and they do tend
    to concentrate their efforts on those attorneys who are the most obnoxious, the most infamous, and
    the least cooperative.
    Retained defense counsel must also make an early determination on whether to supply evidence
    that may build part of a criminal prosecution in the hopes of gaining leniency before the bar
    association
    at the risk of more severe detriment to his client if criminal charges are formally pursued. Such
    decisions are never easy.
    In any event, it is generally good practice at the beginning of representation for an attorney-client
    accused of professional misconduct to contact the grievance or hearing committee's counsel and
    advise
    him that he may expect full cooperation from counsel and the client, any undelivered file will be
    forwarded immediately to the former client or substitute counsel, an informal or formal reply, as
    appropriate,
    will be promptly submitted, and some inquiry about settlement or some other disposition of
    the matter will be made without the filing of formal charges.
    25. The role of retained counsel; in generalSettlement or disposition without hearing; form
    of release
    Settlement is the ideal goal in every case. Seldom can any good come from having a hearing.
    Even though the accused attorney claims complete innocence, the committee members may wonder
    why the matter was not disposed of earlier. They are quite aware of the fact that such matters
    do not get to the hearing stage without the recommendation of the investigating bar attorney, who
    must have found evidence of wrongdoing to justify filing formal charges. Thus, the defense is
    faced with a suspicion of some act of misconduct. Logically, therefore, the goal of avoiding a
    hearing is the most desirable one, and the approach taken should be one that is least likely to lead
    to a hearing. It makes little sense to set one's goal for a hearing when the use of diplomacy can
    avoid it. Settlement is possible only up to a point prior to the hearing, however. Once the hearing
    commences, it is usually too late for the accused attorney to settle with the complainant. The most
    satisfactory and beneficial settlements are those reached within two weeks of the filing of the
    complaint.
    000704
    The potential for various settlement possibilities are plentiful, but, unfortunately, they are usually
    predicated on a commodity in short supply for most attorneys: money. Often it will be necessary
    for the client to contact family members and give promissory notes for loans in order to bargain
    with cash that may be easily replaced, rather than his license, which cannot.
    It should be noted that while it is unethical conduct to "buy off" complaining witnesses, nearly all
    states provide that if the district attorney either approves or encourages a civil settlement, then
    disciplinary proceedings may be avoided. Retained counsel must make certain he violates none of
    the canons of ethics himself. The key to avoiding trouble is to be open and candid with all concerned.
    Retained counsel should immediately make clear to the accused attorney that he is to take no action
    whatever following representation, and a careful inquiry should be made to determine what
    action he has taken to date. Invariably, steps will have to be taken to straighten out the harm that
    he may already have done.
    The single most important ingredient for success is the attitude of the accused attorney. If the
    grievance committee receives the impression that he is merely interested in a "dodge" to avoid the
    consequences of his acts, then great difficulty can be expected. If on the other hand the accused is
    genuinely contrite, both in his words and his actions, few committees are likely to take severe action,
    even in serious cases. On the other hand, some attorneys may attempt some sort of cover-up.
    They may lie to the committee or may otherwise do great disservice to their own cause when they
    are not represented.
    It should always be kept in mind that a contrite attitude by the accused attorney is a difficult one
    for a grievance committee to resist, particularly when it is coupled with a clear and definite plan
    of corrective action.
    Contrition, however, must always be coupled with cooperation, and cooperation must always be
    coupled with corrective action. Should one of these elements be missing, a good result cannot be
    expected. Once defense counsel takes the client firmly in hand, directs a corrective-action program,
    and, most importantly, establishes and maintains a good relationship with bar counsel, he
    may expect good results, even in serious cases.
    The key task for the retained attorney is to coordinate the defensive effort with the goal toward
    receiving
    for the accused the least amount of punishment. For example, the investigating attorney
    for the grievance committee should be informed that the money in dispute has been returned, and
    that the young attorney is facing considerable trouble with the district attorney's office for the
    drunk-driving, collision, and the marijuana possession. It may be appropriate in such case, to suggest
    that the committee take no action until the criminal matter is exposed of.
    If the client is uninsured, and many will be, defense counsel should seek to settle as much of the
    case as he can by the mere payment of money as opposed to disciplinary proceedings. This, of
    course, does not mean fraudulent claims should be paid. If the claimant comes into the hearing
    room with unclean hands, having attempted to extort an unfair cash settlement, the committee is
    entitled to know. However, in the given fact situation, there is a claim for a large sum of money
    the complainant allegedly lost in profit from the sale of the piece of property. A full investigation
    may be required. Did the complainant have full title to the property, free and clear? Was there a
    bona fide written offer? Did the complainant have the right to sell the property without the approval
    of other heirs? A malpractice carrier must certainly know the answer to these questions before
    parting with any money.
    The district attorney's office should be approached with a similar offer: "Because of the DWI and
    marijuana case, the accused attorney is in trouble with the grievance committee. If a civil settlement
    000705
    with the persons who sustained damage in the car wreck can be reached, would the district
    attorney be willing to dismiss the case?" Where changes of misconduct involve theft, it is best to
    make the district attorney aware of settlement negotiations and secure his participation to avoid
    potentially serious problems in a related criminal proceeding.
    The person most important to an overall settlement will be the investigating attorney. The key to
    success is to decide at an early stage upon a specific, reasonable, and achievable course of action,
    and to stick with it. If promises for payment of damages or refunds to clients are made, they must
    be honored, to avoid displeasure of the grievance committee. Plans should be made to raise the
    necessary funds, and an overall plan to solve all the problems of the accused attorney in one
    settlement,
    if possible, should be made. These plans often include requiring attendance at Alcoholics
    Anonymous meetings, psychotherapy with a psychiatrist or clinical social worker, or, in cases of
    negligence or extreme ignorance, attendance at legal ethics classes, continuing legal education
    programs, or other remedial or curative activities. In such cases, the sooner the corrective action
    is undertaken, the more likely good results can be had. Many of the best plans are implemented
    months before the hearing.
    Persuading the investigating bar attorney to propose a solution acceptable to all the parties is
    tantamount to a successful defense. Throughout the attempts at settlement, the bar attorney should be
    informed of the status of negotiations, and the position of the accused attorney should be shown
    as one of reasonableness. If the investigating attorney is made aware that the complainant is seeking
    thousands of dollars when he lost only a few hundred, he very well may suggest that only the
    few hundred be refunded, and may agree to a dismissal of the grievance.
    Set forth below is a suggested form of release by the complainant on receipt of the amount agreed
    to in settlement:
    Form of release:
    RELEASE
    KNOW ALL MEN BY THESE PRESENTS:
    That I, ____________,[complainant] of ____________[address], in consideration of the sum of
    ____________[amount of settlement] to me in hand paid by ____________[attorney], the receipt
    of which is hereby acknowledged and conferred, and recognized as adequate by these presents,
    for myself, my heirs, executors and administrators, release and forever discharge the said
    ____________[accused attorney] of and from all manner of debts, demands, obligations, liabilities,
    suits, and causes of action, whatever, against him, the said ____________[accused attorney],
    in my own right, at the time of executing these presents.
    [Date, subscription, and other formal parts omitted.]
    Dismissal of the hearing should always be a part of any settlement, and all offers should be made
    known to the investigating attorney and subject to his approval. This will insure his good will;
    only rarely will he interpose an objection. However, the defense attorney should not take up too
    much of bar counsel's time. Bar counsel is usually busy with his private practice; he has his own
    cases to handle. He will not appreciate lengthy discussions with the defense attorney over strategy
    or the petty details of the looked for solution.
    Many jurisdictions provide for a "letter of caution," which is sometimes nothing more than an
    informal
    "if-it's true-you-should-not have-done-it." In other words, the bar is simply pointing out
    that the accused attorney is on thin ice, has gotten the attention of the grievance committee, and,
    while the matter may not be serious enough for full inquiry, his conduct could and should improve.
    000706
    In some jurisdictions, the investigating attorney himself has the authority to issue a letter
    of caution.[34]
    In some jurisdictions, previous letters of caution may be used to enhance punishment, in others
    they may not. In some cases the letter of caution may be issued without a complete investigation,
    based only on the complaint of the former client and the answer of the accused. A letter is frequently
    issued when the accused attorney is not cooperative as to a minor inquiry. Often the lack
    of cooperation is the central theme of the letter of caution. Nonetheless, the letter of caution falls
    into the milder end of the discipline range provided by law, and many attorneys can withstand
    receiving
    the letter with only modest wear on their nerves. Usually the issuing of the letter is the
    end of the matter.
    When Bates v. Arizona Bar Association[35] was decided by the United States Supreme Court,
    many advertising taboos fell for the legal profession. The limits which the advertising must observe,
    rather than all advertising, then became the issue. While advertising under certain circumstances
    was held to be proper by the United States Supreme Court, it did not approve of solicitation.
    Where advertising leaves off and solicitation begins is unclear in many cases.
    Attorneys who advertise seem to have far more grievances lodged against them than lawyers who
    do not. Because of the conservative nature of the members of the grievance committee, it is usually
    best to attempt to settle an advertising grievance by ceasing an activity that is questionable. If
    an advertising violation goes to the grievance committee, harsh punishment may follow.
    However, because the law is uncertain as to legal advertising, some grievance committees might
    be willing to forego discipline if the accused attorney agrees to discontinue the activities disapproved
    of. There is a question whether such agreements are enforceable, but because of the uncertain
    state of the law it should be assumed that they are enforceable. The agreements should be
    drawn up with specificity to indicate the extent of advertising that will be allowed.
    V. Defense of Formal Charges
    A. Pleading and Prehearing Procedures
    26. In general
    If it appears that an early settlement or disposition of the matter will not be forthcoming, counsel
    must prepare for a stout defense of the formal charges against his attorney-client. He needs to prepare
    a thoughtful, effective plan of action, if one has not yet been made,[36] analyze the complaint and
    formal charges[37] and prepare an appropriate response to them,[38] prepare his client's defenses to
    the charges[39] or matters to offer in mitigation of punishment,[40] conduct discovery[41] and make
    appropriate procedural motions,[42] and begin preparation for the defense of the client at the formal
    hearing of the grievance committee. These steps are all discussed in the following sections.
    27. Complaints; form
    Virtually all jurisdictions require that grievances be filed in writing. Many require that the complaint
    be sworn to. They are usually rambling, inarticulate, and barely legible. If they are well
    written and make specific reference to violations of particular canons of ethics, the defense attorney
    may logically conclude that an attorney is aiding the complainant.
    A typical client complaint against an attorney, based on the factual background of the present article,
    might read:
    My name is ____________. My mother passed away about three years ago. I went to
    ____________[attorney] to have him probate my mother's will. I wanted to sell the real estate.
    He charged me $____________ and told me he would take care of everything, but I have not
    heard from him since. I have called his office at least twenty times, and he has only returned two
    000707
    ___________________
    or three of those calls. When I finally talked to him, he had done nothing.
    Further, about a year ago, I went to his office to pick up the file so I could go to another lawyer
    and he would not give it to me. He would not give me the will or the other material so that I could
    take it to another attorney. Another attorney has told me I have an absolute right to pick up my
    file. I want my file so that I can get somebody who knows he is doing to file the will to be probated.
    His delay cost me the sale of the house and my lost profit was $____________. I demand an
    immediate
    hearing. Signed: ____________.
    There is usually a small questionaire attached which the complainant is expected to fill out. A
    typical one would read as follows:
    Name of the attorney complained of: ____________.
    How much did he charge you? $____________.
    Did you get a receipt? [] Yes [] No
    Had he done any work for you before? [] Yes [] No
    Are you willing to be a witness and offer sworn testimony? [] Yes [] No
    A copy of the complaint will be sent to the accused attorney with a letter from the chairman of the
    grievance committee that may read as follows:
    Dear ____________:
    Attached herewith please find the complaint of ____________, who has filed a formal grievance
    against you.
    It has also come to the attention of the committee that on ____________, 20___, you were arrested
    for the crime of driving while intoxicated and negligent collision in violation of the penal laws
    of this state. Further, it has come to our attention that when you were arrested, a quantity of
    marijuana and cocaine was found on your person, and that criminal charges are pending against
    you for those three offenses.
    This case has been assigned for investigation to ____________, an attorney of this city. You are
    required to file a written reply with him, with a copy to me and a copy to the complainant,
    ____________, whose address is ____________, within ten days of your receipt of this letter.
    Failure to do so may result in disciplinary action against you. You have a right to an attorney and
    the right to be heard. A hearing for this complaint, if necessary, will be held at a later date. You
    will be advised of the date of the hearing. Of course, in accordance with the secrecy provisions of
    the State Bar Act, we will not discuss the other matters with ____________, the complainant.
    Feel free to file separate replies to each matter.
    Sincerely,
    In the factual background of the article, the complainant has gone to the district attorney's office
    to file theft charges against the attorney, under the theory that his attorney accepted money, did
    no work, and would not return the money. The district attorney has, at this time, rejected the
    charges, and while it is unlikely that they will be accepted for filing in the future, it does give the
    complainant an added option to the detriment of the accused attorney.
    [] Practice Note: Venue. Most state bar acts provide that an attorney must be disciplined in his
    home district. Most states are divided into a number of "districts," usually corresponding to judicial
    districts, and complaints are forwarded to the accused's home area for processing. The only
    exception is discipline before a federal court and contempt proceedings, which are conducted before
    the court where the misconduct took place. Should a complaint be filed in the wrong area, a
    motion to dismiss or a motion to transfer or a plea in abatement is in order.
    000708
    28. Formal charges
    [Cumulative Supplement]
    Formal charges of professional misconduct should not be recommended by bar counsel without
    notifying the attorney who is accused of unethical or illegal conduct.[43] The notice need not be
    given
    immediately, however; it can await the outcome of the bar's investigation into the allegations.[44]
    Following the investigation, the proceedings may be disposed of, without formal charges being
    filed, in one of three ways[45] all of which require the recommendation of bar counsel and the
    concurrence
    of the chairman of the grievance or hearing committee.[46] (1) The proceedings may be dismissed
    if there is insufficient probable cause to believe misconduct has occurred.[47] (2) An admonition
    may be issued if there is probable cause to believe that misconduct has occurred but the problem
    is minor and isolated.[48] (3) Probation can be imposed, with or without an admonition, if there is
    probable cause to believe misconduct has occurred for which probation is appropriate.[49]
    Furthermore,
    if there is a civil or criminal proceeding pending in which the respondent is a party and which
    involves the same subject matter (conduct), the disciplinary proceedings may be stayed if that is
    appropriate.[
    50] A stay will be appropriate where the respondent will suffer prejudice in the pending
    proceeding should the disciplinary action proceed immediately and where the grievance committee
    hearing may be expedited by evidence adduced in the criminal or civil matter.[51]
    Formal proceedings against the accused attorney are warranted where there is probable cause to
    believe misconduct has occurred which is neither minor nor isolated and probation is not appropriate
    or where the respondent does not agree to a recommendation of admonition or probation.[52] The
    charges are prepared by bar counsel who is required to file with the disciplinary board and serve on
    the respondent a written statement of the charges giving a fair and adequate notice of the nature of the
    alleged misconduct.[53] Once the formal charges are filed, the proceedings are no longer confidential
    and are open to the public except for deliberations of the hearing committee, disciplinary board or
    court and information the hearing committee has ordered kept confidential.[54] After the charges
    have been filed, the matter is referred to a specific grievance or hearing committee.[55]
    CUMULATIVE SUPPLEMENT
    Cases:
    No due process errors occurred during the grievance committee proceedings investigating an
    attorney's
    behavior, where attorney alleged that notice of the hearing was untimely and charges against
    him were vague, because grievance committee proceedings are principally investigatory and
    comparable
    to proceedings before a grand jurythey are nonadversarial and there is no right of confrontation
    or cross-examination; the attorney under investigation is not entitled to a bill of particulars until
    the grievance committee completes its investigation. In this context, at a reasonable time before a
    finding of probable cause is made, the attorney will be advised of the conduct under investigation and
    the rules which may have been violated; in addition, the attorney must be given all materials
    considered
    by the committee and an opportunity to make a written statement regarding the alleged misconduct
    under R Reg Fla Bar 3-7.4(g). In any event the notice actually given was sufficient where the
    attorney received notice of the rules allegedly violated 13 days before the hearing was scheduled, and
    000709
    he was represented by counsel at the hearing and had an opportunity to cross-examine witnesses. The
    Florida Bar v. Swickle (1991, Fla) 589 So 2d 901, 16 FLW S737, later proceeding (US) 117 L Ed 2d
    101, 112 S Ct 929, supp op (US) 118 L Ed 2d 203, 112 S Ct 1552.
    Evidence supported the finding of panel of the Kansas Board for Discipline of Attorneys that attorney
    engaged in illegal conduct, as an aggravating factor for purposes of imposing discipline, even
    though criminal charges were not filed against attorney; attorney admitted that he exposed himself to
    administrative assistant for district court, statute defined lewd and lascivious behavior as "publicly
    exposing a sex organ or exposing a sex organ in the presence of a person who is not the spouse of the
    offender and who had not consented thereto," administrative assistant was not attorney's spouse, and
    the American Bar Association's (ABA) standards did not require that an attorney be charged or
    convicted
    by law enforcement before his or her conduct could be considered illegal. West's K.S.A.
    213508(a)(2). In re Depew, 237 P.3d 24 (Kan. 2010).
    Discipline of attorney who engaged in conduct adversely reflecting on fitness to practice and
    placed personal interests above those of clients would be limited to censure where medical evidence
    showed he suffered from mild neurological dysfunction due to cerebral aneurysm at time of
    misconduct,
    years of exemplary practice preceded affliction, he acknowledged misconduct, and he demonstrated
    willingness to take appropriate steps to prevent recurrence. Re Kiley (1991, 4th Dept) 170
    App Div 2d 90, 572 NYS2d 601.
    [Top of Section]
    [END OF SUPPLEMENT]
    29. Response; form
    [Cumulative Supplement]
    Within a prescribed period of time following service of the formal charges, the respondent should
    file a written reply or answer with the board or committee and serve a copy of it on bar counsel.[
    56] Allegations that are not disputed should be admitted to narrow the issues at the hearing and
    denials of fact should be separately stated. Moreover, if the respondent chooses to refuse to answer
    an allegation on constitutional or other grounds, the ground of such refusal should be explicitly
    asserted.[57] Counsel should note that the failure to answer the charges timely may be
    treated as an admission of their truth.[58]
    It should be kept in mind that the reply itself is admissible in both civil, criminal, and disciplinary
    proceedings. The records of the grievance committee themselves are not usually subject to discovery
    proceedings, as they are almost always allowed to be secret by statute. However, the accused
    will be required to send a copy of the reply to the complainant, which may be introduced, in
    evidence at a subsequent civil trial for malpractice, or at a criminal proceeding.
    Many jurisdictions require that the reply be sworn to, and some provide that failure to file a
    timely reply is in itself grounds for disciplinary proceedings. At the very least, the failure to file a
    timely reply will irritate the investigating attorney and the committee, and this conduct will be
    reported
    to the committee and may be viewed as lack of cooperation. Where failure to reply is in
    and of itself an admission that all charges are true and correct, the statement of charges alone can
    be the basis for disciplinary proceedings.
    A good deal of thought and effort must go into the reply, and a well-drafted answer may result in
    no further action by the investigating attorney. For example, legal research into the various issues
    may result in finding cases that exonerate the defendant in the particular fact situation. A motion
    000710
    to dismiss should then be filed with the answer, citing the appropriate authority. In preparing the
    reply, counsel should attach to a motion to dismiss photocopies of important favorable cases or a
    brief in support. If no research is offered, none will be done by the committee on behalf of the client.
    An amazing number of attorneys are unaware of the fact that there has been considerable litigation
    over the years regarding what is and what is not unethical conduct, and formal published ethics
    opinions have been issued by many committees for decades. There is a wealth of authority that
    can be cited. Moreover, most state bar associations have on file advisory opinions from their ethics
    committees. These can sometimes be of immense use, especially where the accused attorney
    actually may have relied upon a prior ethics opinion in trying to conform his behavior to the right
    canon. The problem is that advisory opinions may not be binding, and authority from other states
    or jurisdictions may be cited only as persuasive authority. Finally, the American Bar Association
    has issued numerous opinions over the years, and provides materials that may be purchased for
    ethics law research. The bar association's opinions carry considerable weight.[59]
    Generally, there is no required form for a reply. A typical and acceptable method is to go through
    the allegations and admit those that should be admitted, to identify those as to which corrective
    action has been taken (such as returning the file to the client or to his new attorney), to deny those
    that should be denied and to deny for lack of information or belief other allegations as appropriate.
    A reply similar to answering requests for admissions or interrogatories may be appropriate.
    The second part of the reply should consist of a brief on the issue of whether the conduct complained
    of is (a) a crime or act of moral turpitude; or (b) conduct that normally would subject the
    accused to disciplinary action.
    Based on the factual background of the article, an appropriate response to formal charges might
    be composed as follows:
    [Caption of forum, title of case and other formal parts omitted.]
    ANSWER TO FORMAL CHARGES
    1. The allegations of paragraphs ____________ of the formal charges are admitted.
    2. The allegations of paragraphs ____________ are denied without qualification or reservation.
    3. In response to the remaining allegations, respondent cannot admit or deny the truth of the
    allegations
    for lack of sufficient information and belief. He therefore denies those allegations subject,
    however, to the following factual statement, which is offered in defense of the formal charges and
    in mitigation of punishment as to any charges and allegations found to be true:
    a. I was formally the attorney for the complainant. I advised him at the time I accepted the case
    that I would also need a contractual relationship with his two sisters, and he has never had them
    contact me. I felt uneasy with probating the will without the participation of the two sisters, and I
    did not know how to get in touch with them. He gave me a retainer of $500. Attached herewith
    please find a photocopy of the check for $500, which I have sent to his new counsel since he has
    now made arrangements for another attorney.
    b. I admit that I did not return his file to him when he first requested it because I did not know I
    was required to do so. I have apologized to the complainant with an explanation. [Attach copy of
    letter.]
    c. I admit sending the letter to the complainant referred to in his complaint as I mistakenly
    thought that I was entitled to hold the file until I had been compensated for the time I had spent
    on the case. I was mistaken as to my obligations, and I have stated my regret for any inconvenience
    this has caused the complainant.
    d. ____________[Other statements as appropriate].
    000711
    [Date, subscription, and other formal parts omitted.]
    Particularly when the defense attorney has not been permitted much time to prepare a reply, or the
    accused attorney has filed his own reply, an amended reply may be appropriate. In most cases,
    there are no bar rules to prevent this. Occasionally the grievance committee will frown on very
    late replies, especially those filed just before the hearing.
    The best use of the amended reply is to bring to the committee's attention legal precedents not
    previously shown to them, and particularly any legal authority that the defense attorney feels is
    compelling. [] Practice Hint: The money to fund any costs or refunds should be placed in the defense
    attorney's trust account, and a written statement from the accused attorney should be taken
    granting the attorney full and exclusive power to disperse the money in settlement of the case, in
    his discretion.
    Virtually all jurisdictions require that a written answer to the grievance be filed within a certain
    time limit. Most jurisdictions allow a minimum of 7 days, and some allow up to a maximum of
    60. Nearly always the time by which a reply must be filed is included in the notice of formal
    charges. In many cases, however, with as much as 30 or 40 hours of investigating and preparation
    to do, a timely answer cannot be made. Rather than filing a late answer, it is always appropriate to
    call the investigating attorney and ask for an extension of time in which to file the answer. It
    nearly always will be granted. Indeed, this may be a wise consideration in most cases. The bar
    association
    grievance committee is anxious to have the accused attorney submit to their authority
    and control. Resisting it invariably results in its taking a harsher stance. Therefore, a request for a
    delay in filing a response has the advantage of allowing a more thorough investigation that will
    produce a better and more detailed reply and in letting the committee know that the accused attorney
    has submitted himself to their committee's jurisdiction.
    A case may present itself where the complainant seeks a large and unjustified refund from the accused
    attorney or otherwise seeks to take unfair advantage of him. This is not uncommon, particularly
    among "con men," who may have succeeded in this ploy in the past. The interview with the
    accused attorney will sometimes reveal that the complainant is an accomplished liar who is adept
    at adjusting his testimony to accomplish his goal. In such cases, a vague answer to the grievance
    may be advantageous.
    As a general rule, the committee does not like the holding back of information, but neither does it
    like its offices being used for purposes of extortion. Further, the majority of virtually all committees
    is made up of lawyers, and they are likely to appreciate good tactics. There are exceptions,
    however, and prudent practice requires that the appropriate approach be taken.
    [] Case Illustration: A client paid his attorney a flat fee for defense in a fraud case. When the
    litigation
    was satisfactorily concluded, the client demanded half of the fee back, claiming that the
    attorney had told him that he expected to lose, that that fee would include the costs of an appeal,
    and that if the case was won at the trial stage he would give him a 50 percent refund. Defense
    counsel investigated the matter after the demand was first made but before the grievance was
    filed, and checked the complainant's litigation records at the courthouse, discovering that other
    attorneys
    had defended the complainant in fraud actions as well. He contacted them and learned
    that two had been approached along the same lines; one paid back half of the money to avoid a
    grievance, and the second made a small adjustment in the fee. A purposely vague answer was
    filed, and, at the hearing, the complainant was allowed to tell his story to the committee and
    000712
    cross-examination solidified it. Then, to the surprise of the complainant, the two attorneys against
    whom he had made the same threat several years before were presented as witnesses. Since there
    were two witnesses to the attorney's employment agreement, the attorney and his secretary, and a
    signed written contract that provided as the attorney stated, the fundamentals for presentation of a
    perjury charge existed and the record was turned over to the appropriate authorities. The
    complainant's
    protests that his previous extortions were privileged communications were overruled by
    the committee.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney who on 3 separate occasions refused to cooperate in committee's investigation of client
    complaints, until it became necessary to procure subpoena directing his appearance for examination
    under oath, would be censured despite mitigating factor that he was in midst of terminating
    longstanding
    marriage during period in question, since failure to cooperate in investigation of alleged
    misconduct constitutes misconduct in and of itself, and warrants discipline. Re Feit (1989, 3d Dept)
    156 AD2d 810, 549 NYS2d 829.
    [Top of Section]
    [END OF SUPPLEMENT]
    30. Motion to dismiss; illustrative forms
    The scope of motions to dismiss grievances is limited only by the ingenuity and experience of the
    defense attorney. They can take practically any form, but should, if possible, be supported with
    case citations and a brief in support. Forms for two typical motions, (a) motion to dismiss on the
    ground of res judicata, and (b) a motion to dismiss for lack of standing, are set forth below:
    MOTION TO DISMISS (RES JUDICATA)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, the Respondent in this action, and would show the committee as
    follows:
    I.
    The complaint of ____________, complainant in this cause, is substantially the same as was
    found in her suit for legal malpractice against the respondent filed on ____________, 20___, and
    tried to a jury on ____________, 20___. The jury made findings entirely favorable to the defendant
    in that cause (respondent herein) and the court entered a judgment for the defendant and taxed
    all costs against the plaintiff (complainant herein) and said costs have yet to be paid.
    II.
    Copies of the plaintiff's pleadings, the defendant's answer, and a certified copy of the judgment in
    that cause are attached herewith as respondent's Exhibits "A", "B", and "C", and are herein
    incorporated
    for all purposes by reference.
    III.
    Respondent urges that virtually all issues presented to this committee were presented in
    ____________ court, and resolved by the rules of evidence and that the respondent was shown as
    a matter of law to have been guilty of no professional misconduct.
    IV.
    The complainant herein attempts a collateral attack upon that final judgment (Exhibit "C") which
    000713
    should not be permitted as a matter of law. Respondent respectfully urges that administrative
    hearings such as those held by the grievance committee may not attack facts conclusively established
    in court.
    V.
    Further, respondent respectfully submits that the grievance committee should not set itself up in a
    position above the courts and should not disregard the findings already made.
    WHEREFORE PREMISES CONSIDERED, respondent prays that this grievance be forthwith
    dismissed with prejudice and for all other further relief to which he may show himself to be justly
    entitled.
    [Date, subscription, and other formal parts omitted.]
    As a general rule, the committee is interested in hearing only from an attorney who has discovered
    unethical conduct, law enforcement authorities, the victim of the unethical conduct, but
    no others. In a surprisingly large number of cases, friends, neighbors or, particularly in divorce
    cases, relatives of the person they see as aggrieved will attempt to interpose their will. If tactfully
    handled, these cases can often be dismissed quite early.
    As a practical matter, there are no formal requirements for "standing." Anyone aware of unethical
    behavior may report it to the grievance committee. However, most committees receive complaints
    from third parties that generate unnecessary work for them, and, as a general rule, they are not
    sympathetic to interlopers. They wish to hear from the client or a person who claims to have been
    victimized by the attorney.
    MOTION TO DISMISS (LACK OF STANDING)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, respondent, by and through his attorney of record, and shows as
    follows:
    I.
    Respondent represented ____________, a citizen of Mexico, in litigation against ____________,
    a citizen of the United States. Respondent had an attorney/client relationship with ____________
    [plaintiff], and pursued the matter vigorously. Copies of the pleadings filed against the defendant
    in that case prepared by respondent are attached herewith as Exhibit "A" and incorporated for all
    purposes.
    II.
    The defendant in that case filed an answer, a copy of which is attached herewith as Exhibit "B"
    and incorporated herein for all purposes.
    III.
    Respondent proceeded to take depositions and to prepare for trial but, because of distances, was
    unable to maintain close contact with the plaintiff, his client.
    IV.
    The complainant in this cause is a friend of the plaintiff. The plaintiff often stayed at her home
    while visiting in the United States. Gradually the plaintiff seemed to lose interest in the litigation,
    and stopped paying attorney's fees to respondent. The complainant then attempted to usurp the
    perogatives of the plaintiff, at first by carrying messages to the respondent, then by taking
    independent
    action, and then by attempting to exercise her independent judgment as to how the case
    should be handled.
    V.
    000714
    In time, a dispute arose between the complainant, who had no legal right to interfere in the lawsuit,
    and the respondent, who respectfully suggested to her that he preferred to do business with
    his client only and that legal matters and questions of strategy should be left to the plaintiff and
    the respondent. To this, the complainant took great exception.
    VI.
    Respondent then filed a motion to withdraw, giving the plaintiff sufficient time to make other
    arrangements
    for counsel. The motion for and order permitting withdrawal as attorney of record is
    attached herewith as respondent's Exhibit "C," and incorporated herein for all purposes.
    VII.
    Nonetheless, the complainant continued to assert her wish to control the litigation and the obligation
    of the respondent to represent what had come to be, in her mind, her case. Respondent refused
    to communicate with her, and returned the file to his client in Mexico.
    VIII.
    Complainant refused to accept the court's order permitting withdrawal, and she has continued to
    call the respondent to insist upon a full accounting of all money expended, or an explanation as to
    why the case has not been tried.
    IX.
    Respondent has never had an attorney-client relationship with the complainant, and he respectfully
    suggests that she lacks standing to bring a complaint on charges of professional misconduct
    against him.
    WHEREFORE PREMISES CONSIDERED, the respondent in this case respectfully requests that
    the complaint of this complainant be dismissed with prejudice, and the further prays for all such
    relief, both general and equitable, to which he may show himself to be justly entitled.
    [Date, subscription, and other formal parts omitted.]
    31. Discovery
    [Cumulative Supplement]
    For a limited period following the filing of an answer, both bar counsel and the respondent should
    be afforded reciprocal discovery of matters not privileged.[60] During this period there should be a
    mutual exchange of (1) names and addresses of all persons having knowledge of relevant facts, (2)
    non-privileged information and evidence relevant to the charges or the respondent, and (3) other
    material
    that may be shown to be relevant and material. Protective orders should be available to prevent
    unwarranted discovery.[61]
    While many of the state bar enabling acts make no specific provision for discovery, as a general
    rule, a meeting with the investigating attorney will produce all the discovery necessary to prepare for
    the hearing. Furthermore, not only has the accused attorney an absolute right to a copy of the
    complaint
    lodged against him, and to all later amended complaints, but in most states, the accused has a
    right to a list of the witnesses who will appear against him, and in many states the bar rules provide
    that a summary must also be given of their expected testimony. The accused attorney also will have
    subpoena power to compel the attendance of witnesses, including hostile witnesses, police officers
    and court personnel.[62]
    In a particularly serious case, where the state rules of criminal procedure provide for little in the
    way of discovery, and if it appears that the loss of the accused attorney's law license is all but certain,
    the defense attorney may choose to make the tactical choice of using the grievance proceeding as a
    000715
    discovery tool for the upcoming criminal trial. This is particularly true when an indictment has been
    returned without the opportunity to conduct a preliminary hearing as provided by federal law, or an
    "examining trial" provided by a code of criminal procedure in most states.
    If such a move is made, the defense attorney will often choose to have his client invoke his Fifth
    Amendment rights, and he will not testify. He cannot be compelled to testify if there is criminal
    litigation
    pending. If a disbarment suit is pending, his deposition can usually be taken, and his refusal to
    be deposed can be used against him at the disbarment trial, but not at a criminal trial. The exercise of
    the Fifth Amendment right may not be used for impeachment.[63]
    If the defense attorney's strategy is along those lines, he should request that the committee postpone
    its decision until after the criminal trial is completed. Even though the request will seldom be
    granted, it can do no harm to ask. If the request for a delay of the grievance proceedings is granted
    until after the criminal trial, and there is an acquittal, this outcome should be brought to the attention
    of the committee immediately.
    In most jurisdictions, even though the investigating bar attorney may not have an absolute right to
    pre-hearing discovery, cooperation with him is usually best. However, such cooperation does not
    require
    the defense attorney to build the prosecution's case, and extensive cooperation may very well
    result in that being done. Thus, defense counsel must walk a fine line between proceeding so as to
    irritate
    the committee by refusing to turn over documents, or cooperating and hoping that the matter
    will not be prosecuted. It is always a difficult choice.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney was not entitled to invoke privilege against self-incrimination when ordered to file list
    of all monetary sanctions imposed against him by any federal court since sanctions were public orders
    and attorney did not explain how information could incriminate him. In re Maurice (1995, CA7)
    73 F3d 124.
    [FN31] See, Murphy, Grievance Counsel for the Public, 26 NY LS L Rev 221 (1981).
    [FN32] See 8.
    [FN33] Theoretically, the investigation is secret in virtually all jurisdictions, but a good deal
    of cooperation among law enforcement agencies always seems to take place if criminal allegations
    are made.
    Section 25 Footnotes:
    [FN34].
    See 59.
    [FN35].
    Bates v. State Bar of Arizona (1977) 433 US 350, 53 L Ed 2d 810, 97 S Ct 2691, 51 Ohio Misc 1,
    5 Ohio Ops 3d 60, 2 Media L R 2097, 1977-2 CCH Trade Cases 61573, reh den 434 US 881, 54 L
    Ed 2d 164, 98 S Ct 242, Beasley v. Burt (1946) 201 Ga 144, 39 SE2d 51.
    Shadur, Attorneys' Guide 43 et seq.
    Section 26 Footnotes:
    [FN36] See 21.
    [FN37] See 28.
    [FN38] see 29.
    [FN39] See 32 34.
    000716
    [FN40] See 35.
    [FN41] See 31.
    [FN42] See 30.
    Section 28 Footnotes:
    [FN43] ABA Standards for Lawyer Discipline, Standard 8.8.
    [FN44] Id., Commentary.
    [FN45] ABA Standards for Lawyer Discipline, Standard 8.10(a)(c).
    [FN46] ABA Standards for Lawyer Discipline, Standard 8.9, 8.11.
    [FN47] ABA Standards for Lawyer Discipline, Standard 8.10(a).
    [FN48] ABA Standards for Lawyer Discipline, Standard 8.10(b).
    See 58.
    [FN49] ABA Standards for Lawyer Discipline, Standard 8.10(c).
    See 9, 60.
    [FN50] ABA Standards for Lawyer Discipline, Standard 8.10(e).
    [FN51] ABA Standards for Lawyer Discipline, Standard 8.10, Commentary.
    [FN52] ABA Standards for Lawyer Discipline, Standard 8.10(d). See also Standards
    8.178.20.
    [FN53] ABA Standards for Lawyer Discipline, Standard 8.218.23. Whatever action is taken,
    the respondent is entitled to notice of any disposition of the matter following the investigation.
    Standard 8.14.
    Notice of formal charges and hearing by grievance or other disciplinary tribunal, 2 Am. Jur.
    Pleading and Practice Forms, Attorneys at Law, Form 287290; order to show cause why attorney
    should not be disciplined, 2 Am. Jur. Pleading and Practice Forms, Attorneys at Law,
    Form 291294.
    [FN54] ABA Standards for Lawyer Discipline, Standard 8.248.25.
    [FN55] ABA Standards for Lawyer Discipline, Standard 8.26.
    Section 29 Footnotes:
    [FN56].
    ABA Standards for Lawyer Discipline, Standard 8.27.
    [FN57].
    Id., Commentary.
    The filing of a so-called 'general denial,' which is permitted in civil court in some jurisdictions
    such as Texas and Oklahoma, is not considered a meaningful answer by grievance committees. They
    want admissions of facts that are not in controversy, denials of ones not believed to be true, and
    statements
    of point of view.
    [FN58].
    ABA Standards for Lawyer Discipline, Standard 8.28.
    [FN59].
    See 3.
    Section 31 Footnotes:
    [FN60] ABA Standards for Lawyer Discipline, Standard 8.29.
    Discovery in attorney disciplinary proceedings, 7 Am. Jur. 2d, Attorneys at Law 93.
    Depositiondiscovery procedures in disciplinary proceeding against attorney, 92 A.L.R. 2d
    1328.
    For forms of interrogatories to attorney and for forms directing witness to answer interrogatories
    000717
    in disciplinary proceedings, see 2 Am. Jur. Pleading and Practice Forms, Attorneys at Law,
    Forms 295296, 298.1 (supp.).
    [FN61] Id., Commentary.
    [FN62] ABA Standards for Lawyer Discipline, Standard 8.35.
    [FN63] Due process considerations in attorney disciplinary proceedings, 7 Am. Jur. 2d, Attorneys
    at Law 91.
    Sincerely,
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000718
    Subject: Changing my address on portal
    Zach Coughlin (zachcoughlinhotmail.com) 4/13/12
    To: supportbaralliance.com, suzannewnvbar.org, patrickknvbar.org, renodirectreno.gov,
    courtadminwashoecourts.us, courttechwashoecourts.us, joey.hastingswashoecourts.us,
    joey.ordunawashoecourts.us, craig.Irandenwashoecourts.us, kstancilwashoecounty.us,
    stuttlewashoecounty.us, davidcnvbar.org, glennmnvbar.org, rbakerwashoecounty.us
    From: Zach Coughlin (zachcoughlinhotmail.com)
    Sent: Fri 4/13/12 3:18 PM
    To: supportbaralliance.com; suzannewnvbar.org; patrickknvbar.org; renodirectreno.gov;
    courtadminwashoecourts.us; courttechwashoecourts.us; joey.hastingswashoecourts.us;
    joey.ordunawashoecourts.us; craig.Irandenwashoecourts.us; kstancilwashoecounty.us;
    stuttlewashoecounty.us; davidcnvbar.org; glennmnvbar.org; rbakerwashoecounty.us
    Dear State Bar oI Nevada, Second Judicial District Court, Reno Municipal Court, Reno Justice Court,
    I am attempting to update both my SCR 79 Public Address and my preIerred mailing address on the
    portal and it keeps saying "no changes have been saved". Can you help me Iigure out what is going
    on? My internet explorer is set to allow cookies....
    PLEASE NOTE I HAVE CHANGED MY ADDRESS
    I need my SCR 79 address to read:
    945 W. 12th St.
    Reno, NV 89503
    And my PO BOX and preIerred mailing address should be:
    PO BOX 3961
    Reno, NV 89505
    and my preIerred email (to be held out to the public) should be:
    ZachCoughlinhotmail.com
    and my public telephone: 775 338 8118
    and my public Iax: 949 667 7402
    and my website www.ZachCoughlinEsq.wordpress.com
    Thank You,
    Zach Coughlin
    Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    1/1
    000719
    Print Close
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/02/12 4:09 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Mr. King,
    Could you please provide a copy of whatever it was the Marshals sent you? Further,
    please indicate whether Judge Gardner filed a grievance herself, or whom it was who is
    so filing a grievance based upon a three year old Order by Judge Gardner. For, if that
    Order was just something Judge Nash Holmes included with her submission (which
    also purports to speak for various other RMC Judges), that is further indication of the
    extent to which you have confused or misrepresented material facts throughout this
    matter, if, indeed, your statement that "other different judges" have submitted
    complaints against me, when, in fact, only Judge Nash Holmes has. Please indicate, in
    writing, who submitted the materials upon which you have opened a case incident to the
    Judge Gardner matter. I have asked you to do this at least four times now, several of
    which have been in writing, and yet you have not done so. You may be interested to
    see that I filed a Mandamus action in relation to that grievance by Judge Gardner:
    http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
    Given that I have been unable to get the RMC to give me a copy of the court
    proceedings in RMC 11 TR 26800 (the traffic case before Judge Nash Holmes),
    would you mind if I got one from you?
    You indicated that your investigation revealed a condition admission. Where
    exactly did you glean such materials from? Further, please confirm with Bar
    Counsel that any conditional admission is relevant to the extent the conditions
    of which have long since passed. I know Character and Fitness Committee
    Chairman Rowe has made express promises to applicants in the past that such
    would not be the case.
    Sincerely,
    000720
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Mon, 2 Apr 2012 22:59:08 +0000
    Dear Mr. Coughlin,
    I have opened 3 disciplinary files against you. They are identified by number below:
    NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill
    NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes
    NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner
    You have received the grievance from Mr. Hill and also the grievance from Judge Holmes. The
    Grievance from Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v
    Barti Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13.
    I have received certified copies of the contempt orders, a certified copy of the conviction at
    Wal-Mart, and an incident report from Marshals Thompson and Coppa regarding your conduct
    on March 22, 2012. I also have the recordings of the court proceedings at issue.
    At this time, I do not expect to be providing you with any additional information. If you have
    additional information that you want me to be made aware of in response to the grievances
    identified above please feel free to mail them to me.
    000721
    Sincerely,
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, April 02, 2012 2:39 PM
    To: Patrick King
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I need for basic procedural due process protections to be afforded before any
    consideration of any arrangement you have in mind would be appropriate. It is my
    understanding that we are still in the stage of the process where you are providing me
    indication of the allegations against me and documentation in support and explanation
    thereof, and that there is still additional materials and complaints which you have so far
    chosen not to allow me access to, even to view upon my responding to your stipulation
    that I could only so view such materials upon visiting the Reno office of the State Bar
    of Nevada in person. Such as, please answer the questions I have posed you in my
    recent emails, especially with regard to providing copies of and information related to
    these "other different judges" supposedly submitting written complaints about me to
    you. Further, please explain whether you requested materials from Judge Nash Holmes,
    as her letter to you appears to indicate, in her statements that she "apologizes for taking
    two days to get these materials to you" that you requested such materials rather than she
    sending them to you on her own accord? Please explain.
    Sincerely,
    000722
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/02/12 2:38 PM
    To: patrickk@nvbar.org
    Mr. King,
    I need for basic procedural due process protections to be afforded before any
    consideration of any arrangement you have in mind would be appropriate. It is my
    understanding that we are still in the stage of the process where you are providing me
    indication of the allegations against me and documentation in support and explanation
    thereof, and that there is still additional materials and complaints which you have so far
    chosen not to allow me access to, even to view upon my responding to your stipulation
    that I could only so view such materials upon visiting the Reno office of the State Bar
    of Nevada in person. Such as, please answer the questions I have posed you in my
    recent emails, especially with regard to providing copies of and information related to
    these "other different judges" supposedly submitting written complaints about me to
    you. Further, please explain whether you requested materials from Judge Nash Holmes,
    as her letter to you appears to indicate, in her statements that she "apologizes for taking
    two days to get these materials to you" that you requested such materials rather than she
    sending them to you on her own accord? Please explain.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    000723
    Print Close
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 4/02/12 10:15 AM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Mr. King,
    Now you appear to be bringing an allegedly conditional admission that would have expired over four
    years ago into this arena. Is there no jurisdictional limit to your inquiry? Are there no rules of evidence
    that apply? Further, if one review Chairman Rowe's assertions as my Character and Fitness hearings,
    they go completely counter to your attempts to make a conditional admission a lifetime black mark on
    one's record. Additionally, you have so far failed to expressly, specifically identify one thing that
    troubles you and explicate the basis for it doing so. Mostly, you have given me a "it speaks for itself"
    approach. Which leaves a lot wanting in the way of due process. This is the same sort of thing Geof
    Giles complained about you doing when he sued you in the foreclosure mediation context. Curiously,
    the briefs in that case that address your misconduct have disappeared from the Nevada Supreme
    Court's website. Do you know why? Can you give me an indication of how the Joey Gilbert matter
    was handled incident to his boxing affairs, for which John Bailey was involved, he having a role both
    with the Bar and with the boxing commission.
    As for standards of proof, you seem to find Richard Hill meets his rather easily, based only upon
    unattributed hearsay (same for Judge Nash Holmes assertions). Further, please clarify who the "other
    different judges" are who filed grievances or complaints against me. So far, you have only identified
    Judge Nash Holmes. While Judge Nash Holmes apparently purports to speak on behalf of other RMC
    Judges, none of them have signed anything submitted to the State Bar of Nevada, further, Judge Nash
    Holmes letter to you is littered with inconsistencies, misstatements, and material omissions, particularly
    in matters for which she purports to comment on behalf of other RMC judges. Please indicate when
    and where you became aware of Judge Nash Holmes remarkable seizure of my personal property in
    court, including a smart phone.
    Please indicate whether Judge Nash Holmes attached the April 2009 sanctions Order by Judge Gardner.
    As far as I know, Glenn Machado has jurisdiction over the 11/30/11 conviction in RMC 11 CR 22176.
    Until I have something in writing from the State Bar of Nevada indicating otherwise, that is what I was
    left with upon reporting that conviction pursuant to SCR 111. Please confirm that you have accessed
    confidential Character and Fitness Committee records for any alleged conditional admission of a
    member of the Bar during a time period after the expiration of any such conditional admission.
    Further, Mr. King, you seem to take quite a few liberties as far as offering your own mental health
    diagnosis, ostensibly based primarily upon the unattributed hearsay of a former prison warden become
    judge and an attorney known throughout the bar for engaging in vexatious litigation tactics (Richard
    Cornell, Thomas J. Hall, Geof Giles, etc., etc. have all commented on Mr. Hill's reputation preceding him
    to one extent or another). Mr. King, I wish to know the sources of your alleged "information", including
    your assertions that I was ever "in treatment" and, by implication, you assertion that I am now "out of
    treatment" given you mentioning that I might get "back into treatment".
    Sir, I think you need to ask yourself whether you are selling yourself out and attempting to leverage
    000724
    medicine, law, and psychiatry, in a attempt to please rich people like Richard G. Hill, Judge Nash
    Holmes, etc., etc. You take an Oath as an attorney and as Bar Counsel. While you mention that Oath
    including protecting the public, you see to fail to understand that a large part of protecting the public
    includes working towards maintaining the health of the legal profession. Being an attack dog for the
    rich, seeking to stifle the voice of dissent, and otherwise making a mockery of fundamental notions of
    due process and fair play, whilst leveraging in a malevolent manner both the recovery and psychiatric
    communities, all so Richard G. Hill, Esq. can buy his eleventh Porsche is beyond dangerous and
    objectionable. These are the days of transparency, and there is nothing written to suggest that Bar
    Counsel shall be immune from that.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Mon, 2 Apr 2012 15:56:08 +0000
    Dear Mr. Coughlin,
    That is why it is so important for you to cooperate and to respond to the
    grievances. I did not know for example, until I investigated, that your
    admission to the Bar had been delayed and that you were ordered by a
    character and fitness committee to undergo counseling.
    Now I understand that you suffer from a mental condition. Apparently you
    were arrested for prior to being admitted to the Bar. Since being admitted,
    you have been arrested on more than one occasion. It is apparent to me
    that your mental issues are not resolved. Have you considered getting back
    into treatment?
    000725
    Sincerely,
    Patrick
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/30/12 9:03 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Dear Bar Counsel,
    Why did you earlier mention more than one conviction? That is exactly what I mean by
    "getting confused about material facts". Similarly, Mr. King was confused about
    whether any email is sent from a web site or an email address and whether anyone from
    the State Bar of Nevada emailed me Mr. Kings 3/16/12 letter (that was when Mr. King
    indicated he did not care if I received that letter or not in an alarming delivery). Why
    would you bring up anything about a conditional admission when the conditions
    expired in 2008? It is this alarmingly loose approach to maintaining some fidelity to
    traditional notions of due process and fair play that Mr. King exhibits that troubles me
    the most. For instance, he blanket refusal to provide anything in response to my FOIA
    and other requests. How could that possibly be fair? I have provided additioanl
    documentation in support of the grievances against the Christiansens, Sanft, Kevin
    Kelly and Eichman. Do you still contend that there is no basis for any further inquiry?
    Further, you mention a disability approach, however, you fail to cite with any
    specificity why you suggest that approach. Please do so. Please explain to me how
    your stance is anything other than "well, these powerful people are asking me to mash
    on you and that generally is in my best interest and helps me avoid having any skin in
    the game, and, yeah, I know, ideals, ideals, stand up for brave lawyers, bar counsel
    duties, etc., but really, come on, why should I stick out my neck", etc., etc.
    000726
    When and how did you become aware that Judge Nash Holmes seized my phones and
    other property. Seizing a smart phone is like seizing 10 filing bins. But I am not sure
    you understand that because you seem confused over whether an email is sent from an
    email address or from a website, as indicated in your statements while I was viewing the
    documentation. I ask that you understand some of what I have been through with the
    Bar. You really cannot imagine what I have been through unless you lived it. It
    completely raped my life and it didn't stop when getting admitted in in 2005. It carried
    on for several more years, especially in California. $5K for Christiansen was an
    outrage, then to have him appear at the hearing and say he was doing it "pro bono",
    especially after Kevin Kelly's statements about providing me "the names of three
    attorneys who will do you case pro bono" is further alarming. How in the world Kevin
    Kelly can be on the Character and Fitness Committee for a decade while owning the
    Spearmint Rhino truly mystifies. Its nots the ownership, its the alarming Nifong
    approach he took with me, especially vis a vis his democratic party buddy Mark
    Tratos. Clearly, Tratos received my paper and he and LaFrance were just playing kick
    the can with me. I swear to god on mine and everyone in my families life I turned in
    that paper, and that guy knows it. He swore under oath at the California hearing that he
    had lost other students papers previously. I know legion of people who loath him.
    Whatever, I don't like to embrace hate. Life is short.
    Mr. King, I do get a sense about you that you are interested in fairness in your heart.
    However, I recognize when a scenario is stacked in a way that is likely to affect one's
    judgment. This is such a scenario. But you know what? Judge Flanagan told Richard
    Hill to put the clown makeup down the other day. Judge Sferrazza seemed to be tiring
    of how flagrant Hill was beign with thing, especially with the reputations of those he
    was dragging into hsi chicanery. I destroyed Hill's contractor on cross examinatino on
    March 23, 2012. Judge Flanagan actually lauged and smiled a couple times at how
    ridiculous Phil Stewart's testimony got. First it was he "assumed I climbed on the truck
    because he felt a depression occur on the vehicle when allegedly the 240 pound
    Coughlin supposedly climbed up on the truck, depsite the fact that Stewart had to admit
    that the modified 2 ton dumptruck had approximately 1500 pounds of a "luxury sedan
    car seat collection" and other personal property...then it was, that "he felt the depression
    lift from the truck after he got out to look in the blind spot behind the truck to see what
    Coughlin was doing....then it was, oh wait, he felt the depression of weight lift before he
    alighted from the vehicle", that he misspoke, then it was "well, I know you climbed on
    the truck because I saw your head atop the contents of the dumptruck in the middle of
    the area above the tailgate in my rear view mirror"....Really? Why go into all that about
    000727
    alighting, and depressions of weight, and "assuming"....Why not just say you saw a
    guy's head in the rear view mirror in a place that would indicate he had climbed on the
    truck rather than demonstrated an ability to levitate? Judge Flanagan was done with
    the whole matter after that. He ruled for me and Hill and Baker knew they better not
    be stupid enough to even try to put on any more evidence, and it didn't seem like Judge
    Flanagan was much interested in their doing so at that point anyway.
    I saw Mr. Clark speak at the Family Law conference in Ely in 2008, I believe, and
    spoke with him on the phone about a year and a half ago when I had a question about
    whether there is a respository of contempt orders issued against attorneys. I honestly
    feel sanctions under NRS 18.010(2)(b) and NRS 22.010(3) are becoming very big
    problems in our field. The access to justice is being curtailed through a bullying
    approach to applying such mechanisms. Rather than allowing market forces dicate that
    rich powerful parties engage in legitimate settlement discussion when the law is not on
    their side (ie, when Merliss and Hill wish to ran a summary eviction procedure through
    a court where doing so is per se impermissible in light of the tenant beign a commercial
    one and the notice failing to allege nonpayment of rent).
    But at my core, what really drives me is a belief in competition. If Hill and Merliss can
    run that game on most people, it is what it is. But I suited up and showed up and
    battled and I deserve to have those skills, efforts, energies, guts, and passions that I
    displayed in doing so translate into something tangible in a court of law, particularl
    where the law and facts were as favorable to my case as they were. I don't deserve
    some compassion fascism witch trial.
    Sincerely
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Fri, 30 Mar 2012 19:01:56 +0000
    Dear Mr. Coughlin,
    000728
    I understand that there is one conviction. I also understand that there are other criminal charges pending that have not
    been resolved. One is set for a trial on April 12, 2012, a trespass charge. I am also aware of contempt of Court Orders.
    This behavior on your part appears to be contrary to the commitment you made when you were conditionally admitted.
    Do you think you need and would benefit from treatment? If so, perhaps we could discuss a stipulation pursuant to SCR
    117 2 for you go on a disability status while you obtain treatment. Such an agreement might be beneficial for you. Please
    let me know if you want to discuss a stipulation.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 30, 2012 10:14 AM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Dear Bar Counsel,
    Just quickly (ie, not an exhaustive list as I have a deadline to meet) the facts that you
    seem to have confused so far include:
    1. Mr. King wrote a 9 am on 3/16/12 to indicate my time to reply to Hill's grievance had
    passed or that he has received my reply, when, in fact, Mr. King had, in writing given
    me until 3 pm on 3/16/12 and had been given notice in writing that I would be
    submitting further materials in reply.
    2. Mr. King asserted that multiple convictions are at issue here. As far as I know there
    is one conviction, in 11 CR 22176, which I report to Bar Counsel Clark and Assistant
    Bar Counsel Machado prior to ever having any involvement with Mr. King. As far as I
    know, a finding of civil contempt under NRS 22.010(3) (summary contempt for
    conduct committed in the court's presence) does not require reporting under SCR 111
    and is not criminal in nature. I could be wrong about that, Judge Flanagan recently
    expressed that there was some uncertainty in the judiciary on that point, but regardless,
    nothing in either Summary Contempt Order contains mention of any conduct that, in
    my opinion, comes within the purview of SCR 111(6), or is tantamount to a "serious
    offense" containing any of the elements cited therein. Its not that I do not take such a
    000729
    thing seriously, however, I just do not read SCR 111 or Mr. Machado's Nevada Lawyer
    article explicating that rule to require reporting, and therefore, be relevant to Mr. King's
    inquiry. That is a theme here. Mr. King's inquiry seems to be about as broad and open
    ended as could me and containing nothing in the way of jurisdictional restrictions, much
    less procedural protection (Mr. King did say he didn't care if I received notice of the
    Judge Holmes grievance, and there was a real troubling tone to the way he said it and
    the look on his face when making that statement). How Hill can file a grievance on
    behalf of Gessin or someone other than Hill has not been made clear. Further
    problematic is the varying standard of proof seemingly applied to the grievances I filed
    and those filed by Hill and Judge Holmes (unattributed hearsay goes a long way when
    coming from Hill and Judge Holmes.....written documentation and transcripts of hearing
    supporting my contentions don't even result in any investigation from Mr. King given
    his quick draw determination that the "clear and convincing" standard would not be
    met....". Further, this is the first Mr. King has made any mention of knowing of the
    seizure of my personal property (including a smart phone) by Judge Holmes (something
    I would hope the Bar would take some offense to given the implications of such a
    practice and for which the Bar may have a duty to report to the Judicial Discipline
    Commission, according to my research). Just today is the first I have ever heard of Mr.
    King asserting he knew, independently of the materials I provided him, that Judge
    Holmes had seized my phone. Richard Cornell, Esq. seemed to think that was
    tantamount to a "seizure", not entering, or booking it into evidence.
    3. Another fact Mr. King seems to have confused is whether, on 3/16/12, as his letter
    indicates, he actually had a copy of his letter of that date emailed to me. It certainly
    was not faxed, despite my requesting it be and despite my having and providing a fax
    number for my office. I wrote all Bar Counsel requesting to be sent any notices or
    correspondences via fax or email in light of my status as a victim of domestic violence
    and regarding the misconduct of the USPS supervisors at my postal station and the
    interference with my mail by the domestic abusers and negligent property manager
    (whom did admit, under oath, that one of her managers had received approval from the
    HOA for my former housemates to be at the 1422 E. 9th St. #2 townhome, where they
    were for over 9 months before this Owner of the property management company
    apparently coaxed a resignation out of the former manager (on January 5th, 2012) who
    entered such an arrangement found out. Suddenly, this owner of Western Nevada
    Management, Sue King, apparently wants everyone to drop everything, excuse her
    negligence and alleged lack of knowledge of that arrangment, and countenance her
    allegedly imploring NV Energy to refuse to allow me to have power turned on one the
    000730
    domestic abuser former housemates had it shut off (NV Energy did wait 7 days before
    finally agreeing to let me have the power turned on in my name....so I did not have
    power for from February 3 to February 10, thanks to Ron Jones, of NV Energy, and,
    apparently, the influence of HOA resident agent Gayle Kern, Esq., LTD and her
    property manager, Sue King, owner of Western Nevada Management), then King
    allegedly implores the USPS to refuse me a mailbox key, which they respond to by
    informing me they are "feds" and "don't have to follow state laws" (like NRS 118A.160
    and 118A.190, etc.) and "aren't going to put up with any more of your garbage" and
    "don't care if you are a lawyer", etc., etc., because (Golden Valley Station employees
    Buck Hyde, Terri James and "Ms." Passot) "we think you are a squatter anyways and
    aren't going to waste our time going out an changing the lock since you will probably
    just get evicted anyhow...". It would be great if the State Bar of Nevada may be able to
    provide some help in getting these monolithic entities to follow the law rather than
    retaliate against a lawyer.
    4. Mr. King seems to have confused what occurred on 3/23/12. I appeared at the State
    Bar Offices to view the "other different judges" grievances that Mr. King would only let
    me view by so appearing in person. I informed him I would not consent to or be able to
    meet with him at that time, but was appearing only to view the documentation in the
    only manner being afforded me by Mr. King's approach. Mr. King now seeks to
    categorize my appearance to view such documentation as a "meeting" along the lines of
    those traditionally held in the informal stage of an inquiry like this. It was not. Further,
    Mr. King's characterization of my document viewing on that date is intellectually
    dishonest, overly hostile and aggressive, and in line with much of the prosecutorial
    misconduct that I have written of recently. There are a number of other such instances
    where material facts have been "confused" by Mr. King, but those will need to be
    addressed at a later date.
    Sincerely,
    Zach Coughlin, Esq.
    000731
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Fri, 30 Mar 2012 15:58:14 +0000
    Dear Mr. Coughlin,
    You ask that I be more careful with the facts and yet you will not respond or discuss the facts with me. Please explain
    what extremely important facts we have wrong. I was aware that your phone and cell phone had been taken as evidence.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 6:53 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I only know of one conviction for a crime, which I reported. Please explain your statement with respect to more than one
    conviction.
    Please try to be more careful with the facts, you have misstated several extremely important facts so far, and it is very
    alarming. Further, do you make every attorney who is found in contempt of court explain such a finding? Is there any duty
    to? Does a summary contempt finding come within the purview of SCR 111? Doesn't Mr. Machado have jurisdiction over the
    criminal conviction which I reported to him months ago? Are you not somewhat alarmed that Judge Nash Holmes'
    complaint/letter to you fails to mention her seizure of the attorney's smart phone, other cell phone, and other personal
    property? Or the fact that she makes extremely prejudicial assertions based upon unattributed hearsay?
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Thu, 29 Mar 2012 23:11:41 +0000
    000732
    Dear Mr. Coughlin,
    My information regarding the criminal convictions and the contempt orders against you is limited. I understand
    you were sentenced to jail on more than one occasion for contempt of court. I also understand that you were
    convicted of a crime on more than one occasion. You are obviously aware of these convictions and contempt
    orders. Please provide me with an explanation of each conviction and of each contempt order.
    Thank you.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 1:46 AM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I recall you making no request for a written response to anything incident to my appearing
    at the Double R location of the State Bar of Nevada to view the grievances from the "other
    different judges". The only one you allowed me to view was the two page letter from
    Judge Nash Holmes. You did not indicate if Judge Nash Holmes attached the copy of the
    2009 Order for Sanctions by Judge Gardner to Judge Holmes' letter, or whether that was a
    separate complaint, and if so, by whom was it submitted. Please do so in writing and
    provide a date by which I must submit a response. Please also copy me via email and or
    fax on any other materials submitted with those Complaints, grievances, or letters (it seems
    patently unfair for you to say those are confidential and of limits to me, really). You know
    as well as I do that I was not hostile or intimidating to you and that we did not have a
    "meeting". I indicated to you at the outset of my appearing at your offices that I was only
    there to view the grievances or complaints, and that I would not be able to undertake any
    meeting with you that day. I am 6 foot 4 inches tall and 250 pounds. If you think this is
    the first time somebody has tried to play the old "oh you were trying to intimidate me" card
    on me, you are mistaken. I have been socialized to be docile and calm given my size, and
    really, the idea that my size has any real effecdt on any legal proceeding is just silly, but,
    nonetheless, I have always gone out of my way to avoid the appearance of being "the big
    bullying guy". Many, many people who have known me for the 30 some odd years I have
    lived in this community attest to that, in and out of legal circles. I realize you wanted to
    get more accomplished then and there, and that you have previously expressed
    000733
    disatisfaction at the idea that I would have actually done any research in preparation for
    any future meeting with you, but I assure you, I don't subscribe to the coerced confession
    approach that is so favored by so many prosecutors and Bar Counsel. I will be litigating
    this fully. And I will not be forced into hiring for $5,000 a "lawyer Kevorkian" hand picked
    by a strip club owning Character and Fitness Committee bully, whom appears at the hearing
    and brags about how he is doing it "pro bono".
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Tue, 27 Mar 2012 16:26:11 +0000
    March 27, 2012
    Dear Mr. Coughlin,
    Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived
    you as very hostile and even threatening. Under those circumstances I felt it better to
    terminate the meeting.
    If it was not your intent to appear hostile or to attempt to intimidate me then you might
    consider how I perceived your conduct. I had intended to try to listen to you and determine
    how my office could best
    help you address the grievances that I have received. You said you did not have time and
    simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if
    you received the
    000734
    information I sent to you, I said I did not care how your received it, so long as you received it. I
    do care that you receive the information that I send to you. As I attempted to explain, I will be
    meeting with a panel
    to have them make a determination about the grievances that have been made against you by
    Mr. Hill and the Judge from Department 3 that you read at my office. I have asked for a written
    response to those
    grievances. In response I received many e-mails with attachments. I will soon be sharing the
    grievances with a disciplinary panel and will advise them of your responses to date.
    I will keep you advised of the panels determination.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 5:35 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: my attempt to be provided access to the grievances filed today
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted
    to be provided access the the various "other different judges" grievances that I, prior to last Friday, was completely unaware
    of. I have sent you several written correspondences detailing the tampering and other problems with my USPS mail incident to
    the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash
    Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any
    000735
    other judges from whom you have received any other similar such materials and further refused to allow me to view and such
    items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told
    me you didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters,
    grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am
    considering different attorneys to represent me right now, and indicated I need these materials to prepare for any future
    meeting with you. My records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on
    that letter via email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/30/12 10:14 AM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel,
    Just quickly (ie, not an exhaustive list as I have a deadline to meet) the facts that you
    seem to have confused so far include:
    1. Mr. King wrote a 9 am on 3/16/12 to indicate my time to reply to Hill's grievance had
    passed or that he has received my reply, when, in fact, Mr. King had, in writing given
    me until 3 pm on 3/16/12 and had been given notice in writing that I would be
    submitting further materials in reply.
    2. Mr. King asserted that multiple convictions are at issue here. As far as I know there
    is one conviction, in 11 CR 22176, which I report to Bar Counsel Clark and Assistant
    Bar Counsel Machado prior to ever having any involvement with Mr. King. As far as I
    know, a finding of civil contempt under NRS 22.010(3) (summary contempt for
    conduct committed in the court's presence) does not require reporting under SCR 111
    and is not criminal in nature. I could be wrong about that, Judge Flanagan recently
    expressed that there was some uncertainty in the judiciary on that point, but regardless,
    nothing in either Summary Contempt Order contains mention of any conduct that, in
    my opinion, comes within the purview of SCR 111(6), or is tantamount to a "serious
    offense" containing any of the elements cited therein. Its not that I do not take such a
    thing seriously, however, I just do not read SCR 111 or Mr. Machado's Nevada Lawyer
    000736
    article explicating that rule to require reporting, and therefore, be relevant to Mr. King's
    inquiry. That is a theme here. Mr. King's inquiry seems to be about as broad and open
    ended as could me and containing nothing in the way of jurisdictional restrictions, much
    less procedural protection (Mr. King did say he didn't care if I received notice of the
    Judge Holmes grievance, and there was a real troubling tone to the way he said it and
    the look on his face when making that statement). How Hill can file a grievance on
    behalf of Gessin or someone other than Hill has not been made clear. Further
    problematic is the varying standard of proof seemingly applied to the grievances I filed
    and those filed by Hill and Judge Holmes (unattributed hearsay goes a long way when
    coming from Hill and Judge Holmes.....written documentation and transcripts of hearing
    supporting my contentions don't even result in any investigation from Mr. King given
    his quick draw determination that the "clear and convincing" standard would not be
    met....". Further, this is the first Mr. King has made any mention of knowing of the
    seizure of my personal property (including a smart phone) by Judge Holmes (something
    I would hope the Bar would take some offense to given the implications of such a
    practice and for which the Bar may have a duty to report to the Judicial Discipline
    Commission, according to my research). Just today is the first I have ever heard of Mr.
    King asserting he knew, independently of the materials I provided him, that Judge
    Holmes had seized my phone. Richard Cornell, Esq. seemed to think that was
    tantamount to a "seizure", not entering, or booking it into evidence.
    3. Another fact Mr. King seems to have confused is whether, on 3/16/12, as his letter
    indicates, he actually had a copy of his letter of that date emailed to me. It certainly
    was not faxed, despite my requesting it be and despite my having and providing a fax
    number for my office. I wrote all Bar Counsel requesting to be sent any notices or
    correspondences via fax or email in light of my status as a victim of domestic violence
    and regarding the misconduct of the USPS supervisors at my postal station and the
    interference with my mail by the domestic abusers and negligent property manager
    (whom did admit, under oath, that one of her managers had received approval from the
    HOA for my former housemates to be at the 1422 E. 9th St. #2 townhome, where they
    were for over 9 months before this Owner of the property management company
    apparently coaxed a resignation out of the former manager (on January 5th, 2012) who
    entered such an arrangement found out. Suddenly, this owner of Western Nevada
    Management, Sue King, apparently wants everyone to drop everything, excuse her
    negligence and alleged lack of knowledge of that arrangment, and countenance her
    allegedly imploring NV Energy to refuse to allow me to have power turned on one the
    domestic abuser former housemates had it shut off (NV Energy did wait 7 days before
    000737
    finally agreeing to let me have the power turned on in my name....so I did not have
    power for from February 3 to February 10, thanks to Ron Jones, of NV Energy, and,
    apparently, the influence of HOA resident agent Gayle Kern, Esq., LTD and her
    property manager, Sue King, owner of Western Nevada Management), then King
    allegedly implores the USPS to refuse me a mailbox key, which they respond to by
    informing me they are "feds" and "don't have to follow state laws" (like NRS 118A.160
    and 118A.190, etc.) and "aren't going to put up with any more of your garbage" and
    "don't care if you are a lawyer", etc., etc., because (Golden Valley Station employees
    Buck Hyde, Terri James and "Ms." Passot) "we think you are a squatter anyways and
    aren't going to waste our time going out an changing the lock since you will probably
    just get evicted anyhow...". It would be great if the State Bar of Nevada may be able to
    provide some help in getting these monolithic entities to follow the law rather than
    retaliate against a lawyer.
    4. Mr. King seems to have confused what occurred on 3/23/12. I appeared at the State
    Bar Offices to view the "other different judges" grievances that Mr. King would only let
    me view by so appearing in person. I informed him I would not consent to or be able to
    meet with him at that time, but was appearing only to view the documentation in the
    only manner being afforded me by Mr. King's approach. Mr. King now seeks to
    categorize my appearance to view such documentation as a "meeting" along the lines of
    those traditionally held in the informal stage of an inquiry like this. It was not. Further,
    Mr. King's characterization of my document viewing on that date is intellectually
    dishonest, overly hostile and aggressive, and in line with much of the prosecutorial
    misconduct that I have written of recently. There are a number of other such instances
    where material facts have been "confused" by Mr. King, but those will need to be
    addressed at a later date.
    Sincerely,
    Zach Coughlin, Esq.
    000738
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Fri, 30 Mar 2012 15:58:14 +0000
    Dear Mr. Coughlin,
    You ask that I be more careful with the facts and yet you will not respond or discuss the facts with me. Please explain
    what extremely important facts we have wrong. I was aware that your phone and cell phone had been taken as evidence.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 6:53 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I only know of one conviction for a crime, which I reported. Please explain your statement with respect to more than one
    conviction.
    Please try to be more careful with the facts, you have misstated several extremely important facts so far, and it is very
    alarming. Further, do you make every attorney who is found in contempt of court explain such a finding? Is there any duty
    to? Does a summary contempt finding come within the purview of SCR 111? Doesn't Mr. Machado have jurisdiction over the
    criminal conviction which I reported to him months ago? Are you not somewhat alarmed that Judge Nash Holmes'
    complaint/letter to you fails to mention her seizure of the attorney's smart phone, other cell phone, and other personal
    property? Or the fact that she makes extremely prejudicial assertions based upon unattributed hearsay?
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Thu, 29 Mar 2012 23:11:41 +0000
    Dear Mr. Coughlin,
    000739
    My information regarding the criminal convictions and the contempt orders against you is limited. I understand
    you were sentenced to jail on more than one occasion for contempt of court. I also understand that you were
    convicted of a crime on more than one occasion. You are obviously aware of these convictions and contempt
    orders. Please provide me with an explanation of each conviction and of each contempt order.
    Thank you.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 1:46 AM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I recall you making no request for a written response to anything incident to my appearing
    at the Double R location of the State Bar of Nevada to view the grievances from the "other
    different judges". The only one you allowed me to view was the two page letter from
    Judge Nash Holmes. You did not indicate if Judge Nash Holmes attached the copy of the
    2009 Order for Sanctions by Judge Gardner to Judge Holmes' letter, or whether that was a
    separate complaint, and if so, by whom was it submitted. Please do so in writing and
    provide a date by which I must submit a response. Please also copy me via email and or
    fax on any other materials submitted with those Complaints, grievances, or letters (it seems
    patently unfair for you to say those are confidential and of limits to me, really). You know
    as well as I do that I was not hostile or intimidating to you and that we did not have a
    "meeting". I indicated to you at the outset of my appearing at your offices that I was only
    there to view the grievances or complaints, and that I would not be able to undertake any
    meeting with you that day. I am 6 foot 4 inches tall and 250 pounds. If you think this is
    the first time somebody has tried to play the old "oh you were trying to intimidate me" card
    on me, you are mistaken. I have been socialized to be docile and calm given my size, and
    really, the idea that my size has any real effecdt on any legal proceeding is just silly, but,
    nonetheless, I have always gone out of my way to avoid the appearance of being "the big
    bullying guy". Many, many people who have known me for the 30 some odd years I have
    lived in this community attest to that, in and out of legal circles. I realize you wanted to
    get more accomplished then and there, and that you have previously expressed
    disatisfaction at the idea that I would have actually done any research in preparation for
    any future meeting with you, but I assure you, I don't subscribe to the coerced confession
    000740
    approach that is so favored by so many prosecutors and Bar Counsel. I will be litigating
    this fully. And I will not be forced into hiring for $5,000 a "lawyer Kevorkian" hand picked
    by a strip club owning Character and Fitness Committee bully, whom appears at the hearing
    and brags about how he is doing it "pro bono".
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Tue, 27 Mar 2012 16:26:11 +0000
    March 27, 2012
    Dear Mr. Coughlin,
    Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived
    you as very hostile and even threatening. Under those circumstances I felt it better to
    terminate the meeting.
    If it was not your intent to appear hostile or to attempt to intimidate me then you might
    consider how I perceived your conduct. I had intended to try to listen to you and determine
    how my office could best
    help you address the grievances that I have received. You said you did not have time and
    simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if
    you received the
    information I sent to you, I said I did not care how your received it, so long as you received it. I
    000741
    do care that you receive the information that I send to you. As I attempted to explain, I will be
    meeting with a panel
    to have them make a determination about the grievances that have been made against you by
    Mr. Hill and the Judge from Department 3 that you read at my office. I have asked for a written
    response to those
    grievances. In response I received many e-mails with attachments. I will soon be sharing the
    grievances with a disciplinary panel and will advise them of your responses to date.
    I will keep you advised of the panels determination.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 5:35 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: my attempt to be provided access to the grievances filed today
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted
    to be provided access the the various "other different judges" grievances that I, prior to last Friday, was completely unaware
    of. I have sent you several written correspondences detailing the tampering and other problems with my USPS mail incident to
    the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash
    Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any
    other judges from whom you have received any other similar such materials and further refused to allow me to view and such
    items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told
    me you didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters,
    000742
    grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am
    considering different attorneys to represent me right now, and indicated I need these materials to prepare for any future
    meeting with you. My records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on
    that letter via email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    000743
    Subject: rpd sargent siIre loses Z coughlin's dog Jackson is gone voicemail Irom (775) 762-1595 at
    4:27 PM
    Zach Coughlin (zachcoughlinhotmail.com) 3/29/12
    To: renopdcoplogic.com, schultztcityoIreno.com, kadlicjreno.gov, renodirectreno.gov,
    cityclerkreno.gov, nvrenopdcoplogic.com, thewzreno.gov, siIrepreno.gov, ednpri.org,
    marybarkbarkyahoo.com, geoIgileshotmail.com, carcoughstergmail.com,
    carly.coughlincrcgmail.com, melissa.l.ulloagmail.com, loriwnvbar.org
    Outlook Active View
    Reno Police Department Sargent Paul SiIre arrests Reno Attorney Ior misuse oI 911
    Play video
    could not get suzanne ramos to do anything beyond hug Reno City Attorney Jill Drake while giggling
    like a school girl, or cackle menacingly along with Reno City Attorney Dan Wong. Nice goin'.
    00:03:55
    Added on 3/19/12
    507 views
    Dear City oI Reno Animal Control, SPCA, and Reno Police Department, and Reno City Attorney's
    OIIice,
    Please help me Iind my dog, and please place a copy oI this complaint in RPD Sargent Paul SiIre's
    employment/personnel Iile. Also, dear city clerk, i would like a date to dispute all parking tickets or
    traIIic citations outstanding and I believe the parking ticket Irom 1/12/12 shoudl be rescinded given it
    occured while i was in custody on the jaywalking arrest by RPD Sargent SiIre, the one who just lost my
    dog, and who also arrested me Ior misues oI 911 incident to a 1/14/12 wherein i called to report Iurther
    domestic violence against me, including the mysterious disappearance oI my dog and where SiIre made
    sarcastic statements about me and my dog.
    t: Z coughlin's dog Jackson is goneFwd: New voicemail Irom (775) 762-1595 at 4:27 PM
    I received a call Irom someone claiming the Iound Jackson, but that they then took oII his
    collar/harness which had his dog tag on it which had my phone number engraved in it 775 338 8118.
    This 3.5 year old Pekingnese has a micro chip identiIier embedded in it. Please help me Iind him.
    my dog Jackson was adopted Irom the spca with an adoption id oI 13142.
    his microchip number oI 022261310 with the dhpp oI 3/10/11 and bb oI 3/109/11 he has all his
    vaccinations and is a cream colored pekingnese whose collar/harness was removed by the people who
    Iound them whose phone number is included herein
    IThe way the Reno PD treated the 911 call oI 3/27/12 and allowed my dog, Jackson, to escape is
    reminiscent oI the RPD approach to situations where Richard G. Hill, Esq. makes a report oI some
    criminal violation, in comparision to when someone reports a criminal violation by Richard G. Hill,
    Esq. Some might say when Hill's Iiles a report or signs a criminal complaint, the RPD treats it as a
    "violation Io criminal law, a police matter", but that when anyone points out Hill's attempts at extortion,
    bribery, abuse oI process, larceny, withholding one's state issued identiIication, perjury, etc., etc., the
    RPD simply washes their hands clean oI the complainants request, indicating, "sorry, buddy, that's a
    civil matter, your remedy is with the courts...". So, when Hill wants a Temporary Protection Order
    1/5
    000744
    against Zach Coughlin, because, gosh darn it, Coughlin is Iimliming and collectding evidence oI the
    personal property that Hill's contractor, Phil Stewart's crew is throwing away Irom Coughlin's Iormer
    home law oIIice, in anticipation oI a wrongIul eviction lawsuit against Hill and his Beverly Hill's High
    School graduate CaliIornia Neurosurgeon landlord client, Matt Merliss (now on appeal in CV11-03628,
    wherein Judge Flanagan oI Department 7 recently denied one oI Hill's "quadruple jeopardy" cheap
    shots at Coughlin, by denying Hill's Motion Ior Order to Show Cause (now that just leaves the baseless
    State Bar oI Nevada grievance Hill Iiled on behalI oI individuals whom are not even his clients,
    wherein he cites unattributed hearsay and Ior which he Iailed to attach an actual signature thereto, and
    which consists chieIly oI innuendo and complaining that Coughlin dared to actually request a Iee
    waiver Irom the District Court to Iile a complaint, despite doing so being an acceptable practice as set
    Iorth in statute in NRS 12.015). So, where Coughlins peaceIully Iilming on a sidewalk, the RPD
    doesn't tell Richard Hill, Esq. that "its a civil matter, sorry your remedy is with the courts", but rather,
    Sargent Paul SiIre orders a young trainee , OIIicer Leedy, to walk up to Coughlin unprovoked, grab the
    video camera out oI his hand prior to making any sort oI attempt to engage Coughlin or otherwise
    explain why the RPD would be, in a matter oI two seconds, applying excessive Iorce to Coughlin's bent
    back wrists and obstructing justice by turning oII his video camera despite Coughlin's express
    insistance that Sargent Paul SiIre reIrain Irom doing so.
    Incidentally, the RPD Sargent whom charged me with the "misuse oI 911" gross misdemeanor that I am
    currently Iacing, plagued wtih the representation oI one Biray Dogan in, actually managed to lose my
    dog on 3/27/12, when Sargent SiIre was responding to a true instance oI misuse oI 911, where Zach
    Coughlin's "sister" Carly Noel Coughlin, called 911 to report that Mr. Coughlin had arrived at Carly's
    house, where she had invited him to drop oI his pekingnese dog, Jackson Pawluck, iI he ever wanted
    Ms. Coughlin's "Iriend" to watch Jackson again. Ms. Coughlin indicated that "the peopel who watched
    him last time cried when I went to go get him, so I don't really wanna do this again" despite her earlier
    indication that she would. Ms. Coughlin, grew annoyed with Mr. Coughlin's request and renegged on
    her oIIer to transport the dog to the disabled woman to whom it brought so much joy, and her daughter.
    Mr. Coughlin walked back to his car with his dog to leave, but his car was apparently to low on gas to
    start. Ms. Coughlin continued to regale Mr. Coughlin with her hypocritical, saturnine approach to
    human relations (this despite her working in the mental health care Iield, apparently, and perhaps, most
    troubling). Ms. Coughlin threatened to call 911 iI Mr. Coughlin did not leave immediately, Mr.
    Coughlin said he would, asked what on earth she would be calling 911 about, and promptly attempted
    to start his car to leave. It would not, and Ms. Coughlin drove oII. Mr. Coughlin, knowing Iull well that
    his sister would in Iact be calling 911, and that she was well aware oI Mr. Coughlin's recent trials and
    tribulations with local law enIorcement in light oI Mr. Coughlin's aberrant belieI that people in this
    county actually do have rights and that we do not live in a police state), and that she, in Iact, sought to
    Iurther cause Mr. Coughlin discord with law enIorcement, somethign which should would, oI course,
    later "remix" as her "concern" Ior his "welIare". Sargent SiIre, whom Ior some reason was assigned to
    answer this call by the RPD, echoed these sentiments to Mr. Coughlin and provided his proIessional
    opinion that Ms. Coughlin did "care so very deeply" about Mr. Coughlin. Apparently, this proIound
    concern was also exhibited in Ms. Coughlin calling 911 a second time the night oI 3/27/12 when Mr.
    Coughlin returned some two hours laters to his vehicle, parked on Keele St., on a public street, with a
    gas can with halI a gallon oI gas, intending to place it in his care and drive oI, hopeIully beIore, once
    again, being abused by local law enIorcement, like Sargnet SiIre, whom was laughing on 1/14/12 when
    he arrested Coughlin and charged him with a gross misdemeanor, "misuse oI 911". Ms. Coughlin oI
    course sought to have Mr. Coughlin arrested Ior nothing and to Iurther involve Mr. Coughlin with local
    law enIorcement, though that probably has nothing to do with her various bitter statements over the
    2/5
    000745
    years about how It has not been Iound and may well be dead given the proximity oI traIIic and the
    dog's inexperience in dealing with it. How Sargent SiIre could possibly lecture Mr. Coughlin Ior over
    an hour, perhaps causing Coughlin to miss an electronic Iiling deadline in an important legal matter is
    unclear, particularly where Sargent SiIre admitted to Coughlin that Ms. Coughlin admitted Mr.
    Coughlin did not touch her, harm her, or threaten her in any way. How it is that Ms. Coughlin is not
    guilty oI "misuse oI 911" whereas Mr. Coughlin was subject to a custodial arrest Ior the very same
    charge, by the very same RPD Sargent, Paul SiIre, is just not very clear. .. Anyways, Sargent Paul SiIre
    had to admit to Zach Coughlin, on 3/27/12, that he and his RPD associate had allowed Mr. Coughlin's
    dog Jackson, to escape Irom Ms. Coughlins unlocked residence, where Mr. Coughlin had placed the
    dog immediately beIore attempting to go walk to a gas station and get gas, given Mr. Coughlin's
    reasonable believe that iI he leIt his dog in his parked car, outside Ms. Coughlin's house, he would be
    arrested by the RPD Ior "dog endangerment or neglect or animal cruelty"....Amazingly, even aIter
    letting Mr. Coughlin's dog escape Irom Ms. Coughlin's house, and perhaps be hit by a car, Sargent SiIre
    still saw Iit to lecture Mr. Coughlin and point out the benevolence oI the police state Sargent SiIre and
    those like him currently have in place in Washoe County and the City oI Reno. But, RPD Sargent SiIre
    was sure to point out to attorney Coughlin how very proIoundly deep Dr. Coughlin and Carly N.
    Coughlin's concern was Ior attorney Coughlin. However, their concern is apparently not so signiIicant
    as to allow, say, attorney to store a plastic garbage bag Iull oI expensive suits under Dr. Coughlin's
    Caughlin Ranch home, which has 5 empty bedrooms and a "mudroom" the size oI an aircraIt hanger
    under the home Ior storing things. AIter the bag oI suits being beneath Dr. Coughlin's home Ior
    approximately a week they outwore their welcome, prompting Dr. Coughlin and his wiIe, Monica
    Morelli Coughlin to inquire as to when attorney Coughlin might be able to remove such bag Irom the
    "mudroom" underneath their home, which, again, has 5 empty bedrooms. Dr. Coughlin previously
    telephone the Dean oI the UNLV Boyd School oI law to deIame his son, whereupon Dean Richard
    Morgan, ever the risk minimizer middle managing, business attorney, cutthroat, educator that is he,
    promptly called up the State Bar to report as much. And would Carly Noel Coughlin be alright with
    allowing her brother, attorney Coughlin to store, say, a guitar or a box oI papers at her home Ior a little
    while? OI course she wouldn't. Though, Miss Carly sure will put on a show oI "concern" Ior Sargent
    SiIre when he shows up, twice.....Oh, but how very much they want to "help". Just only with
    psychobabble and Iaux concern and selI serving power hungry, manipulative ego trips, rather than any
    discernible, tangible beneIit to the tasks at hand. Dr. Coughlin is Reno City Attorney John Kadlic's
    personal physician, and Kadlic is godIather to the daugther Dr. Coughlin had with Monica Morelli
    Coughlin, oI Morelli v. Morelli Iame:
    http://www.leagle.com/xmlResult.aspx?
    xmldoc19861424720P2d70411419.xml&docbaseCSLWAR2-1986-2006
    In Morelli v. Morelli, Nevada's Iirst Italian Neurosurgeon was sued by his now attorney 18 year old
    daugther Ior the cost oI her college and law school tuition, which was expressly set Iorth as a
    stipulation in the marital settlement agreement in that matter. The daughter was awarded the tution and
    Iather and daughter never spoke again during Dr. Morelli's liIetime, some 20 more years.
    Ironically, the "misuse oI 911" charged stemmed Irom my calling about the mysterious and menacing
    disappearance oI my dog (whom I appeared with in the December 2012 issue oI the Nevada Lawyer),
    which occured in the context oI a continuous barrage oI domestic violence to which I was exposed,
    3/5
    000746
    thorugh the Iirst six weeks oI 2012, by the actions oI my then housemates, and Ior which I attempted to
    obtain protection or justice Irom by contacting the RPD, including Sargent Zach Thew (allegedly, I was
    arrested while allegedly attempting to contact Sargent Thew, in accordance with Sargent Thew's
    express instructions that I do so
    http://www.youtube.com/watch?voU3tkRR0RA
    ....which Biray Dogan knows, but Ior which Mr. Dogan has reIused to Iile any Motion to Dismiss or
    other action on my behalI, rather, Mr. Dogan seeks to retaliate against me and to embarass me with yet
    another retaliatory "competency" evaluation, despite the Iact that I passed, with Ilying colors, the one
    administered by Libby Heijne aIter Deputy Washoe County Public DeIendenr Cary Hylin ordered one
    (subsequent Iilings by the WCPD indicated that a "hearing" took place wherein such an evaluation was
    requested by Hylin and orderd by Judge Jack Schroeder, yet no such "hearing" took place);
    RPD Sargent SiIre (whom actually makes more money through his public employment than most
    District Court Judges) arrested me another time, making it twice in two days, on January 12th, 2012 Ior
    "jaywalking, then he obstructed justice by turning oII my video camera while RPD OIIicer Look and
    OIIicer Leedy were using excessive Iorce (completely out oI the blue and with zero justiIication Ior
    doing so, as evinced by the video itselI) on me.
    http://www.youtube.com/watch?vgBu9zIlGALE&Ieaturerelated
    Deputy District Attorney Zach NiIong, er, Zach Young, Esq., has been extremely resistant to any sort oI
    plea bargaining in either case, as he has been in the matter Ior which Deputy Public DeIender Joe
    Goodnight, Esq. is "representing" me as my "attorney". That matter RCR also included police
    misconduct by the Reno Police Department, by OIIicers Ron Rosa and Nick Duralde. Where would
    Reno attorney Zach Coughlin, Esq. be iI there was not video tape oI all oI this police misconduct?
    http://www.youtube.com/watch?v5PR7q4OI5b0&Ieaturerelated
    Despite having this video, DA Zach Young retaliated against Coughlin Ior Coughlin's Iiling a NRCP 11
    Motion against both Goodnight and Young by amending the criminal complaint to overcharge some
    more. No, rather DA Zach Young and the RPD see the witness tampering and attempts to dissuade
    Nicole Watson Irom oIIering any insight into the wrongIul arrest oI 8/20/12 by Nicholas Duradle as "a
    civil matter", not a "criminal one". Heck, the RPD doesn't even see battery, assault, aggravated assault,
    or domestic violence as "criminal in nature" when these things happen to pesky First Amendment
    attorney Zachary Barker Coughlin, Esq., ...no, rather, those are matters oI a "civil nature" and
    Coughlin's "remedy is with the court's", so sayeth RPD OIIicer Stacey Gardner, Sargent Monica Lopez,
    OIIicer Mcquattry, OIIicer Look and Leedy and Delvecchio, OIIicer Warren, etc., etc.,
    4/5
    000747
    Incidentally, it would be helpIul iI an entity like Washoe Legal Services took an aggresive approach to
    advocating on behalI oI tenants'.....Washoe Legal Services Executive Director Paul Elcano has
    reportedly call Dr. Coughlin in an attempt to inIluence attorney Coughlin to close the case Coughlin
    has against WLS Ior wrongIul termination.
    Its a good thing Nevada has so many brave First Amendment attorney's like JM Devoy and his
    associate Marc Randazza, neither oI whom have any association with Mr. Coughlin. I, Mr. Coughlin
    am aware that it is slightly awkward to write this switching between the Iirst and third person, however,
    the exigencies and economics oI solo law practice were at play in doing so.
    At least there isn't much oI a societal cost to the legally questionable manner in which evictions are
    decided and carried out in Washoe County:
    http://www.youtube.com/watch?vssE0FWHFNEY
    http://www.youtube.com/watch?vKjG2aEjslr4
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    Date: Thu, 29 Mar 2012 18:29:18 -0700
    Subject: Z coughlin's dog Jackson is goneFwd: New voicemail Irom (775) 762-1595 at 4:27 PM
    To:
    ---------- Forwarded message ----------
    From: Google Voice voice-noreplygoogle.com~
    Date: Thu, Mar 29, 2012 at 4:31 PM
    Subject: New voicemail Irom (775) 762-1595 at 4:27 PM
    Voicemail Irom: (775) 762-1595 at 4:27 PM
    Transcript not available
    Play message
    5/5
    000748
    Print Close
    RE: my attempt to be provided access to the grievances filed
    today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/29/12 6:52 PM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Mr. King,
    I only know of one conviction for a crime, which I reported. Please explain your statement with respect
    to more than one conviction.
    Please try to be more careful with the facts, you have misstated several extremely important facts so
    far, and it is very alarming. Further, do you make every attorney who is found in contempt of court
    explain such a finding? Is there any duty to? Does a summary contempt finding come within the
    purview of SCR 111? Doesn't Mr. Machado have jurisdiction over the criminal conviction which I
    reported to him months ago? Are you not somewhat alarmed that Judge Nash Holmes' complaint/letter
    to you fails to mention her seizure of the attorney's smart phone, other cell phone, and other personal
    property? Or the fact that she makes extremely prejudicial assertions based upon unattributed
    hearsay?
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Thu, 29 Mar 2012 23:11:41 +0000
    Dear Mr. Coughlin,
    My information regarding the criminal convictions and the contempt orders against you is limited. I understand
    you were sentenced to jail on more than one occasion for contempt of court. I also understand that you were
    convicted of a crime on more than one occasion. You are obviously aware of these convictions and contempt
    orders. Please provide me with an explanation of each conviction and of each contempt order.
    Thank you.
    000749
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 29, 2012 1:46 AM
    To: Patrick King; Glenn Machado; David Clark
    Subject: RE: my attempt to be provided access to the grievances filed today
    Mr. King,
    I recall you making no request for a written response to anything incident to my appearing at the
    Double R location of the State Bar of Nevada to view the grievances from the "other different
    judges". The only one you allowed me to view was the two page letter from Judge Nash Holmes.
    You did not indicate if Judge Nash Holmes attached the copy of the 2009 Order for Sanctions by
    Judge Gardner to Judge Holmes' letter, or whether that was a separate complaint, and if so, by whom
    was it submitted. Please do so in writing and provide a date by which I must submit a response.
    Please also copy me via email and or fax on any other materials submitted with those Complaints,
    grievances, or letters (it seems patently unfair for you to say those are confidential and of limits to
    me, really). You know as well as I do that I was not hostile or intimidating to you and that we did
    not have a "meeting". I indicated to you at the outset of my appearing at your offices that I was only
    there to view the grievances or complaints, and that I would not be able to undertake any meeting
    with you that day. I am 6 foot 4 inches tall and 250 pounds. If you think this is the first time
    somebody has tried to play the old "oh you were trying to intimidate me" card on me, you are
    mistaken. I have been socialized to be docile and calm given my size, and really, the idea that my
    size has any real effecdt on any legal proceeding is just silly, but, nonetheless, I have always gone
    out of my way to avoid the appearance of being "the big bullying guy". Many, many people who
    have known me for the 30 some odd years I have lived in this community attest to that, in and out of
    legal circles. I realize you wanted to get more accomplished then and there, and that you have
    previously expressed disatisfaction at the idea that I would have actually done any research in
    preparation for any future meeting with you, but I assure you, I don't subscribe to the coerced
    confession approach that is so favored by so many prosecutors and Bar Counsel. I will be litigating
    this fully. And I will not be forced into hiring for $5,000 a "lawyer Kevorkian" hand picked by a
    strip club owning Character and Fitness Committee bully, whom appears at the hearing and brags
    about how he is doing it "pro bono".
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    000750
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Tue, 27 Mar 2012 16:26:11 +0000
    March 27, 2012
    Dear Mr. Coughlin,
    Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived
    you as very hostile and even threatening. Under those circumstances I felt it better to
    terminate the meeting.
    If it was not your intent to appear hostile or to attempt to intimidate me then you might
    consider how I perceived your conduct. I had intended to try to listen to you and determine
    how my office could best
    help you address the grievances that I have received. You said you did not have time and
    simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if
    you received the
    information I sent to you, I said I did not care how your received it, so long as you received it. I
    do care that you receive the information that I send to you. As I attempted to explain, I will be
    meeting with a panel
    to have them make a determination about the grievances that have been made against you by
    Mr. Hill and the Judge from Department 3 that you read at my office. I have asked for a written
    response to those
    grievances. In response I received many e-mails with attachments. I will soon be sharing the
    grievances with a disciplinary panel and will advise them of your responses to date.
    000751
    I will keep you advised of the panels determination.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 5:35 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: my attempt to be provided access to the grievances filed today
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted
    to be provided access the the various "other different judges" grievances that I, prior to last Friday, was completely unaware
    of. I have sent you several written correspondences detailing the tampering and other problems with my USPS mail incident to
    the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash
    Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any
    other judges from whom you have received any other similar such materials and further refused to allow me to view and such
    items. I asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told
    me you didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters,
    grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am
    considering different attorneys to represent me right now, and indicated I need these materials to prepare for any future
    meeting with you. My records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on
    that letter via email on that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    000752
    Print Close
    RE: my attempt to be provided access to the grievances filed today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/29/12 1:46 AM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Mr. King,
    I recall you making no request for a written response to anything incident to my appearing at the Double R location of the
    State Bar of Nevada to view the grievances from the "other different judges". The only one you allowed me to view was the
    two page letter from Judge Nash Holmes. You did not indicate if Judge Nash Holmes attached the copy of the 2009 Order for
    Sanctions by Judge Gardner to Judge Holmes' letter, or whether that was a separate complaint, and if so, by whom was it
    submitted. Please do so in writing and provide a date by which I must submit a response. Please also copy me via email and
    or fax on any other materials submitted with those Complaints, grievances, or letters (it seems patently unfair for you to say
    those are confidential and of limits to me, really). You know as well as I do that I was not hostile or intimidating to you and
    that we did not have a "meeting". I indicated to you at the outset of my appearing at your offices that I was only there to view
    the grievances or complaints, and that I would not be able to undertake any meeting with you that day. I am 6 foot 4 inches
    tall and 250 pounds. If you think this is the first time somebody has tried to play the old "oh you were trying to intimidate
    me" card on me, you are mistaken. I have been socialized to be docile and calm given my size, and really, the idea that my
    size has any real effecdt on any legal proceeding is just silly, but, nonetheless, I have always gone out of my way to avoid the
    appearance of being "the big bullying guy". Many, many people who have known me for the 30 some odd years I have lived
    in this community attest to that, in and out of legal circles. I realize you wanted to get more accomplished then and there,
    and that you have previously expressed disatisfaction at the idea that I would have actually done any research in preparation
    for any future meeting with you, but I assure you, I don't subscribe to the coerced confession approach that is so favored by so
    many prosecutors and Bar Counsel. I will be litigating this fully. And I will not be forced into hiring for $5,000 a "lawyer
    Kevorkian" hand picked by a strip club owning Character and Fitness Committee bully, whom appears at the hearing and
    brags about how he is doing it "pro bono".
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Tue, 27 Mar 2012 16:26:11 +0000
    March 27, 2012
    Dear Mr. Coughlin,
    Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived you as very hostile and
    even threatening. Under those circumstances I felt it better to terminate the meeting.
    000753
    If it was not your intent to appear hostile or to attempt to intimidate me then you might consider how I perceived
    your conduct. I had intended to try to listen to you and determine how my office could best
    help you address the grievances that I have received. You said you did not have time and simply wanted to argue
    about your receipt of e-mail or mail. I did not say that I did not care if you received the
    information I sent to you, I said I did not care how your received it, so long as you received it. I do care that you
    receive the information that I send to you. As I attempted to explain, I will be meeting with a panel
    to have them make a determination about the grievances that have been made against you by Mr. Hill and the Judge
    from Department 3 that you read at my office. I have asked for a written response to those
    grievances. In response I received many e-mails with attachments. I will soon be sharing the grievances with a
    disciplinary panel and will advise them of your responses to date.
    I will keep you advised of the panels determination.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 5:35 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: my attempt to be provided access to the grievances filed today
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted to be provided access the the
    various "other different judges" grievances that I, prior to last Friday, was completely unaware of. I have sent you several written correspondences detailing
    the tampering and other problems with my USPS mail incident to the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask
    that you copy my on all correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash Holmes. Did
    you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any other judges from whom you have received
    any other similar such materials and further refused to allow me to view and such items. I asked for a copy of the large box of documents, and other FOIA
    request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated that I did not have a right to review such
    complaint letters, grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am considering different
    attorneys to represent me right now, and indicated I need these materials to prepare for any future meeting with you. My records incidate that your letter of
    3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know if you received any sort of "return
    to sender" letter for that mailing.
    000754
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    FW: my attempt to be provided access to the grievances filed today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 3/28/12 6:29 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    15 attachments
    CV11-03628 Coughlin v Merliss 3 26 2012 Richard G. Hil's Motion for Order to Show Cause Against Coughlin is
    DENIED.pdf (66.8 KB) , notice of appeal 11 tr 26800 rmc and Motion for reconsideration set aside etc.pdf (2.6 MB) ,
    Pages from mary barker rmc 11 tr 26800 order denying motion for return of bond.pdf (508.2 KB) ,
    DCampbell@washoecounty.us emails 11 tr 26800.pdf (2.6 MB) , 3 26 12 fax to rmc regarding address emails and car
    sleeping allegations.pdf (51.9 KB) , JOEL HARLEY TransparentNevada RMC Marshal Harley.htm (3.3 KB) , 3 19 12
    fas to rmc marshals regarding property wcso.pdf (40.0 KB) , 2 24 20 fax to rmc regarding deficiency in record on
    appeal.pdf (55.6 KB) , JOHN TARTER TransparentNevada year city failed to report.pdf (25.7 KB) , PAUL SIFRE
    TransparentNevada sifre 2009.htm (3.6 KB) , PAUL SIFRE TransparentNevada city of reno failed to report cost of
    health care benefits.htm (3.6 KB) , 1 10 12 email from RMC Interim Court Administrator Cassandra Jackson re Judge
    Howards Order of 12 16 11.pdf (91.4 KB) , JUSTIN ROPER TransparentNevada rmc chief marshal justin roper 2010
    base pay 109K.htm (3.3 KB) , rmc judge bios.pdf (18.2 KB) ,
    Motion_for_Continuance_to_Reno_City_Atty_Roberts_RMC.pdf (448.9 KB)
    Dear Bar Counsel,
    I apologize, I meant to attach the attached Order Dismissing Richard G. Hill, Esq.'s Motion for Order to Show Cause before
    Judge Flanagan in Department 7 of the Second Judicial District Court. Also, Mr. King, would you please confirm that it was,
    in fact, Department 3 that wrote about my apparel in Department 7 on Friday, March 23, 2012? Could I have a copy of that
    correspondence or something in writing attesting to its contents? Judge Hardy in Department 15 is the Chief Judge of the
    Second Judicial District Court for 2012. The Hearing was in CV11-03628 on 3/23/12 in Department 7 before Judge
    Flanagan.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    --Forwarded Message Attachment--
    Detail page for JOEL HARLEY
    Name JOEL HARLEY
    Position
    7821 - Marshal
    Reno
    Year 2010
    Base Pay $85,323.07
    Overtime and
    Callback Collected
    $6,755.56
    Other Pay $478.65
    Total Pay $92,557.28
    000755
    Benefits Accumulated N/A
    Total Pay & Benefits $124,126.82
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Name PAUL SIFRE
    Position
    Sergeant
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost
    of retirement benefits is included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $89,019.87
    Overtime and
    Callback Collected
    $7,595.10
    Total Pay $108,955.53
    Benefits Accumulated $32,937.35
    Total Pay & Benefits $141,892.88
    Detail page for PAUL SIFRE
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    --Forwarded Message Attachment--
    Name PAUL SIFRE
    Position
    Sergeant
    Reno
    Notice
    The City of Reno failed to report the cost of employee health care benefits. Only the cost
    of retirement benefits is included within the "Benefits" category for this jurisdiction.
    Year 2009
    Base Pay $89,019.87
    Overtime and
    Callback Collected
    $7,595.10
    Total Pay $108,955.53
    Benefits Accumulated $32,937.35
    Total Pay & Benefits $141,892.88
    Detail page for PAUL SIFRE
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    000756
    --Forwarded Message Attachment--
    Detail page for JUSTIN ROPER
    Name JUSTIN ROPER
    Position
    7819 Marshal Commander
    Reno
    Year 2010
    Base Pay $107,914.00
    Overtime and
    Callback Collected
    $0.00
    Other Pay ($2,697.89)
    Total Pay $105,216.11
    Benefits Accumulated N/A
    Total Pay & Benefits $145,144.36
    State Government: Salaries, CAFRS, Main Contracts Page, State Financial Documents
    Education: CCSD Warrants, NSHE Budgets
    Politicians: 2010 Transparency Survey, Congressional Disbursements
    Connect: Facebook, Twitter
    About Us: Contact Us, FAQ, Disclaimer
    TransparentNevada is provided by the Nevada Policy Research Institute as a public service.
    RE: my attempt to be provided access to the grievances filed today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 3/28/12 6:01 PM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Dear Mr. King,
    I was never of the understanding that we had any "meeting". You explained to me in writing that I could only see the "other
    different judges" grievances against me that you received if I came into the Double R offices of the State Bar of Nevada and
    viewed them. I explained to you that I was there to view those grievances only. You attempted to turn that into the "meeting"
    for which I have informed you I am interview counsel for in anticipation of a future meeting. Please provide a date by which I
    must respond to the "other different judges" grievances, including, I guess, those which you are still refusing to allow me to
    view.
    You informed me that I did not have a right to copy or view the other materials provided to your Office (there was a box the
    height of a shoe box full of such documents and media....
    I have done some work with Geof Giles, Esq. and he indicates to me that perhaps you should be conflicted out of this matter.
    What is your position on that? Please include specifics with regard to any dealings you have had with Mr. Giles which might
    preclude you from being attached to this matter.
    I would like an opportunity to supplement my response to Richard G. Hill's grievance, but I would like a ruling from Bar Counsel
    as to whether such a response should, must, or ought speak to the conviction in 11 CR 22176 that I previously reported,
    pursuant to SCR 111 to Bar Counsel David Clark and Assistant Bar Counsel Glenn Machado, or whether that is a separate matter
    which should be excised from this Richard G. Hill, Esq. "grievance" inquiry. Further, I would like a similar ruling as to whether
    any pending criminal charges need or should be spoken to or whether any such response from me is in Order prior to the
    expiration of the pendency of such proceedings.
    As to Mr. King's commentary on whether he said or did not say something, I stand by what I wrote.
    Sincerely,
    Zach Coughlin, Esq.
    000757
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: my attempt to be provided access to the grievances filed today
    Date: Tue, 27 Mar 2012 16:26:11 +0000
    March 27, 2012
    Dear Mr. Coughlin,
    Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived you as very hostile and
    even threatening. Under those circumstances I felt it better to terminate the meeting.
    If it was not your intent to appear hostile or to attempt to intimidate me then you might consider how I perceived
    your conduct. I had intended to try to listen to you and determine how my office could best
    help you address the grievances that I have received. You said you did not have time and simply wanted to argue
    about your receipt of e-mail or mail. I did not say that I did not care if you received the
    information I sent to you, I said I did not care how your received it, so long as you received it. I do care that you
    receive the information that I send to you. As I attempted to explain, I will be meeting with a panel
    to have them make a determination about the grievances that have been made against you by Mr. Hill and the Judge
    from Department 3 that you read at my office. I have asked for a written response to those
    grievances. In response I received many e-mails with attachments. I will soon be sharing the grievances with a
    disciplinary panel and will advise them of your responses to date.
    I will keep you advised of the panels determination.
    Sincerely,
    000758
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, March 26, 2012 5:35 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: my attempt to be provided access to the grievances filed today
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted to be provided access the the
    various "other different judges" grievances that I, prior to last Friday, was completely unaware of. I have sent you several written correspondences detailing
    the tampering and other problems with my USPS mail incident to the two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask
    that you copy my on all correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash Holmes. Did
    you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any other judges from whom you have received
    any other similar such materials and further refused to allow me to view and such items. I asked for a copy of the large box of documents, and other FOIA
    request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated that I did not have a right to review such
    complaint letters, grievances, or other materials, prior to being questioned by you and before any such meeting. I informed you that I am considering different
    attorneys to represent me right now, and indicated I need these materials to prepare for any future meeting with you. My records incidate that your letter of
    3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know if you received any sort of "return
    to sender" letter for that mailing.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    please note my new address, SOLACE PROGRAM REQUEST
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 3/28/12 5:34 PM
    To: bdogan@washoecounty.us; rwhomes@washoecounty.us; jbosler@washoecounty.us; stermitz@sbcglobal.net;
    kg@npri.org; ed@npri.org; jmd@randazza.com; mjr@randazza.com; kadlicj@reno.gov; keithloomis@earthlink.net;
    jgoodnight@washoecounty.us; kstancil@washoecounty.us; zyoung@da.washoecounty.us; carly.coughlincrc@gmail.com;
    am@npri.org; geofgiles@hotmail.com; loriw@nvbar.org; ehejny@lakes.nv.gov; info@lakes.nv.gov; coughlin@yplj.com;
    rcornlaw@150.reno.nv.us; vsanevada@juno.com
    12 attachments
    CV11-03628 Coughlin v Merliss 3 26 2012 Richard G. Hil's Motion for Order to Show Cause Against Coughlin is
    DENIED.pdf (66.8 KB) , Coughlin w_exhibits_031612 3 16 12 Letter from Bar Counsel Patrick King with Judge Nash
    Holmes Formal Complaint Attached.pdf (1133.2 KB) , 3 26 12 fax to rmc regarding address emails and car sleeping
    allegations.pdf (51.9 KB) , all emails from Patrick King Bar Counsel Nevada PatrickK@nvbar.org.pdf (368.9 KB) , CR11-
    2064-2676094 (Opposition to Mtn ...).pdf (171.6 KB) , CR11-2064-2682479 (Supplemental ...).pdf (153.7 KB) , CR11-
    2064-2691431 (Mtn for Extension of Time).pdf (132.1 KB) , CR11-2064-2691386 (Opening Brief).pdf (130.5 KB) , 3
    16 12 fax to wcso re eviction park terrace hill etc revmargins removed.pdf (1893.3 KB) , THE 2 11 12 email to WCSO
    RPD Reno City Attorney Hill NPUC Hill et al.pdf (142.9 KB) , 11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12
    WITH EXHIBIT 1 ATTACHED.pdf (2.6 MB) , CV11-03628-2690815 (Opening Brief).pdf (358.9 KB)
    Dear Deputy Washoe County Public Defender Biray Dogan, Esq., et al,
    000759
    Must I use Lake's Crossing for this second competency evaluation? Do you have some sort of financial arrangment with Lake's Crossing?
    Please provide a written answer as to whom else I may utilize for such an evaluation and the requirements, certifications, or standards, which
    they must meet in order to be eligibel to perform such an evaluation. Nonetheless, I have yet to receive anything from Lake's Crossing, but I
    will call them now and copy them on this email in an attempt to comply with the evaluation requirement. Ms. Hejny of Lakes Crossing, I was
    able to check my voice mails despite former prison warden or administrator RMC Judge Nash Holmes summarily seizing my, an attorney's,
    cellular and smartphone in court on 2/27/12, and still refusing to release them, despite Her Honor filing a grievance against Coughlin with the
    State Bar of Nevada that neglects to mention that seizure at all....nonetheless, a difficult to discern message sound like it was from a Dr. Brown
    with Lakes Crossing...Ms. Hejny, would you forward this on to him with a message that I am trying to meet him and comply with all
    scheduling requirements imposed upon me?
    Please copy me via email and fax on my entire file. The domestic violence attacks against me in FV12-00188 and FV12-00187 resulted in
    interference with receipt of my USPS mail. I have taken all reasonable steps to counteract that, however, in an abundance of caution, I ask that
    you copy me on everything via email and fax and have Lakes Crossing do so as well. Additionally, Judge Nash Holmes confiscated my phones
    on 2/27/12 and still has not released them or provided (as far as I know) any indication for her basis for doing so, etc.
    Mr. Dogan, please explain your position vis a vis your missing the Arraignment in my cases, including specific reference to the approximately
    90 minute meeting you and I had in advance of that arraignment. Further, please provide an indication in writing as to why you felt this more
    invasive, more involved competency evaluation you moved for was a request based in law or fact, including specific details and documentation
    in support thereof. Oh, that's right, Biray Dogan and Joe Goodnight of the WCPD only believe that NRCP 11 applies to criminal matters
    where they need to leverage it as an excuse not to file a Motion to Dismiss or some other pre-trial motion....Dogan and Goodnight's position
    on Nevada Rule of Civil Procedure 11 in a criminal context, though, in the context of filing any Motion for Sanctions against Goodnight's
    organic free trade coffee shop buddy DA Zach Young is that "NRCP 11 does not apply in a criminal context". Its reminiscent of the RPD
    approach to situations where Richard G. Hill, Esq. makes a report of some criminal violation, in comparision to when someone reports a
    criminal violation by Richard G. Hill, Esq. Some might say when Hill's files a report or signs a criminal complaint, the RPD treats it as a
    "violation fo criminal law, a police matter", but that when anyone points out Hill's attempts at extortion, bribery, abuse of process, larceny,
    withholding one's state issued identification, perjury, etc., etc., the RPD simply washes their hands clean of the complainants request,
    indicating, "sorry, buddy, that's a civil matter, your remedy is with the courts...". So, when Hill wants a Temporary Protection Order against
    Zach Coughlin, because, gosh darn it, Coughlin is fimliming and collectding evidence of the personal property that Hill's contractor, Phil
    Stewart's crew is throwing away from Coughlin's former home law office, in anticipation of a wrongful eviction lawsuit against Hill and his
    Beverly Hill's High School graduate California Neurosurgeon landlord client, Matt Merliss (now on appeal in CV11-03628, wherein Judge
    Flanagan of Department 7 recently denied one of Hill's "quadruple jeopardy" cheap shots at Coughlin, by denying Hill's Motion for Order to
    Show Cause (now that just leaves the baseless State Bar of Nevada grievance Hill filed on behalf of individuals whom are not even his clients,
    wherein he cites unattributed hearsay and for which he failed to attach an actual signature thereto, and which consists chiefly of innuendo and
    complaining that Coughlin dared to actually request a fee waiver from the District Court to file a complaint, despite doing so being an
    acceptable practice as set forth in statute in NRS 12.015). So, where Coughlins peacefully filming on a sidewalk, the RPD doesn't tell Richard
    Hill, Esq. that "its a civil matter, sorry your remedy is with the courts", but rather, Sargent Paul Sifre orders a young trainee , Officer Leedy, to
    walk up to Coughlin unprovoked, grab the video camera out of his hand prior to making any sort of attempt to engage Coughlin or otherwise
    explain why the RPD would be, in a matter of two seconds, applying excessive force to Coughlin's bent back wrists and obstructing justice by
    turning off his video camera despite Coughlin's express insistance that Sargent Paul Sifre refrain from doing so.
    Further, please explain what exactly you meant when you told me, after we discussed my previous work experience at Hale Lane, that you
    could never do civil law in the private sector what with all that hard work and the billable hours requirements being demanding of your time
    and effort, and that you found the public defender lifestyle much more to your liking. Please also explain why you found it necessary to point
    out how bitterly disappointed you were with the lack of diversity in Reno's judiciary and Reno in general, and how much you sympathized
    with the plight of poor Judge Howard (whom has never defeated anyone in an election despite being on the bench since 1998) in having to
    deal with me in 11 cr 22176, wherein he sentenced Reno attorney Coughlin to 3 days in jail for a finding of summary contempt under NRS
    22.010 for zealously advocating on behalf of a defendant in a criminal matter where police misconduct was alleged. Mr. Bosler, I am hereby
    requesting that a copy of this and all other correspondences between Biray Dogan and myself and my complete file in the matter for which
    Mr. Dogan is representing me be placed in Mr. Dogan's file and that a formal complaint investigation against Mr. Dogan for his negligence in
    representing me so far and his retaliatory approach (having a psyche evaluation ordered that is displayed on the www.ccwashoe.com
    courtconnect docket in close proximity to my complaining of Mr. Dogan's failure to appear at my arraingment and his questionable statements
    to me, as well as the practice he and Deputy PD Joe Goodnight attempted to employe previously were they insisted upon talking to me on the
    phone as a pair, in a surprise approach manner.
    000760
    In Morelli v. Morelli, Nevada's Iirst Italian Neurosurgeon was sued by his now attorney 18 year old
    daugther Ior the cost oI her college and law school tuition, which was expressly set Iorth as a
    stipulation in the marital settlement agreement in that matter. The daughter was awarded the tution and
    Iather and daughter never spoke again during Dr. Morelli's liIetime, some 20 more years. Ironically, the
    "misuse oI 911" charged stemmed Irom my calling about the mysterious and menacing disappearance
    oI my dog (whom I appeared with in the December 2012 issue oI the Nevada Lawyer), which occured
    in the context oI a continuous barrage oI domestic violence to which I was exposed, thorugh the Iirst
    six weeks oI 2012, by the actions oI my then housemates, and Ior which I attempted to obtain
    protection or justice Irom by contacting the RPD, including Sargent Zach Thew (allegedly, I was
    arrested while allegedly attempting to contact Sargent Thew, in accordance with Sargent Thew's
    express instructions that I do so http://www.youtube.com/watch?voU3tkRR0RA ....which Biray
    Dogan knows, but Ior which Mr. Dogan has reIused to Iile any Motion to Dismiss or other action on
    my behalI, rather, Mr. Dogan seeks to retaliate against me and to embarass me with yet another
    retaliatory "competency" evaluation, despite the Iact that I passed, with Ilying colors, the one
    administered by Libby Heijne aIter Deputy Washoe County Public DeIendenr Cary Hylin ordered one
    (subsequent Iilings by the WCPD indicated that a "hearing" took place wherein such an evaluation was
    requested by Hylin and orderd by Judge Jack Schroeder, yet no such "hearing" took place); RPD
    Sargent SiIre (whom actually makes more money through his public employment than most District
    Court Judges) arrested me another time, making it twice in two days, on January 12th, 2012 Ior
    "jaywalking, then he obstructed justice by turning oII my video camera while RPD OIIicer Look and
    OIIicer Leedy were using excessive Iorce (completely out oI the blue and with zero justiIication Ior
    doing so, as evinced by the video itselI) on me. http://www.youtube.com/watch?
    vgBu9zIlGALE&Ieaturerelated Deputy District Attorney Zach NiIong, er, Zach Young, Esq., has
    been extremely resistant to any sort oI plea bargaining in either case, as he has been in the matter Ior
    which Deputy Public DeIender Joe Goodnight, Esq. is "representing" me as my "attorney". That matter
    RCR also included police misconduct by the Reno Police Department, by OIIicers Ron Rosa and Nick
    Duralde. Where would Reno attorney Zach Coughlin, Esq. be iI there was not video tape oI all oI this
    police misconduct? http://www.youtube.com/watch?v5PR7q4OI5b0&Ieaturerelated Despite having
    this video, DA Zach Young retaliated against Coughlin Ior Coughlin's Iiling a NRCP 11 Motion against
    both Goodnight and Young by amending the criminal complaint to overcharge some more. No, rather
    DA Zach Young and the RPD see the witness tampering and attempts to dissuade Nicole Watson Irom
    oIIering any insight into the wrongIul arrest oI 8/20/12 by Nicholas Duradle as "a civil matter", not a
    "criminal one". Heck, the RPD doesn't even see battery, assault, aggravated assault, or domestic
    violence as "criminal in nature" when these things happen to pesky First Amendment attorney Zachary
    Barker Coughlin, Esq., ...no, rather, those are matters oI a "civil nature" and Coughlin's "remedy is with
    the court's", so sayeth RPD OIIicer Stacey Gardner, Sargent Monica Lopez, OIIicer Mcquattry, OIIicer
    Look and Leedy and Delvecchio, OIIicer Warren, etc., etc., Incidentally, it would be helpIul iI an entity
    like Washoe Legal Services took an aggresive approach to advocating on behalI oI tenants'.....Washoe
    Legal Services Executive Director Paul Elcano has reportedly call Dr. Coughlin in an attempt to
    inIluence attorney Coughlin to close the case Coughlin has against WLS Ior wrongIul termination. Its a
    good thing Nevada has so many brave First Amendment attorney's like JM Devoy and his associate
    Marc Randazza, neither oI whom have any association with Mr. Coughlin. I, Mr. Coughlin am aware
    that it is slightly awkward to write this switching between the Iirst and third person, however, the
    exigencies and economics oI solo law practice were at play in doing so. At least there isn't much oI a
    societal cost to the legally questionable manner in which evictions are decided and carried out in
    Washoe County: http://www.youtube.com/watch?vssE0FWHFNEY http://www.youtube.com/watch?
    vKjG2aEjslr4 Well, Mr. Loomis, thinks my arguments about the insuIIiciency oI service oI the
    Summary Eviction Order's is "Irivolous", but, hey, he is just getting paid to zealously advocate on my
    behalI, so.... And just because Bar Counsel Patrick King, Esq., Ieels the greivances I Iiled are not worth
    000761
    pursuing whereas those Iiled by Richard G. Hill, Esq. are deIinately worthy oI lots and lots oI Iollow
    up (even where he lacks standing to so Iile or is oIIering only unattributed hearsay in support oI his
    contentions, etc.) does not mean Bar Counsel Patrick King is acting as an attack dog Ior the rich, that
    would not be an accurate statement, in all likelihood. Sincerely, Zach Coughlin, Esq., PO BOX 60952,
    RENO, NV, 89506, tel: 775 338 8118, Iax: 949 667 7402; ZachCoughlinhotmail.com Nevada Bar
    No: 9473 Dear Mr. Coughlin: This message is sent to address issues raised in the e-mail you sent on 3-
    26-12. 1. Please note that you are Iree to send the communications you send to me, to anyone else you
    desire. You should be aware that sending your communications to other parties will cause your
    communications to me to lose their attorney-client conIidentiality. 2. For what speciIic purposes do you
    need a continuance? A continuance purely Ior the purpose oI delay is not a proper reason Ior a
    continuance. 3. Whether you are entitled to e-mail the Reno Municipal Court is not my concern. That is
    a problem to be addressed between you and the Court. 4. Ms. Drake is no longer the attorney handling
    your case Ior the Reno City Attorney`s OIIice. Your case is now being handled by Christopher Hazlett-
    Stevens, Esq. 5. In response to your question regarding the weaknesses oI the trespassing case I oIIer
    the Iollowing: a. The complaint is deIicient in that iI Iails to set Iorth the elements oI the crime oI
    trespass. It Iails to identiIy whether your presence on the premises was Ior the purpose to vex or annoy
    the owner or occupant oI the premises or whether it was an entry onto the premises aIter a warning not
    to so trespass. This is probably easily remedied by an amendment at the time oI trial. Nevertheless
    these are alternative theories on which a trespass case can be pursued and the deIendant is entitled to
    know on which theory or theories a case is being prosecuted in advance oI showing up Ior trial. b. You
    Iiled an appeal on October 19, 2011, apparently, oI the order made by Justice oI the Peace SIerrazza on
    October 13, 2011. That order denied your request Ior a continuance and granted summary eviction
    unless you Iiled a deposit with the court. Typically the courts lose jurisdiction to rule on other matters
    in the case once an appeal is taken. It is clear Irom the court records that this appeal was pending beIore
    the Second Judicial District Court at the time the court held a hearing on the unlawIul detainer on
    October 25, 2011. It may well be that the Justice Court lost jurisdiction to hold the eviction hearing
    while the appeal was pending. c. I am working on some other thoughts. 6. II you are dissatisIied with
    the way I am representing you, you remain Iree to seek a new attorney. 7. Another chuckle regarding
    my ownership oI strip clubs. I don`t own or have any ownership interest in any strip clubs, brothels,
    adult book stores or movie houses. I guess that leaves me Iree to moralize. 8. I still don`t see the
    importance oI Dr. Merliss. The request Ior payment oI an amount equal to rent, was Ior storage oI your
    personal property. You are entitled to contest the amount oI the storage Iee, which you did. There is no
    credible evidence anywhere which suggests that anyone intended to reopen or create a new tenancy
    allowing you to retain possession oI the premises. 9. Dr. Merliss is an out oI state witness. In order to
    compel his appearance, his testimony must be material. NRS 174.425(1). It does not appear that his
    testimony is material under the inIormation you have provided Further, under NRS 174.425(2) he is
    entitled to be paid his subsistence and travel expenses incurred in coming to Nevada. Are you prepared
    to pay those expenses in advance oI his coming to Nevada? 10. I don`t intend to Iax or e-mail to you,
    your Iull Iile in this case. You already have everything with the exception oI a couple oI items which I
    mailed to your old address. I will send them again to your new address. II you want to review the Iile
    you are welcome to do so at my oIIice. II you want copies oI anything in the Iile you may mark the
    items. AIter giving you a cost estimate, Ior which I require payment in advance, we will provide you
    with copies oI the marked items. Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Monday, March 26, 2012 10:33 PM To:
    keithloomisearthlink.net; stermitzsbcglobal.net; jmdrandazza.com; jbolescallatg.com;
    kristiemanningyahoo.com; kadlicjreno.gov Subject: i was evicted 3 15 12, i need a continuance
    Dear Mr. Loomis, I was wrongIully evicted on 3 15 12, and I need a continuance in the criminal
    trespass matter that you set overly quickly against my express wishes anyway. My ability to collect
    evidence necessary to my deIense and otherwise prepare has been adversely aIIected. Additionally, I
    000762
    don't Ieel as though you are perIorming in an appropriate manner as deIense counsel, but rather you
    seem stuck in your prosecutorial ways, too quick to look Ior any excuse whatsoever to bury one's case,
    so I think you have Iorced a split here, which Iurther prejudices my case and augers towards a
    continuance. Please move Ior one immediately and copy me on my entire Iile by email and Iax please.
    Additionally, please seek clariIication Irom the RMC as to whether I am allowed to ever send an email
    to renomunicrecordsreno.gov. Please note, today, Judge Flanagan denied Richard Hill's latest
    Irivolous motion. Did you know that Kevin Kelly, oI the State Bar oI Nevada's Character and Fitness
    Committee Ior at least the last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
    http://www.reviewjournal.com/lvrjhome/2002/Mar-06-Wed-2002/news/18241452.html I know I
    always like my three hour tours oI heavy handed moralizing Irom someone who runs a monolithic strip
    club in Las Vegas. You are on the State Bar oI Nevada's Iee dispute committee, aren't you Mr. Loomis?
    Do you own any strip clubs? Mr. Loomis, which oI the elements oI the trespass charge RMC 8.10.040
    do you Ieel are weakest Ior Deputy City Attorney Jill Drake, whom I inIormed about the admission by
    Reno PD OIIicer Chris Carter that Richard G. Hill, Esq. bribes him, but Ior which Ms. Drake indicated
    a complete lack oI interest and expressed that she would not be Iollowing up on that report oI bribery
    oI a RPD OIIicer. Mr. Kadlic, please place a copy oI this correspondence in Jill Drake's personnel Iile.
    Additionally please place one in Allison Ormaas's personnel and employment Iile too, in addition to
    Deputy City Attorney Dan Wong's employment Iile, as all three oI those Deputy City Attorney's were
    provided that report and all three indicated they did not care and had no intention oI Iollowing up or
    otherwise investigating the admission by RPD OIIicer Chris Carter that Richard G. Hill, Esq. bribed
    him. I think the Iailure to Iollow up by any oI these 3 Deputy City Attorney's relates to any Iuture
    negligent hiring, training, and supervision claims that the Reno City Attorney may need to deIend
    against when representing the Reno PD like it did in the EeoI v. Pitsnogle case:
    http://www.lvrj.com/news/reno-oIIicial-accused-oI-witness-tampering-116586528.html You know,
    Deputy City Attorney Ormaas's decision to push on Ior that $70 traIIic ticket is looking more and more
    interesting. \\ Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his understanding oI the
    extent to which his attorney, Richard G. Hill, Esq. had eIIectively rescinded any eviction Order by
    sending a bill Ior the same amount as Iull use and occupany oI the location at 121 River Rock St. goes
    to the substance oI the elements Iound in RMC 8.10.040 as well as the credibility oI both Merliss and
    Hill. Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, Iax: 949
    667 7402; ZachCoughlinhotmail.com Nevada Bar No: 9473 Zach Coughlin, Esq., PO BOX 60952,
    RENO, NV, 89506, tel: 775 338 8118, Iax: 949 667 7402; ZachCoughlinhotmail.com Nevada Bar
    No: 9473 Close Print Full view , , Back to messages RE: rmc 11 cr 26405 you are appointed counsel?
    Ior puentes ne taitel? 2/27/12 Keith Loomis To 'Zach Coughlin' From: Keith Loomis
    (keithloomisearthlink.net) Sent: Mon 2/27/12 3:27 PM To: 'Zach Coughlin'
    (zachcoughlinhotmail.com) Mr. Coughlin: E-mail works well Ior me. Keith Loomis From: Zach
    Coughlin |mailto:zachcoughlinhotmail.com| Sent: Monday, February 27, 2012 7:56 AM To:
    keithloomisearthlink.net Subject: rmc 11 cr 26405 you are appointed counsel? Ior puentes ne taitel?
    hi, i guess Mr. Loomis was appointed as my 3rd deIense attorney in RMC case 11 cr 26405. I have not
    heard anything about this case, and the RMC indicated they had nothing scheduled. Please
    communicate with me only via email or Iax please, having issues with my mail incident to domestic
    violence committed against me my Iax is 949 667 7402. thanks, Zach Coughlin Full view , , Back to
    messages court date 3/05/12 Keith Loomis To 'Zach Coughlin' From: Keith Loomis
    (keithloomisearthlink.net) Sent: Mon 3/05/12 4:09 PM To: 'Zach Coughlin'
    (zachcoughlinhotmail.com) Mr. Coughlin: I have requested that court set your trespass case Ior trial
    in about 30 days. I will let you know the date and time as soon as I know. Keith Loomis Full view , ,
    Back to messages RE: court date 3/07/12 Keith Loomis To zachcoughlinhotmail.com From: Keith
    Loomis (keithloomisearthlink.net) Sent: Wed 3/07/12 4:36 PM To: zachcoughlinhotmail.com Mr.
    Coughlin: On what grounds, other than those already set Iorth in your existing motion, do you believe a
    000763
    motion to dismiss should be Iiled? Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Wednesday, March 07, 2012 12:45 AM To:
    keithloomisearthlink.net Subject: RE: court date Mr. Loomis, Please copy me on any and all
    correspondences, Iiling, or other documentation or verbal requests, correspondences, etc. that you
    submit to the Court, including the one you reIerence below. Please do not Iollow Taitel's tact oI
    agreeing to requests or Iailing to oppose motions without even attempting to obtain my permission to in
    advance thereoI. I would like Ior you to draIt a Motion to Dismiss in this case Ior me review. Thanks,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: court date Date: Mon, 5 Mar 2012 16:09:19 -0800 Mr.
    Coughlin: I have requested that court set your trespass case Ior trial in about 30 days. I will let you
    know the date and time as soon as I know. Keith Loomis Full view , , Back to messages RE: court date
    3/09/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Fri 3/09/12 10:14 AM To: zachcoughlinhotmail.com No worries.
    Made me laugh. Couple oI questions: Did you Iile an appeal Irom Justice oI the Peace SIerrazza`s
    eviction order? II yes, has it been resolved? Did SIerrazza announce at the close oI the hearing on the
    25th that he was granting the eviction and ask Hill/Baker to provide a written order? Did you ever see
    the eviction order posted by WCSO II yes, when? What is relevance oI personnel Iiles oI Carter or
    Lopez? How is Dr. Merliss` testimony material to the deIense oI this case? Keith Loomis From: Zach
    Coughlin |mailto:zachcoughlinhotmail.com| Sent: Thursday, March 08, 2012 12:46 AM To:
    keithloomisearthlink.net Subject: RE: court date Dear Mr. Loomis, I apologize Sir Ior what I am sure
    comes across as rudeness on my part. You seem like a good guy, and you have great hair. I simply don't
    have time, money or energy to do any oI this the polite way given the "uniqueness" oI this
    situation....Please just know I mean you no disrespect. Would you please Iile a request or Motion Ior
    the Personnel File oI RPD OIIicer Chris Carter and Sargent Monica Lopez as well as supboena Irom
    the RPD all the volumns oI crap Richard Hill has given them on this in addition to noticing the court
    and City Atty as to Richard HIll being a witness, subpoena him (though the earlier continuance would
    appear to imply he already is) AND SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO
    CAN GET HIS OUT DOWN HERE FOR THE TRIAL AND A DEPOSITION PRIOR THERETO,
    ETSPECIALLY CONSIDERING THAT THE VARIOUS POLICE REPORTS AND MOTIONS FOR
    ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE WAS AT THE PROPERTY IN
    THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY PUENTES GOT
    YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT CLEARLY).
    iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON ME,
    THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT. ALSO PLEASE FILE A MOTION TO
    dismiss based upon denial oI right to a speedy trial, spoliation oI evidence, etc.... PEACE Zach
    Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- Full view , , Back to messages Trial
    Date 3/09/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Fri 3/09/12 10:44 AM To: zachcoughlinhotmail.com 1 attachment
    Coughlin Trial Setting.pdI (771.8 KB) See attached Full view , , Back to messages RE: Trial Date
    3/12/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Mon 3/12/12 9:26 AM To: zachcoughlinhotmail.com I can do that
    iI there is a good reason to vacate the date. What is the reason? Keith From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Friday, March 09, 2012 6:28 PM To:
    keithloomisearthlink.net Subject: RE: Trial Date Please Iile something with the court seeking to
    000764
    vacate that trial date and explaining that you Iailed to even once consult with your client prior to setting
    it. Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: Trial Date Date: Fri, 9 Mar 2012 10:44:17 -0800 See attached
    Full view , , Back to messages RE: court date 3/12/12 Keith Loomis To zachcoughlinhotmail.com
    From: Keith Loomis (keithloomisearthlink.net) Sent: Mon 3/12/12 10:02 AM To:
    zachcoughlinhotmail.com This e-mail is sent to address the grounds you identiIied as Iorming the
    basis oI a motion to dismiss. As you know there is both a constitutional right and a statutory right to a
    speedy trial. This case is nowhere close to a violation oI the constitutional right to a speedy trial. The
    statute does provide Ior a right to trial within 60 days oI arraignment in municipal
    court. NRS 178.556(2). In this circumstance the court 'may dismiss the complaint. The statute
    requires, however, that the trial not have been postponed at the request oI the deIendant. It is my
    understanding that the January 10, 2012, trial date, was postponed at your request. II that is true then
    there are not grounds to dismiss on the basis oI a violation oI a right to speedy trial. Dismissal based on
    spoliation is a civil concept. It has not been applied to criminal cases in Nevada as oI yet. See Higgs v.
    State, 126 Nev. Adv. Opn 1 (2010). Rather deIendants in criminal cases are protected Irom the loss oI
    evidence in the hands oI the prosecution by the doctrine oI due process. Consequently you might have a
    basis to request dismissal iI the City Attorney`s OIIice lost evidence, in its possession material to the
    case. In such case iI the City acted in bad Iaith or with connivance or iI you were prejudiced by the loss
    then there may be grounds on which to base a dismissal. Please advise as to what evidence was lost and
    how it was lost. You have not identiIied any other grounds as a basis Ior dismissal. II you believe there
    are other grounds, let me know. Thanks Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Thursday, March 08, 2012 12:46 AM To:
    keithloomisearthlink.net Subject: RE: court date Dear Mr. Loomis, I apologize Sir Ior what I am sure
    comes across as rudeness on my part. You seem like a good guy, and you have great hair. I simply don't
    have time, money or energy to do any oI this the polite way given the "uniqueness" oI this
    situation....Please just know I mean you no disrespect. Would you please Iile a request or Motion Ior
    the Personnel File oI RPD OIIicer Chris Carter and Sargent Monica Lopez as well as supboena Irom
    the RPD all the volumns oI crap Richard Hill has given them on this in addition to noticing the court
    and City Atty as to Richard HIll being a witness, subpoena him (though the earlier continuance would
    appear to imply he already is) AND SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO
    CAN GET HIS OUT DOWN HERE FOR THE TRIAL AND A DEPOSITION PRIOR THERETO,
    ETSPECIALLY CONSIDERING THAT THE VARIOUS POLICE REPORTS AND MOTIONS FOR
    ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE WAS AT THE PROPERTY IN
    THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY PUENTES GOT
    YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT CLEARLY).
    iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON ME,
    THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT. ALSO PLEASE FILE A MOTION TO
    dismiss based upon denial oI right to a speedy trial, spoliation oI evidence, etc.... PEACE Zach
    Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- RE: Trial Date 3/14/12 Keith
    Loomis To zachcoughlinhotmail.com From: Keith Loomis (keithloomisearthlink.net) Sent: Wed
    3/14/12 2:35 PM To: zachcoughlinhotmail.com Dear Mr. Coughlin: My obligation under Nevada
    Rule oI ProIessional Conduct 1.2 is to abide by a client`s decision concerning the objectives oI
    representation and, as required by Rule 1.4 to consult with the client as to the means by which the
    objectives oI representation are to be pursued. . In a criminal case the lawyer shall abide by the
    000765
    clients decision, aIter consultation with the lawyer, as to plea to be entered, whether to waive jury trial
    whether the client will testiIy. Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any
    relevant limitations on the lawyers conduct when the lawyer knows that the client expects assistance
    not permitted by the Rules oI ProIessional Conduct or other law. Under Rule 2.1. In representing a
    client, a lawyer shall exercise independent proIessional judgment and render candid advice. In
    rendering advice, a lawyer may reIer not only to law but to other considerations such as moral
    economic, social and political Iactors, that may be relevant to the client`s situation. Under Rule 3.1. A
    lawyer shall not bring or deIend a proceeding, or assert or controvert an issue therein, unless there is a
    basis in law and Iact Ior doing so that is not Irivolous, which includes a good Iaith argument Ior an
    extension, modiIication or reversal oI existing law. A lawyer Ior a deIendant in a criminal proceeding
    that could result in incarceration, may nevertheless so deIend the proceeding as to require that every
    element oI the case be established. Under Rule 3.2(a) and (b). A lawyer shall make reasonable eIIorts to
    expedite litigation consistent with the interests oI the client. The duty stated in paragraph (a) does not
    preclude a lawyer Irom granting a reasonable request Irom opposing counsel Ior an accommodation,
    such as an extension oI time, or Irom disagreeing with a client`s wishes on administrative and tactical
    matters, such as scheduling depositions, the number oI depositions to be taken, and the Irequency and
    use oI written discovery requests. Under Rule 8.4(d) It is misconduct Ior a lawyer to engage in conduct
    which is prejudicial to the administration oI justice. These, and others, are the proIessional rules I
    operate under in providing legal representation to you in case number 11 CR 26405, a case in which
    you are charged with the crime oI trespass. It is my understanding that your objective in this criminal
    case is that you be acquitted oI the crime oI trespass. That is my purpose in representing you. I am
    happy to work towards that outcome to the best oI my ability. It is my opinion, however, that much oI
    what you ask to be done is not in compliance with the above rules. Accordingly, I will not be Iiling a
    motion to dismiss based upon NRCP 6(a) and (b), I see that argument as Irivolous. I will not be
    proceeding with the summoning oI an out-oI-state witness (Merliss) unless you can establish his
    materiality to the deIense. Nor will I be subpoenaing the personnel records oI law enIorcement
    personnel unless you can establish to my satisIaction why they are relevant to this case. I have no
    intention at this time oI conducting any depositions in the case or sending requests Ior production oI
    documents or interrogatories in the case. I see these actions as unduly burdensome on the judicial
    system, and unwarranted by anything you have provided to this point. I also see them as Irivolous and
    an attempt to utilize the criminal justice system to accomplish objectives not relevant to my purpose in
    representing you. II you are dissatisIied with the limitations I perceive to exist regarding my
    representation oI you, you are welcome to terminate my representation oI you. You may then ask the
    Court to appoint a new lawyer to represent you. It is my understanding that Deputy Machem will be
    testiIying in the case along with Richard Hill and Casey Baker. I do think that there are some
    interesting angles to the case upon which a deIense can be based and I will be pursuing those angles. I
    have asked you in previous e-mails to provide inIormation which I believe will be helpIul to the
    deIense oI your case. I advise you that the City has oIIered to recommend time-served as a sentence iI
    you enter a no-contest plea to trespass. It is also my understanding that you have other criminal cases
    pending in both Reno Justice Court and in the Second Judicial District Court oI the State oI Nevada. It
    is my understanding Iurther that all oI the criminal cases can be resolved in a single plea to a
    misdemeanor oIIense iI you will obtain psychological counseling. It is my obligation to inIorm you oI
    the availability oI these resolutions to the present criminal case in which I provide representation. I
    will, oI course, abide by your decision as to whether to accept these resolutions or not. I note that there
    is a psychiatric evaluation scheduled Ior you in 2nd Judicial District Court Case No. CR12-0376 on
    April 3, 2012. The outcome oI that evaluation could have an important impact on this case. I am asking
    that you authorize a release oI the inIormation contained in the evaluation to me so that I may
    determine what impact it could have on your behalI in this case. I remain prepared to represent you in
    the trespass case. I think that a trial oI the case will be interesting. My representation, however, is
    000766
    circumscribed by the Nevada Rules oI ProIessional Conduct. Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Tuesday, March 13, 2012 4:29 PM To:
    keithloomisearthlink.net Subject: RE: Trial Date Dear Mr. Loomis, In your motion to dismiss, I
    would like you to really Iocus on and set Iorth to the court the Iact that the eviction order needed to be
    served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules oI practice. The provisions oI NRS,
    Nevada Rules oI Civil Procedure and Nevada
    000767
    Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with the provisions of NRS
    40.220 to 40.420, inclusive, apply to the proceedings mentioned in those sections.
    The language about "removing the tenant with in 24 hours of receipt of the order" is only applicable to those situations where the tenant does
    not file a Tenant's Answer or Tenant's Affidavit. I did file such a Tenan'ts Affidavit, and litigated the matter thoroughly. In those situations,
    NRS 40.400 requires NRCP to apply, specifically NRCP 6(a) and 6(e), and clearly WCSO Machem (please subpoena and identify as witnesses
    Mary Kandaras, Esq. of the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO Civil Division supervisor Liz Stuchell for the trial
    in this matter, and further send out a request for production and subpoena duces tecum to the WCDA and the WCSO askign them to specify,
    in writing and in detail, the exact procedures and policies in place with respect to the service and conducting of such lockouts (ie, not default
    lockouts where there is not a summary eviction hearing, but one's like the present one, where there was a Tenant's Answer and hearing held,
    etc....). Be sure to ask whether the are aware of what "personally served" means, and whether they mail the Orders on top of merely posting
    them to the door. Further, I have been told that the WCSO has a policy or penatly system in place whereby the deputies must get these
    lockouts performed "within 24 hours of receipt of the order" the receipt being the WCSO's receipt, and not the tenant's receipt. I don't
    ncessarily read the statute that way, but....the WCSO policy and punishment system would be at least some indication of what the legislature
    meant (I guess, but I dont' really think so, though, you will note that Hill was left with nothing but citing to the "usual and customary practice
    of the WCSO" in serving the Eviction ORders and performign lockouts, I believe, because the law does not contain much to support Hill's
    contention and therefore he wishes to see the WCSO "customary practices" being given the weight of law.
    Please see some specific selections attached from the eviction matter. I know, I know, you want to curtail the scope of your representation to
    an immaculate degree....but Hill can clearly be seen in his various Motion to Show Cause, State Bar Grievances, Temproary Protection Order
    Applications, etc., etc., to be a punk who doesn't much like competing on an even playing field, like any good private schooler, he would
    rather sick an attack dog on somebody than get in the octogon and go toe to toe mentally. Regardless, Hill shows a continual desire to subvert
    NRCP 6(e), which applies to service of documents filed elecronically in the Second Judicial District Court. He would rather withhold opposing
    counsels computers, laptops, client files, driver's license, etc. The last thing he wants is to go argument for argument, research for research,
    writing for writing. Private school and daddy's pleading bank. Hill files a Motion to Show caue allegeing Coughlin subvreted an Order that
    was filed on January 11th, 2012 with Couglin's action of January 12th, 2012. Under NRCP 6(e), the Order Denying the TRO had not even
    been served yet, and there has been no indidcation that Hill gave the Order at the town dump to anyone other than an RPD Officer.
    Further, it is not all that clear why Hills Motion for ORder to Show Cause deserves a full blown hearing when D7 does not indicate a hearing
    will be accorded to the appeal. This is particularly suspect given that Anvui sets forth that appeals in summary eviction matters are done on a
    trial de novo basis.
    There are a number, but how about your complete lack of communication with me prior to so setting that date. How about Mr. Taitel and Mr.
    Puentes's failure in this matter and the prejudice to my case so created? How about your failing to identify yourself as the public defender to a
    room full of defendants in jail at the arraignment?
    There are other reasons as well, including, but not limited to, your resistance to subpoena the materials I have and am requesting.
    I wish for you to subpoena the personnel files of both RPD Sargent Monica Lopez and Officer Chris Carter. I wish for you to list Dr. Merliss
    as a witness and subpoena his appearance and appropriately notice the City of Reno in that regard, same goes for Richard Hill and Casey
    Baker (Baker, by letter dated November 10th, 2011 demands the full rental value for the property as "storage" under NRS 40.253, while also
    asserting he will go after moving and inventory costs, in addition to Hill's contractor Phil Stewarts later ridiculous charges and perjury. Please
    subpoena Stewart as well.
    Most importantly subpoena Washoe County Sheriff's Office Deputy Machem to testify and serve a subpoena dueces tecum, requests for
    production, and interrogatories seeking records and responses from the WCSO as set forth in the letter I sent Liz Stuchell (see attached) on or
    about February 10th, 2012. You see, the WCSO and Deputy Machem may be committing a fraud upon the public by repeatedly filing
    affidavits of service that attest to personal service where Liz Stuchell, of the WCSO admits that they clearly do not know, or choose to "remix"
    the legal meaning of "personally serve".
    Further, please inform the City of Reno and appropriately notice the same as to the existence and intent to offer into evidence a video of
    Richard Hill, Esq., admitting that he and his firm, on behalf of Dr. Merliss, were withholding the accused personal property, in addition to the
    client's files from the former commercial lease home law office of the accused and asserting a lien, under NRS 40.253 for "storage", however,
    as the video tape shows, Hill admits to charging the undersigned the same $900 per month rent as was charged for the "full use and
    occupancy" of the premises at 121 River Rock St., Reno, NV 89512. Hill further demands that property be removed in a certain order,
    regardless of whether his articifically inflated lien was paid or not. Additionally, Hill committed fraud upon the court in a number of instances
    and filed false police reports wherein he alleges that he agreed to or otherwise made available to the accused items such as the accused's
    clients files (and for a time wallet and state issued driver's license) where, clearly, without requiring any payment by the accused, however,
    clearly, the facts show that Hill never actually lived up to those assertions and repeatedly failed to show provide such items absent payment of
    his artifically inflated lien.
    Further, I wish for you to divulge and provide notice that it is available for pickup and that we intent to introduce into evidence a video of
    RPD Sargent Monica Lopez admitting that she and RPD Officer Carter did not identify themselves as police officers or otherwise ask the
    000768
    --------------------------------------------------------------------------------
    accused to leave 121 River Rock St. on the date of the arrest prior to Merliss opening the door to the basement. This is apparently in direct
    contradiction to the sworn filings made by Richard Hill, Esq. in his affidavits attached to his various Motions to Show Cause, the Reply to
    Opposition thereto, Opposition to TRO, etc., etc. (in RJC Rev2011-001708 and the appeal in CV11-03628). For that reason alone Merliss'
    presence is required. He was a precipient witness and you are asking me why he should be there? You have a duty to zealously advocate on
    my behalf, Mr. Loomis. You are paid, by the public, to do so. Please divulge any prior associations you have with anyone employed by or
    workign as an independent contractor with the RMC and or the Reno City Attorney, including anyone you went to law school with or attended
    the same law school as, within a 5 year period.
    Further, I wish for you to file a motion seeking a mistrial or otherwise requiring the recusal of the RMC and further disclosing why it is that
    Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth recuse Judge Dilworth?) in one case, without detailing
    why exactly, while Judge Gardner apparently is intent on remaining on in 11 CR 26405, despite the fact that an apparent conflict exists, one
    which he only disclosed upon prompting from the accused, with respect to Judge Gardner's very recent employment with the Reno City
    Attorney's office and the existing and or brewing litigation (or, at least, possible litigation) between the accused and the City of Reno, Reno
    City Attorney, and possibly, the RMC.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: keithloomis@earthlink.net
    To: zachcoughlin@hotmail.com
    Subject: RE: Trial Date
    Date: Mon, 12 Mar 2012 09:26:35 -0700
    I can do that if there is a good reason to vacate the date. What is the reason?
    Keith
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 6:28 PM
    To: keithloomis@earthlink.net
    Subject: RE: Trial Date
    Please file something with the court seeking to vacate that trial date and explaining that you failed to even once consult with your client prior
    to setting it.
    000769
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: Trial Date Date: Fri, 9 Mar 2012 10:44:17 -0800 See attached
    Full view , , Back to messages RE: i was evicted 3 15 12, i need a continuance 2:03 PM Keith Loomis
    To zachcoughlinhotmail.com From: Keith Loomis (keithloomisearthlink.net) Sent: Wed 3/28/12
    2:03 PM To: zachcoughlinhotmail.com Dear Mr. Coughlin: This message is sent to address issues
    raised in the e-mail you sent on 3-26-12. 1. Please note that you are Iree to send the communications
    you send to me, to anyone else you desire. You should be aware that sending your communications to
    other parties will cause your communications to me to lose their attorney-client conIidentiality. 2. For
    what speciIic purposes do you need a continuance? A continuance purely Ior the purpose oI delay is not
    a proper reason Ior a continuance. 3. Whether you are entitled to e-mail the Reno Municipal Court is
    not my concern. That is a problem to be addressed between you and the Court. 4. Ms. Drake is no
    longer the attorney handling your case Ior the Reno City Attorney`s OIIice. Your case is now being
    handled by Christopher Hazlett-Stevens, Esq. 5. In response to your question regarding the weaknesses
    oI the trespassing case I oIIer the Iollowing: a. The complaint is deIicient in that iI Iails to set Iorth the
    elements oI the crime oI trespass. It Iails to identiIy whether your presence on the premises was Ior the
    purpose to vex or annoy the owner or occupant oI the premises or whether it was an entry onto the
    premises aIter a warning not to so trespass. This is probably easily remedied by an amendment at the
    time oI trial. Nevertheless these are alternative theories on which a trespass case can be pursued and the
    deIendant is entitled to know on which theory or theories a case is being prosecuted in advance oI
    showing up Ior trial. b. You Iiled an appeal on October 19, 2011, apparently, oI the order made by
    Justice oI the Peace SIerrazza on October 13, 2011. That order denied your request Ior a continuance
    and granted summary eviction unless you Iiled a deposit with the court. Typically the courts lose
    jurisdiction to rule on other matters in the case once an appeal is taken. It is clear Irom the court records
    that this appeal was pending beIore the Second Judicial District Court at the time the court held a
    hearing on the unlawIul detainer on October 25, 2011. It may well be that the Justice Court lost
    jurisdiction to hold the eviction hearing while the appeal was pending. c. I am working on some other
    thoughts. 6. II you are dissatisIied with the way I am representing you, you remain Iree to seek a new
    attorney. 7. Another chuckle regarding my ownership oI strip clubs. I don`t own or have any ownership
    interest in any strip clubs, brothels, adult book stores or movie houses. I guess that leaves me Iree to
    moralize. 8. I still don`t see the importance oI Dr. Merliss. The request Ior payment oI an amount equal
    to rent, was Ior storage oI your personal property. You are entitled to contest the amount oI the storage
    Iee, which you did. There is no credible evidence anywhere which suggests that anyone intended to
    reopen or create a new tenancy allowing you to retain possession oI the premises. 9. Dr. Merliss is an
    out oI state witness. In order to compel his appearance, his testimony must be material. NRS
    174.425(1). It does not appear that his testimony is material under the inIormation you have provided
    Further, under NRS 174.425(2) he is entitled to be paid his subsistence and travel expenses incurred in
    coming to Nevada. Are you prepared to pay those expenses in advance oI his coming to Nevada? 10. I
    don`t intend to Iax or e-mail to you, your Iull Iile in this case. You already have everything with the
    exception oI a couple oI items which I mailed to your old address. I will send them again to your new
    address. II you want to review the Iile you are welcome to do so at my oIIice. II you want copies oI
    anything in the Iile you may mark the items. AIter giving you a cost estimate, Ior which I require
    payment in advance, we will provide you with copies oI the marked items. Keith Loomis From: Zach
    Coughlin |mailto:zachcoughlinhotmail.com| Sent: Monday, March 26, 2012 10:33 PM To:
    keithloomisearthlink.net; stermitzsbcglobal.net; jmdrandazza.com; jbolescallatg.com;
    kristiemanningyahoo.com; kadlicjreno.gov Subject: i was evicted 3 15 12, i need a continuance
    Dear Mr. Loomis, I was wrongIully evicted on 3 15 12, and I need a continuance in the criminal
    trespass matter that you set overly quickly against my express wishes anyway. My ability to collect
    000770
    evidence necessary to my deIense and otherwise prepare has been adversely aIIected. Additionally, I
    don't Ieel as though you are perIorming in an appropriate manner as deIense counsel, but rather you
    seem stuck in your prosecutorial ways, too quick to look Ior any excuse whatsoever to bury one's case,
    so I think you have Iorced a split here, which Iurther prejudices my case and augers towards a
    continuance. Please move Ior one immediately and copy me on my entire Iile by email and Iax please.
    Additionally, please seek clariIication Irom the RMC as to whether I am allowed to ever send an email
    to renomunicrecordsreno.gov. Please note, today, Judge Flanagan denied Richard Hill's latest
    Irivolous motion. Did you know that Kevin Kelly, oI the State Bar oI Nevada's Character and Fitness
    Committee Ior at least the last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
    http://www.reviewjournal.com/lvrjhome/2002/Mar-06-Wed-2002/news/18241452.html I know I
    always like my three hour tours oI heavy handed moralizing Irom someone who runs a monolithic strip
    club in Las Vegas. You are on the State Bar oI Nevada's Iee dispute committee, aren't you Mr. Loomis?
    Do you own any strip clubs? Mr. Loomis, which oI the elements oI the trespass charge RMC 8.10.040
    do you Ieel are weakest Ior Deputy City Attorney Jill Drake, whom I inIormed about the admission by
    Reno PD OIIicer Chris Carter that Richard G. Hill, Esq. bribes him, but Ior which Ms. Drake indicated
    a complete lack oI interest and expressed that she would not be Iollowing up on that report oI bribery
    oI a RPD OIIicer. Mr. Kadlic, please place a copy oI this correspondence in Jill Drake's personnel Iile.
    Additionally please place one in Allison Ormaa's personnel and employment Iile too, in addition to
    Deputy City Attorney Dan Wong's employment Iile, as all three oI those Deputy City Attorney's were
    provided that report and all three indicated they did not care and had no intention oI Iollowing up or
    otherwise investigating the admission by RPD OIIicer Chris Carter that Richard G. Hill, Esq. bribed
    him. I think the Iailure to Iollow up by any oI these 3 Deputy City Attorney's relates to any Iuture
    negligent hiring, training, and supervision claims that the Reno City Attorney may need to deIend
    against when representing the Reno PD like it did in the EeoI v. Pitsnogle case:
    http://www.lvrj.com/news/reno-oIIicial-accused-oI-witness-tampering-116586528.html You know,
    Deputy City Attorney Ormaas's decision to push on Ior that $70 traIIic ticket is looking more and more
    interesting. \\ Oh, and, Mr. Loomis, Dr. Merliss presence is necessary because his understanding oI the
    extent to which his attorney, Richard G. Hill, Esq. had eIIectively rescinded any eviction Order by
    sending a bill Ior the same amount as Iull use and occupany oI the location at 121 River Rock St. goes
    to the substance oI the elements Iound in RMC 8.10.040 as well as the credibility oI both Merliss and
    Hill. Sincerely, Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, Iax: 949
    667 7402; ZachCoughlinhotmail.com Nevada Bar No: 9473 Close Print Full view , , Back to
    messages RE: rmc 11 cr 26405 you are appointed counsel? Ior puentes ne taitel? 2/27/12 Keith Loomis
    To 'Zach Coughlin' From: Keith Loomis (keithloomisearthlink.net) Sent: Mon 2/27/12 3:27 PM To:
    'Zach Coughlin' (zachcoughlinhotmail.com) Mr. Coughlin: E-mail works well Ior me. Keith Loomis
    From: Zach Coughlin |mailto:zachcoughlinhotmail.com| Sent: Monday, February 27, 2012 7:56 AM
    To: keithloomisearthlink.net Subject: rmc 11 cr 26405 you are appointed counsel? Ior puentes ne
    taitel? hi, i guess Mr. Loomis was appointed as my 3rd deIense attorney in RMC case 11 cr 26405. I
    have not heard anything about this case, and the RMC indicated they had nothing scheduled. Please
    communicate with me only via email or Iax please, having issues with my mail incident to domestic
    violence committed against me my Iax is 949 667 7402. thanks, Zach Coughlin Full view , , Back to
    messages court date 3/05/12 Keith Loomis To 'Zach Coughlin' From: Keith Loomis
    (keithloomisearthlink.net) Sent: Mon 3/05/12 4:09 PM To: 'Zach Coughlin'
    (zachcoughlinhotmail.com) Mr. Coughlin: I have requested that court set your trespass case Ior trial
    in about 30 days. I will let you know the date and time as soon as I know. Keith Loomis Full view , ,
    Back to messages RE: court date 3/07/12 Keith Loomis To zachcoughlinhotmail.com From: Keith
    Loomis (keithloomisearthlink.net) Sent: Wed 3/07/12 4:36 PM To: zachcoughlinhotmail.com Mr.
    Coughlin: On what grounds, other than those already set Iorth in your existing motion, do you believe a
    motion to dismiss should be Iiled? Keith Loomis From: Zach Coughlin
    000771
    |mailto:zachcoughlinhotmail.com| Sent: Wednesday, March 07, 2012 12:45 AM To:
    keithloomisearthlink.net Subject: RE: court date Mr. Loomis, Please copy me on any and all
    correspondences, Iiling, or other documentation or verbal requests, correspondences, etc. that you
    submit to the
    Court, including the one you reIerence below. Please do not Iollow Taitel's tact oI agreeing to requests
    or Iailing to oppose motions without even attempting to obtain my permission to in advance thereoI. I
    would like Ior you to draIt a Motion to Dismiss in this case Ior me review. Thanks, Zach Coughlin,
    Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: court date Date: Mon, 5 Mar 2012 16:09:19 -0800 Mr.
    Coughlin: I have requested that court set your trespass case Ior trial in about 30 days. I will let you
    know the date and time as soon as I know. Keith Loomis Full view , , Back to messages RE: court date
    3/09/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Fri 3/09/12 10:14 AM To: zachcoughlinhotmail.com No worries.
    Made me laugh. Couple oI questions: Did you Iile an appeal Irom Justice oI the Peace SIerrazza`s
    eviction order? II yes, has it been resolved? Did SIerrazza announce at the close oI the hearing on the
    25th that he was granting the eviction and ask Hill/Baker to provide a written order? Did you ever see
    the eviction order posted by WCSO II yes, when? What is relevance oI personnel Iiles oI Carter or
    Lopez? How is Dr. Merliss` testimony material to the deIense oI this case? Keith Loomis From: Zach
    Coughlin |mailto:zachcoughlinhotmail.com| Sent: Thursday, March 08, 2012 12:46 AM To:
    keithloomisearthlink.net Subject: RE: court date Dear Mr. Loomis, I apologize Sir Ior what I am sure
    comes across as rudeness on my part. You seem like a good guy, and you have great hair. I simply don't
    have time, money or energy to do any oI this the polite way given the "uniqueness" oI this
    situation....Please just know I mean you no disrespect. Would you please Iile a request or Motion Ior
    the Personnel File oI RPD OIIicer Chris Carter and Sargent Monica Lopez as well as supboena Irom
    the RPD all the volumns oI crap Richard Hill has given them on this in addition to noticing the court
    and City Atty as to Richard HIll being a witness, subpoena him (though the earlier continuance would
    appear to imply he already is) AND SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO
    CAN GET HIS OUT DOWN HERE FOR THE TRIAL AND A DEPOSITION PRIOR THERETO,
    ETSPECIALLY CONSIDERING THAT THE VARIOUS POLICE REPORTS AND MOTIONS FOR
    ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE WAS AT THE PROPERTY IN
    THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY PUENTES GOT
    YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT CLEARLY).
    iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON ME,
    THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT. ALSO PLEASE FILE A MOTION TO
    dismiss based upon denial oI right to a speedy trial, spoliation oI evidence, etc.... PEACE Zach
    Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- Full view , , Back to messages Trial
    Date 3/09/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Fri 3/09/12 10:44 AM To: zachcoughlinhotmail.com 1 attachment
    Coughlin Trial Setting.pdI (771.8 KB) See attached Full view , , Back to messages RE: Trial Date
    3/12/12 Keith Loomis To zachcoughlinhotmail.com From: Keith Loomis
    (keithloomisearthlink.net) Sent: Mon 3/12/12 9:26 AM To: zachcoughlinhotmail.com I can do that
    iI there is a good reason to vacate the date. What is the reason? Keith From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Friday, March 09, 2012 6:28 PM To:
    keithloomisearthlink.net Subject: RE: Trial Date Please Iile something with the court seeking to
    000772
    vacate that trial date and explaining that you Iailed to even once consult with your client prior to setting
    it. Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: Trial Date Date: Fri, 9 Mar 2012 10:44:17 -0800 See attached
    Full view , , Back to messages RE: court date 3/12/12 Keith Loomis To zachcoughlinhotmail.com
    From: Keith Loomis (keithloomisearthlink.net) Sent: Mon 3/12/12 10:02 AM To:
    zachcoughlinhotmail.com This e-mail is sent to address the grounds you identiIied as Iorming the
    basis oI a motion to dismiss. As you know there is both a constitutional right and a statutory right to a
    speedy trial. This case is nowhere close to a violation oI the constitutional right to a speedy trial. The
    statute does provide Ior a right to trial within 60 days oI arraignment in municipal court. NRS
    178.556(2). In this circumstance the court 'may dismiss the complaint. The statute requires, however,
    that the trial not have been postponed at the request oI the deIendant. It is my understanding that the
    January 10, 2012, trial date, was postponed at your request. II that is true then there are not grounds to
    dismiss on the basis oI a violation oI a right to speedy trial. Dismissal based on spoliation is a civil
    concept. It has not been applied to criminal cases in Nevada as oI yet. See Higgs v. State, 126 Nev.
    Adv. Opn 1 (2010). Rather deIendants in criminal cases are protected Irom the loss oI evidence in the
    hands oI the prosecution by the doctrine oI due process. Consequently you might have a basis to
    request dismissal iI the City Attorney`s OIIice lost evidence, in its possession material to the case. In
    such case iI the City acted in bad Iaith or with connivance or iI you were prejudiced by the loss then
    there may be grounds on which to base a dismissal. Please advise as to what evidence was lost and how
    it was lost. You have not identiIied any other grounds as a basis Ior dismissal. II you believe there are
    other grounds, let me know. Thanks Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Thursday, March 08, 2012 12:46 AM To:
    keithloomisearthlink.net Subject: RE: court date Dear Mr. Loomis, I apologize Sir Ior what I am sure
    comes across as rudeness on my part. You seem like a good guy, and you have great hair. I simply don't
    have time, money or energy to do any oI this the polite way given the "uniqueness" oI this
    situation....Please just know I mean you no disrespect. Would you please Iile a request or Motion Ior
    the Personnel File oI RPD OIIicer Chris Carter and Sargent Monica Lopez as well as supboena Irom
    the RPD all the volumns oI crap Richard Hill has given them on this in addition to noticing the court
    and City Atty as to Richard HIll being a witness, subpoena him (though the earlier continuance would
    appear to imply he already is) AND SUBPOENA THE OLD CALIFORNIA NEUROSURGEON WHO
    CAN GET HIS OUT DOWN HERE FOR THE TRIAL AND A DEPOSITION PRIOR THERETO,
    ETSPECIALLY CONSIDERING THAT THE VARIOUS POLICE REPORTS AND MOTIONS FOR
    ORDERS TO SHOW CAUSE QUOTE MERLISS AS SAYING HE WAS AT THE PROPERTY IN
    THE "WEEKS PRECEEDING" THE ARREST, ETC., ETC. (THE STUFF BOBBY PUENTES GOT
    YOU WHEN HE COPIED YOU MY FILE, IE MY FAXES TO BOBBY, SET THIS OUT CLEARLY).
    iF THESE FOOLS WANT TO HAVE ME ARREST AND ATTEMPT TO RUN A TRAIN ON ME,
    THEN THEY CAN PUT THE TIME AND WORK IN AND NOT PHONE IT IN FROM CALI AND
    HAVE THEIR RENT-A-LYCAN rICHARD HILL DO IT. ALSO PLEASE FILE A MOTION TO
    dismiss based upon denial oI right to a speedy trial, spoliation oI evidence, etc.... PEACE Zach
    Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- RE: Trial Date 3/14/12 Keith
    Loomis To zachcoughlinhotmail.com From: Keith Loomis (keithloomisearthlink.net) Sent: Wed
    3/14/12 2:35 PM To: zachcoughlinhotmail.com Dear Mr. Coughlin: My obligation under Nevada
    Rule oI ProIessional Conduct 1.2 is to abide by a client`s decision concerning the objectives oI
    representation and, as required by Rule 1.4 to consult with the client as to the means by which the
    objectives oI representation are to be pursued. . In a criminal case the lawyer shall abide by the
    000773
    clients decision, aIter consultation with the lawyer, as to plea to be entered, whether to waive jury trial
    whether the client will testiIy. Under Rule 1.4 (a)(5) a lawyer shall consult with the client about any
    relevant limitations on the lawyers conduct when the lawyer knows that the client expects assistance
    not permitted by the Rules oI ProIessional Conduct or other law. Under Rule 2.1. In representing a
    client, a lawyer shall exercise independent proIessional judgment and render candid advice. In
    rendering advice, a lawyer may reIer not only to law but to other considerations such as moral
    economic, social and political Iactors, that may be relevant to the client`s situation. Under Rule 3.1. A
    lawyer shall not bring or deIend a proceeding, or assert or controvert an issue therein, unless there is a
    basis in law and Iact Ior doing so that is not Irivolous, which includes a good Iaith argument Ior an
    extension, modiIication or reversal oI existing law. A lawyer Ior a deIendant in a criminal proceeding
    that could result in incarceration, may nevertheless so deIend the proceeding as to require that every
    element oI the case be established. Under Rule 3.2(a) and (b). A lawyer shall make reasonable eIIorts to
    expedite litigation consistent with the interests oI the client. The duty stated in paragraph (a) does not
    preclude a lawyer Irom granting a reasonable request Irom
    opposing counsel Ior an accommodation, such as an extension oI time, or Irom disagreeing with a
    client`s wishes on administrative and tactical matters, such as scheduling depositions, the number oI
    depositions to be taken, and the Irequency and use oI written discovery requests. Under Rule 8.4(d) It is
    misconduct Ior a lawyer to engage in conduct which is prejudicial to the administration oI justice.
    These, and others, are the proIessional rules I operate under in providing legal representation to you in
    case number 11 CR 26405, a case in which you are charged with the crime oI trespass. It is my
    understanding that your objective in this criminal case is that you be acquitted oI the crime oI trespass.
    That is my purpose in representing you. I am happy to work towards that outcome to the best oI my
    ability. It is my opinion, however, that much oI what you ask to be done is not in compliance with the
    above rules. Accordingly, I will not be Iiling a motion to dismiss based upon NRCP 6(a) and (b), I see
    that argument as Irivolous. I will not be proceeding with the summoning oI an out-oI-state witness
    (Merliss) unless you can establish his materiality to the deIense. Nor will I be subpoenaing the
    personnel records oI law enIorcement personnel unless you can establish to my satisIaction why they
    are relevant to this case. I have no intention at this time oI conducting any depositions in the case or
    sending requests Ior production oI documents or interrogatories in the case. I see these actions as
    unduly burdensome on the judicial system, and unwarranted by anything you have provided to this
    point. I also see them as Irivolous and an attempt to utilize the criminal justice system to accomplish
    objectives not relevant to my purpose in representing you. II you are dissatisIied with the limitations I
    perceive to exist regarding my representation oI you, you are welcome to terminate my representation
    oI you. You may then ask the Court to appoint a new lawyer to represent you. It is my understanding
    that Deputy Machem will be testiIying in the case along with Richard Hill and Casey Baker. I do think
    that there are some interesting angles to the case upon which a deIense can be based and I will be
    pursuing those angles. I have asked you in previous e-mails to provide inIormation which I believe will
    be helpIul to the deIense oI your case. I advise you that the City has oIIered to recommend time-served
    as a sentence iI you enter a no-contest plea to trespass. It is also my understanding that you have other
    criminal cases pending in both Reno Justice Court and in the Second Judicial District Court oI the State
    oI Nevada. It is my understanding Iurther that all oI the criminal cases can be resolved in a single plea
    to a misdemeanor oIIense iI you will obtain psychological counseling. It is my obligation to inIorm you
    oI the availability oI these resolutions to the present criminal case in which I provide representation. I
    will, oI course, abide by your decision as to whether to accept these resolutions or not. I note that there
    is a psychiatric evaluation scheduled Ior you in 2nd Judicial District Court Case No. CR12-0376 on
    April 3, 2012. The outcome oI that evaluation could have an important impact on this case. I am asking
    that you authorize a release oI the inIormation contained in the evaluation to me so that I may
    determine what impact it could have on your behalI in this case. I remain prepared to represent you in
    the trespass case. I think that a trial oI the case will be interesting. My representation, however, is
    000774
    circumscribed by the Nevada Rules oI ProIessional Conduct. Keith Loomis From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Tuesday, March 13, 2012 4:29 PM To:
    keithloomisearthlink.net Subject: RE: Trial Date Dear Mr. Loomis, In your motion to dismiss, I
    would like you to really Iocus on and set Iorth to the court the Iact that the eviction order needed to be
    served in compliance with NRCP 6(a) and 6(e). NRS 40.400 Rules oI practice. The provisions oI NRS,
    Nevada Rules oI Civil Procedure and Nevada Rules oI Appellate Procedure relative to civil actions,
    appeals and new trials, so Iar as they are not inconsistent with the provisions oI NRS 40.220 to 40.420,
    inclusive, apply to the proceedings mentioned in those sections. The language about "removing the
    tenant with in 24 hours oI receipt oI the order" is only applicable to those situations where the tenant
    does not Iile a Tenant's Answer or Tenant's AIIidavit. I did Iile such a Tenan'ts AIIidavit, and litigated
    the matter thoroughly. In those situations, NRS 40.400 requires NRCP to apply, speciIically NRCP 6(a)
    and 6(e), and clearly WCSO Machem (please subpoena and identiIy as witnesses Mary Kandaras, Esq.
    oI the WCDA Civil Disvision, WCSO Deputy Machem, and WCSO Civil Division supervisor Liz
    Stuchell Ior the trial in this matter, and Iurther send out a request Ior production and subpoena duces
    tecum to the WCDA and the WCSO askign them to speciIy, in writing and in detail, the exact
    procedures and policies in place with respect to the service and conducting oI such lockouts (ie, not
    deIault lockouts where there is not a summary eviction hearing, but one's like the present one, where
    there was a Tenant's Answer and hearing held, etc....). Be sure to ask whether the are aware oI what
    "personally served" means, and whether they mail the Orders on top oI merely posting them to the
    door. Further, I have been told that the WCSO has a policy or penatly system in place whereby the
    deputies must get these lockouts perIormed "within 24 hours oI receipt oI the order" the receipt being
    the WCSO's receipt, and not the tenant's receipt. I don't ncessarily read the statute that way, but....the
    WCSO policy and punishment system would be at least some indication oI what the legislature meant
    (I guess, but I dont' really think so, though, you will note that Hill was leIt with nothing but citing to
    the "usual and customary practice oI the WCSO" in serving the Eviction ORders and perIormign
    lockouts, I believe, because the law does not contain much to support Hill's contention and thereIore he
    wishes to see the WCSO "customary practices" being given the weight oI law. Please see some speciIic
    selections attached Irom the eviction matter. I know, I know, you want to curtail the scope oI your
    representation to an immaculate degree....but Hill can clearly be seen in his various Motion to Show
    Cause, State Bar Grievances, Temproary Protection Order Applications, etc., etc., to be a punk who
    doesn't much like competing on an even playing Iield, like any good private schooler, he would rather
    sick an attack dog on somebody than get in the octogon and go toe to toe mentally. Regardless, Hill
    shows a continual desire to subvert NRCP 6(e), which applies to service oI documents Iiled
    elecronically in the Second Judicial District Court. He would rather withhold opposing counsels
    computers, laptops, client Iiles, driver's license, etc. The last thing he wants is to go argument Ior
    argument, research Ior research, writing Ior writing. Private school and daddy's pleading bank. Hill
    Iiles a Motion to Show caue allegeing Coughlin subvreted an Order that was Iiled on January 11th,
    2012 with Couglin's action oI January 12th, 2012. Under NRCP 6(e), the Order Denying the TRO had
    not even been served yet, and there has been no indidcation that Hill gave the Order at the town dump
    to anyone other than an RPD OIIicer. Further, it is not all that clear why Hills Motion Ior ORder to
    Show Cause deserves a Iull blown hearing when D7 does not indicate a hearing will be accorded to the
    appeal. This is particularly suspect given that Anvui sets Iorth that appeals in summary eviction matters
    are done on a trial de novo basis. There are a number, but how about your complete lack oI
    communication with me prior to so setting that date. How about Mr. Taitel and Mr. Puentes's Iailure in
    this matter and the prejudice to my case so created? How about your Iailing to identiIy yourselI as the
    public deIender to a room Iull oI deIendants in jail at the arraignment? There are other reasons as well,
    including, but not limited to, your resistance to subpoena the materials I have and am requesting. I wish
    Ior you to subpoena the personnel Iiles oI both RPD Sargent Monica Lopez and OIIicer Chris Carter. I
    wish Ior you to list Dr. Merliss as a witness and subpoena his appearance and appropriately notice the
    000775
    City oI Reno in that regard, same goes Ior Richard Hill and Casey Baker (Baker, by letter dated
    November 10th, 2011 demands the Iull rental value Ior the property as "storage" under NRS 40.253,
    while also asserting he will go aIter moving and inventory costs, in addition to Hill's contractor Phil
    Stewarts later ridiculous charges and perjury. Please subpoena Stewart as well. Most importantly
    subpoena Washoe County SheriII's OIIice Deputy Machem to testiIy and serve a subpoena dueces
    tecum, requests Ior production, and interrogatories seeking records and responses Irom the WCSO as
    set Iorth in the letter I sent Liz Stuchell (see attached) on or about February 10th, 2012. You see, the
    WCSO and Deputy Machem may be committing a Iraud upon the public by repeatedly Iiling aIIidavits
    oI service that attest to personal service where Liz Stuchell, oI the WCSO admits that they clearly do
    not know, or choose to "remix" the legal meaning oI "personally serve". Further, please inIorm the City
    oI Reno and appropriately notice the same as to the existence and intent to oIIer into evidence a video
    oI Richard Hill, Esq., admitting that he and his Iirm, on behalI oI Dr. Merliss, were withholding the
    accused personal property, in addition to the client's Iiles Irom the Iormer commercial lease home law
    oIIice oI the accused and asserting a lien, under NRS 40.253 Ior "storage", however, as the video tape
    shows, Hill admits to charging
    the undersigned the same $900 per month rent as was charged Ior the "Iull use and occupancy" oI the
    premises at 121 River Rock St., Reno, NV 89512. Hill Iurther demands that property be removed in a
    certain order, regardless oI whether his articiIically inIlated lien was paid or not. Additionally, Hill
    committed Iraud upon the court in a number oI instances and Iiled Ialse police reports wherein he
    alleges that he agreed to or otherwise made available to the accused items such as the accused's clients
    Iiles (and Ior a time wallet and state issued driver's license) where, clearly, without requiring any
    payment by the accused, however, clearly, the Iacts show that Hill never actually lived up to those
    assertions and repeatedly Iailed to show provide such items absent payment oI his artiIically inIlated
    lien. Further, I wish Ior you to divulge and provide notice that it is available Ior pickup and that we
    intent to introduce into evidence a video oI RPD Sargent Monica Lopez admitting that she and RPD
    OIIicer Carter did not identiIy themselves as police oIIicers or otherwise ask the accused to leave 121
    River Rock St. on the date oI the arrest prior to Merliss opening the door to the basement. This is
    apparently in direct contradiction to the sworn Iilings made by Richard Hill, Esq. in his aIIidavits
    attached to his various Motions to Show Cause, the Reply to Opposition thereto, Opposition to TRO,
    etc., etc. (in RJC Rev2011-001708 and the appeal in CV11-03628). For that reason alone Merliss'
    presence is required. He was a precipient witness and you are asking me why he should be there? You
    have a duty to zealously advocate on my behalI, Mr. Loomis. You are paid, by the public, to do so.
    Please divulge any prior associations you have with anyone employed by or workign as an independent
    contractor with the RMC and or the Reno City Attorney, including anyone you went to law school with
    or attended the same law school as, within a 5 year period. Further, I wish Ior you to Iile a motion
    seeking a mistrial or otherwise requiring the recusal oI the RMC and Iurther disclosing why it is that
    Judge Gardner seemingly has recused Judge Dilworth (why wouldn't Judge Dilworth recuse Judge
    Dilworth?) in one case, without detailing why exactly, while Judge Gardner apparently is intent on
    remaining on in 11 CR 26405, despite the Iact that an apparent conIlict exists, one which he only
    disclosed upon prompting Irom the accused, with respect to Judge Gardner's very recent employment
    with the Reno City Attorney's oIIice and the existing and or brewing litigation (or, at least, possible
    litigation) between the accused and the City oI Reno, Reno City Attorney, and possibly, the RMC. Zach
    Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: RE: Trial Date Date: Mon, 12 Mar 2012 09:26:35 -0700 I can
    do that iI there is a good reason to vacate the date. What is the reason? Keith From: Zach Coughlin
    |mailto:zachcoughlinhotmail.com| Sent: Friday, March 09, 2012 6:28 PM To:
    keithloomisearthlink.net Subject: RE: Trial Date Please Iile something with the court seeking to
    000776
    vacate that trial date and explaining that you Iailed to even once consult with your client prior to setting
    it. Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, Iax: 949 667 7402;
    ZachCoughlinhotmail.com Nevada Bar No: 9473
    -------------------------------------------------------------------------------- From: keithloomisearthlink.net
    To: zachcoughlinhotmail.com Subject: Trial Date Date: Fri, 9 Mar 2012 10:44:17 -0800 See attached
    Full view , , Back to messages RE: i was evicted 3 15 12, i need a continuance 2:03 PM Keith Loomis
    To zachcoughlinhotmail.com From: Keith Loomis (keithloomisearthlink.net) Sent: Wed 3/28/12
    2:03 PM To: zachcoughlinhotmail.com Dear Mr. Coughlin: This message is sent to address issues
    raised in the e-mail you sent on 3-26-12. 1. Please note that you are Iree to send the communications
    you send to me, to anyone else you desire. You should be aware that sending your communications to
    other parties will cause your communications to me to lose their attorney-client conIidentiality. 2. For
    what speciIic purposes do you need a continuance? A continuance purely Ior the purpose oI delay is not
    a proper reason Ior a continuance. 3. Whether you are entitled to e-mail the Reno Municipal Court is
    not my concern. That is a problem to be addressed between you and the Court. 4. Ms. Drake is no
    longer the attorney handling your case Ior the Reno City Attorney`s OIIice. Your case is now being
    handled by Christopher Hazlett-Stevens, Esq. 5. In response to your question regarding the weaknesses
    oI the trespassing case I oIIer the Iollowing: a. The complaint is deIicient in that iI Iails to set Iorth the
    elements oI the crime oI trespass. It Iails to identiIy whether your presence on the premises was Ior the
    purpose to vex or annoy the owner or occupant oI the premises or whether it was an entry onto the
    premises aIter a warning not to so trespass. This is probably easily remedied by an amendment at the
    time oI trial. Nevertheless these are alternative theories on which a trespass case can be pursued and the
    deIendant is entitled to know on which theory or theories a case is being prosecuted in advance oI
    showing up Ior trial. b. You Iiled an appeal on October 19, 2011, apparently, oI the order made by
    Justice oI the Peace SIerrazza on October 13, 2011. That order denied your request Ior a continuance
    and granted summary eviction unless you Iiled a deposit with the court. Typically the courts lose
    jurisdiction to rule on other matters in the case once an appeal is taken. It is clear Irom the court records
    that this appeal was pending beIore the Second Judicial District Court at the time the court held a
    hearing on the unlawIul detainer on October 25, 2011. It may well be that the Justice Court lost
    jurisdiction to hold the eviction hearing while the appeal was pending. c. I am working on some other
    thoughts. 6. II you are dissatisIied with the way I am representing you, you remain Iree to seek a new
    attorney. 7. Another chuckle regarding my ownership oI strip clubs. I don`t own or have any ownership
    interest in any strip clubs, brothels, adult book stores or movie houses. I guess that leaves me Iree to
    moralize. 8. I still don`t see the importance oI Dr. Merliss. The request Ior payment oI an amount equal
    to rent, was Ior storage oI your personal property. You are entitled to contest the amount oI the storage
    Iee, which you did. There is no credible evidence anywhere which suggests that anyone intended to
    reopen or create a new tenancy allowing you to retain possession oI the premises. 9. Dr. Merliss is an
    out oI state witness. In order to compel his appearance, his testimony must be material. NRS
    174.425(1). It does not appear that his testimony is material under the inIormation you have provided
    Further, under NRS 174.425(2) he is entitled to be paid his subsistence and travel expenses incurred in
    coming to Nevada. Are you prepared to pay those expenses in advance oI his coming to Nevada? 10. I
    don`t intend to Iax or e-mail to you, your Iull Iile in this case. You already have everything with the
    exception oI a couple oI items which I mailed to your old address. I will send them again to your new
    address. II you want to review the Iile you are welcome to do so at my oIIice. II you want copies oI
    anything in the Iile you may mark the items. AIter giving you a cost estimate, Ior which I require
    payment in advance, we will provide you with copies oI the marked items. Keith Loomis From: Zach
    Coughlin |mailto:zachcoughlinhotmail.com| Sent: Monday, March 26, 2012 10:33 PM To:
    keithloomisearthlink.net; stermitzsbcglobal.net; jmdrandazza.com; jbolescallatg.com;
    kristiemanningyahoo.com; kadlicjreno.gov Subject: i was evicted 3 15 12, i need a continuance
    Dear Mr. Loomis, I was wrongIully evicted on 3 15 12, and I need a continuance in the criminal
    000777
    trespass matter that you set overly quickly against my express wishes anyway. My ability to collect
    evidence necessary to my deIense and otherwise prepare has been adversely aIIected. Additionally, I
    don't Ieel as though you are perIorming in an appropriate manner as deIense counsel, but rather you
    seem stuck in your prosecutorial ways, too quick to look Ior any excuse whatsoever to bury one's case,
    so I think you have Iorced a split here, which Iurther prejudices my case and augers towards a
    continuance. Please move Ior one immediately and copy me on my entire Iile by email and Iax please.
    Additionally, please seek clariIication Irom the RMC as to whether I am allowed to ever send an email
    to renomunicrecordsreno.gov. Please note, today, Judge Flanagan denied Richard Hill's latest
    Irivolous motion. Did you know that Kevin Kelly, oI the State Bar oI Nevada's Character and Fitness
    Committee Ior at least the last decade owns and runs the Spearmint Rhino strip club in Las Vegas:
    http://www.reviewjournal.com/lvrjhome/2002/Mar-06-Wed-2002/news/18241452.html I know I
    always like my three hour tours oI heavy handed moralizing Irom someone who runs a monolithic strip
    club in Las Vegas. You are on the State Bar oI Nevada's Iee dispute committee, aren't you Mr. Loomis?
    Do you own any strip clubs? Mr. Loomis, which oI the elements oI the trespass charge RMC 8.10.040
    do you Ieel are weakest Ior Deputy City Attorney Jill Drake, whom I inIormed about the admission by
    Reno PD OIIicer Chris Carter that Richard G. Hill, Esq. bribes him, but Ior which Ms. Drake indicated
    a complete lack oI interest and expressed that she would not be Iollowing up on that report oI bribery
    oI a RPD OIIicer.
    Mr. Kadlic, please place a copy oI this correspondence in Jill Drake's personnel Iile. Additionally
    please place one in Allison Ormaa's personnel and employment Iile too, in addition to Deputy City
    Attorney Dan Wong's employment Iile, as all three oI those Deputy City Attorney's were provided that
    report and all three indicated they did not care and had no intention oI Iollowing up or otherwise
    investigating the admission by RPD OIIicer Chris Carter that Richard G. Hill, Esq. bribed him. I think
    the Iailure to Iollow up by any oI these 3 Deputy City Attorney's relates to any Iuture negligent hiring,
    training, and supervision claims that the Reno City Attorney may need to deIend against when
    representing the Reno PD like it did in the EeoI v. Pitsnogle case: http://www.lvrj.com/news/reno-
    oIIicial-accused-oI-witness-tampering-116586528.html You know, Deputy City Attorney Ormaas's
    decision to push on Ior that $70 traIIic ticket is looking more and more interesting. \\ Oh, and, Mr.
    Loomis, Dr. Merliss presence is necessary because his understanding oI the extent to which his
    attorney, Richard G. Hill, Esq. had eIIectively rescinded any eviction Order by sending a bill Ior the
    same amount as Iull use and occupany oI the location at 121 River Rock St. goes to the substance oI
    the elements Iound in RMC 8.10.040 as well as the credibility oI both Merliss and Hill. Sincerely,
    000778
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No:
    9473
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No:
    9473
    my attempt to be provided access to the grievances filed today
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 3/26/12 5:35 PM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    Dear Mr. King,
    This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and attempted
    to be provided access the the various "other different judges" grievances that I, prior to last Friday, was completely unaware of.
    I have sent you several written correspondences detailing the tampering and other problems with my USPS mail incident to the
    two domestic abuser attacks I have been subject to since approximately 1/1/12, and ask that you copy my on all
    correspondences or document production via email and fax. Today, you showed me a two page letter from Judge Nash Holmes.
    Did you interpret it to be a "grievance"? How is that designation arrived at? You refused to identify the names of any other
    judges from whom you have received any other similar such materials and further refused to allow me to view and such items. I
    asked for a copy of the large box of documents, and other FOIA request materials and you refused. Further, you told me you
    didn't care I received anything you sent me and stated that I did not have a right to review such complaint letters, grievances, or
    other materials, prior to being questioned by you and before any such meeting. I informed you that I am considering different
    attorneys to represent me right now, and indicated I need these materials to prepare for any future meeting with you. My
    records incidate that your letter of 3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on
    that date. Please let me know if you received any sort of "return to sender" letter for that mailing.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    000779
    Print Close
    Please note my new mailing address.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 3/26/12 5:27 PM
    To: glennm@nvbar.org
    Dear Assistant Bar Counsel Machado,
    Please note my new mailing address.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    FOIA REQUEST
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 3/26/12 5:27 PM
    To: laurap@nvbar.org
    Dear Mr. Peters,
    I have faced attacks by domestic abusers recently, as adjudged in FV12-0187, and
    FV12-00188 and my mail has apparently been tampered with. Please resend me
    anything you have mailed me since 12/15/11 to the new address below and update my
    address on file.
    Mr. King showed me a signed letter today that indicated he email me a copy of it on
    3/16/12. My records do not indicate any such email was received. Please correct your
    records and my file in this matter to reflect any misstatement in Mr. King's letter of
    3/16/12. This is a FOIA Request as well, I would like a copy of all the documentation,
    tapes, cds, letters, media, reports, in this and any other matters involving me (preferably
    fax or email it, and failing that, please mail it to the address below).
    Sincerely,
    000780
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: Due Process concerns related to the "grievances"
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 3/24/12 4:45 AM
    To: davidc@nvbar.org; glennm@nvbar.org; coe@gbis.com; keith@leelawoffice.net;
    tjhlaw@eschelon.com; geofgiles@hotmail.com
    2 attachments
    all emails from Patrick King Bar Counsel Nevada PatrickK@nvbar.org.pdf (368.9 KB) ,
    EMAILS TO PATRICKK@NVBAR.ORG PATRICK KING BAR COUNSEL.pdf (827.6 KB)
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    FW: Due Process concerns related to the "grievances"
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 3/24/12 4:32 AM
    To: davidc@nvbar.org; glennm@nvbar.org; coe@gbis.com; keith@leelawoffice.net;
    tjhlaw@eschelon.com; geofgiles@hotmail.com
    5 attachments
    3 23 12 FAX TO BAR COUNSEL PATRICK KING NEVADA BAR.pdf (55.3 KB) , 3 19 12 fas to
    rmc marshals regarding property wcso.pdf (40.0 KB) , Pages from mary barker rmc 11 tr
    26800 order denying motion for return of bond.pdf (508.2 KB) , notice of appeal 11 tr
    26800 rmc and Motion for reconsideration set aside etc.pdf (2.6 MB) , combined collection
    of materials for State Bar of Nevada Grievance against Peter Christiansen, Kevin Kelly,
    Michael Sanft, Patrice Eichman, etc adobe 4 and later grey.pdf (17.1 MB)
    Dear Sirs,
    I am concerned that the Bar Counsel I am working with is getting a bit confused about a few thing, Mr.
    Patrick King. He seems to think he previously informed me of things for which he has not, like
    "different judges filing grievances" against me and whether or not Mr. King ever provided me anything
    in that regard, or any documentation related thereto. He has not and did not, and indicates he will
    not. All why arguing that I am not scheduling a meeting with him quick enough to respond to these
    materials for which he only informed me of their existence yesterday, and for which he will not allow
    me to review prior to meeting him.
    Please find attached materials related to the grievance that Mr. King refuses to file or investigate
    incident to my 2002-2008 interactions with the Character and Fitness Committee (including the owner
    of the strip club, Spearmint Rhino, and one time would be judge, Kevin Kelly, and the attorney I was
    000781
    "referred" to "on a pro bono basis". I feel it is a bit untoward that Richard G. Hill, Esq. is able to file a
    grievance against me based on so little, and where what it is based on relies primarily on innuendo and
    hearsay. Further, I am very upset that Mr. Hill has made his ridiculous "crack pipe and a bag of weed
    allegations", particularly to the extent it undermines the good work done by those in the recovery
    community.
    I note that Judge Flanagan did not quite seem to share the sentiment after the hearing on Friday
    3/23/12 on Hill's Motion to Show Cause that Mr. King echo's from that of, allegedly, the Department 3
    clerk and the City of Reno Marshals. I do find it a bit objectionable when support staff as the court
    interject themselves to an impermissible extent into the merits of a litigation or exert an overly heavy
    hand on sturm and drang of a matter. I realize the way things are set up nowadays, that members of
    law enforcement make more money than lawyers, but when we are in a court room, I still consider that
    the domain of judges and lawyers, and of course, the litigants, and do not believe overgrown, overpaid
    City of Reno Marshals should be rummaging through counsels cell phones and laptops because they are
    afraid some of their malfeasance may be testified to at some point. And I don't believe Bailiff's at the
    RJC should tell me they are going to "stick their foot up my ass" and that I must "get my ass out of
    here" at 4:55pm when I am trying to file something urgent, like a Motion to Stay Eviction, or that the
    filign office clerks, like Christine Erickson of the RJC should be able to lie to me for months about
    whether or not I can file by fascimile, then repeatedly fail to file documents that I submit for filing in
    direct contravention of the dictates of Sullivan v. Eighth Judicial Districtd Court. And there is a bit too
    much of Judges throwing attorneys in jail for their merely tryint to preserve objections for the record on
    appeal, for my taste, at least. And when they take me to jail, they don't let me make all the calls I
    need to make like they would a Lavere Redfield. I submit this respectfully for your consideration.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: patrickk@nvbar.org
    Subject: Due Process concerns related to the "grievances"
    Date: Sat, 24 Mar 2012 01:28:01 -0700
    Zach Coughlin, Esq.
    Nevada Bar No: 9473
    PO Box 60952
    RENO, NV 89506
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    000782
    TO: Patrick King, Esq.
    State Bar of Nevada Assistant Bar Counsel
    sent via email to: PatrickK@nvbar.org
    March 23, 2012
    Dear Assistant Bar Counsel King,
    I have a few question I would like to respectfully submit to you. What have you done to ascertain whether the
    Marshal's have a vested interest in discrediting me? I would like you to forward me all communications from
    anyone in Department Three. I would like for you to obtain a copy of the hearing today, wherein Judge Flanagan
    concluded the hearing by quoting to something I wrote (it was the only thing he mentioned after indicating that he
    wished to speak to the attorney's in this matter after dismissing the witness, the lying contractor for Richard G.
    Hill, Phil Stewart, who has offered perjured testimony numerous times on Mr. Hill's and his client's behalf. Judge
    Flanagan quote something I wrote in a filing in 11 TR 26800, where the Judge, Dorothy Nash Holmes, a lifetime
    prosecutor and or warden of a prison (or something along those lines) had me arrested and confiscated my
    property, including a smart phone (and a smart phone these days could store the entire contents of a law firm's
    files and a law library in one), my less advanced cell phone, my premium electric shaver and other items. My car
    was towed during the summary 5 day jail stay Judge Nash Holmes found appropriate, costing me $300 to get it out
    of the lot (also lost a client that would have brought in a substantial amoutn of money, by my standards anyway).
    A $100 bail was paid to get me out of jail on the fourth day (thus avoiding a fifth day) and accepted by the RMC,
    yet, I was not released and the RMC has decided to keep the money anyways.
    Yesterday I went to the RMC to pick up a copy of the audio transcript of the 2/27/12 Trial in that matter 11 TR
    26800. After asking some questions of filing office supervisor Donna Ballard and a front counter clerk named
    Daniel, wherein both agree with me that some of the ways things were done done at the Reno Municipal Court
    lacked transparency, a system of checks and balances, and other fundamental notions of due process and fair play,
    all of the sudden, two beefy City of Reno Marshals in their mid 20's decided, unilaterally, it seems, to ask me to
    leave, as Ms. Ballard certainly had expressed nothing in the way of discontent with our conversation, nor had
    Daniel. While I was leaving I could clearly hear Marshal Thompson lying extensively into his radio, trying to
    manufacture some sort of report of a scene were there had been none, other than that put on by the City of Reno
    Marshals, whom have lied extensively about whether or not they ever took possession of a micro sd card incident
    to the full body all pockets, belligerent, accusatory search they performed incident to the summary contempt
    finding and arrest of 2/27/12. I request that you ask for a copy of Marshal Harley's employment file from BOTH
    the RMC and the City of Reno Marshals Division and see if they put in my letter and complaint in that regard.
    Or, do you "find that the burden of proof in the various grievances I have filed with you has not been met, that all
    the evidence needed for a conviction has not been presented to your lap with a bow? Did Mr. Hill present such
    proof, meeting such a burden. Clearly, the only thing you provided to me from Mr. Hill was an EXCERPT of his
    1/14/12 letter to you, which reference numerous shadowy previous phone calls between the two of you (are you
    Mr. Hill's hand picked Bar Counsel, or was this case assigned randomly? Does Mr. Hill get to pick which RPD
    Sargents and Officers show up for his calls for help? Have you made any inquiry to ascertain this. Why does
    Richard Hill constantly file a peremptory challenge anytime he is assigned to Judge Adam's Department 6,
    apparently? Did the innuendo and hearsay Richard G. Hill, Esq. Mentioned in his unsigned, unsworn letter to you
    of 1/14/12 provide you sufficient proof to meet the clear and convincing evidence stand you indicate that the
    grievances I filed did not? How do the copies of electronic correspondences between myself, State Bar of Nevada
    Director of Admissions Patrice Eichman, Peter Christiansen, Esq., and Michael Sanft, Esq.,'s legal assistant Kelly
    Huff, wherein she explicitly admits to her firm committing malpractice in my case, fail to provoke even a scintilla
    000783
    of investigation into a grievance from or the State Bar of Nevada?
    And the impropriety implicated by Kevin Kelley's conduct, and Mr. Christiansen's later lying under oath at the
    June 2002 Character and Fitness Committee hearing for which he feels he satisfied the $5,000 he received in
    payment (well, okay, he did file an 8 page pre-hearing brief that rehashed factual recitations from various previous
    filings of the Committee, then did manage to cite to the Claiborne case, which concerned a former judge, not an
    applicant for admission to the bar, and he did fail to subpoena percipient witness Mark Tratos, or any of the
    relevant faculty from Boyd School of Law, and he did screw up the affidavits of the students witnessing me
    turning in the hard copy of the paper, and his office did forward a correspondence about alcoholism to the State
    Bar despite an express indication by the client atop of it that said not to do so, and his office did mistate whether
    they ever turned in the second Consent Agreement send with confirmation to them on September 27
    th
    , 2004 in a
    November 2004 email, so....wait, are you really saying there isn't enough there for a grievance FROM A CLIENT
    FILING ONE AGAINST HE WHO WAS COMPENSATED $5,000 TO REPRESENT HIM (THOUGH
    CHRISTIANSEN LIED UNDER OATH AND SAID IT WAS ON A PRO BONO BASIS, IN ACCORD WITH
    THE REPRESENTATIONS MADE BY STRIP CLUB SPEARMINT RHINO OWNING CHARACTER AND
    FITNESS COMMITTEE MEMBER KEVIN KELLEY, ESQ., WHOSE BEST FRIEND WAS THE
    PSYCHOLOGIST THE APPLICANT WAS STEERED TO IN THE ADMISSIONS PROCESS)? BUT, YOU
    ARE SAYING PURSUING A GRIEVANCE PROCEDURE AND, APPARENTLY, FORMAL HEARING
    INCIDENT TO THE ATTEMPT TO FILE A GRIEVANCE BY A KNOWN SCANDALOUS OPPOSING
    ATTORNEY RICHARD G. HILL, ESQ., AGAINST MYSELF, IN A MATTER FOR WHICH I AM NOT AN
    ATTORNEY OF RECORD (PRO SE ATTORNEY LITIGATNS, APPARENTLY, CANNOT RECEIVE
    ATTORNEY'S FEE AWARDS UNDER THE SELLERS CASE, SO HOW CAN THE RULES OF
    PROFESSIONAL CONDUCT BE APPLIED TO ANY OF MY CONDUCT IN A CASE WHERE I AM A PRO
    SE LITIGANT?)? It sure is curious how you find sufficient proof to pursue Richard G. Hill, Esq.'s grievance
    against me, yet, you claim that all the grievances I filed do not warrant any sort of investigation on your part. Very
    curious, indeed...
    You wrote: "As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect
    the public and the administration of justice by insuring that Nevada Lawyers are complying with standards
    required of the profession. It appears that you are not."
    I would like you to specify in detail exactly what forms the basis of your assertions in those a statements, as
    heretofore you seem to rely upon only the unsigned, unsworn, hearsay cited to by Richard G. Hill and some
    apparent grievances filed by judges, to which you have not previously informed me of or offered any proof
    thereof, despite your incorrect assertion that you have done so. If you, as you wrote that you did, previously
    provide any indication or documentation in support of these "grievances" filed by Judges, please provide support
    therefor in explicit written detail with supporting documentation and proof service.
    You further wrote, and I seek explication and specificity with regard to details and attribution incident to the
    allegations therein contained that:
    " I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
    claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal
    research." Would you say, Mr. King, that you would very much prefer it if I had done NO legal research prior to
    meeting with you?
    You go on to write "You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
    standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As
    I have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from
    different Courts."
    That statement casts extreme doubt upon everything you have said to me, Mr. King, and everything you will say to
    me. Please provide the requested proof of any grievances against me that came from "Judges from different
    Courts". You do realize, Sir, that some "Judges in Different Courts" have pulled drivers over recently and
    impersonated a highway patrol officer, and that some Clerks of Court have embezzled $250,000 from the public
    fisc? And, just to be clear, you truly do not find anything worthy of a grievance per Mr. Taitel's curious
    appearance/disappearance as attorney of record, failure to do a conflicts check, failure to subsequently disclose
    such a failure and the tangible harm it has done to me vis a vis my suing Nevada Court Services and his sharing
    an office, receptionist, and being listed on the Nevada Court Services web site as "associated with" their business
    entity? Didn't Mr. Taitel have a recent ethics investigation pursuant to some run for judicial office?
    000784
    Also, Judge Nash Holmes indicated at trial, and this is a direct quote, that she "doesn't care about corruption, or
    bribery, retaliation, or police misconduct"...well, that is as close to a direct quote as I can make given the fact that
    the RMC, just yesterday refused to provide me a copy of the audio transcript from the 2/27/12 Trial in 11 TR
    26800, presided over by Judge Nash Holmes, after a length disappearance by her immediately before calling my
    case, and after hearing all the other matters on that stacked docket, and after denying my request for a continuance
    but granting Deputy City Attorney Allison Ormaas's request for one to "speak" with Reno Police Department
    Sargent Tarter, whose cross examination formed the basis for my arrest and incarceration incident to the summary
    contempt finding. The cross examination focused on whether Sargent Tarter had retaliated against me for reporting
    the bribery admission by RPD Officer Chris Carter (he admitted Richard G. Hill, Esq. bribes him) to Sargent
    Tarter while at the scene of my attempts to get Richard G. Hill to turn over my client's files and my wallet and
    state issued identification. If you want to put your name on the line over this, Mr. King, and you think we still live
    in a world with very little transparency, who am I to tell you any different.
    You further wrote: "These grievances, and the evidence attached with them, rather clearly puts into question your
    competence to practice law." Please narrow down which parts of which grievances you feel so implicate my
    competence, in explicit written detail.
    You further wrote: "As I have explained to you, I will make the evidence and exhibits available to you when you
    come to inspect them at my office." Mr. King, please indicate when it was and in what form or method you
    communicated this offer to "make the evidence and exhibits available to you when you come to inspect them at
    my office"? Please further explain why on earth I would only be allowed to inspect them at your office and how
    that does not create and overly bullying and intimidating scenario departing entirely from fundamental notions of
    due process. Please just fax and email (both please) the entire contents of all these materials to me. I am likely
    suing the USPS and some of its local postal inspectors and or station supervisors under the Federal Tort Claim Act
    and while I have taken every prudent step to ensure the timely delivery of my mail (I have a ton of evidence and
    documentation in support of this), I am EXPLICITLY indicating to you that I wish for you to fax and email me all
    of these materials rather than send them through the mails (USPS, UPS, Fed-Ex, etc, etc.).
    You then wrote: "I will not send you reports or document, especially since you claim your mail is being
    compromised. " I am appalled that you would write this, and offended really. Please email and or fax them to me.
    I have communicated with the USPS and my change of address has been processed (there was a delay through no
    fault of my own) and if you refuse to send these to me via email or fax, the go ahead and mail them to my new PO
    BOX, though taking that tact will likely only make your conduct throughout this proceeding further suspect. Such
    as when you wrote:
    " As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
    could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters.
    As such, at this time we have not opened any files based on the information you have submitted. " Please indicate
    how, exactly, Richard G. Hill's grievance met such a standard of proof where the one's I submitted did not.
    Further, while you have indicated that I have not responded to your request to meet with you (which is not the
    case), you only just, for the first time, today, even mentioned anything about any judges filing or corresponding
    anywith with or to you, and you have failed to provide any documentation of such or copies thereof sufficient to
    satisfy my Sixth Amendment Right to Confrontation, etc. Please do so.
    Sincerely,
    /S/
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    000785
    CC: DavidC@nvbar.org
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 19:10:10 +0000
    March 23, 2012
    Dear Mr. Coughlin,
    Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She
    said that you appeared wearing pajamas over your clothes and were demanding and
    argumentative. Apparently I will be receiving a report from the Marshals. As Assistant Bar
    Counsel I would like to help you. However, my primary responsibility is to protect the public
    and the administration of justice by insuring that Nevada Lawyers are complying with standards
    required of the profession. It appears that you are not. I believe that there are ways to get you
    assistance that may protect your license to practice law. I would sure appreciate the
    opportunity to talk with you about resources and assistance that may help you through this
    difficult time.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 10:39 AM
    To: Patrick King
    Subject: RE: does Richard Hill have standing to file a grievance
    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a
    grievance. Please provide any documentation or proof related to these apparent
    communications from judges that you are only now bringing up.
    Sincerely,
    000786
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    Due Process concerns related to the "grievances"
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 3/24/12 1:28 AM
    To: patrickk@nvbar.org
    4 attachments
    3 23 12 FAX TO BAR COUNSEL PATRICK KING NEVADA BAR.pdf (55.3 KB) , 3 19 12 fas to
    rmc marshals regarding property wcso.pdf (40.0 KB) , Pages from mary barker rmc 11 tr
    26800 order denying motion for return of bond.pdf (508.2 KB) , notice of appeal 11 tr
    26800 rmc and Motion for reconsideration set aside etc.pdf (2.6 MB)
    Zach Coughlin, Esq.
    Nevada Bar No: 9473
    PO Box 60952
    RENO, NV 89506
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    TO: Patrick King, Esq.
    State Bar of Nevada Assistant Bar Counsel
    sent via email to: PatrickK@nvbar.org
    March 23, 2012
    Dear Assistant Bar Counsel King,
    I have a few question I would like to respectfully submit to you. What have you done to ascertain whether the
    Marshal's have a vested interest in discrediting me? I would like you to forward me all communications from
    anyone in Department Three. I would like for you to obtain a copy of the hearing today, wherein Judge Flanagan
    concluded the hearing by quoting to something I wrote (it was the only thing he mentioned after indicating that he
    wished to speak to the attorney's in this matter after dismissing the witness, the lying contractor for Richard G.
    000787
    Hill, Phil Stewart, who has offered perjured testimony numerous times on Mr. Hill's and his client's behalf. Judge
    Flanagan quote something I wrote in a filing in 11 TR 26800, where the Judge, Dorothy Nash Holmes, a lifetime
    prosecutor and or warden of a prison (or something along those lines) had me arrested and confiscated my
    property, including a smart phone (and a smart phone these days could store the entire contents of a law firm's
    files and a law library in one), my less advanced cell phone, my premium electric shaver and other items. My car
    was towed during the summary 5 day jail stay Judge Nash Holmes found appropriate, costing me $300 to get it out
    of the lot (also lost a client that would have brought in a substantial amoutn of money, by my standards anyway).
    A $100 bail was paid to get me out of jail on the fourth day (thus avoiding a fifth day) and accepted by the RMC,
    yet, I was not released and the RMC has decided to keep the money anyways.
    Yesterday I went to the RMC to pick up a copy of the audio transcript of the 2/27/12 Trial in that matter 11 TR
    26800. After asking some questions of filing office supervisor Donna Ballard and a front counter clerk named
    Daniel, wherein both agree with me that some of the ways things were done done at the Reno Municipal Court
    lacked transparency, a system of checks and balances, and other fundamental notions of due process and fair play,
    all of the sudden, two beefy City of Reno Marshals in their mid 20's decided, unilaterally, it seems, to ask me to
    leave, as Ms. Ballard certainly had expressed nothing in the way of discontent with our conversation, nor had
    Daniel. While I was leaving I could clearly hear Marshal Thompson lying extensively into his radio, trying to
    manufacture some sort of report of a scene were there had been none, other than that put on by the City of Reno
    Marshals, whom have lied extensively about whether or not they ever took possession of a micro sd card incident
    to the full body all pockets, belligerent, accusatory search they performed incident to the summary contempt
    finding and arrest of 2/27/12. I request that you ask for a copy of Marshal Harley's employment file from BOTH
    the RMC and the City of Reno Marshals Division and see if they put in my letter and complaint in that regard.
    Or, do you "find that the burden of proof in the various grievances I have filed with you has not been met, that all
    the evidence needed for a conviction has not been presented to your lap with a bow? Did Mr. Hill present such
    proof, meeting such a burden. Clearly, the only thing you provided to me from Mr. Hill was an EXCERPT of his
    1/14/12 letter to you, which reference numerous shadowy previous phone calls between the two of you (are you
    Mr. Hill's hand picked Bar Counsel, or was this case assigned randomly? Does Mr. Hill get to pick which RPD
    Sargents and Officers show up for his calls for help? Have you made any inquiry to ascertain this. Why does
    Richard Hill constantly file a peremptory challenge anytime he is assigned to Judge Adam's Department 6,
    apparently? Did the innuendo and hearsay Richard G. Hill, Esq. Mentioned in his unsigned, unsworn letter to you
    of 1/14/12 provide you sufficient proof to meet the clear and convincing evidence stand you indicate that the
    grievances I filed did not? How do the copies of electronic correspondences between myself, State Bar of Nevada
    Director of Admissions Patrice Eichman, Peter Christiansen, Esq., and Michael Sanft, Esq.,'s legal assistant Kelly
    Huff, wherein she explicitly admits to her firm committing malpractice in my case, fail to provoke even a scintilla
    of investigation into a grievance from or the State Bar of Nevada?
    And the impropriety implicated by Kevin Kelley's conduct, and Mr. Christiansen's later lying under oath at the
    June 2002 Character and Fitness Committee hearing for which he feels he satisfied the $5,000 he received in
    payment (well, okay, he did file an 8 page pre-hearing brief that rehashed factual recitations from various previous
    filings of the Committee, then did manage to cite to the Claiborne case, which concerned a former judge, not an
    applicant for admission to the bar, and he did fail to subpoena percipient witness Mark Tratos, or any of the
    relevant faculty from Boyd School of Law, and he did screw up the affidavits of the students witnessing me
    turning in the hard copy of the paper, and his office did forward a correspondence about alcoholism to the State
    Bar despite an express indication by the client atop of it that said not to do so, and his office did mistate whether
    they ever turned in the second Consent Agreement send with confirmation to them on September 27
    th
    , 2004 in a
    November 2004 email, so....wait, are you really saying there isn't enough there for a grievance FROM A CLIENT
    FILING ONE AGAINST HE WHO WAS COMPENSATED $5,000 TO REPRESENT HIM (THOUGH
    CHRISTIANSEN LIED UNDER OATH AND SAID IT WAS ON A PRO BONO BASIS, IN ACCORD WITH
    THE REPRESENTATIONS MADE BY STRIP CLUB SPEARMINT RHINO OWNING CHARACTER AND
    FITNESS COMMITTEE MEMBER KEVIN KELLEY, ESQ., WHOSE BEST FRIEND WAS THE
    PSYCHOLOGIST THE APPLICANT WAS STEERED TO IN THE ADMISSIONS PROCESS)? BUT, YOU
    ARE SAYING PURSUING A GRIEVANCE PROCEDURE AND, APPARENTLY, FORMAL HEARING
    INCIDENT TO THE ATTEMPT TO FILE A GRIEVANCE BY A KNOWN SCANDALOUS OPPOSING
    000788
    ATTORNEY RICHARD G. HILL, ESQ., AGAINST MYSELF, IN A MATTER FOR WHICH I AM NOT AN
    ATTORNEY OF RECORD (PRO SE ATTORNEY LITIGATNS, APPARENTLY, CANNOT RECEIVE
    ATTORNEY'S FEE AWARDS UNDER THE SELLERS CASE, SO HOW CAN THE RULES OF
    PROFESSIONAL CONDUCT BE APPLIED TO ANY OF MY CONDUCT IN A CASE WHERE I AM A PRO
    SE LITIGANT?)? It sure is curious how you find sufficient proof to pursue Richard G. Hill, Esq.'s grievance
    against me, yet, you claim that all the grievances I filed do not warrant any sort of investigation on your part. Very
    curious, indeed...
    You wrote: "As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect
    the public and the administration of justice by insuring that Nevada Lawyers are complying with standards
    required of the profession. It appears that you are not."
    I would like you to specify in detail exactly what forms the basis of your assertions in those a statements, as
    heretofore you seem to rely upon only the unsigned, unsworn, hearsay cited to by Richard G. Hill and some
    apparent grievances filed by judges, to which you have not previously informed me of or offered any proof
    thereof, despite your incorrect assertion that you have done so. If you, as you wrote that you did, previously
    provide any indication or documentation in support of these "grievances" filed by Judges, please provide support
    therefor in explicit written detail with supporting documentation and proof service.
    You further wrote, and I seek explication and specificity with regard to details and attribution incident to the
    allegations therein contained that:
    " I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
    claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal
    research." Would you say, Mr. King, that you would very much prefer it if I had done NO legal research prior to
    meeting with you?
    You go on to write "You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
    standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As
    I have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from
    different Courts."
    That statement casts extreme doubt upon everything you have said to me, Mr. King, and everything you will say to
    me. Please provide the requested proof of any grievances against me that came from "Judges from different
    Courts". You do realize, Sir, that some "Judges in Different Courts" have pulled drivers over recently and
    impersonated a highway patrol officer, and that some Clerks of Court have embezzled $250,000 from the public
    fisc? And, just to be clear, you truly do not find anything worthy of a grievance per Mr. Taitel's curious
    appearance/disappearance as attorney of record, failure to do a conflicts check, failure to subsequently disclose
    such a failure and the tangible harm it has done to me vis a vis my suing Nevada Court Services and his sharing
    an office, receptionist, and being listed on the Nevada Court Services web site as "associated with" their business
    entity? Didn't Mr. Taitel have a recent ethics investigation pursuant to some run for judicial office?
    Also, Judge Nash Holmes indicated at trial, and this is a direct quote, that she "doesn't care about corruption, or
    bribery, retaliation, or police misconduct"...well, that is as close to a direct quote as I can make given the fact that
    the RMC, just yesterday refused to provide me a copy of the audio transcript from the 2/27/12 Trial in 11 TR
    26800, presided over by Judge Nash Holmes, after a length disappearance by her immediately before calling my
    case, and after hearing all the other matters on that stacked docket, and after denying my request for a continuance
    but granting Deputy City Attorney Allison Ormaas's request for one to "speak" with Reno Police Department
    Sargent Tarter, whose cross examination formed the basis for my arrest and incarceration incident to the summary
    contempt finding. The cross examination focused on whether Sargent Tarter had retaliated against me for reporting
    the bribery admission by RPD Officer Chris Carter (he admitted Richard G. Hill, Esq. bribes him) to Sargent
    Tarter while at the scene of my attempts to get Richard G. Hill to turn over my client's files and my wallet and
    state issued identification. If you want to put your name on the line over this, Mr. King, and you think we still live
    in a world with very little transparency, who am I to tell you any different.
    You further wrote: "These grievances, and the evidence attached with them, rather clearly puts into question your
    competence to practice law." Please narrow down which parts of which grievances you feel so implicate my
    competence, in explicit written detail.
    You further wrote: "As I have explained to you, I will make the evidence and exhibits available to you when you
    000789
    come to inspect them at my office." Mr. King, please indicate when it was and in what form or method you
    communicated this offer to "make the evidence and exhibits available to you when you come to inspect them at
    my office"? Please further explain why on earth I would only be allowed to inspect them at your office and how
    that does not create and overly bullying and intimidating scenario departing entirely from fundamental notions of
    due process. Please just fax and email (both please) the entire contents of all these materials to me. I am likely
    suing the USPS and some of its local postal inspectors and or station supervisors under the Federal Tort Claim Act
    and while I have taken every prudent step to ensure the timely delivery of my mail (I have a ton of evidence and
    documentation in support of this), I am EXPLICITLY indicating to you that I wish for you to fax and email me all
    of these materials rather than send them through the mails (USPS, UPS, Fed-Ex, etc, etc.).
    You then wrote: "I will not send you reports or document, especially since you claim your mail is being
    compromised. " I am appalled that you would write this, and offended really. Please email and or fax them to me.
    I have communicated with the USPS and my change of address has been processed (there was a delay through no
    fault of my own) and if you refuse to send these to me via email or fax, the go ahead and mail them to my new PO
    BOX, though taking that tact will likely only make your conduct throughout this proceeding further suspect. Such
    as when you wrote:
    " As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
    could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters.
    As such, at this time we have not opened any files based on the information you have submitted. " Please indicate
    how, exactly, Richard G. Hill's grievance met such a standard of proof where the one's I submitted did not.
    Further, while you have indicated that I have not responded to your request to meet with you (which is not the
    case), you only just, for the first time, today, even mentioned anything about any judges filing or corresponding
    anywith with or to you, and you have failed to provide any documentation of such or copies thereof sufficient to
    satisfy my Sixth Amendment Right to Confrontation, etc. Please do so.
    Sincerely,
    /S/
    Zach Coughlin, Esq.
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 19:10:10 +0000
    March 23, 2012
    Dear Mr. Coughlin,
    Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She
    000790
    said that you appeared wearing pajamas over your clothes and were demanding and
    argumentative. Apparently I will be receiving a report from the Marshals. As Assistant Bar
    Counsel I would like to help you. However, my primary responsibility is to protect the public
    and the administration of justice by insuring that Nevada Lawyers are complying with standards
    required of the profession. It appears that you are not. I believe that there are ways to get you
    assistance that may protect your license to practice law. I would sure appreciate the
    opportunity to talk with you about resources and assistance that may help you through this
    difficult time.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 10:39 AM
    To: Patrick King
    Subject: RE: does Richard Hill have standing to file a grievance
    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a
    grievance. Please provide any documentation or proof related to these apparent
    communications from judges that you are only now bringing up.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    000791
    Print Close
    FOIA Request RE: does Richard Hill have standing to file a grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/23/12 4:57 PM
    To: patrickk@nvbar.org
    3 attachments
    State Bar of Nevada Character and Fitness Committee Grievance Christiansen Eichman, Kevin Kelly Mike Sanft for Bar
    Counsel.pdf (379.4 KB) , Character and Fitness Committee Member Kevin Kelly, ESq..htm (6.4 KB) , Reno's Hawkins,
    Ormaas & van Winkle - Biggest Little Act in the World Babelation ormaas.htm (72.0 KB)
    Dear Mr. King,
    this is a subpoena and a FOIA Request, requesting that you send to me, in writing, via email and fax a copy of any
    documentation (such as a copy of the email from Department 3 you mentioned in your last email, in addition to these
    "communications from judges" that you only mentioned for the first time today, yet claim to have noticed me of in the past).
    You see, this is exactly why is would be disadvantageous to communciate with you on the telephone (something you and I have
    never done). When I began asking Director of Admissions Patrice Eichman (a licensed attorney) uncomfortable questions
    related to her breach of her duties and negligence (if not more) between 2001-2005, she didn't want to correspond in writing
    anymore, but preferred talkign on the phone...
    Please add the attached materials to my grievance against Eichman, Michael Sanft, Kevin Kelly of the C&F Committee and both
    Peter Christiansen's (father and son).
    I believe you may have violated my Sixth Amendment Right to Counsel by failing to copy me on and or inform me of your
    communications with judges prior to your email of today, wherein you incorrectly mention that you previously did so, which
    you did not. I think it might be appropriate for you to recuse yourself from this matter given some of your ommissions and
    conduct thus far.
    Sincerely,
    Zach Coughlin
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 19:10:10 +0000
    March 23, 2012
    Dear Mr. Coughlin,
    Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She said that you appeared
    wearing pajamas over your clothes and were demanding and argumentative. Apparently I will be receiving a report from
    000792
    the Marshals. As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect the
    public and the administration of justice by insuring that Nevada Lawyers are complying with standards required of the
    profession. It appears that you are not. I believe that there are ways to get you assistance that may protect your license
    to practice law. I would sure appreciate the opportunity to talk with you about resources and assistance that may help
    you through this difficult time.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 10:39 AM
    To: Patrick King
    Subject: RE: does Richard Hill have standing to file a grievance
    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a grievance. Please provide
    any documentation or proof related to these apparent communications from judges that you are only now
    bringing up. In your March 23, 2012 email to me you wrote: " As I have explained to you, the grievances against you came
    not only from Mr. Hill but also from Judges from different Courts." This is not true. That is the first you ever communicated anything like
    that to me, unless you can point to something in the written record between us. With respect to your refusal to pursue any of the grievances
    I filed, please indicate specifically what about Mr. Hill's grievance met the standard you cite to, as well as specifically, for each attempted filing
    of a grievance, indicate where mine failed to meet that standard, with details and specifics, and an indication of any research of investigation
    you conducted in that regard.
    Sincerely,
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 17:18:34 +0000
    Dear Mr. Coughlin,
    I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You claim to be too busy to meet
    with me, yet you have time to write lengthy e-mails and apparently to do legal research.
    You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a grievance, as a lawyer in Nevada he may
    have an ethical obligation to report to the State Bar. As I have explained to you, the grievances against you came not only from Mr. Hill but also from
    Judges from different Courts. These grievances, and the evidence attached with them, rather clearly puts into question your competence to practice
    law. As I have explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I will not send you
    reports or document, especially since you claim your mail is being compromised.
    000793
    As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that could be proved by clear and
    convincing evidence, which is the standard of proof required in disciplinary matters. As such, at this time we have not opened any files based on the
    information you have submitted.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 9:12 AM
    To: Patrick King; cdbaker@richardhillaw.com
    Subject: does Richard Hill have standing to file a grievance
    American Jurisprudence Trials
    Database updated April 2011
    Defending Lawyers in Disciplinary Proceedings
    31 Am. Jur. Trials 633 (Originally published in 1984)
    III Attorney-Client Grievances
    10 In general
    11 Sources of complaints and grievances; checklist
    12 Former criminal clients
    13 Particular problem clients
    14 Fee disputes; checklist of factors of reasonableness
    15 Arbitration; forms
    16 Fee dispute committee hearings; illustrative testimony
    Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
    misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
    and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
    filed documents which he or someone in his office generated to falsely certify debtors' completion of
    required credit counseling course and which he knew, or should have known, that debtors did not
    sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
    109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).
    Mr. King, could you please update me on that status and progress of the various grievances I filed recently in
    addition to providing a detailed summary of the content of all of your correspondences, written or otherwise, and
    000794
    telephone communciatiosn with Richard Hill or anyone with his office. Further, please state whether Casey Baker is
    part of the grievance, as Hill asserts he is filing it on Mr. Baker's behalf.
    Sincerely,
    Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for opposing counsel?
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    --Forwarded Message Attachment--
    Wednesday, March 06, 2002
    Copyright Las Vegas Review-Journal
    COLUMN: John L.
    Smith
    Spearmint Rhino owners expanding empire with British
    invasion
    Whether you consider topless cabarets acceptable adult
    diversions or shadowy dens of iniquity, you have to admit the
    Spearmint Rhino club has one catchy name.
    It's probably safe to say its patrons are unlikely to confuse it
    with other topless joints, and surely that's the way Spearmint
    Rhino's owners like it. It turns out developing brand loyalty is
    important, whether you're selling breakfast cereal or babes
    and boobs.
    It must be working. These days, the Spearmint Rhino empire
    is rapidly expanding. From clubs in California, to one in Las
    Vegas, the company has created something of an American
    invasion in England, where majority owner John Gray has
    opened six clubs with plans for up to 100 more.
    With that kind of expansion in mind, there's talk that
    Spearmint Rhino might begin selling stock as a publicly
    traded company. It makes you wonder what those stockholder
    meetings might look like. I'm willing to bet they'd be well
    attended.
    In Las Vegas, the club operates with a somewhat confused
    ownership status. Admittedly, I'm the one confused.
    Although it is listed on the company's Web site as one of
    several Spearmint Rhino clubs, the Las Vegas cabaret is
    officially not owned by Gray, but by local attorney Kevin
    Kelly, Gray's long-time partner Thomas Nabarrette, and
    Mumtaz Ali. When asked about the ownership issue, and the
    fact the Las Vegas club was listed on the Gray-owned
    000795
    company Web site, Kelly said it was possible Nabarrette had
    worked out an agreement with his friend to advertise the club
    on the Internet.
    Makes sense, but it doesn't exactly explain why the only
    reference to the topless company on the secretary of state's
    Web site lists Gray as secretary and treasurer of The
    Spearmint Rhino Worldwide Inc. The Las Vegas club is
    owned by K-Kel Inc., which lists Kelly and Ali as officers,
    but not Nabarrette.
    No matter. The Las Vegas Spearmint Rhino officially is not
    owned by Gray. Which is probably a good thing considering
    Gray's controversial past, which was recently profiled by
    reporters Adrian Gatton and Paul Lashmar in the Independent
    newspaper of London.
    The story caught the topless entrepreneur attempting to rewrite
    his personal history. In the Feb. 17 article, Gray was quoted
    briefly denying his criminal past -- he has a couple
    convictions in California for making a false statement to win a
    military contract and bouncing checks -- before fessing up to
    reporters. The boss also failed to explain why he once used
    several aliases, including Johnny Win, John Luciano, and
    John Luciano Gianni.
    Gray served six months in jail, according to the newspaper,
    and emerged with plans to expand his topless bar empire.
    Next stop, Las Vegas. Although that move officially did not
    work out, and Gray's name is not listed on the local
    paperwork, it did not deter him from hopping overseas, where
    he has taken England by storm as the sole director of
    Spearmint Rhino Companies of Europe Ltd. According to the
    Independent, Gray's clubs are popular with businessmen and a
    favorite site for office parties.
    Possibly standing in the way of his expansion plans in
    England are those pesky background details, which he
    apparently didn't disclose in much detail to licensing
    authorities.
    A year ago, police reported that, in their opinion, "activity
    within the club, intentionally or otherwise, borders on offenses
    of prostitution and permitting the keeping of a brothel."
    In Las Vegas, police have uttered similar phrases for decades.
    Every few years, an undercover vice unit compiles enough
    evidence of whispered propositions and backfields in
    excessive motion to make headlines and a few arrests. Beyond
    a little embarrassment and some attorney fees, the club
    owners are rarely ruffled.
    It's probably only a coincidence that the topless operators
    perennially rank among the top donors to local political
    campaigns, showering thousands of dollars on favorite
    candidates and maintaining close contact with their public
    official friends thereafter.
    Somehow, Gray didn't officially make the grade in Las Vegas.
    Hey, our loss is England's gain.
    John L. Smith's column appears Tuesday, Wednesday, Friday
    and Sunday. E-mail him at Smith@lvrj.com or call him at
    383-0295.
    This story is located at:
    000796
    Print Close
    FOIA Request RE: does Richard Hill have standing to file a grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/23/12 4:57 PM
    To: patrickk@nvbar.org
    3 attachments
    State Bar of Nevada Character and Fitness Committee Grievance Christiansen Eichman, Kevin Kelly Mike Sanft for Bar
    Counsel.pdf (379.4 KB) , Character and Fitness Committee Member Kevin Kelly, ESq..htm (6.4 KB) , Reno's Hawkins,
    Ormaas & van Winkle - Biggest Little Act in the World Babelation ormaas.htm (72.0 KB)
    Dear Mr. King,
    this is a subpoena and a FOIA Request, requesting that you send to me, in writing, via email and fax a copy of any
    documentation (such as a copy of the email from Department 3 you mentioned in your last email, in addition to these
    "communications from judges" that you only mentioned for the first time today, yet claim to have noticed me of in the past).
    You see, this is exactly why is would be disadvantageous to communciate with you on the telephone (something you and I have
    never done). When I began asking Director of Admissions Patrice Eichman (a licensed attorney) uncomfortable questions
    related to her breach of her duties and negligence (if not more) between 2001-2005, she didn't want to correspond in writing
    anymore, but preferred talkign on the phone...
    Please add the attached materials to my grievance against Eichman, Michael Sanft, Kevin Kelly of the C&F Committee and both
    Peter Christiansen's (father and son).
    I believe you may have violated my Sixth Amendment Right to Counsel by failing to copy me on and or inform me of your
    communications with judges prior to your email of today, wherein you incorrectly mention that you previously did so, which
    you did not. I think it might be appropriate for you to recuse yourself from this matter given some of your ommissions and
    conduct thus far.
    Sincerely,
    Zach Coughlin
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 19:10:10 +0000
    March 23, 2012
    Dear Mr. Coughlin,
    Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She said that you appeared
    wearing pajamas over your clothes and were demanding and argumentative. Apparently I will be receiving a report from
    000797
    the Marshals. As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect the
    public and the administration of justice by insuring that Nevada Lawyers are complying with standards required of the
    profession. It appears that you are not. I believe that there are ways to get you assistance that may protect your license
    to practice law. I would sure appreciate the opportunity to talk with you about resources and assistance that may help
    you through this difficult time.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 10:39 AM
    To: Patrick King
    Subject: RE: does Richard Hill have standing to file a grievance
    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a grievance. Please provide
    any documentation or proof related to these apparent communications from judges that you are only now
    bringing up. In your March 23, 2012 email to me you wrote: " As I have explained to you, the grievances against you came
    not only from Mr. Hill but also from Judges from different Courts." This is not true. That is the first you ever communicated anything like
    that to me, unless you can point to something in the written record between us. With respect to your refusal to pursue any of the grievances
    I filed, please indicate specifically what about Mr. Hill's grievance met the standard you cite to, as well as specifically, for each attempted filing
    of a grievance, indicate where mine failed to meet that standard, with details and specifics, and an indication of any research of investigation
    you conducted in that regard.
    Sincerely,
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 17:18:34 +0000
    Dear Mr. Coughlin,
    I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You claim to be too busy to meet
    with me, yet you have time to write lengthy e-mails and apparently to do legal research.
    You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a grievance, as a lawyer in Nevada he may
    have an ethical obligation to report to the State Bar. As I have explained to you, the grievances against you came not only from Mr. Hill but also from
    Judges from different Courts. These grievances, and the evidence attached with them, rather clearly puts into question your competence to practice
    law. As I have explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I will not send you
    reports or document, especially since you claim your mail is being compromised.
    000798
    As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that could be proved by clear and
    convincing evidence, which is the standard of proof required in disciplinary matters. As such, at this time we have not opened any files based on the
    information you have submitted.
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 9:12 AM
    To: Patrick King; cdbaker@richardhillaw.com
    Subject: does Richard Hill have standing to file a grievance
    American Jurisprudence Trials
    Database updated April 2011
    Defending Lawyers in Disciplinary Proceedings
    31 Am. Jur. Trials 633 (Originally published in 1984)
    III Attorney-Client Grievances
    10 In general
    11 Sources of complaints and grievances; checklist
    12 Former criminal clients
    13 Particular problem clients
    14 Fee disputes; checklist of factors of reasonableness
    15 Arbitration; forms
    16 Fee dispute committee hearings; illustrative testimony
    Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
    misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
    and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
    filed documents which he or someone in his office generated to falsely certify debtors' completion of
    required credit counseling course and which he knew, or should have known, that debtors did not
    sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
    109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).
    Mr. King, could you please update me on that status and progress of the various grievances I filed recently in
    addition to providing a detailed summary of the content of all of your correspondences, written or otherwise, and
    000799
    telephone communciatiosn with Richard Hill or anyone with his office. Further, please state whether Casey Baker is
    part of the grievance, as Hill asserts he is filing it on Mr. Baker's behalf.
    Sincerely,
    Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for opposing counsel?
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    --Forwarded Message Attachment--
    Wednesday, March 06, 2002
    Copyright Las Vegas Review-Journal
    COLUMN: John L.
    Smith
    Spearmint Rhino owners expanding empire with British
    invasion
    Whether you consider topless cabarets acceptable adult
    diversions or shadowy dens of iniquity, you have to admit the
    Spearmint Rhino club has one catchy name.
    It's probably safe to say its patrons are unlikely to confuse it
    with other topless joints, and surely that's the way Spearmint
    Rhino's owners like it. It turns out developing brand loyalty is
    important, whether you're selling breakfast cereal or babes
    and boobs.
    It must be working. These days, the Spearmint Rhino empire
    is rapidly expanding. From clubs in California, to one in Las
    Vegas, the company has created something of an American
    invasion in England, where majority owner John Gray has
    opened six clubs with plans for up to 100 more.
    With that kind of expansion in mind, there's talk that
    Spearmint Rhino might begin selling stock as a publicly
    traded company. It makes you wonder what those stockholder
    meetings might look like. I'm willing to bet they'd be well
    attended.
    In Las Vegas, the club operates with a somewhat confused
    ownership status. Admittedly, I'm the one confused.
    Although it is listed on the company's Web site as one of
    several Spearmint Rhino clubs, the Las Vegas cabaret is
    officially not owned by Gray, but by local attorney Kevin
    Kelly, Gray's long-time partner Thomas Nabarrette, and
    Mumtaz Ali. When asked about the ownership issue, and the
    fact the Las Vegas club was listed on the Gray-owned
    000800
    company Web site, Kelly said it was possible Nabarrette had
    worked out an agreement with his friend to advertise the club
    on the Internet.
    Makes sense, but it doesn't exactly explain why the only
    reference to the topless company on the secretary of state's
    Web site lists Gray as secretary and treasurer of The
    Spearmint Rhino Worldwide Inc. The Las Vegas club is
    owned by K-Kel Inc., which lists Kelly and Ali as officers,
    but not Nabarrette.
    No matter. The Las Vegas Spearmint Rhino officially is not
    owned by Gray. Which is probably a good thing considering
    Gray's controversial past, which was recently profiled by
    reporters Adrian Gatton and Paul Lashmar in the Independent
    newspaper of London.
    The story caught the topless entrepreneur attempting to rewrite
    his personal history. In the Feb. 17 article, Gray was quoted
    briefly denying his criminal past -- he has a couple
    convictions in California for making a false statement to win a
    military contract and bouncing checks -- before fessing up to
    reporters. The boss also failed to explain why he once used
    several aliases, including Johnny Win, John Luciano, and
    John Luciano Gianni.
    Gray served six months in jail, according to the newspaper,
    and emerged with plans to expand his topless bar empire.
    Next stop, Las Vegas. Although that move officially did not
    work out, and Gray's name is not listed on the local
    paperwork, it did not deter him from hopping overseas, where
    he has taken England by storm as the sole director of
    Spearmint Rhino Companies of Europe Ltd. According to the
    Independent, Gray's clubs are popular with businessmen and a
    favorite site for office parties.
    Possibly standing in the way of his expansion plans in
    England are those pesky background details, which he
    apparently didn't disclose in much detail to licensing
    authorities.
    A year ago, police reported that, in their opinion, "activity
    within the club, intentionally or otherwise, borders on offenses
    of prostitution and permitting the keeping of a brothel."
    In Las Vegas, police have uttered similar phrases for decades.
    Every few years, an undercover vice unit compiles enough
    evidence of whispered propositions and backfields in
    excessive motion to make headlines and a few arrests. Beyond
    a little embarrassment and some attorney fees, the club
    owners are rarely ruffled.
    It's probably only a coincidence that the topless operators
    perennially rank among the top donors to local political
    campaigns, showering thousands of dollars on favorite
    candidates and maintaining close contact with their public
    official friends thereafter.
    Somehow, Gray didn't officially make the grade in Las Vegas.
    Hey, our loss is England's gain.
    John L. Smith's column appears Tuesday, Wednesday, Friday
    and Sunday. E-mail him at Smith@lvrj.com or call him at
    383-0295.
    This story is located at:
    000801
    HOME | ABOUT | INVESTORS | CONTACT | HOTAUTOWEB | THE BABEL | MAXIMUM
    site design Babelation, LLC 2010
    RE: does Richard Hill have standing to file a grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/23/12 10:38 AM
    To: patrickk@nvbar.org
    Mr. King,
    This is the very first time you allege anyone other than Mr. King filed or alleged a grievance. Please provide
    any documentation or proof related to these apparent communications from judges that you are only now
    bringing up.
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: does Richard Hill have standing to file a grievance
    Date: Fri, 23 Mar 2012 17:18:34 +0000
    Dear Mr. Coughlin,
    I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You claim to be too busy to meet
    with me, yet you have time to write lengthy e-mails and apparently to do legal research.
    You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a grievance, as a lawyer in Nevada he may
    have an ethical obligation to report to the State Bar. As I have explained to you, the grievances against you came not only from Mr. Hill but also from
    Judges from different Courts. These grievances, and the evidence attached with them, rather clearly puts into question your competence to practice
    law. As I have explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I will not send you
    reports or document, especially since you claim your mail is being compromised.
    As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that could be proved by clear and
    convincing evidence, which is the standard of proof required in disciplinary matters. As such, at this time we have not opened any files based on the
    information you have submitted.
    Sincerely,
    Patrick King
    000802
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 23, 2012 9:12 AM
    To: Patrick King; cdbaker@richardhillaw.com
    Subject: does Richard Hill have standing to file a grievance
    American Jurisprudence Trials
    Database updated April 2011
    Defending Lawyers in Disciplinary Proceedings
    31 Am. Jur. Trials 633 (Originally published in 1984)
    III Attorney-Client Grievances
    10 In general
    11 Sources of complaints and grievances; checklist
    12 Former criminal clients
    13 Particular problem clients
    14 Fee disputes; checklist of factors of reasonableness
    15 Arbitration; forms
    16 Fee dispute committee hearings; illustrative testimony
    Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
    misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
    and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
    filed documents which he or someone in his office generated to falsely certify debtors' completion of
    required credit counseling course and which he knew, or should have known, that debtors did not
    sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
    109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).
    Mr. King, could you please update me on that status and progress of the various grievances I filed recently in addition to
    providing a detailed summary of the content of all of your correspondences, written or otherwise, and telephone communciatiosn
    with Richard Hill or anyone with his office. Further, please state whether Casey Baker is part of the grievance, as Hill asserts
    he is filing it on Mr. Baker's behalf.
    Sincerely,
    Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for opposing counsel?
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    FOIA REQUEST; Motion to Dismiss Grievance for lack of standing
    000803
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/23/12 9:30 AM
    To: patrickk@nvbar.org
    Dear Mr. King,
    Please accept and respond to this FOIA REQUEST seeking for you to produce any and all documentation and or a summary of
    any correspondence, written or otherwise (including the many telephone calls referenced in Hills 1/14/12 letter to you) from
    Richard HIll or anyone with his office, or anyone else, EVER, in any way involving me, in connection with ANY matter.
    I am focusing on 24. The role of retained counsel; in generalNegotiations with bar counsel... and wish to meet with you
    soon. I have to prepare for and attend several hearings in the coming days, and will update you as to my availability in short
    order. This is also a Motion to Dismiss the grievance Hill filed for a lack of standing, and for failure to state a valid claim.
    Further, please note, that I previously contact Bar Counsel Clark and Assitant Bar Counsel Machado, via written communication
    and telephone to comply with my obligation under SCR 111. Any other reports by Hill are not to the point where I have a SCR
    111 Obligation (other than perhaps a summary contempt Order against me from 2/27/12, for which I have provided written
    indication of to you in my response to Hill's grievance, though I do not believe that Order falls within the purview of SCR 111.
    I wish to register my objection to the fact that Richard Hill did not sign his "grievance". I do not believe he even has standing
    to file a greivance. He was never my client. Under RPC 8.3, I do not believe a "greivance" is the appropriate means of
    fulfilling such a duty, nor do I believe Richard Hill (or Casey Baker, Esq. whom he purports to speak for and file on behalf of)
    have a good faith basis in making any complaint of any sort, and rather, are impermissibly attempting to circumvent the process
    of my having my day in court with respect to any outstanding criminal charges (particularly where non involved contact with
    any clients, and none are felony charges). Please provide some indication in writing of your stance in this regard.
    21. The role of retained counsel; in generalPlan of action
    A thorough review of the file is a vital prerequisite to an effective plan of action, which, ideally,
    should be outlined immediately upon the conclusion of the interview with the accused attorney. A
    typical plan of action might be as follows:
    [] Reduce all fee considerations to writing
    If a proper understanding between counsel and client concerning attorney's fees for the representation
    has not been arrived at in the initial interview, it should be immediately settled and reduced
    to writing.[25]
    [] Establish a fund for costs
    A fund for costs normally will include enough money for a refund of the client's fees, court
    transcripts, if necessary, and incidental expenses such as photocopying costs and long distance
    calls. Ninety percent of all grievances can be settled with a fund of $1,000 or less. Thus, it becomes
    obvious that most disciplinary actions against attorneys are unnecessary and could have
    been easily avoided by their early retention of a competent lawyer. While the accused cannot
    settle the matter, an objective attorney, acting in the best interest of the accused, usually can.
    [] Communicate with bar counsel
    Counsel must remember that the investigating bar attorney is usually in private practice, prominent
    in his field and very busy. His sole desire is to have the matter disposed of fairly and
    promptly, so that he can tend to his own practice. Early and diplomatic communication with him
    is often an important first step toward settling the grievance.
    000804
    [] If permissible, talk to the complainant
    If the complainant is not represented by an attorney, he should be promptly interviewed.
    However, the complainant should not be contacted by telephone; the defense attorney should visit
    him in person. If the canons of ethics permit, the conversation should be taped, provided counsel
    bears in mind that many states provide that taping a conversation without the knowledge of the
    person being taped is illegal and a violation of ethical standards. Most attorneys prefer to conduct
    the interview with the tape recorder in plain sight. The best method the author has found to get the
    complainants to open up is to simply say: "I need to hear your side of the story, I need to find out
    what really happened. You folks may be totally correct, and if so, I need to know that, to advise
    my client."
    If possible, and particularly if the defense attorney is a notary public, a sworn statement should
    be taken, preferably in the handwriting of the complainant, as to all the facts and details of the
    complaint. If possible, alternatives for settlement should be included in the statement.
    A checklist of questions, compiled from the accused attorney's file will be helpful. The more detail
    counsel can bring out, the better. Counsel should not hesitate to let relatives give their version
    of what the complainant has said to them. Often such version will not only be at variance
    with the truth, but it may vary from complainant's later version.
    A determination should be made as to whether the complainant is mentally stable and whether
    he will be an effective witness before the committee. The cross-examination should be drawn up
    from the tapes or from the notes taken of the interview.
    [] Meet and talk with the prosecutor
    The meeting should not be tape-recorded, as most prosecutors will object to such activity as devious.
    In any case, attorneys should be able to deal with one another on a professional basis. All the
    possibilities should be explored with the prosecutor. A determination should be made as to whether
    the case would be accepted for criminal prosecution taking into consideration the amount of
    money involved.
    If the matter is due to be presented to the grand jury, and the prosecutor is not agreeable to a delay
    in presenting it, defense counsel should consider writing a letter to the grand jury since this can be
    helpful in delaying the proceedings. There is danger in writing such a letter, however. Federal
    grand juries should not be contacted, since to contact them directly is a violation of federal law,
    and in some cases, state law. Research may be required to determine if counsel may approach the
    local grand jury.
    Occasionally, the attorney-client can avoid an indictment against him by making some sort of refund.
    Where this is the case, a brief delay may be afforded defense counsel to allow him to discuss
    the matter with his client. Counsel, of course, should take full advantage of such delay. With
    an indictment pending, he should advise his client strongly that standing on principle is futile.
    000805
    22. The role of retained counsel; in generalHandling related malpractice and criminal
    charges
    Where a claim of malpractice has not been formally presented against the client but circumstances
    indicate that one will be, counsel should communicate with the client's legal malpractice insurance
    carrier and notify it of a potential malpractice claim. This is necessary to satisfy the requirement in
    most policies that the company be notified in the event the insured attorney is in possession of information
    which reasonably leads him to believe that a malpractice claim may be filed against him.
    The provision is designed to allow the malpractice insurance carrier as much time as possible to investigate
    a potential claim even though it might not result in a malpractice suit.[26]
    A charge of malpractice can be expected to follow when a grievance complaint successfully
    shows dereliction of duty on the part of the attorney. However, an attorney representing the complainant
    occasionally will file a malpractice suit against the attorney before the grievance is heard,
    hoping thereby to benefit by using the pressure of the disciplinary proceeding to improve his bargaining
    position in the malpractice action. This may actually be unethical on his part since an attorney
    may not use the threat of criminal, or even quasi-criminal action to settle related civil litigation.
    Therefore, since the grievance complaint is considered quasi-criminal in some jurisdictions,[27] it
    would follow that an attorney should not take advantage of the grievance process to settle his civil
    suit for malpractice against the accused attorney.
    Although insurance counsel will be concerned mainly with settlement of the malpractice claim,
    counsel for the accused attorney should point out that a good result in the grievance hearing will
    make settlement of the malpractice suit easier. Some insurance attorneys are sympathetic and may
    agree to use some of their client's resources to settle the grievance as well as the malpractice suit. Of
    course, counsel can expect that the client's malpractice insurance will be cancelled even if the accused
    attorney prevails.
    Up until recent times, most people did not consider a conviction of driving while intoxicated a
    crime of moral turpitude, particularly where there was no incident connected thereto that caused loss
    of life, serious injury, or property damage to a third person. Similarly, simple negligence in driving
    leading to a collision or possession of a small amount of marijuana has not been considered moral
    wrongdoing. Grievance committee members take a similar attitude, being concerned not with the
    moral principles involved, but only with preventing a recurrence of the incident.[28]
    During the course of the investigation, the probabilities of criminal litigation will become obvious.
    Actual criminal prosecution is the exception, however. Nonetheless, if defense counsel feels that
    a criminal investigation is likely to result in an indictment, then the possibility of an agreed to resignation
    from the bar in exchange for no prosecution should be considered.[29]
    Cooperation in the form of a client interview should not be given to a criminal investigator. This
    000806
    does not, of course, mean that defense counsel should be discourteous or uncooporative in supplying
    documents that are easily obtainable at the county clerk's office. It is simply better practice to not permit
    the attorney-client to be interviewed by a criminal investigator, for the probabilities of the client
    becoming rude and hostile are very high.
    If the accused attorney has a good explanation, or has made full restitution, or has otherwise acted
    equitably, defense counsel might consider communicating with the grand jury.[30] However, this
    course of action is hazardous for two reasons. First, in all federal investigations it is a crime to communicate
    or attempt to communicate with the grand jury. The same effect can be had by simply writing
    a letter to the Assistant United States Attorney handling the grand jury presentment and request-
    ing that the client be permitted to appear before him and the grand jury for questioning, in the hopes
    of preventing an indictment. Of course, he cannot be compelled to appear before the grand jury unless
    either full or use immunity is granted; but since most of such appearances would be on a "request"
    basis, he would thus waive his Fifth Amendment rights, and his statements before the grand
    jury would be admissible at a criminal trial.
    The obvious danger of the client's testifying before the grand jury is that the he may make serious
    admissions during the course of the questioning. Thus, it goes without saying that before a grand jury
    appearance, the accused attorney should be thoroughly prepared and should confer often with counsel,
    who in most states is not allowed to be present in the grand jury room with his client. Such conferences
    should be reasonable, and should not be held after each question.
    Of course, the district attorney usually has the power not to permit the appearance of the client
    before the grand jury; but in most cases, he will welcome it. If he intends to indict regardless of the
    testimony, then the statements of the accused attorney are recorded under oath and his story can be
    investigated. The prosecutor can, if this grand jury does not indict, present the same information to
    the next grand jury, without the presence of the accused. On the other hand, if the prosecutor is truly
    fair minded, an appearance by the client may explain any ambiguous points, and preclude an indictment.
    [Top of Section]
    24. The role of retained counsel; in generalNegotiations with bar counsel
    Quite often bar counsel will be a well-known practicing attorney with a large, prominent law
    firm, that is, an attorney who can afford to take time off for bar-related activities. He is likely to be
    middle-aged, wealthy, conservative, and quite busy with his own private practice. He is also unlikely
    to be sympathetic to an unrepresented accused attorney, and will find it difficult to understand the
    problems of young, sole practitioner, for he customarily represents corporate clients, insurance companies,
    and banks. He will probably do no divorce or criminal work, and he is likely to be highly specialized
    in his own practice.[31] His goal will be to dispose of the matter as painlessly and as quickly
    as possible, and he will resent lack of cooperation or a hostile attitude. By the time retained counsel
    000807
    enters the case, the accused attorney may have had two or three bitter confrontations with this attorney,
    and he may have given him no cooperation nor shown any contrition. The attitude of the investigating
    attorney is likely to be guarded, if not hostile.[32]
    The considerable powers of bar counsel should be understood: he has the authority to file formal
    charges and set the case for hearing, or he may dispose of it without further investigation. He may sit
    on a case indefinitely, or he can see that it is thoroughly prosecuted, even getting assistance of the attorney
    general's office or the local district attorney. Indeed, occasionally bar counsel may coordinate
    his efforts with the local United States Attorney or district attorney for the purpose of prosecuting a
    particular attorney for perjury or for some breach of fiduciary duty. He may even suggest to the district
    attorney that the case be presented to a grand jury.
    It is therefore obvious that early in the case, retained counsel must communicate, in a friendly
    way with the committee's attorney. He should first determine whether the client has offended him and
    make necessary apologies, although this courtesy will not always fall on receptive ears. If bar counsel
    is irreversibly opposed to the client because of personal animosity, however, he may be amenable to
    replacement by another attorney. This should be requested in a tactful way.
    As a general rule, the committee's counsel will be pleased to suggest prompt methods of settlement.
    If he makes specific suggestions, they should be complied with if at all possible. This is true
    even where they resolve doubts in matters of equity in favor of the complainant. The investigator has
    the power to see that his wishes are enforced. Concrete steps should be proposed and efforts made to
    determine the bar counsel's attitude toward possible rehabilitation through Alcoholics Anonymous or
    psychotherapy treatment or whatever is appropriate of a medical or educational nature.
    Everything that should obviously be done should be done promptly. For example, if a refund of a
    few hundred dollars is clearly in order, it should be done speedily. It is wise to coordinate such efforts
    with the committee's staff personnel.
    Sometimes a proposed written agreement for an immediate specific refund, or attendance at ethics
    seminars or remedial courses, to be completed within a given period of time, will be favorably received.
    Trickery or failing to live up to agreements made are almost certain to have bad results.
    Therefore it is particularly important that any restitution promised be promptly paid. Occasionally,
    the curative action is simplicity itself, and a request for a letter of apology to the complainant or the
    immediate turning over of a file to substitute counsel should be promptly complied with. However,
    the most important points to make with the investigating bar attorney, where there is no defense under
    the facts of the case, are contrition, cooperation, and corrective measures.
    There will be cases, however, where the client has committed no wrongful act and is innocent. It
    should be explained to the bar attorney that innocence will be the defense and that it will be vigorously
    pursued. Weaknesses in the complainant's case, his or her past criminal or psychiatric history
    should be pointed out, and an inquiry made as to what steps are necessary to settle the matter under
    000808
    those circumstances.
    In some jurisdictions, the investigating bar attorney is a full-time employee of the state bar association,
    the attorney general's office or an employee of the local judicial district. The approach in that
    case will probably be somewhat different. Whereas the committee member participating in the investigation
    is seldom compensated for his work, counsel employed by a state bar association or the attorney
    general's office always is. The only exception would be a "special prosecutor" appointed to
    handle a particular, and usually quite spectacular, case. This is rare, but when it does occur, it usually
    involves a political figure or a judge.
    An investigating attorney who is employed full time to investigate and prosecute grievances will
    be harder to deal with. He is less likely to be sympathetic to the accused attorney, particularly if he
    has a record of prior disciplinary action. Nonetheless, most of these grievance committee prosecutors
    have more than enough work, and they tend to concentrate their efforts on the worst offenders, those
    who have been least cooperative, or those who have offended them.
    Retained counsel can expect closer cooperation with federal criminal or state and local district attorney
    investigators if the investigating committee attorney is a state or bar association employee.
    Committee counsel acts as the prosecutor, and he may have had considerable experience working
    with the Internal Revenue Service, the Federal Bureau of Investigation or comparable state office,
    and he may have been a former prosecutor himself. If such an investigating attorney is handling the
    matter, a quick determination must be made of the probability of criminal prosecution, and possibly
    serious, adverse tax consequences.[33]
    Regardless of whether the investigating attorney is a committee member or a state bar or attorney
    general's employee, the duty of all investigating or prosecuting attorneys is the same: to do justice.
    They are bound by the code of professional responsibility just as others are. Regrettably, they do not
    seem to enjoy hearing that from defense counsel, and reminding them of their ethical duties will be
    irritating. Nonetheless, most of these investigating attorneys have a heavy workload, and they do tend
    to concentrate their efforts on those attorneys who are the most obnoxious, the most infamous, and
    the least cooperative.
    Retained defense counsel must also make an early determination on whether to supply evidence
    that may build part of a criminal prosecution in the hopes of gaining leniency before the bar association
    at the risk of more severe detriment to his client if criminal charges are formally pursued. Such
    decisions are never easy.
    In any event, it is generally good practice at the beginning of representation for an attorney-client
    accused of professional misconduct to contact the grievance or hearing committee's counsel and advise
    him that he may expect full cooperation from counsel and the client, any undelivered file will be
    forwarded immediately to the former client or substitute counsel, an informal or formal reply, as appropriate,
    000809
    will be promptly submitted, and some inquiry about settlement or some other disposition of
    the matter will be made without the filing of formal charges.
    25. The role of retained counsel; in generalSettlement or disposition without hearing; form
    of release
    Settlement is the ideal goal in every case. Seldom can any good come from having a hearing.
    Even though the accused attorney claims complete innocence, the committee members may wonder
    why the matter was not disposed of earlier. They are quite aware of the fact that such matters
    do not get to the hearing stage without the recommendation of the investigating bar attorney, who
    must have found evidence of wrongdoing to justify filing formal charges. Thus, the defense is
    faced with a suspicion of some act of misconduct. Logically, therefore, the goal of avoiding a
    hearing is the most desirable one, and the approach taken should be one that is least likely to lead
    to a hearing. It makes little sense to set one's goal for a hearing when the use of diplomacy can
    avoid it. Settlement is possible only up to a point prior to the hearing, however. Once the hearing
    commences, it is usually too late for the accused attorney to settle with the complainant. The most
    satisfactory and beneficial settlements are those reached within two weeks of the filing of the
    complaint.
    The potential for various settlement possibilities are plentiful, but, unfortunately, they are usually
    predicated on a commodity in short supply for most attorneys: money. Often it will be necessary
    for the client to contact family members and give promissory notes for loans in order to bargain
    with cash that may be easily replaced, rather than his license, which cannot.
    It should be noted that while it is unethical conduct to "buy off" complaining witnesses, nearly all
    states provide that if the district attorney either approves or encourages a civil settlement, then
    disciplinary proceedings may be avoided. Retained counsel must make certain he violates none of
    the canons of ethics himself. The key to avoiding trouble is to be open and candid with all concerned.
    Retained counsel should immediately make clear to the accused attorney that he is to take no action
    whatever following representation, and a careful inquiry should be made to determine what
    action he has taken to date. Invariably, steps will have to be taken to straighten out the harm that
    he may already have done.
    The single most important ingredient for success is the attitude of the accused attorney. If the
    grievance committee receives the impression that he is merely interested in a "dodge" to avoid the
    consequences of his acts, then great difficulty can be expected. If on the other hand the accused is
    genuinely contrite, both in his words and his actions, few committees are likely to take severe action,
    even in serious cases. On the other hand, some attorneys may attempt some sort of cover-up.
    They may lie to the committee or may otherwise do great disservice to their own cause when they
    are not represented.
    It should always be kept in mind that a contrite attitude by the accused attorney is a difficult one
    000810
    for a grievance committee to resist, particularly when it is coupled with a clear and definite plan
    of corrective action.
    Contrition, however, must always be coupled with cooperation, and cooperation must always be
    coupled with corrective action. Should one of these elements be missing, a good result cannot be
    expected. Once defense counsel takes the client firmly in hand, directs a corrective-action program,
    and, most importantly, establishes and maintains a good relationship with bar counsel, he
    may expect good results, even in serious cases.
    The key task for the retained attorney is to coordinate the defensive effort with the goal toward receiving
    for the accused the least amount of punishment. For example, the investigating attorney
    for the grievance committee should be informed that the money in dispute has been returned, and
    that the young attorney is facing considerable trouble with the district attorney's office for the
    drunk-driving, collision, and the marijuana possession. It may be appropriate in such case, to suggest
    that the committee take no action until the criminal matter is exposed of.
    If the client is uninsured, and many will be, defense counsel should seek to settle as much of the
    case as he can by the mere payment of money as opposed to disciplinary proceedings. This, of
    course, does not mean fraudulent claims should be paid. If the claimant comes into the hearing
    room with unclean hands, having attempted to extort an unfair cash settlement, the committee is
    entitled to know. However, in the given fact situation, there is a claim for a large sum of money
    the complainant allegedly lost in profit from the sale of the piece of property. A full investigation
    may be required. Did the complainant have full title to the property, free and clear? Was there a
    bona fide written offer? Did the complainant have the right to sell the property without the approval
    of other heirs? A malpractice carrier must certainly know the answer to these questions before
    parting with any money.
    The district attorney's office should be approached with a similar offer: "Because of the DWI and
    marijuana case, the accused attorney is in trouble with the grievance committee. If a civil settlement
    with the persons who sustained damage in the car wreck can be reached, would the district
    attorney be willing to dismiss the case?" Where changes of misconduct involve theft, it is best to
    make the district attorney aware of settlement negotiations and secure his participation to avoid
    potentially serious problems in a related criminal proceeding.
    The person most important to an overall settlement will be the investigating attorney. The key to
    success is to decide at an early stage upon a specific, reasonable, and achievable course of action,
    and to stick with it. If promises for payment of damages or refunds to clients are made, they must
    be honored, to avoid displeasure of the grievance committee. Plans should be made to raise the
    necessary funds, and an overall plan to solve all the problems of the accused attorney in one settlement,
    if possible, should be made. These plans often include requiring attendance at Alcoholics
    Anonymous meetings, psychotherapy with a psychiatrist or clinical social worker, or, in cases of
    000811
    negligence or extreme ignorance, attendance at legal ethics classes, continuing legal education
    programs, or other remedial or curative activities. In such cases, the sooner the corrective action
    is undertaken, the more likely good results can be had. Many of the best plans are implemented
    months before the hearing.
    Persuading the investigating bar attorney to propose a solution acceptable to all the parties is tantamount
    to a successful defense. Throughout the attempts at settlement, the bar attorney should be
    informed of the status of negotiations, and the position of the accused attorney should be shown
    as one of reasonableness. If the investigating attorney is made aware that the complainant is seeking
    thousands of dollars when he lost only a few hundred, he very well may suggest that only the
    few hundred be refunded, and may agree to a dismissal of the grievance.
    Set forth below is a suggested form of release by the complainant on receipt of the amount agreed
    to in settlement:
    Form of release:
    RELEASE
    KNOW ALL MEN BY THESE PRESENTS:
    That I, ____________,[complainant] of ____________[address], in consideration of the sum of
    ____________[amount of settlement] to me in hand paid by ____________[attorney], the receipt
    of which is hereby acknowledged and conferred, and recognized as adequate by these presents,
    for myself, my heirs, executors and administrators, release and forever discharge the said
    ____________[accused attorney] of and from all manner of debts, demands, obligations, liabilities,
    suits, and causes of action, whatever, against him, the said ____________[accused attorney],
    in my own right, at the time of executing these presents.
    [Date, subscription, and other formal parts omitted.]
    Dismissal of the hearing should always be a part of any settlement, and all offers should be made
    known to the investigating attorney and subject to his approval. This will insure his good will;
    only rarely will he interpose an objection. However, the defense attorney should not take up too
    much of bar counsel's time. Bar counsel is usually busy with his private practice; he has his own
    cases to handle. He will not appreciate lengthy discussions with the defense attorney over strategy
    or the petty details of the looked for solution.
    Many jurisdictions provide for a "letter of caution," which is sometimes nothing more than an informal
    "if-it's true-you-should-not have-done-it." In other words, the bar is simply pointing out
    that the accused attorney is on thin ice, has gotten the attention of the grievance committee, and,
    while the matter may not be serious enough for full inquiry, his conduct could and should improve.
    In some jurisdictions, the investigating attorney himself has the authority to issue a letter
    of caution.[34]
    000812
    In some jurisdictions, previous letters of caution may be used to enhance punishment, in others
    they may not. In some cases the letter of caution may be issued without a complete investigation,
    based only on the complaint of the former client and the answer of the accused. A letter is frequently
    issued when the accused attorney is not cooperative as to a minor inquiry. Often the lack
    of cooperation is the central theme of the letter of caution. Nonetheless, the letter of caution falls
    into the milder end of the discipline range provided by law, and many attorneys can withstand receiving
    the letter with only modest wear on their nerves. Usually the issuing of the letter is the
    end of the matter.
    When Bates v. Arizona Bar Association[35] was decided by the United States Supreme Court,
    many advertising taboos fell for the legal profession. The limits which the advertising must observe,
    rather than all advertising, then became the issue. While advertising under certain circumstances
    was held to be proper by the United States Supreme Court, it did not approve of solicitation.
    Where advertising leaves off and solicitation begins is unclear in many cases.
    Attorneys who advertise seem to have far more grievances lodged against them than lawyers who
    do not. Because of the conservative nature of the members of the grievance committee, it is usually
    best to attempt to settle an advertising grievance by ceasing an activity that is questionable. If
    an advertising violation goes to the grievance committee, harsh punishment may follow.
    However, because the law is uncertain as to legal advertising, some grievance committees might
    be willing to forego discipline if the accused attorney agrees to discontinue the activities disapproved
    of. There is a question whether such agreements are enforceable, but because of the uncertain
    state of the law it should be assumed that they are enforceable. The agreements should be
    drawn up with specificity to indicate the extent of advertising that will be allowed.
    28. Formal charges
    [Cumulative Supplement]
    Formal charges of professional misconduct should not be recommended by bar counsel without
    notifying the attorney who is accused of unethical or illegal conduct.[43] The notice need not be given
    immediately, however; it can await the outcome of the bar's investigation into the allegations.[44]
    Following the investigation, the proceedings may be disposed of, without formal charges being
    filed, in one of three ways[45] all of which require the recommendation of bar counsel and the concurrence
    of the chairman of the grievance or hearing committee.[46] (1) The proceedings may be dismissed
    if there is insufficient probable cause to believe misconduct has occurred.[47] (2) An admonition
    may be issued if there is probable cause to believe that misconduct has occurred but the problem
    is minor and isolated.[48] (3) Probation can be imposed, with or without an admonition, if there is
    probable cause to believe misconduct has occurred for which probation is appropriate.[49] Furthermore,
    if there is a civil or criminal proceeding pending in which the respondent is a party and which
    000813
    involves the same subject matter (conduct), the disciplinary proceedings may be stayed if that is appropriate.[
    50] A stay will be appropriate where the respondent will suffer prejudice in the pending
    proceeding should the disciplinary action proceed immediately and where the grievance committee
    hearing may be expedited by evidence adduced in the criminal or civil matter.[51]
    Formal proceedings against the accused attorney are warranted where there is probable cause to
    believe misconduct has occurred which is neither minor nor isolated and probation is not appropriate
    or where the respondent does not agree to a recommendation of admonition or probation.[52] The
    charges are prepared by bar counsel who is required to file with the disciplinary board and serve on
    the respondent a written statement of the charges giving a fair and adequate notice of the nature of the
    alleged misconduct.[53] Once the formal charges are filed, the proceedings are no longer confidential
    and are open to the public except for deliberations of the hearing committee, disciplinary board or
    court and information the hearing committee has ordered kept confidential.[54] After the charges
    have been filed, the matter is referred to a specific grievance or hearing committee.[55]
    CUMULATIVE SUPPLEMENT
    Cases:
    No due process errors occurred during the grievance committee proceedings investigating an attorney's
    behavior, where attorney alleged that notice of the hearing was untimely and charges against
    him were vague, because grievance committee proceedings are principally investigatory and comparable
    to proceedings before a grand jurythey are nonadversarial and there is no right of confrontation
    or cross-examination; the attorney under investigation is not entitled to a bill of particulars until
    the grievance committee completes its investigation. In this context, at a reasonable time before a
    finding of probable cause is made, the attorney will be advised of the conduct under investigation and
    the rules which may have been violated; in addition, the attorney must be given all materials considered
    by the committee and an opportunity to make a written statement regarding the alleged misconduct
    under R Reg Fla Bar 3-7.4(g). In any event the notice actually given was sufficient where the
    attorney received notice of the rules allegedly violated 13 days before the hearing was scheduled, and
    he was represented by counsel at the hearing and had an opportunity to cross-examine witnesses. The
    Florida Bar v. Swickle (1991, Fla) 589 So 2d 901, 16 FLW S737, later proceeding (US) 117 L Ed 2d
    101, 112 S Ct 929, supp op (US) 118 L Ed 2d 203, 112 S Ct 1552.
    Evidence supported the finding of panel of the Kansas Board for Discipline of Attorneys that attorney
    engaged in illegal conduct, as an aggravating factor for purposes of imposing discipline, even
    though criminal charges were not filed against attorney; attorney admitted that he exposed himself to
    administrative assistant for district court, statute defined lewd and lascivious behavior as "publicly
    exposing a sex organ or exposing a sex organ in the presence of a person who is not the spouse of the
    offender and who had not consented thereto," administrative assistant was not attorney's spouse, and
    the American Bar Association's (ABA) standards did not require that an attorney be charged or convicted
    000814
    by law enforcement before his or her conduct could be considered illegal. West's K.S.A.
    213508(a)(2). In re Depew, 237 P.3d 24 (Kan. 2010).
    Discipline of attorney who engaged in conduct adversely reflecting on fitness to practice and
    placed personal interests above those of clients would be limited to censure where medical evidence
    showed he suffered from mild neurological dysfunction due to cerebral aneurysm at time of misconduct,
    years of exemplary practice preceded affliction, he acknowledged misconduct, and he demonstrated
    willingness to take appropriate steps to prevent recurrence. Re Kiley (1991, 4th Dept) 170
    App Div 2d 90, 572 NYS2d 601.
    [Top of Section]
    [END OF SUPPLEMENT]
    29. Response; form
    [Cumulative Supplement]
    Within a prescribed period of time following service of the formal charges, the respondent should
    file a written reply or answer with the board or committee and serve a copy of it on bar counsel.[
    56] Allegations that are not disputed should be admitted to narrow the issues at the hearing and
    denials of fact should be separately stated. Moreover, if the respondent chooses to refuse to answer
    an allegation on constitutional or other grounds, the ground of such refusal should be explicitly
    asserted.[57] Counsel should note that the failure to answer the charges timely may be
    treated as an admission of their truth.[58]
    It should be kept in mind that the reply itself is admissible in both civil, criminal, and disciplinary
    proceedings. The records of the grievance committee themselves are not usually subject to discovery
    proceedings, as they are almost always allowed to be secret by statute. However, the accused
    will be required to send a copy of the reply to the complainant, which may be introduced, in
    evidence at a subsequent civil trial for malpractice, or at a criminal proceeding.
    Many jurisdictions require that the reply be sworn to, and some provide that failure to file a
    timely reply is in itself grounds for disciplinary proceedings. At the very least, the failure to file a
    timely reply will irritate the investigating attorney and the committee, and this conduct will be reported
    to the committee and may be viewed as lack of cooperation. Where failure to reply is in
    and of itself an admission that all charges are true and correct, the statement of charges alone can
    be the basis for disciplinary proceedings.
    A good deal of thought and effort must go into the reply, and a well-drafted answer may result in
    no further action by the investigating attorney. For example, legal research into the various issues
    may result in finding cases that exonerate the defendant in the particular fact situation. A motion
    to dismiss should then be filed with the answer, citing the appropriate authority. In preparing the
    reply, counsel should attach to a motion to dismiss photocopies of important favorable cases or a
    000815
    brief in support. If no research is offered, none will be done by the committee on behalf of the client.
    An amazing number of attorneys are unaware of the fact that there has been considerable litigation
    over the years regarding what is and what is not unethical conduct, and formal published ethics
    opinions have been issued by many committees for decades. There is a wealth of authority that
    can be cited. Moreover, most state bar associations have on file advisory opinions from their ethics
    committees. These can sometimes be of immense use, especially where the accused attorney
    actually may have relied upon a prior ethics opinion in trying to conform his behavior to the right
    canon. The problem is that advisory opinions may not be binding, and authority from other states
    or jurisdictions may be cited only as persuasive authority. Finally, the American Bar Association
    has issued numerous opinions over the years, and provides materials that may be purchased for
    ethics law research. The bar association's opinions carry considerable weight.[59]
    Generally, there is no required form for a reply. A typical and acceptable method is to go through
    the allegations and admit those that should be admitted, to identify those as to which corrective
    action has been taken (such as returning the file to the client or to his new attorney), to deny those
    that should be denied and to deny for lack of information or belief other allegations as appropriate.
    A reply similar to answering requests for admissions or interrogatories may be appropriate.
    The second part of the reply should consist of a brief on the issue of whether the conduct complained
    of is (a) a crime or act of moral turpitude; or (b) conduct that normally would subject the
    accused to disciplinary action.
    Based on the factual background of the article, an appropriate response to formal charges might
    be composed as follows:
    [Caption of forum, title of case and other formal parts omitted.]
    ANSWER TO FORMAL CHARGES
    1. The allegations of paragraphs ____________ of the formal charges are admitted.
    2. The allegations of paragraphs ____________ are denied without qualification or reservation.
    3. In response to the remaining allegations, respondent cannot admit or deny the truth of the allegations
    for lack of sufficient information and belief. He therefore denies those allegations subject,
    however, to the following factual statement, which is offered in defense of the formal charges and
    in mitigation of punishment as to any charges and allegations found to be true:
    a. I was formally the attorney for the complainant. I advised him at the time I accepted the case
    that I would also need a contractual relationship with his two sisters, and he has never had them
    contact me. I felt uneasy with probating the will without the participation of the two sisters, and I
    did not know how to get in touch with them. He gave me a retainer of $500. Attached herewith
    please find a photocopy of the check for $500, which I have sent to his new counsel since he has
    now made arrangements for another attorney.
    b. I admit that I did not return his file to him when he first requested it because I did not know I
    000816
    was required to do so. I have apologized to the complainant with an explanation. [Attach copy of
    letter.]
    c. I admit sending the letter to the complainant referred to in his complaint as I mistakenly
    thought that I was entitled to hold the file until I had been compensated for the time I had spent
    on the case. I was mistaken as to my obligations, and I have stated my regret for any inconvenience
    this has caused the complainant.
    d. ____________[Other statements as appropriate].
    [Date, subscription, and other formal parts omitted.]
    Particularly when the defense attorney has not been permitted much time to prepare a reply, or the
    accused attorney has filed his own reply, an amended reply may be appropriate. In most cases,
    there are no bar rules to prevent this. Occasionally the grievance committee will frown on very
    late replies, especially those filed just before the hearing.
    The best use of the amended reply is to bring to the committee's attention legal precedents not
    previously shown to them, and particularly any legal authority that the defense attorney feels is
    compelling. [] Practice Hint: The money to fund any costs or refunds should be placed in the defense
    attorney's trust account, and a written statement from the accused attorney should be taken
    granting the attorney full and exclusive power to disperse the money in settlement of the case, in
    his discretion.
    Virtually all jurisdictions require that a written answer to the grievance be filed within a certain
    time limit. Most jurisdictions allow a minimum of 7 days, and some allow up to a maximum of
    60. Nearly always the time by which a reply must be filed is included in the notice of formal
    charges. In many cases, however, with as much as 30 or 40 hours of investigating and preparation
    to do, a timely answer cannot be made. Rather than filing a late answer, it is always appropriate to
    call the investigating attorney and ask for an extension of time in which to file the answer. It
    nearly always will be granted. Indeed, this may be a wise consideration in most cases. The bar association
    grievance committee is anxious to have the accused attorney submit to their authority
    and control. Resisting it invariably results in its taking a harsher stance. Therefore, a request for a
    delay in filing a response has the advantage of allowing a more thorough investigation that will
    produce a better and more detailed reply and in letting the committee know that the accused attorney
    has submitted himself to their committee's jurisdiction.
    A case may present itself where the complainant seeks a large and unjustified refund from the accused
    attorney or otherwise seeks to take unfair advantage of him. This is not uncommon, particularly
    among "con men," who may have succeeded in this ploy in the past. The interview with the
    accused attorney will sometimes reveal that the complainant is an accomplished liar who is adept
    at adjusting his testimony to accomplish his goal. In such cases, a vague answer to the grievance
    may be advantageous.
    000817
    As a general rule, the committee does not like the holding back of information, but neither does it
    like its offices being used for purposes of extortion. Further, the majority of virtually all committees
    is made up of lawyers, and they are likely to appreciate good tactics. There are exceptions,
    however, and prudent practice requires that the appropriate approach be taken.
    [] Case Illustration: A client paid his attorney a flat fee for defense in a fraud case. When the litigation
    was satisfactorily concluded, the client demanded half of the fee back, claiming that the
    attorney had told him that he expected to lose, that that fee would include the costs of an appeal,
    and that if the case was won at the trial stage he would give him a 50 percent refund. Defense
    counsel investigated the matter after the demand was first made but before the grievance was
    filed, and checked the complainant's litigation records at the courthouse, discovering that other attorneys
    had defended the complainant in fraud actions as well. He contacted them and learned
    that two had been approached along the same lines; one paid back half of the money to avoid a
    grievance, and the second made a small adjustment in the fee. A purposely vague answer was
    filed, and, at the hearing, the complainant was allowed to tell his story to the committee and
    cross-examination solidified it. Then, to the surprise of the complainant, the two attorneys against
    whom he had made the same threat several years before were presented as witnesses. Since there
    were two witnesses to the attorney's employment agreement, the attorney and his secretary, and a
    signed written contract that provided as the attorney stated, the fundamentals for presentation of a
    perjury charge existed and the record was turned over to the appropriate authorities. The complainant's
    protests that his previous extortions were privileged communications were overruled by
    the committee.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney who on 3 separate occasions refused to cooperate in committee's investigation of client
    complaints, until it became necessary to procure subpoena directing his appearance for examination
    under oath, would be censured despite mitigating factor that he was in midst of terminating longstanding
    marriage during period in question, since failure to cooperate in investigation of alleged
    misconduct constitutes misconduct in and of itself, and warrants discipline. Re Feit (1989, 3d Dept)
    156 AD2d 810, 549 NYS2d 829.
    [Top of Section]
    [END OF SUPPLEMENT]
    30. Motion to dismiss; illustrative forms
    The scope of motions to dismiss grievances is limited only by the ingenuity and experience of the
    defense attorney. They can take practically any form, but should, if possible, be supported with
    case citations and a brief in support. Forms for two typical motions, (a) motion to dismiss on the
    000818
    ground of res judicata, and (b) a motion to dismiss for lack of standing, are set forth below:
    MOTION TO DISMISS (RES JUDICATA)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, the Respondent in this action, and would show the committee as
    follows:
    I.
    The complaint of ____________, complainant in this cause, is substantially the same as was
    found in her suit for legal malpractice against the respondent filed on ____________, 20___, and
    tried to a jury on ____________, 20___. The jury made findings entirely favorable to the defendant
    in that cause (respondent herein) and the court entered a judgment for the defendant and taxed
    all costs against the plaintiff (complainant herein) and said costs have yet to be paid.
    II.
    Copies of the plaintiff's pleadings, the defendant's answer, and a certified copy of the judgment in
    that cause are attached herewith as respondent's Exhibits "A", "B", and "C", and are herein incorporated
    for all purposes by reference.
    III.
    Respondent urges that virtually all issues presented to this committee were presented in
    ____________ court, and resolved by the rules of evidence and that the respondent was shown as
    a matter of law to have been guilty of no professional misconduct.
    IV.
    The complainant herein attempts a collateral attack upon that final judgment (Exhibit "C") which
    should not be permitted as a matter of law. Respondent respectfully urges that administrative
    hearings such as those held by the grievance committee may not attack facts conclusively established
    in court.
    V.
    Further, respondent respectfully submits that the grievance committee should not set itself up in a
    position above the courts and should not disregard the findings already made.
    WHEREFORE PREMISES CONSIDERED, respondent prays that this grievance be forthwith
    dismissed with prejudice and for all other further relief to which he may show himself to be justly
    entitled.
    [Date, subscription, and other formal parts omitted.]
    As a general rule, the committee is interested in hearing only from an attorney who has discovered
    unethical conduct, law enforcement authorities, the victim of the unethical conduct, but
    no others. In a surprisingly large number of cases, friends, neighbors or, particularly in divorce
    cases, relatives of the person they see as aggrieved will attempt to interpose their will. If tactfully
    000819
    handled, these cases can often be dismissed quite early.
    As a practical matter, there are no formal requirements for "standing." Anyone aware of unethical
    behavior may report it to the grievance committee. However, most committees receive complaints
    from third parties that generate unnecessary work for them, and, as a general rule, they are not
    sympathetic to interlopers. They wish to hear from the client or a person who claims to have been
    victimized by the attorney.
    MOTION TO DISMISS (LACK OF STANDING)
    [Caption of tribunal, title of case and other formal parts omitted.]
    TO THE HONORABLE GRIEVANCE COMMITTEE:
    NOW COMES ____________, respondent, by and through his attorney of record, and shows as
    follows:
    I.
    Respondent represented ____________, a citizen of Mexico, in litigation against ____________,
    a citizen of the United States. Respondent had an attorney/client relationship with ____________
    [plaintiff], and pursued the matter vigorously. Copies of the pleadings filed against the defendant
    in that case prepared by respondent are attached herewith as Exhibit "A" and incorporated for all
    purposes.
    II.
    The defendant in that case filed an answer, a copy of which is attached herewith as Exhibit "B"
    and incorporated herein for all purposes.
    III.
    Respondent proceeded to take depositions and to prepare for trial but, because of distances, was
    unable to maintain close contact with the plaintiff, his client.
    IV.
    The complainant in this cause is a friend of the plaintiff. The plaintiff often stayed at her home
    while visiting in the United States. Gradually the plaintiff seemed to lose interest in the litigation,
    and stopped paying attorney's fees to respondent. The complainant then attempted to usurp the
    perogatives of the plaintiff, at first by carrying messages to the respondent, then by taking independent
    action, and then by attempting to exercise her independent judgment as to how the case
    should be handled.
    V.
    In time, a dispute arose between the complainant, who had no legal right to interfere in the lawsuit,
    and the respondent, who respectfully suggested to her that he preferred to do business with
    his client only and that legal matters and questions of strategy should be left to the plaintiff and
    the respondent. To this, the complainant took great exception.
    VI.
    000820
    Respondent then filed a motion to withdraw, giving the plaintiff sufficient time to make other arrangements
    for counsel. The motion for and order permitting withdrawal as attorney of record is
    attached herewith as respondent's Exhibit "C," and incorporated herein for all purposes.
    VII.
    Nonetheless, the complainant continued to assert her wish to control the litigation and the obligation
    of the respondent to represent what had come to be, in her mind, her case. Respondent refused
    to communicate with her, and returned the file to his client in Mexico.
    VIII.
    Complainant refused to accept the court's order permitting withdrawal, and she has continued to
    call the respondent to insist upon a full accounting of all money expended, or an explanation as to
    why the case has not been tried.
    IX.
    Respondent has never had an attorney-client relationship with the complainant, and he respectfully
    suggests that she lacks standing to bring a complaint on charges of professional misconduct
    against him.
    WHEREFORE PREMISES CONSIDERED, the respondent in this case respectfully requests that
    the complaint of this complainant be dismissed with prejudice, and the further prays for all such
    relief, both general and equitable, to which he may show himself to be justly entitled.
    [Date, subscription, and other formal parts omitted.]
    31. Discovery
    [Cumulative Supplement]
    For a limited period following the filing of an answer, both bar counsel and the respondent should
    be afforded reciprocal discovery of matters not privileged.[60] During this period there should be a
    mutual exchange of (1) names and addresses of all persons having knowledge of relevant facts, (2)
    non-privileged information and evidence relevant to the charges or the respondent, and (3) other material
    that may be shown to be relevant and material. Protective orders should be available to prevent
    unwarranted discovery.[61]
    While many of the state bar enabling acts make no specific provision for discovery, as a general
    rule, a meeting with the investigating attorney will produce all the discovery necessary to prepare for
    the hearing. Furthermore, not only has the accused attorney an absolute right to a copy of the complaint
    lodged against him, and to all later amended complaints, but in most states, the accused has a
    right to a list of the witnesses who will appear against him, and in many states the bar rules provide
    that a summary must also be given of their expected testimony. The accused attorney also will have
    subpoena power to compel the attendance of witnesses, including hostile witnesses, police officers
    and court personnel.[62]
    000821
    In a particularly serious case, where the state rules of criminal procedure provide for little in the
    way of discovery, and if it appears that the loss of the accused attorney's law license is all but certain,
    the defense attorney may choose to make the tactical choice of using the grievance proceeding as a
    discovery tool for the upcoming criminal trial. This is particularly true when an indictment has been
    returned without the opportunity to conduct a preliminary hearing as provided by federal law, or an
    "examining trial" provided by a code of criminal procedure in most states.
    If such a move is made, the defense attorney will often choose to have his client invoke his Fifth
    Amendment rights, and he will not testify. He cannot be compelled to testify if there is criminal litigation
    pending. If a disbarment suit is pending, his deposition can usually be taken, and his refusal to
    be deposed can be used against him at the disbarment trial, but not at a criminal trial. The exercise of
    the Fifth Amendment right may not be used for impeachment.[63]
    If the defense attorney's strategy is along those lines, he should request that the committee postpone
    its decision until after the criminal trial is completed. Even though the request will seldom be
    granted, it can do no harm to ask. If the request for a delay of the grievance proceedings is granted
    until after the criminal trial, and there is an acquittal, this outcome should be brought to the attention
    of the committee immediately.
    In most jurisdictions, even though the investigating bar attorney may not have an absolute right to
    pre-hearing discovery, cooperation with him is usually best. However, such cooperation does not require
    the defense attorney to build the prosecution's case, and extensive cooperation may very well
    result in that being done. Thus, defense counsel must walk a fine line between proceeding so as to irritate
    the committee by refusing to turn over documents, or cooperating and hoping that the matter
    will not be prosecuted. It is always a difficult choice.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney was not entitled to invoke privilege against self-incrimination when ordered to file list
    of all monetary sanctions imposed against him by any federal court since sanctions were public orders
    and attorney did not explain how information could incriminate him. In re Maurice (1995, CA7)
    73 F3d 124.
    57. Conviction of crime
    [Cumulative Supplement]
    Many states provide for automatic disbarment upon proof of a felony conviction. The term "conviction"
    tends to have a very broad application. Some states provide for automatic disbarment in the
    case of a conviction for a crime of moral turpitude, and, in others, for all felonies. Crimes of moral
    turpitude include all crimes of theft, but there is some question as to whether it includes the frequently
    encountered crimes of income tax evasion and nonfiling of returns. There are cases that have
    decided both ways.[36]
    000822
    Some states do not specifically provide for disbarment in case of a misdemeanor conviction, even
    if it does involve moral turpitude. Nonetheless, most grievance committees will take considerable interest
    in the situation where an attorney suffers such a conviction. Since the bar rules vary greatly
    from one state to another, only an examination of the statutes and rules in one's jurisdiction can answer
    the questions likely to come up concerning the sanctions that may be imposed.
    The bar association ordinarily is required to be notified whenever a lawyer is convicted of a serious
    crime, such as a felony or an offense involving moral turpitude.[37] The investigating bar attorney
    will then prepare a proposed order of interim suspension and will notify the attorney when the
    matter will be be presented to the court,[38] and will file formal charges against the attorney based on
    the conviction.[39] Since an interim suspension is not a formal disposition of the accusation formal
    charges need to be filed, but they should not be heard until all avenues of appeal of the criminal conviction
    have been exhausted.[40]
    When presented with the interim order of suspension for a conviction of serious crime, the court
    will immediately suspend the attorney regardless of the pendency of an appeal.[41] A certified copy
    of the judgment of conviction is conclusive evidence that the lawyer has committed the crime
    charged, and the sole issue at the hearing is the nature and extent of the discipline to be imposed.[42]
    If the lawyer has been convicted of a minor offense, the bar association will treat notice of the conviction
    like it would the receipt of any other complaint against an attorney.[43]
    The respondent may be able to consent to being disciplined while disciplinary proceedings are
    pending if he admits the truth of the charges in writing.[44] He may then, if he desires, save time and
    further trauma by stipulating to specified discipline.[45] Thus, if the charges are admitted in writing,
    counsel and the client should be able to agree on the nature and extent of the discipline imposed, subject
    to the approval of the hearing committee, and, ordinarily, also subject to review by the disciplinary
    board and the court.[46]
    The criminal law of many states often contains various types of non-final adjudication and punishments.
    The titles of these punishments include "deferred adjudication," "conditional discharge,"
    "unimposed probation," "probation," and others. The attitude of the grievance committee members
    should not be based upon the type of punishment method out in criminal court. In all probability, the
    grievance committee can still take action against the attorney during this interlocutory period. As a
    general rule, if an attorney is under any kind of restraint by a court, whether the judgment is final or
    not, the committee is apt to regard it as "probation" and take action consistent with suspension or disbarment.
    A federal suspended sentence is a final conviction for most purposes, including grievance
    procedings.[47]
    CUMULATIVE SUPPLEMENT
    Cases:
    Two-year suspension from practice of law, with credit for time served under interim felony suspension
    000823
    but with reinstatement conditioned on completion of federal supervised release, was appropriate
    for attorney who engaged in conduct adversely reflecting on fitness to practice law based on
    his conviction for transportation and importation of obscene matters; although mitigating factors included
    lack of prior discipline, cooperation in disciplinary proceedings, and evidence of good character,
    Supreme Court also considered severity of attorney's crime as measured by 15-month prison term
    and three years of supervised release. 18 U.S.C.A. 1462(a); BCGD Proc.Reg. 10(B)(2)(a, d, e);
    Code of Prof.Resp., DR 1-102(A)(6) (2006). Disciplinary Counsel v. O'Malley, 935 N.E.2d 5 (Ohio
    2010).
    [Top of Section]
    [END OF SUPPLEMENT]
    58. Diversion-type programs
    [Cumulative Supplement]
    An increasing number of states are taking a very enlightened approach: they are requiring the accused
    attorney, if he is to avoid disbarment or suspension, to promptly take continuing legal education
    or remedial courses concerning legal ethics that are designed to teach the to attorney to avoid the
    type of activity that resulted in his appearance before the grievance committee. A frequent requirement
    is attendance at state bar ethics programs. Other typical requirements are law school courses on
    legal ethics or other academic work to correct deficiencies.
    Usually these corrective action programs are in lieu of discipline; that is, if the attorney will agree
    to participate, a decision or sanctions may be postponed for a given period of time, normally one
    year.
    Another proposal, seldom applied, has been to allow the attorney to resign from the bar but require
    him to retake the state bar examination as his "punishment.". If he passes, he may be relicensed.
    This normally requires a period of study, participation in a bar review course, and other remedial
    work that may go a long way toward solving his problems.[48]
    Where alcohol has been a factor in the misconduct of the accused attorney, a committee may occasionally
    postpone a determination until after restitution has been made or an agreed alcohol abuse
    treatment program has been completed, as the case may be. Often the hearing will be put off for as
    little as two weeks, and sometimes for as much as a year or two, to see how the accused progresses.
    Committees are reluctant to require specific programs, but when a specific program is required, the
    most frequent one is a hospitalization program or membership and active participation in Alcoholics
    Anonymous.[49]
    [] Case Illustration: In a recent case in Illinois,[50] an alcoholic attorney, who had converted his
    client's funds, made restitution, claimed that he had been rehabilitated, and showed that he was regularly
    attending meetings of Alcoholics Anomymous. Taking the view that the accused attorney's alcoholism
    000824
    was a physical and mental impairment that substantially hampered his ability to practice law
    competently, but was not an indication of his moral weakness, the court reduced from 30 months to 6
    months the disciplinary board's recommended suspension period as a reward for his effort to overcome
    his impairment, on condition, however, that he continue attending regular meetings of Alcoholics
    Anonymous or of a lawyer's assistance program under a probationary supervision for an indefinite
    period both before and after his suspension. The court added that if the accused attorney had remained
    an active alcoholic it would have disbarred the attorney, particularly if it were not shown that
    alcoholism contributed to his wrongdoing.
    Occasionally a "suspended suspension" is imposed, conditioned upon the attorney not being arrested
    for anything, including driving while intoxicated, public intoxication, or any alcoholic-related
    episode for a given period, sometimes for as long as five years.
    The action of the bar in these programs is commendable, for without seeking punishment, they are
    requiring treatment. Their attitude can only be praised, as it both protects the public and insures treatment.
    The typical grievance committee, however, is usually less sympathetic to narcotics use and thus to
    enrollment in a narcotics abuse program. Normally, when the attorney has reached this stage with a
    narcotics problem, he also has a criminal prosecution pending. The defense may be reluctant, under
    such circumstances, either to admit to narcotics use or to offer evidence of the respondent's willingness
    to rehabilitate, since such evidence may well be available to use at the criminal trial. The criminal
    trial, of course, should be given higher priority than the grievance proceeding. Nonetheless, some
    committees will take an enlightened view and will postpone proceedings until the attorney's narcotics
    problem is solved.
    It is only to be expected that certain drug problems are likely to be met with more sympathy than
    others. Use of marijuana is one thing, but use of cocaine, methamphetamines or heroin is another; and
    in the latter case, little sympathy can be expected from committee members. Indeed, in most narcotics
    cases, the committee will be hearing the disciplinary matter after a conviction has been had in the
    criminal trial court, and the best that defense can expect to do for the client is to have his suspension
    run concurrent with a probation or prison term.
    It is becoming more common, however, for grievance committees to suspend imposition of punishment
    pending completion of psychiatric treatment or hospitalization. This enlightened view has
    been slow in coming, under the theory that the first consideration of the bar should be protection of
    the public.
    Many state bar acts provide for suspension of an attorney during a disabling illness or for transfer
    to inactive status in case of a disability.[51]
    Virtually all the cases involving diversion programs are the result of problems related to mental
    illness or alcoholism. An agreed psychiatric treatment program may be permitted in cases with a high
    rate of recovery, such as a reactive depression or manic-depressive disease, but permanent suspension
    000825
    pursuant to statute for illness or disability is likely to continue for those disorders which carry a poor
    prognosis, such as schizophrenia. Counsel should take note and not prove too much. Committees are
    primarily interested in protecting the public. For example, when the misconduct charged is minor and
    will result in a short suspension, counsel must take into consideration that proof of a serious mental
    illness in defense or mitigation may lead to an indefinite suspension for mental or emotional disability.
    CUMULATIVE SUPPLEMENT
    Cases:
    Monitored probation: Reinstatement to practice of law was warranted conditioned on attorney
    being monitored by a mental health professional who would report to Character and Fitness Committee,
    where attorney complied with order of suspension, attorney possessed sufficient professional
    capabilities and qualifications to practice law, attorney showed by clear and convincing evidence that
    he was of good and moral character and that his readmission would not be a detriment to legal profession,
    but Committee expressed concern about potential pressures that attorney would encounter upon
    re-entry into profession. Sup.Ct.Rules, Rule 3.510(2). Bowling v. Kentucky Bar Ass'n, 54 S.W.3d
    160 (Ky. 2001); West's Key Number Digest, Attorney and Client 61.
    Where an attorney neglected five cases of clients seeking relief in bankruptcy and suffered from
    alcoholism and depression, the attorney is suspended from the practice of law in Ohio for two years,
    but the suspension is stayed and he is placed on probation under the following conditions: monitoring
    by an attorney, biannual report by psychiatrist, compliance with disciplinary rules, and participation
    in the Ohio Lawyer's Assistance Program and in alcohol abuse counseling. Cincinnati Bar Ass'n v.
    Wolosin, 71 Ohio St. 3d 611, 646 NE2d 455.
    [Top of Section]
    [END OF SUPPLEMENT]
    59. Reprimand
    [Cumulative Supplement]
    The mildest form of sanction is an admonition or informal reprimand, sometimes called a public
    reprimand. Ordinarily, it is imposed by the bar attorney or bar counsel with a consent of the respondent
    and without the filing of formal charges.[52] It is a private form of discipline, although a summary
    may be published in a bar publication without identifying the accused attorney. It is recorded,
    moreover, and may be offered as evidence of past discipline on the issue of punishment in subsequent
    disciplinary proceedings against the admonished lawyer.[53] A formal reprimand is imposed by the
    court after formal charges have been filed in cases of relatively minor misconduct.[54] This type of
    discipline exists in various forms in nearly all states. Often, no record of the Admonition is kept. Although
    some record may be retained by the committee, the action is not made public. Normally, this
    course of action is taken when full restitution has been made and the accused attorney has been both
    cooperative and contrite and gives sincere assurances to the committee that no future recurrences are
    000826
    likely. It falls into the milder end of the punishment spectrum and should be considered as a relatively
    desirable one in the context of negotiation. In other words, counsel may wish to suggest an informal
    reprimand to the bar to chasten the accused, without harming him financially or publicly. Often these
    informal reprimands are issued to older and highly regarded members of the bar who have breached a
    canon of ethics by an unintentional act from which they did not profit financially.
    A formal reprimand is in the nature of public disgrace. It is occasionally coupled with a requirement
    for restitution, and is sometimes only given in lieu of a suspension if full restitution and a corrective
    course, such as continuing legal education or a new bookkeeping system is adopted by the accused.
    Usually the formal reprimand is published in a state bar journal, and copies of the reprimand
    are sent to the judges and administrative officers and magistrates in the district.
    The effect of a formal reprimand can be devastating to some individuals. Suicide by the accused
    attorney prior to the reprimand being published is not unheard of. On the other hand, some attorneys
    seem to not mind the public reprimand at all. The notoriety does not seem to bother them, and they
    regard the sanction as a mild one. These are the attorneys the grievance committee can expect to hear
    from again.
    A judicial reprimand normally occurs when the attorney is guilty of contempt or some other
    breach of ethics in the presence of the court, such as destroying evidence or harassing a witness. In
    these cases, the only record that is normally kept is in the contempt proceedings themselves. The
    types of contempt are actual and constructive contempt, and civil and criminal contempt. A full discussion
    of these subjects is beyond the scope of this article. Occasionally a judge will notify the
    grievance committee of the breach and occasionally will instruct the grievance committee to take appropriate
    action. In such cases, the lawyers on the committee, ever anxious to please the court, can be
    expected to take firm and prompt action against the attorney in question.
    In a few states, the complainant must file suit to discipline the attorney if he does not agree to the
    committee's action, or the attorney must file suit to set aside discipline imposed by the committee.
    This is the rule in Texas and a few other states. In such cases, after a trial, the judge (not the jury) is
    required to announce what discipline should be ordered. Generally, if it has gotten this fare, hopes of
    a mere judicial reprimand are generally gone, but occasionally a court will impose this type of punishment
    and the lawyer who is prosecuting the case will agree to it. It is a matter of public record, and
    constitutes a significant disgrace for the attorney in question. Actual judicial reprimands are fairly
    rare, and most judges go through their entire career without ever ordering one.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney would be publicly reprimanded for neglect of client's business where letter of mitigation
    attested to "substantial personal and emotional difficulties," including financial hardships, foreclosure
    000827
    of family residence, and stress of relocating family and practice. People v. Smith (1988, Colo) 757
    P2d 628.
    Review Panel reprimand was appropriate disciplinary sanction for attorney's lack of diligence in
    client's Chapter 13 bankruptcy case, which lack of diligence exposed client to injury, i.e., the bankruptcy
    complaint was dismissed but the bankruptcy court later reinstated it and terminated attorney's
    representation of client; in mitigation, the attorney's misconduct was not a cause of client's loss of her
    home two years later for failure to make payments, attorney had practiced bankruptcy law for over 15
    years, he had no history of discipline, and since the filing of the disciplinary grievance he had filed
    numerous bankruptcy complaints without objection. State Bar Rules and Regulations, Rule 4102(d),
    Rules 1.3, 3.2. In re Robinson, 288 Ga. 30, 701 S.E.2d 142 (2010).
    Where attorney failed to file income tax return for three year period, court, in finding that failure
    was caused by either negligence or ignorance and that attorney had otherwise unblemished professional
    reputation, held that such action warranted censure. Re Towles (1983) 98 Ill 2d 179, 74 Ill Dec
    625, 456 NE2d 127.
    Public reprimand was warranted due to attorney's violation of the rules of professional conduct by
    intentionally withholding documents from client given the absence of a prior disciplinary record for
    attorney, the fact that he did not have a dishonest or deceitful motive in regards to his client in withholding
    the documents, and the fact that client was not harmed by his actions. Md.Rule 16812,
    Rules of Prof.Conduct, Rules 1.4, 1.16(d), 8.4(a). Attorney Grievance Com'n of Maryland v. Edib,
    415 Md. 696, 4 A.3d 957 (2010).
    See Petition for Disciplinary Action against Wylie (1991, Minn) 464 NW2d 720, supra 9 Probation.
    Public reprimand was appropriate sanction for attorney who violated professional conduct rules
    relating to communication in his representation of client in personal-injury action, and who also
    failed to inform client that attorney did not maintain professional liability insurance, where attorney
    had a long career with no previous disciplinary action. Rules of Prof.Conduct, Rule 1.4; Code of
    Prof.Resp., DR 1104(A) (2006). Lorain Cty. Bar Assn. v. Godles, 2010-Ohio-6274, 943 N.E.2d 988
    (Ohio 2010).
    Public reprimand of attorney was warranted, in attorney disciplinary case in which attorney admitted
    misconduct and cooperated with the Office of Disciplinary Counsel (ODC), where attorney, in
    a series of real estate transactions, prepared an inaccurate Department of Housing and Urban Development
    (HUD) statement, disbursed funds prematurely, unreasonably delayed in filing deeds, and
    failed to respond to clients' requests for information, in violation of the professional rules. Appellate
    Court Rule 407, Rules of Prof.Conduct, Rules 1.1, 1.3, 1.4, 1.15, 4.1, 5.3, 8.4(a, e). In re Martin, 389
    S.C. 467, 699 S.E.2d 695 (2010).
    Public reprimand, conditioned upon attorney's completion of 10 ethicsapproved continuing legal
    education (CLE) credits within 12 months and, within 60 days, his payment of costs for attorney disciplinary
    000828
    proceeding, was appropriate sanction for attorney's representation of criminal defendant in
    matter for which he previously had attorneyclient relationship with victim, who shared sensitive information
    regarding alleged sexual assault by defendant; attorney's failure to recognize ethical issues
    involved reflected lack of awareness of or attention to his clients' rights and his responsibilities as
    lawyer to guard sensitive information. SCR 20:1.9(a). In re Disciplinary Proceedings Against
    Kostich, 2010 WI 136, 793 N.W.2d 494 (Wis. 2010).
    Public reprimand and order to pay restitution were appropriate sanctions for attorney's misconduct
    in failing to communicate with client about the status of his criminal case, failing to explain a matter
    to the extent necessary to permit client to make informed decisions, failing to take steps reasonably
    practicable to protect client's interests, and failing to refund an unearned fee. SCR 20:1.4(a, b),
    20:1.16(b, d) (2005). In re Disciplinary Proceedings Against Blise, 2010 WI 34, 782 N.W.2d 407
    (Wis. 2010).
    [Top of Section]
    [END OF SUPPLEMENT]
    60. Suspension
    [Cumulative Supplement]
    Many committees completely disregard the great financial and emotional cost that the client has
    already suffered and order a suspension from practice for a specific time. The minimum suspension is
    usually 30 days, and the maximum normally is three to five years. In many states, the maximum time
    is fixed by statute.[55]
    About the best an attorney can hope for, if he has been convicted of a crime and placed under a
    suspended sentence or on probation, is to have the time affixed by the court run concurrently with the
    time of his suspension. For example, should the respondent be given six months probation for driving
    while intoxicated, a common punishment would be a suspension to run concurrently with the probation
    time. Some states permit probation on the suspension, based upon future good behavior.[56]
    Often the committee is unwilling to settle for a mere suspension and will insist on disbarment.
    This is particularly true in cases where the accused attorney has been sent to prison. Some states require
    disbarrment by statute in case of conviction for any felony, or for any crime of moral turpitude.
    Others require suspension during probation.
    The conditions for readmission sometimes can be bewildering. Occasionally, the suspension will
    last only as long as the accused attorney needs to complete a course in ethics at a local law school, or
    to obtain a divorce. Such cases usually involve some degree of emotional illness. Very often a condition
    precedent to reinstatement after suspension in the bar is complete restitution. Such a sentence always
    causes great financial hardship to the attorney in question.
    The order of suspension normally will include language to preclude the attorney from offering or
    giving legal advice except for himself and forbids him from sharing offices with attorneys or holding
    000829
    himself out to be an attorney during the period of the suspension. If the order of suspension is not
    honored by the disciplined attorney, subsequent disbarment is certain.
    Occasionally a governmental office, the United States' Attorney's Office, the Internal Revenue
    Service, the district attorney's office or the grievance committee may have a very strong case, but
    may be willing to drop criminal and disbarment proceedings in exchange for an agreed suspension.
    Normally the minimum suspension period is 15 days, and the maximum is likely to be five years.
    Sometimes reapplication or a retaking of the bar examination is required for reinstatement. An agreed
    suspension from practice should always be considered when the prosecutor has a very strong case,
    particularly where criminal prosecution is possible.
    CUMULATIVE SUPPLEMENT
    Cases:
    Attorney who continued to practice law following court order of suspension was not entitled to attorney
    fees for cases on which he and his associates worked after suspension order, since order was
    not ambiguous, there was no evidence that he acted in good faith, and he ignored language of disciplinary
    rule and of only reported federal case on point. Cooper v. Texaco, Inc. (1992, CA5 La) 961
    F2d 71.
    Failure of attorney to file probation reports with state bar while on professional probation arising
    from misconduct warranted imposition of outright suspension and revocation of professional probation.
    Potack v. State Bar (1991) 54 Cal 3d 132, 284 Cal Rptr 335, 813 P2d 1365, 91 CDOS 6674, 91
    Daily Journal DAR 10141.
    Six-month suspension was warranted for attorney who violated Bar Rules regarding conflicts of
    interest, providing competent representation, and prohibiting conduct involving dishonesty, fraud, deceit,
    or misrepresentation, and conduct prejudicial to the administration of justice. West's F.S.A. Bar
    Rules 4-1.1, 4-1.4(b), 4-1.7(b), 4-8.4(c, d). The Florida Bar v. Shankman, 41 So. 3d 166 (Fla. 2010).
    Three year suspension was warranted for attorney who engaged in misconduct by representing
    clients with unwaivable conflicts of interest and making misrepresentations to client. West's F.S.A.
    Bar Rules 41.7(a), 41.9(a), 41.16(a)(1), 44.1(a), 48.4(c). The Florida Bar v. Scott, 39 So. 3d
    309 (Fla. 2010).
    Three-year suspension, with reinstatement on conditions, was warranted for attorney whose conduct
    in representing client charged with violation of municipal ordinance, filing numerous frivolous
    appeals and petitions for certiorari or habeas corpus, telling client to stop requesting information
    about the representation, continuing the representation after client had discharged him and without informing
    client that he was continuing to file motions and petitions in the matter, refusing to respond
    to discovery requests, and refusing to cooperate in disciplinary investigation, violated rules requiring
    attorney to provide competent representation, abide by client's decision concerning objectives of representation,
    000830
    keep client reasonably informed, not continue representation in the event of a significant
    risk of conflict of interest, not continue representation if discharged by client, and not assert a claim
    or defense that is unwarranted under existing law. State Bar Rules and Regulations, Rule 4102(d),
    Rules 1.1, 1.2(a), 1.4, 1.7(a), 1.16(a), 3.1. In re Millard, 288 Ga. 449, 704 S.E.2d 779 (2011).
    Three month suspension from the practice of law was warranted, in disciplinary action in which
    attorney filed a petition for voluntary discipline prior to the filing of a formal complaint against attorney,
    where attorney, who suffered from emotional distress bordering on depression at the time of the
    incidents at issue due to a personal child support case, did not have a dishonest or selfish motive and
    acknowledged the wrongful nature of his conduct. In re Polk, 288 Ga. 63, 701 S.E.2d 161 (2010).
    Six-month suspension was warranted for attorney whose failure to timely respond to a court order
    and discovery requests resulted in default judgment against clients, who did not inform clients of de-
    fault judgment, and who stated falsely during disciplinary process that the litigation was resolved by
    settlement, where attorney had two prior instances of discipline. State Bar Rules and Regulations,
    Rule 4102(d), Rules 1.3, 1.4, 3.2, 8.4(a)(4); State Bar Rules and Regulations, Rule 4103. In re
    Hardwick, 288 Ga. 60, 701 S.E.2d 163 (2010).
    Attorney's commission of mortgage fraud and entry of guilty plea to felony offense warranted
    two-year suspension from practice of law, with reinstatement conditioned upon consultation with
    State Bar Law Office Management Program, agreement to implement Program's directives in connection
    with the reestablishment of law office, and attendance of first Ethics School conducted by Office
    of General Counsel after date of reinstatement. West's Ga.Code Ann. 168102(2), 168105(a).
    In re Suttle, 288 Ga. 14, 701 S.E.2d 154 (2010).
    Indefinite suspension without possibility of reinstatement for 12 months was warranted for attorney
    who, among other things, failed to timely file both federal and state income tax returns. Committee
    on Professional Ethics & Conduct of the Iowa State Bar Asso. v. Bertelli (1988, Iowa) 422 NW2d
    175.
    Three-year suspension was appropriate sanction for attorney's misconduct in driving under the influence
    of alcohol (DUI), committing aggravated battery, driving recklessly, and leaving the scene of
    resulting accident, where attorney caused both personal injury and property damage. Sup.Ct.Rules,
    Rule 226, Rules of Prof.Conduct, Rule 8.4(b). In re Frahm, 241 P.3d 1010 (Kan. 2010).
    Indefinite suspension was appropriate sanction for attorney who waived oral argument before the
    Court of Appeals without client's knowledge or authorization, failed to diligently and promptly represent
    his clients, failed to adequately communicate with clients, repeatedly accepted fees and failed
    to perform the work that he was paid to perform, failed to reduce contingency fee agreement to writing,
    failed to properly account for and refund unearned fees, failed to file timely written response to
    eight disciplinary complaints, and failed to properly notify two clients following his suspension from
    practice of law. Sup.Ct. Rules, Rule 207(b), 218(a); Sup.Ct.Rules, Rule 226, Rules of Prof.Conduct,
    000831
    Rules 1.2, 1.3, 1.4(a), 1.5(a, d), 1.15(b), 1.16, 8.1(b). In re Thomas, 241 P.3d 104 (Kan. 2010).
    Two-year suspension, as opposed to indefinite suspension, was appropriate sanction for attorney's
    misconduct that included conviction for attempt to obstruct a police officer's official duty, falsely
    telling police officers that interviewee whom attorney accompanied to interview had rewound and recorded
    over tape of interview, and not making reasonable efforts to correct misunderstanding of interviewee
    that attorney was representing him, where attorney lacked prior disciplinary record and had
    good reputation among peers in county bar. Sup.Ct.Rules, Rule 226, Rules of Prof.Conduct, Rules 4.3
    , 8.4(bd). In re Millett, 241 P.3d 35 (Kan. 2010).
    One-year suspension from the practice of law was warranted in attorney disciplinary case, where
    attorney subjected five administrative assistants for district court to sexual harassment, and he attempted
    to minimize the seriousness of his conduct, in violation of the professional rules.
    Sup.Ct.Rules, Rule 226, Rules of Prof.Conduct, Rule 8.4(d, g). In re Depew, 237 P.3d 24 (Kan. 2010)
    .
    Attorney's conduct in agreeing to represent client in grandchild visitation dispute and medical
    malpractice action, only to neglect each separate action and ignore client despite receipt of upfront
    payment of fees in the amount of $1,650, coupled with her failure to respond to bar complaint, warranted
    one-year suspension from practice of law and order requiring attorney to pay client restitution
    of all unearned fees. Kentucky Bar Ass'n v. Whitlock, 324 S.W.3d 415 (Ky. 2010).
    Attorney's conduct in continuing to practice law during disciplinary suspension, by representing
    client in a domestic case, coupled with his failure to respond to informational requests during ethics
    investigation, in violation of professional rules, warranted one-year suspension from practice of law.
    Sup.Ct.Rules, Rule 3.130, Rules of Prof.Conduct, Rules 3.4(c), 5.5(a), 8.1(b). Kentucky Bar Ass'n v.
    Grider, 324 S.W.3d 411 (Ky. 2010).
    Suspension of 60 days was warranted for attorney whose conduct, in failing to contact client or
    keep him advised of deadlines or court events, failing to return paperwork to client, failing to timely
    file paperwork in Social Security disability appeal, resulting in dismissal of appeal, failing to respond
    to discovery in personal injury case, resulting in dismissal of case with prejudice, and failing to respond
    to bar complaint, violated rules requiring attorney to act with reasonable diligence, keep client
    reasonably informed, return client materials, and requiring attorney to respond to disciplinary authorities.
    Sup.Ct.Rules, Rule 3.130, Rules of Prof.Conduct, Rules 1.3, 1.4, 1.16, 8.1(b). Kentucky Bar
    Ass'n v. Bryant, 318 S.W.3d 96 (Ky. 2010).
    Suspension of 181 days, requiring a reinstatement by the Supreme Court before resumption of
    practice and a review by Character and Fitness Committee of an application for reinstatement, was
    warranted for attorney who failed to return an unearned $1,000.00 retainer after being suspended
    from practice and who failed to respond to Bar complaint, where attorney had three prior suspensions
    and a prior public reprimand. Sup.Ct.Rules, Rule 3.130, Rules of Prof.Conduct, Rules 1.16(d), 8.1(b);
    000832
    Sup.Ct.Rules, Rules 3.505(1), 3.510(1). Kentucky Bar Ass'n v. Leadingham, 317 S.W.3d 583 (Ky.
    2010).
    Ninety-day suspension was appropriate sanction for attorney's misconduct in misrepresenting to
    the grantor of a mortgage that had been assigned to attorney's client that he had prepared a mortgage
    release and sent it to client, duplicating this lie to Bar Counsel on two separate occasions, and improperly
    withdrawing fund from his trust account by drawing a check payable to cash, where attorney
    had no duty to draft mortgage release for the grantor, attorney did not aggravate offense involving
    check payable to cash by misusing those funds for personal financial gain, attorney conceded wrongdoing
    before Court of Appeals and appeared willing to take responsibility for his actions, and attorney
    assisted his counsel in procuring the necessary mortgage release from his client. Md.Rule 16609
    (b); Md.Rule 16812, Rules of Prof.Conduct, Rules 4.1(a)(1), 8.1(a), 8.4(c, d). Attorney Grievance
    Com'n of Maryland v. Brown, 415 Md. 269, 999 A.2d 1040 (2010).
    Attorney's mental and emotional state due to marital problems would be mitigating factor in discipline,
    but attorney would nevertheless be suspended from practice for indefinite period for allowing
    statute of limitations to run, delaying return of funds, failing to keep sufficient funds in trust account
    to pay obligations, and failing to cooperate with investigators. Re Tessler (1990, Mo) 783 SW2d 906.
    One-year suspension was appropriate sanction for attorney's misconduct in offering discounted
    legal fees to three female bankruptcy clients and a family member of another client in exchange for
    sexual favors of various kinds, considering that none of the grievants accused attorney of forcing
    them to endure any unwanted physical contact or even attempting to do so, none felt sufficiently pressured
    that she even considered giving in, none sought therapy or treatment to overcome the experience,
    none suggested the incidents were traumatic, none pursued criminal charges, nothing suggested
    the grievants were especially vulnerable or more in distress because of the nature of their legal matters
    than were other categories of clients, and attorney had a prior history of disciplinary infractions.
    In re Witherspoon, 203 N.J. 343, 3 A.3d 496 (2010).
    Attorney diagnosed with "major depressive disorder without psychosis" would be suspended
    pending determination of capacity to defend herself against charges of neglect, failing to respond to
    inquiries from client and opposing counsel, and failure to cooperate with Bar investigation. Re Wunderlich
    (1988, 3d Dept) 141 App Div 2d 971, 530 NYS2d 636, motion gr (3d Dept) 149 App Div 2d
    809, 540 NYS2d 340.
    Two-year suspension with one year stayed, conditioned upon no further violations, two years of
    monitored probation upon attorney's return to practice, and eight hours of continuing legal education
    in law-office management were warranted as sanction for attorney's conduct, failing to appear or appearing
    tardily for hearings before municipal court, leaving one hearing early despite judge's specific
    instruction to remain, resulting in multiple contempt citations against attorney, and failing to respond
    000833
    to letters from disciplinary authorities, in violation of rules requiring reasonable diligence in representing
    a client, prohibiting undignified or discourteous conduct that is degrading to a tribunal, prohibiting
    conduct that is prejudicial to the administration of justice, prohibiting conduct that adversely reflects
    on the lawyer's fitness to practice law, and cooperation with a disciplinary investigation. Rules
    of Prof.Conduct, Rules 1.3, 3.5(a)(6), 8.4(d, h); Government of the Bar Rule V(4)(G). Mahoning
    County Bar Ass'n v. Sakmar, 2010-Ohio-5720, 938 N.E.2d 355 (Ohio 2010).
    Indefinite suspension was appropriate sanction for attorney who was convicted of three counts of
    theft based on stealing approximately $22,000 from three banks, who failed to notify any Ohio disciplinary
    authority of his conviction, and who failed to respond to disciplinary investigation. Rules of
    Prof.Conduct, Rules 8.1(b), 8.3(a), 8.4(b). Cincinnati Bar Assn. v. Newman, 2010-Ohio-5034, 937
    N.E.2d 81 (Ohio 2010).
    Two-year suspension from practice of law, with one year stayed on conditions, was appropriate
    sanction for attorney who prepared trust document for elderly client naming attorney's own children
    as beneficiaries, obtained loan from same client without advising her of risks of making unsecured
    loan and failed to repay loan, and in another matter received checks for fees from a guardianship account
    without first obtaining approval from probate court, where only mitigating circumstance was
    lack of prior disciplinary record, while aggravating factors included a pattern of misconduct involving
    multiple offenses of taking advantage of an elderly and vulnerable client for personal gain.
    Rules of Prof.Conduct, Rules 3.4(c), 8.4(d, h); Government of the Bar Rule V(4)(G); BCGD
    Proc.Reg. 10(B); Code of Prof.Resp., DR 1102(A)(5, 6), 5101(A)(1, 2), 5104(A) (2006). Disciplinary
    Counsel v. Shaw, 2010-Ohio-4412, 935 N.E.2d 405 (Ohio 2010).
    Two-year suspension, with one year stayed on conditions, was warranted for attorney whose conduct,
    failing to remit to his employer law firm over $7,000 in fees, resulting in a conviction for theft,
    violated rules prohibiting a lawyer from committing an illegal act that reflects adversely on the lawyer's
    honesty or trustworthiness, prohibiting conduct involving dishonesty, fraud, deceit, or misrepresentation,
    prohibiting conduct that is prejudicial to the administration of justice, and prohibiting
    conduct that adversely reflects on the lawyer's fitness to practice law. Rules of Prof.Conduct, Rule
    8.4(bd, h). Disciplinary Counsel v. Kraemer, 2010-Ohio-3300, 931 N.E.2d 571 (Ohio 2010).
    Two-year suspension with 18 months conditionally stayed, instead of entirely stayed two-year
    suspension, was appropriate sanction for attorney who, by using crack cocaine, violated disciplinary
    rules barring conduct prejudicial to administration of justice and conduct adversely reflecting on fitness
    to practice law; despite such mitigating factors as lack of prior disciplinary record, absence of
    dishonest or selfish motive, and cooperation in disciplinary proceeding, mitigating factor of a chemical
    dependency was absent, and aggravating factors included attorney's terminating participation in
    Ohio Lawyers Assistance Program (OLAP) and failure to appreciate seriousness of his conduct.
    Rules of Prof.Conduct, Rule 8.4(d, h). Ohio State Bar Assn. v. Peskin, 2010-Ohio-1811, 927 N.E.2d
    000834
    598 (Ohio 2010).
    Six-month stayed suspension was appropriate for attorney who violated disciplinary rules by representing
    a client's daughter, without daughter's knowledge or consent, in action by creditor to recov-
    er debt on credit card issued to client in daughter's name without her knowledge; 12-month stayed
    suspension recommended by parties was predicated in part on charges that had been dismissed,
    harsher sanction than public reprimand was justified because client's daughter had to employ counsel
    to vacate judgment for creditor and also had wages garnished, and mitigating factors included lack of
    prior disciplinary record, lack of dishonest or selfish motive, and full cooperation in investigation.
    Rules of Prof. Cond., Rules 1.7(a)(2), 1.16(a)(1), 5.4(c), 8.4(d). Disciplinary Counsel v. Mamich,
    2010-Ohio-1044, 928 N.E.2d 691 (Ohio 2010).
    One-year actual suspension, as opposed to a stayed suspension, was appropriate sanction for attorney
    who testified falsely that he had not removed certain files or information from his office, in his
    former law firm's action to enjoin alleged violation of the nonsolicitation and nondisclosure covenant
    of his employment agreement, and who destroyed firm documents to conceal his possession of them;
    mitigating factors of a lack of prior discipline and a good reputation were outweighed by aggravating
    factors including a pattern of misconduct involving multiple instances of lying and misrepresentation
    under oath, as well as attorney's refusal to acknowledge wrongful nature of his conduct. Rules of
    Prof.Conduct, Rule 3.4(a), 8.4(c, d, h); BCGD Proc.Reg. 10(B). Disciplinary Counsel v. Robinson,
    933 N.E.2d 1095 (Ohio 2010).
    Two-year suspension, with one year conditionally stayed, was appropriate sanction for attorney
    who engaged in misconduct by submitting false and fraudulent billing for her appointed-counsel services.
    Code of Prof.Resp., 1102(A)(4, 5, 6), 2106(A) (2006). Toledo Bar Assn. v. Stahlbush, 933
    N.E.2d 1091 (Ohio 2010).
    Indefinite suspension, and requirement that prior to reinstatement attorney provides proof to a
    reasonable degree of medical certainty that he is mentally fit to return to the practice of law, was appropriate
    sanction for attorney who recklessly filed court documents containing unfounded accusations
    against two judges, misused his power as an attorney to issue subpoenas to further his personal
    agenda, misused his authority as a notary public, and accused three judges and a prosecutor of engaging
    in improper ex parte communications; mitigating fact that attorney had no prior disciplinary record,
    made full and free disclosure to the board, and was professional, respectful, and cooperative
    during disciplinary proceedings did not outweigh the aggravating effect of having demonstrated a dishonest
    and selfish motive, abusing his position as a lawyer, making false and dishonest accusations
    against judges and prosecutors, and providing false and dishonest explanations of his actions. Code of
    Prof.Resp., DR 1102(A)(4 to 6), 7106(A) (2006); Government of the Bar Rule IV(2); Rules of
    Prof.Conduct, Rules 3.1, 3.5(a)(6), 8.2(a), 8.4(c, d). Disciplinary Counsel v. Pullins, 127 Ohio St. 3d
    436, 2010-Ohio-6241, 940 N.E.2d 952 (2010).
    000835
    Suspension from practice of law for two years, with final six months stayed on condition that, attorney
    make full accounting and full restitution to affected clients and return all client files within 90
    days of suspension, was warranted as sanction for attorney's misconduct in failing to act on behalf
    clients, respond to clients, or refund unearned fees to clients; as factors in aggravation, attorney acted
    with a selfish motive, engaged in a pattern of misconduct, caused harm to vulnerable clients, and initially
    failed to cooperate in the disciplinary investigation, but in mitigation, attorney had no disciplinary
    record, relinquished his bankruptcy court electronic case filing privileges and complied with other
    bankruptcy sanction orders, and ultimately cooperated in the disciplinary process. Rules of
    Prof.Conduct, Rules 1.3, 1.4(a)(3, 4), 1.15(d), 1.16(e), 8.4(d, h). Cleveland Metro. Bar Assn. v. Gresley,
    127 Ohio St. 3d 430, 2010-Ohio-6208, 940 N.E.2d 945 (2010).
    Attorney's conduct in failing to participate in the discovery process and by failing to respond to a
    motion for default judgment resulted in a judgment in excess of $330,000 against her clients and in
    failing to timely prosecute a second client matter which resulted in the dismissal without prejudice of
    that client's complaint warranted one-year suspension of license to practice law with six months
    stayed based on certain conditions. Code of Prof.Resp., DR 6101(A)(3) (2006); Rules of
    Prof.Conduct, Rules 1.3, 1.16(c, d), 3.4(c). Cleveland Metro. Bar Assn. v. Johnson, 127 Ohio St. 3d
    97, 2010-Ohio-4832, 936 N.E.2d 938 (2010).
    Attorney's mishandling of his personal injury client's funds warranted suspension from the practice
    of law for one year with entire year stayed, conditioned upon his continued treatment for depression
    due to his father's death by a psychologist/psychiatrist for duration of suspension, where misconduct
    was an isolated incident in his nineteen years of practice and attorney settled accounts of client's
    medical bills, showed remorse, and cooperated fully with investigation. New York DR 9-102(A),
    (B)(3, 4). Toledo Bar Assn. v. Kramer, 89 Ohio St. 3d 321, 731 N.E.2d 643 (2000); West's Key Number
    Digest, Attorney and Client 58.
    While Board of Commissioners on Grievances and Discipline of the Supreme Court may properly
    consider attorney's mental illness at the time of alleged misconduct as a mitigating factor in determining
    what sanction should be imposed, the mental illness provisions for summary suspension are not
    intended to be used by attorney in a disciplinary action to avoid suspension for violations. Government
    of the Bar Rule V, 7. Cincinnati Bar Assn. v. Komarek, 84 Ohio St. 3d 90, 702 N.E.2d 62
    (1998).
    Attorney's misconduct in mishandling clients' trust account funds in violation of rules of professional
    conduct warranted two year suspension from the practice of law, where attorney disbursed settlement
    sums to her clients, but in many cases failed to make full payments to third party medical
    providers, a client was unable to apply for credit due to a tax lien placed by a medical provider due to
    attorney's actions, and another client did not receive settlement funds, and attorney had prior disciplinary
    000836
    history, though attorney fully accepted responsibility for her actions. Appellate Court Rule
    407, Rules of Prof.Conduct, Rules 1.1, 1.3, 1.15, 8.4(a, d, e); Appellate Court Rule 413, Lawyer Disciplinary
    Enforcement, Rule 7(a)(1, 6). In re Hardee-Thomas, 706 S.E.2d 507 (S.C. 2011).
    Attorney's admitted misconduct in three separate disciplinary matters, each involving a general
    failure to diligently protect the rights of his clients and mismanagement of his caseload over a period
    in which he worked for two separate law firms, resulting in, for example, dismissal of a personal injury
    action by operation of statute of limitations, preventing a client from appealing an order denying
    postconviction relief, and a failure to properly account for unearned fees in other cases, warranted
    two-year suspension from practice of law. In re Holcombe, 697 S.E.2d 600 (S.C. 2010).
    Attorney's admitted misconduct in two disciplinary matters, in one case failing to diligently pursue
    postconviction relief matter while neglecting his duty to communicate with his client or his family,
    and in another case mismanaging his client trust accounts by commingling personal funds with
    client funds resulting in bounced check, warranted two-year suspension from practice of law, retroactive
    to date of interim suspension, resulting in a nine-month remaining term, conditioned upon attorney's
    completion of legal ethics and law practice accounting training, in addition to various steps
    towards treatment of his severe depression. In re Ginn, 697 S.E.2d 572 (S.C. 2010).
    Definite suspension of two years, plus restitution, was warranted as a sanction for attorney who
    entered Agreement for Discipline by Consent, admitting misconduct in failing to keep clients reasonably
    informed of the status of litigation, failing to hold unearned client funds in trust account, failing
    to return unearned fees to client, failing to respond to client requests for information, failing to appropriately
    terminate client representation, and failing to respond to a lawful demand for information
    from disciplinary authority. In re Moody, 387 S.C. 352, 692 S.E.2d 906 (2010).
    In attorney disciplinary proceedings for misconduct arising from mishandling of client funds, appropriate
    sanction was retroactive two-year suspension where unethical conduct stemmed from poor
    judgment brought on by manic depressive depressed episode and medical evidence showed attorney
    was recovering from depressed episode through treatment with antidepressant drug. Re Howle (1988)
    294 SC 244, 363 SE2d 693.
    One-year suspension from practice of law was appropriate sanction for attorney's misconduct in
    connection with his representation of multiple clients, including providing dilatory responses relating
    to client matters, using worthless check drawn on unapproved trust account to reimburse client for
    unearned fees, repeatedly failing to maintain his trust account properly, tendering worthless checks to
    United States Court of Appeals, failing to file appeal for client or inform her of his oversight, filing
    of frivolous appeals, practicing law while his license was suspended, and failing to notify clients and
    tribunals that his license was suspended; in aggravation, victims were vulnerable, and attorney had
    prior disciplinary offense, selfish motive by failing to return unearned fees, pattern of neglect and
    dilatory conduct constituting multiple offenses, refusal to acknowledge wrongful nature of conduct,
    000837
    and indifference to making restitution to clients. Sup.Ct.Rules, Rule 8, Rules of Prof.Conduct, Rules
    1.3, 1.4(a, b), 1.15(a), 4.4(a), 8.1(b). Flowers v. Board of Professional Responsibility, 314 S.W.3d
    882 (Tenn. 2010).
    Attorney's misconduct in affiliating himself with a nonlawyer who gave legal advice in connection
    with a living trust scam targeted at seniors warranted two-year suspension from practice of law;
    although disbarment was presumptive sanction, attorney attempted to remediate the harm caused by
    his misconduct, such that disbarment was not necessary to protect the public or educate other lawyers.
    In re Disciplinary Proceeding Against Shepard, 239 P.3d 1066 (Wash. 2010).
    Four-month suspension was appropriate sanction for attorney's misconduct in billing the State
    Public Defender for work he did not actually perform, continuing to practice law after receiving notice
    of his administrative suspension for failing to comply with his continuing legal education requirements,
    willingly misleading a sitting judge about whether or not he had a valid law license, failing
    to refund unearned fees, and failing to respond to the Office of Lawyer Regulation, where attorney
    committed these ethical violations while overextended professionally and trying to maintain his
    practice during the break-up of his legal partnership. SCR 20:1.16(d), 20:3.3(a)(1), 20:8.4(c),
    22.03(2), 31.10(1); . In re Disciplinary Proceedings Against Hammis, 2011 WI 3, 793 N.W.2d 884
    (Wis. 2011).
    Two-year suspension from the practice of law was warranted as sanction for attorney who stipulated
    to committing professional misconduct by his conviction for possession of narcotic drugs and
    felony bail jumping; attorney had prior disciplinary history and engaged in a pattern of misconduct,
    and attorney admitted his misconduct, expressed remorse, and was undergoing voluntary drug treatment
    and monitoring. SCR 20:8.4(b). In re Disciplinary Proceedings Against Compton, 2010 WI 112,
    787 N.W.2d 831 (Wis. 2010).
    31 AMJUR TRIALS 633 Page 152
    31 Am. Jur. Trials 633 (Originally published in 1984)
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    does Richard Hill have standing to file a grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/23/12 9:12 AM
    To: patrickk@nvbar.org; cdbaker@richardhillaw.com
    American Jurisprudence Trials
    Database updated April 2011
    000838
    Defending Lawyers in Disciplinary Proceedings
    31 Am. Jur. Trials 633 (Originally published in 1984)
    III Attorney-Client Grievances
    10 In general
    11 Sources of complaints and grievances; checklist
    12 Former criminal clients
    13 Particular problem clients
    14 Fee disputes; checklist of factors of reasonableness
    15 Arbitration; forms
    16 Fee dispute committee hearings; illustrative testimony
    Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
    misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
    and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
    filed documents which he or someone in his office generated to falsely certify debtors' completion of
    required credit counseling course and which he knew, or should have known, that debtors did not
    sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
    109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).
    Mr. King, could you please update me on that status and progress of the various grievances I filed recently in addition to
    providing a detailed summary of the content of all of your correspondences, written or otherwise, and telephone communciatiosn
    with Richard Hill or anyone with his office. Further, please state whether Casey Baker is part of the grievance, as Hill asserts
    he is filing it on Mr. Baker's behalf.
    Sincerely,
    Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for opposing counsel?
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    Change of Address
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/22/12 1:46 PM
    To: patrickk@nvbar.org
    Dear Mr. King,
    Please note my new address. I attempted to change this online at the Bar's online portal several days ago, yet it
    still has not updated. My new mailing address is:
    000839
    PO BOX 60952
    RENO NV 89506
    Also, as I mentioned to you in a previous written correspondence, I did write to Bar Counsel previously in an attempt to fulfill my duties under
    SCR 111. At least one of the allegation in Mr. Hill's greivance related to a criminal charge that has yet to be adjudicated. Is it your's or the Bar's
    position that I must reply to or otherwise defend myself in this grievance setting prior to having an opportunity to do so in the case wherein such
    a charge is found itself? If it is, can you provide some citation to the authority for such a position?
    Sincerely,
    Zach Coughlin, Esq., PO BOX 60952, RENO, NV, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: hello from Zach Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/22/12 12:29 PM
    To: patrickk@nvbar.org
    Thank Mr. King,
    I will. Things are coming together quickly though I have faced many obstacles. I may have mentioned this
    already, but I did file a Motion to Withdraw in the two Gessin Adversary Proceedings in NVB. However, in
    the meantime, as I understand it, I have a duty to represent Mr. Gessin, even despite his indications that he
    doesn't necessarily want me to, that doing so is unnecessary (he apparently is in the process or already has had
    his main BK case withdrawn, though I pointed out to him, that does not necessarily make moot the adversary
    proceedings...). It has been a good lesson in how very important that attorney of record designation is.
    However, I did learn a lot of lessons about that with Mr. Christiansen as my attorney in 2002-2004, along with
    the extent to which a proper, detailed fee agreement setting forth in explicit detail the scope of one's
    representation is very, very important.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    CC: DavidC@nvbar.org
    Subject: RE: hello from Zach Coughlin
    Date: Thu, 22 Mar 2012 17:51:20 +0000
    Good Morning Mr. Coughlin,
    I sorry to hear that you are having to deal with some extremely tough circumstances. Please come see me as soon as you can.
    000840
    Sincerely,
    Patrick King
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Thursday, March 22, 2012 2:31 AM
    To: Patrick King
    Subject: RE: hello from Zach Coughlin
    Dear Mr. King,
    I appreciate the seriousness of the process and want to show it the respectd it deserves. I take what I do very, very seriously. If
    you can give me some time, it would help. Due to the recent eviction (and that is an area of law where I am doing important
    work that often goes neglected...the societal cost to Nevadans subject to this ultra fast summary evictions, on top of the
    procedurally questionable manner in which they are carried out and served, is immense...sure it might help pay some RPD
    Sargents more than District Court Judges, but its done on the backs of real human beings suffering, etc....).
    I had a hearing today where I represented a client in a UIFSA matter. He needs me. My representation is very important to his
    life. He is a committed father who has been dealt some extremely tough circumstances. I think I have only received something
    like $500 from this client so far, and have done enough work to make that less than minimum wage, etc..
    I do want to meet with you. It would be most prudent though, for my clients and myself, if you and the State Bar could afford
    me some time to tend to the immediate need to get a new living space and office, attend and defend the "quadruple jeopardy"
    abuse of process that Richard Hill is orchestrating, and otherwise protect my client's interests. I am not refusing to speak with
    you on the phone or meet in person. My two phones are still being held by the Washoe County jail, under an Order by RMC
    Judge Nash Holmes, so....The USPS Golden Valley Station has retaliated against me by interferring with my mail, though I have
    taken all reasonable steps to counter that, including securing a new PO BOX, which I added as my public address on the Bar's
    online portal days ago, but for which I still do not see a change reflected. The Federal Torts Claims act has likely been violated
    by USPS Golden Valley Station supervisors Terry James and Buck Hyde, whom took it upon themselves to play judge and jury
    incident to a complicated eviction process that I have recently been litigating against Park Terrace Townhomes HOA and
    Western Nevada Management and Gayle Kern, LTD. It involves respondeat superior liability, etc., etc. Western Nevada
    Management knew of and orchestrated, and received approval from the Park Terrace HOA to have the two individuals who I
    rented from live at the 1422 E. 9th St. 89512 location. This involved a Robyn Badalato, then a property manager at Park
    Terrace. For some reason, when her boss found out about this, she started crying, saying she was going to be fired, etc., etc..
    Then she apparently resigned. This was litigated in an interruption of essential services (electricity) complaint I filed recently.
    The HOA and Sue King admitted these things, yet they want to turn right around and disclaim an responsibility for anything,
    pursue a summary eviction despite the facts not lining up with the Glazier case sufficient to allow such, etc., etc.
    I can sit down and talk with you whenever you want. However, I am writing to explain why this week or the immediate future
    would prevent a hardship for me with regard to scheduling such a meeting. Please no that is not a reflection upon my respect
    for you, the State Bar, your office, or this process, but rather indicative of the realities faced by businesses subject to summary
    evictions where the non payment of rent is NOT alleged, something which the law is supposed to forbid under NRS 40.253, but
    for which the Reno Justice Court has now subjected me to TWICE in three or four months....
    I hope you can understand though, that deadlines are running, Richard Hill has me facing quadruple jeopardy via his abuse of
    processes, etc. I have a hearing on that this week. But I am not some young punk who is going to come in and let Jon Bailey
    blow a lot of intimidation and hot air at him for his millionaire buddy Mark Tratos (whom had to admit under oath, that he had
    previously "lost" other student's papers in his illustrious career as an adjunct professor. And that was also confirmed by
    Anderson and Morishita, two former patent attorney associates for Mr. Tratos. Also, Mr. Tratos lost or "failed to receive"
    Jessica Wolf's paper in that 2002 Cyber Law course, but I don't recall the State Bar of Nevada raping her. Further, Tratos wrote
    me asking for "another copy of your paper", which implies he received one. Then he went on to ask for detail about the paper,
    what it was about etc., clearly implying he did have possession of the one I turned in with only my "blind grading" social
    000841
    security number, etc. (he had a student in the class who worked for his firm, he probably interpreted my adherence to the "blind
    grading" setup that was utilized in every other course I took at Boyd as a personal affront, etc....To me it is disturbing that the
    State Bar of Nevada had allowed Mark Tratos to so leverage the resources of the State Bar to wreck shop on my life, while,
    apparently, no real inquiry has ever been made as to whether Tratos did so inappropriately. He was "on vacation in Europe"
    according to my "pro bono" attorney Pete Christiansen (and so did not appear at the June 2002 conclusion of the hearing before
    the C&F Committtee, whom was referred by Character and Fitness Committee member Kevin Kelly, whom owns the strip club,
    The Spearmint Rhino, or did at the time. I believe in Senator Grassley's "sunshine and transparency" in government, and in
    this grievance process too.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: hello from Zach Coughlin
    Date: Wed, 21 Mar 2012 18:36:13 +0000
    Dear Mr. Coughlin,
    The allegations against you are serious and put into question your competence to practice law. I would like to meet with you so that I can talk with you about the allegations
    and see if there is a way
    to assist you.
    If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of actually getting to sit down and talk with you.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 21, 2012 8:31 AM
    To: Patrick King
    Subject: hello from Zach Coughlin
    Dear Mr. King,
    The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can check voice mail by email, such as:
    "Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some emails. I
    would like to hear from you, so we can talk on the phone if you could please call me at (775) 328-1384 Thanks a
    lot. Bye. "
    Until then, could we communicate in writing please. I provided you a great deal of material in response to Hill's
    grievance, and I feel that should take you more than one hour to appropriately review, so....
    Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition, though I don't
    really know what in the hell that matters or why Richard Hill is able to leverage your office to make busy work for
    me by making completely unsupported "ghostwriting" accusations, etc., etc.
    000842
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: hello from Zach Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/22/12 2:30 AM
    To: patrickk@nvbar.org
    Dear Mr. King,
    I appreciate the seriousness of the process and want to show it the respectd it deserves. I take what I do very, very seriously. If
    you can give me some time, it would help. Due to the recent eviction (and that is an area of law where I am doing important
    work that often goes neglected...the societal cost to Nevadans subject to this ultra fast summary evictions, on top of the
    procedurally questionable manner in which they are carried out and served, is immense...sure it might help pay some RPD
    Sargents more than District Court Judges, but its done on the backs of real human beings suffering, etc....).
    I had a hearing today where I represented a client in a UIFSA matter. He needs me. My representation is very important to his
    life. He is a committed father who has been dealt some extremely tough circumstances. I think I have only received something
    like $500 from this client so far, and have done enough work to make that less than minimum wage, etc..
    I do want to meet with you. It would be most prudent though, for my clients and myself, if you and the State Bar could afford
    me some time to tend to the immediate need to get a new living space and office, attend and defend the "quadruple jeopardy"
    abuse of process that Richard Hill is orchestrating, and otherwise protect my client's interests. I am not refusing to speak with
    you on the phone or meet in person. My two phones are still being held by the Washoe County jail, under an Order by RMC
    Judge Nash Holmes, so....The USPS Golden Valley Station has retaliated against me by interferring with my mail, though I have
    taken all reasonable steps to counter that, including securing a new PO BOX, which I added as my public address on the Bar's
    online portal days ago, but for which I still do not see a change reflected. The Federal Torts Claims act has likely been violated
    by USPS Golden Valley Station supervisors Terry James and Buck Hyde, whom took it upon themselves to play judge and jury
    incident to a complicated eviction process that I have recently been litigating against Park Terrace Townhomes HOA and
    Western Nevada Management and Gayle Kern, LTD. It involves respondeat superior liability, etc., etc. Western Nevada
    Management knew of and orchestrated, and received approval from the Park Terrace HOA to have the two individuals who I
    rented from live at the 1422 E. 9th St. 89512 location. This involved a Robyn Badalato, then a property manager at Park
    Terrace. For some reason, when her boss found out about this, she started crying, saying she was going to be fired, etc., etc..
    Then she apparently resigned. This was litigated in an interruption of essential services (electricity) complaint I filed recently.
    The HOA and Sue King admitted these things, yet they want to turn right around and disclaim an responsibility for anything,
    pursue a summary eviction despite the facts not lining up with the Glazier case sufficient to allow such, etc., etc.
    I can sit down and talk with you whenever you want. However, I am writing to explain why this week or the immediate future
    would prevent a hardship for me with regard to scheduling such a meeting. Please no that is not a reflection upon my respect
    for you, the State Bar, your office, or this process, but rather indicative of the realities faced by businesses subject to summary
    evictions where the non payment of rent is NOT alleged, something which the law is supposed to forbid under NRS 40.253, but
    for which the Reno Justice Court has now subjected me to TWICE in three or four months....
    I hope you can understand though, that deadlines are running, Richard Hill has me facing quadruple jeopardy via his abuse of
    processes, etc. I have a hearing on that this week. But I am not some young punk who is going to come in and let Jon Bailey
    blow a lot of intimidation and hot air at him for his millionaire buddy Mark Tratos (whom had to admit under oath, that he had
    previously "lost" other student's papers in his illustrious career as an adjunct professor. And that was also confirmed by
    Anderson and Morishita, two former patent attorney associates for Mr. Tratos. Also, Mr. Tratos lost or "failed to receive"
    Jessica Wolf's paper in that 2002 Cyber Law course, but I don't recall the State Bar of Nevada raping her. Further, Tratos wrote
    me asking for "another copy of your paper", which implies he received one. Then he went on to ask for detail about the paper,
    what it was about etc., clearly implying he did have possession of the one I turned in with only my "blind grading" social
    000843
    security number, etc. (he had a student in the class who worked for his firm, he probably interpreted my adherence to the "blind
    grading" setup that was utilized in every other course I took at Boyd as a personal affront, etc....To me it is disturbing that the
    State Bar of Nevada had allowed Mark Tratos to so leverage the resources of the State Bar to wreck shop on my life, while,
    apparently, no real inquiry has ever been made as to whether Tratos did so inappropriately. He was "on vacation in Europe"
    according to my "pro bono" attorney Pete Christiansen (and so did not appear at the June 2002 conclusion of the hearing before
    the C&F Committtee, whom was referred by Character and Fitness Committee member Kevin Kelly, whom owns the strip club,
    The Spearmint Rhino, or did at the time. I believe in Senator Grassley's "sunshine and transparency" in government, and in
    this grievance process too.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: hello from Zach Coughlin
    Date: Wed, 21 Mar 2012 18:36:13 +0000
    Dear Mr. Coughlin,
    The allegations against you are serious and put into question your competence to practice law. I would like to meet with you so that I can
    talk with you about the allegations and see if there is a way
    to assist you.
    If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of actually getting to sit down
    and talk with you.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 21, 2012 8:31 AM
    To: Patrick King
    Subject: hello from Zach Coughlin
    Dear Mr. King,
    The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can check voice mail by email, such as:
    "Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some emails. I would like to
    hear from you, so we can talk on the phone if you could please call me at (775) 328-1384 Thanks a lot. Bye. "
    Until then, could we communicate in writing please. I provided you a great deal of material in response to Hill's grievance, and
    I feel that should take you more than one hour to appropriately review, so....
    000844
    Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition, though I don't really know
    what in the hell that matters or why Richard Hill is able to leverage your office to make busy work for me by making
    completely unsupported "ghostwriting" accusations, etc., etc.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: hello from Zach Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/22/12 2:02 AM
    To: patrickk@nvbar.org
    Mr. King,
    I am preparing a Supplemental Response to the grievance and will have it to you as soon as possible, though it may take a few
    weeks.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: hello from Zach Coughlin
    Date: Wed, 21 Mar 2012 18:36:13 +0000
    Dear Mr. Coughlin,
    The allegations against you are serious and put into question your competence to practice law. I would like to meet with you so that I can
    talk with you about the allegations and see if there is a way
    to assist you.
    If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of actually getting to sit down
    and talk with you.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 21, 2012 8:31 AM
    000845
    To: Patrick King
    Subject: hello from Zach Coughlin
    Dear Mr. King,
    The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can check voice mail by email, such as:
    "Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some emails. I would like to
    hear from you, so we can talk on the phone if you could please call me at (775) 328-1384 Thanks a lot. Bye. "
    Until then, could we communicate in writing please. I provided you a great deal of material in response to Hill's grievance, and
    I feel that should take you more than one hour to appropriately review, so....
    Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition, though I don't really know
    what in the hell that matters or why Richard Hill is able to leverage your office to make busy work for me by making
    completely unsupported "ghostwriting" accusations, etc., etc.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    RE: hello from Zach Coughlin
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 3/22/12 2:01 AM
    To: patrickk@nvbar.org
    Mr. King,
    I did not categorically characterize all "allegations" in any way, so there has been no statement from me as to whether they are
    "serious" or not. I do prefer doing things in writing. Ms. Eichman wanted to talk on the phone in 2003 when it came time to
    explain why she failed to honor the documents I submitted in response to her express instructions to so submit. I met with Jon
    Bailey in 2002 and found it to be an appalling experience. Lots of people taking up for Mark Tratos, despite a wealth of
    evidence to suggest he was playing games with my career to feed his own ego. Lots of faux offense taking at my pointing that
    out by Bailey and Mike Rowe. Tratos was a millionaire at the time. I was riding a ten speed for transportation and had just
    finished law school.
    I would like to know what you have done with the various grievances I filed? Are you meeting with the attorneys against whom
    I have filed a grievance? I am looking for indications from you that this process will be conducted in a fair manner with
    sufficient due process protections. I was evicted at gunpoint by the Washoe County Sheriffs on 3/15 (this is the standard
    practice of the WCSO and had nothing to do with anything I did, I was compliant and docile when the Sheriff's broke into my
    location with guns drawn in their attempts to carry out the service of process of a Summary Eviction Order and a lockout...). I
    have hearings this week, etc. I can meet with you anytime the week of April 23rd, through April 27th, 2012. When are you
    available?
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    000846
    No: 9473
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: hello from Zach Coughlin
    Date: Wed, 21 Mar 2012 18:36:13 +0000
    Dear Mr. Coughlin,
    The allegations against you are serious and put into question your competence to practice law. I would like to meet with you so that I can
    talk with you about the allegations and see if there is a way
    to assist you.
    If you do not meet with me, then the Office of Bar Counsel will be forced to make decisions without the benefit of actually getting to sit down
    and talk with you.
    Patrick King, Assistant Bar Counsel.
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Wednesday, March 21, 2012 8:31 AM
    To: Patrick King
    Subject: hello from Zach Coughlin
    Dear Mr. King,
    The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can check voice mail by email, such as:
    "Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some emails. I would like to
    hear from you, so we can talk on the phone if you could please call me at (775) 328-1384 Thanks a lot. Bye. "
    Until then, could we communicate in writing please. I provided you a great deal of material in response to Hill's grievance, and
    I feel that should take you more than one hour to appropriately review, so....
    Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition, though I don't really know
    what in the hell that matters or why Richard Hill is able to leverage your office to make busy work for me by making
    completely unsupported "ghostwriting" accusations, etc., etc.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    hello from Zach Coughlin
    000847
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 3/21/12 8:30 AM
    To: patrickk@nvbar.org
    Dear Mr. King,
    The Reno Munic Court is still withholding both of my cells phones and some others items, so calling you is problematic. I can check voice mail by email, such as:
    "Bye, hey jack is packing. How are you doing. My assistant Bar Council and we've been sharing some emails. I would like to
    hear from you, so we can talk on the phone if you could please call me at (775) 328-1384 Thanks a lot. Bye. "
    Until then, could we communicate in writing please. I provided you a great deal of material in response to Hill's grievance, and
    I feel that should take you more than one hour to appropriately review, so....
    Also, I have filed a motion to withdraw in Gessin's Bankruptcy AP cases and a Reply to Opposition, though I don't really know
    what in the hell that matters or why Richard Hill is able to leverage your office to make busy work for me by making
    completely unsupported "ghostwriting" accusations, etc., etc.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    000848
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    000852
    Print Close
    supplement to response to grievance
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 3/19/12 4:05 AM
    To: patrickk@nvbar.org
    1 attachment
    rcp 2012-000018 D3 Hill v Coughlin Protection Order back.pdf (22.6 MB)
    Dear Mr. King,
    Please see attached.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000853
    Print Close
    Gessin ghostwriting issue
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 3/19/12 3:24 AM
    To: patrickk@nvbar.org
    19 attachments
    THE 2 11 12 email to WCSO RPD Reno City Attorney Hill NPUC Hill et al b e.pdf (137.8 KB) , 1 13
    12 email to Hill copying Hill on Supplemental filed in Carpentier case to avoid any ex parte
    allegations.pdf (78.9 KB) , 1 13 12 email to Hill copying Hill on Supplemental filed in Carpentier case
    to avoid any ex parte allegations.htm (12.5 KB) , CV11-03628-2658302 (Mtn Ord to Show
    Cause).pdf (88.0 KB) , CV11-03628-2688476 (Opening Brief).pdf (99.9 KB) , CV11-03628-2690815
    (Opening Brief).pdf (358.9 KB) , CV11-03628-2690998 (Mtn for Extension of Time).pdf (102.5 KB)
    , CV11-03628-2696056 (Ord to Show Cause).pdf (62.0 KB) , CV11-03628-2697022 (Opposition to
    Mtn ...).pdf (63.1 KB) , CV11-03628-2704374 (Reply to in Opposition).pdf (133.1 KB) , CV11-
    03628-2704375 (Reply to in Opposition).pdf (129.8 KB) , CV11-03628-2728621 (Motion ...).pdf
    (50.8 KB) , CV11-03628-2728630 (Answering Brief).pdf (178.6 KB) , CV11-03628-2728630
    (Exhibit 1).pdf (239.9 KB) , CV11-03628-2728630 (Exhibit 2).pdf (178.1 KB) , CV11-03628-
    2728630 (Exhibit 3).pdf (183.2 KB) , CV11-03628-2728630 (Exhibit 4).pdf (492.6 KB) , CV11-
    03628-2728630 (Exhibit 5).pdf (431.4 KB) , CV11-03628-2728630 (Exhibit 6).pdf (225.1 KB)
    Dear Mr. King,
    I do not understand. I provided you a ton of information and documentation in my Response to Hill's grievance,
    and, after emailing me six hours prior to the deadline to do so saying you already received my Response (which
    you had not, and which I had informed you that you had not but would be recieving it), you know call and or
    write me less than a day after receiving my voluminous Response and want to meet urgently. This sends a
    strong message that you did not put much time into analyzing my response, which would tend to indicate such a
    meeting would lack traditional due process protections, would it not? I have already been attacked by a
    Character and Fitness Committee member while he owned the Spearmint Rhino strip club in Las Vegas, and
    where the Committee promised to get me the names of "three attorneys who will handle your case on a pro se
    basis" but where only one name was provided, and that name wound up being and attorney would extracted soem
    approximately $7,000 i his fees and the fees of a gambling addiction specialist (both of whom admitted to being
    extremely close personal friends of Character and Fitness Committee member Kevin Kelly, Esq. who then owned
    the Spearmint Rhino strip club. Next, Christiansen and Sanft bungled several deadlines and client confidences
    related to extremely sensitive information, whereupon, finally, Director of Admissions Eichman made the
    unilateral decision to refrain from submitting my case for review, despite her receipt of my Request for
    Reconsideration. Finally, Christiansen's legal assistant Kelly Huff wrote me explaing that I had failed to provide
    their office with the Request for Reconsideration that I sent it on 9/15/03, despite my having fax confirmation
    proof of this and despite a subsequent copy of the file provided by Christiansen's office proving they had recieved
    such a Request, and that is was received by them on 9/15/03. I do not mean to be standoffish, Mr. King, but it is
    what it is. How Ms. Eichman's rationale for her action is different than what any attorney might say upon
    blowing some deadline or otherwise having a client's file fall behind a filing cabinet for a couple years, is really
    not at all clear to me.
    As to my official address with the State Bar and receiving my mail, the USPS is likely going to be sued for the
    handling of my mail, should it become clear that any client matters where prejudiced in light of what has been
    000854
    deplorable conduct by the station involved.
    Further, as to Hill's Motion for Order To Show Cause, please see the attached copy of Hill's application for an
    Order of Protection, then compare it to Hill's other filings wherein he suddenly backs off his assertion that I was
    "climbing on the contractor's truck". Hill lied when he wrote that. I did not climb on anybody's truck. Hill
    merely did not want me to film all that he was throwing away, especially given that he was throwing away unique
    items that had both monetary and sentimental value and because he had no good reason for refusing to allow me to
    take those items other than spite and an attempt to get me to sign away my security deposit, which Hill still has
    not returned. Further, Hill is not licensed under the FDCPA as a debt collector yet attempts to so practice, as
    such, this grievance should focus on that as well. Hill needs to answer for his lies about me allegedly "making
    contact" with him, about me allegedly "climbining on the contractors truck", about his abusing the TPO process to
    gain advantage in a litigation (ie, to prevent evidence collection and discovery), about his abuse of process in
    seeking to get me arrested and signing a criminal complaint where service of the evictio order was insufficient,
    and regardless, Hill had vitiated its import anyway by billing me for the same amount as the "full use and
    occupancy" (and I have a video of Hilll admitting to this and his firms 11/10/11 letter admits to that as well.
    Further, as for his Motion for Order to Show Cause, as it relates to an alleged contempt on my part in failing to
    abide by the 1/11/12 Order from in CV11-03628, well, NRCP 6(e) requires that 3 days for mailing be accorded
    even for electronic filings. As such, any activity on my part of 1/12/12 clearly is irrelevant as service was not
    effectuated at that point and there is not allegation that any "personal service" was undertaken. That being the
    case, here is another basis for grievance against Hill, especially his continually filing documents not based in fact
    or law, as here.
    Some more regarding Hill's grievance. Hill clearly attempts to mislead when he suggest that the Supplemental I
    filed in the Carpentier's foreclosure defense matter was incorrectly filed there. Clearly, I intended to file it there
    and the attached email I sent to Hill explains clearly why I copied him on it (because I foresaw Hill filign a Bar
    grievance for "ex parte communications" based upon some idea that arguments made in one case that bare some
    connection to another case would be a basis for Hill crying foul, and, as seen in Hill's "ghostwriting" grieviance,
    its a very low standard for crying foul that Richard has, which is typical of all the most feckless attorneys. That
    email indicated to Hill and his staff:
    One, I would like to reserve my objection to "Good Samiritan" Richard G. Hill purporting to file grievances on
    behalf of the public in general or Mr. Gessin, or whoever it is Richard is doing this for. I suspect Richard is
    doing this for the same reason he does so many other things: to keep opposing counsel busy with responding to all
    spineless paper pushing that Richard G. Hill is so very well known for throughout Northern Nevada legal
    circles. Nonetheless, important issues are brought up in Mr. Hill's grievance. To a great extent, I foresaw
    these issues long ago and attempted to address them appropriately. I often get clients who are on their third or
    fourth attorney. Mr. Gessin was one such client. By that time they all want to sue their former attorneys, and
    feel quite burned by the fees they have paid. Mr. Gessin was a good example of this and he wished to proceed
    on an unbundled services arrangement, or a flat fee per motion/opposition/pleading basis, etc. From the very,
    very long time that went by between my passing the July 2001 Nevada Bar Examination and being admitted to
    practice in March of 2005, the issue of the legality of ghostwriting for pro se litigants was something I was
    somewhat aware of, but I don't believe I ever did. I am somewhat disappointed that I was not industrious
    enough to get anywhere close to doing such a thing but mostly I was just so demoralized by not having a license
    and from the rape that the character and fitness committee and Kelly, and Christiansen and Eichman et al
    committed upon me that I mostly just worked for Thomas J. Hall, Esq. for about $0.89 per hour (just kidding, I
    love Tom) doing legal research in the Washoe County Law Library while the librarians glared at me and let me
    know how very disappointed they were that I, or any member of the public, really, had interrupted their solitude.
    So now it seems there is a tough situation where, on one hand, as a now licensed attorney, there is some taboo to
    "ghostwriting" (necessitating such lucrative activities as responding to grievances filed by opposing counsel like
    Richard G. Hill, Esq.....and I sure hope you will countenance the grievances I am filing against Hill, Christiansen,
    Sanft, Kevin Kelly, Eichman, etc, with the same seriousness that your are taking Richard G. Hills. I notice
    000855
    Richard G. Hill, Esq. has a funny way of being able to get the police (and some others that I probably shouldn't
    mention) to take his complaints just a little bit more seriously than they take others. I would also like to file a
    grievance against all three of the public defenders I have been appointed in the trespass case in Reno Municipal
    Court for 11 CR 26405, Lew Taitel, Roberto Puentes, and Keith Loomis. Each have thoroughly failed to
    zealously advocate on my behalf, with Loomis calling my arguments vis a vis the procedural requirements for
    serving eviction orders in thoroughly contested summary eviction proceedings "frivolous" despite being provided
    the attached 22 page memorandum detailing those arguments and despite the procedures requiring as much set
    forth in the Anvui decision of the Nevada Supreme Court. I would also like to file a greivance against Deputy
    Reno City Attorney Ormaas for her blase indication that she cared not about any admission of bribery on the part
    of Reno Police Officer Chris Carter, and that she would not be following up on that, even where it bared some
    relation to the citation in 11 TR 26800 issued by Sargent Tarter, for which I cross examined Sargent Tarter as to
    whether he did so in retaliation for my reporting Officer Carters admission of accepting bribes from Richard G.
    Hill. Instead, I believe Deputy City Attorney Ormaas and City of Reno Marshal Hiney (the spelling might be a
    bit off) conspired to have Judge Nash Holmes have me arrested for summary contempt in Order to obtain my
    cell phones, which upon information and belief, Ormaas and Hiney believe might contain "evidence" of
    misconduct on both of their parts. Hiney attempted to serve me Notice of Hearing on Motion for Order to
    Show Cause in the appeal of the Richard G. Hill, Esq. eviction matter (one of three instances of "triple jeopardy"
    Hill has me facing here....this Bar grievance, the criminal complaint in 11 CR 26405, and, actually, multiple
    Orders to Show Cause (one in the Trial Court in RJC Rev201--001708 and one in the associated Appeal in CV11-
    03628). However, the actual Affidavit of Service that the WCSO filed for the Notice of Hearing Marshal
    Hiney attempted to serve me (please inquire with Chief Marshal Roper, perhaps?) was actually signed by the same
    WCSO Deputy Machem that swore, under oath, in his 11/7/11 Affidavit of Service in the eviction case RJC
    REv2011--001708 that he "personally served" the Order of Summary Eviction. The attached 22 page
    memorandum sent to various individuals and the admission of WCSO Civil Section Supervisor Liz Stuchell that,
    in their mind, "personally served" can mean a lot of things that it has never meant in any legal settings, is provided
    for background. I also wish this to begin a grievance against Deputy Reno City Attorney Pam Roberts for what
    I believe may be several violations on her part of the rules relative to prosecutorial misconduct, especially those
    involving suborning perjury, including that of Officer Kameron Crawfor saying in 11 CR 22176, that I did not
    provide him my drivers license, and therefor issuing me a citation would not be an option, but rather, my failure to
    provide my driver's license buttressed his proable cause finding justifying a search incident to arrest. However,
    Roberts, in 11 CR 22176 and later on appeal in CR11-2064, had in her possession Wal-Mart AP video from the
    interrogation room clearly showing me providing Officer Kameron Crawford my driver's license and other
    evidence supports a finding that he had it (including dispatch reports and the information culled by Officer
    Kameron from the driver's license and placed on the arrest report, which Officer Crawford later lied about,
    saying he got that information at the WCSO, which is clearly contrary to established protocol and privacy
    policies). One more grievance against Reno City Attorney Christopher Hazlett-Stevens for lying to me on the
    phone about whether the City of Reno had the arrest report from the September 9, 2011 arrest at Wal-mart from
    the Reno Sparks Indian Colony in 11 CR 22176. I wish for all of these grievances to go forward now, but I
    may provide supplementary materials in support thereof later. Additionally, she has the "purchased receipt" that
    showed it had the very UPC number that both Frontino and Crawford swore under oath that it did not.
    Barrie Althoff, Limiting the Scope of Your Representation: When Your Client Wants, or Can Afford, Only Part of
    You, Washington State Bar News (Jun. 1997).
    Anthony P. Capozzi, Responding to the Pro Per Crisis, California Bar Journal (Feb 2004).
    Alicia M. Farley, An Important Piece of the Bundle: How Limited Appearances Can Provide an Ethically Sound
    Way to Increase Access to Justice for Pro Se Litigants, The Georgetown Journal of Legal Ethics, Vol. 20, No. 3
    (Summer 2007).
    Kim Prochnau, Slicing the Onion: Rules of Professional Conduct and Court Rules Make It Easier for Private and
    Non-Profit Legal Practitioners to Provide "Unbundled" Legal Services, Washington State Bar News (Apr. 2003).
    Bradley A. Vauter, Unbundling: Filling the Gap, Michigan Bar Journal, Vol. 79, at 1688 (2000).
    Books and Reports
    000856
    Caught in the Middle: 2003 Report and Recommendations of the North Carolina Bar Association Pro Se Task
    Force (Dec. 2003).
    Challenge to Justice: A Report on Self-Represented Litigants in the New Hampshire Courts, New Hampshire
    Supreme Court Task Force on Self-Representation (Jan. 2004).
    Ethics Issues Regarding the Concept of Unbundled Legal Services (Memorandum), Rob Bare, Nevada State Bar
    (Mar. 31, 1999).
    Family Law Limited Representation Risk Management Materials, Limited Representation Committee, California
    Commission on Access to Justice (January 12, 2004).
    Handbook on Limited Scope Legal Assistance, ABA Section of Litigation (2003).
    Pro Se Litigants: The Challenge of the Future, Massachusetts Probate and Family Court Department Pro Se
    Committee Report (Dec. 1999).
    Report and Recommendations on "Unbundled" Legal Services, Commission on Providing Access to Legal
    Services for Middle Income Consumers, New York State Bar Association (Dec. 2002).
    Report of the Unbundled Legal Services Special Committee II, Florida Bar Association (Jul. 26, 2002).
    Report on Limited Scope Legal Assistance with Initial Recommendations, Limited Representation Committee of
    the California Commission on Access to Justice (Oct. 2001). Appendix
    Self Represented Litigants in the Virginia Court System, Supreme Court of Virginia Pro Se Litigation Planning
    Committee, Enhancing Access to Justice Report (Sept. 2002).
    Unbundling Legal Services: A Guide to Delivering Legal Services a la Carte, Forrest S. Mosten, American Bar
    Association (2000).
    Cases
    Melvin Finance, Inc. v. Artis, 157 N.C. App. 716, 2003 WL 21153426 (N.C.App.)
    Defendant retained an attorney on a limited basis, following an action filed by the plaintiff to recover costs on a
    defaulted loan. Limited representation attorney agreed to file responsive pleadings and negotiate a settlement
    agreement, and filed a notice of limited appearance. While the defendant received notice of a scheduled hearing
    and forwarded it to his limited representation attorney, neither defendant nor attorney appeared at the hearing and,
    consequently, an arbitration award was entered for the plaintiff. Defendant filed a motion to set aside judgment,
    which was denied. On appeal, the defendant claimed the limited representation attorneys failure to appear at
    the hearing amounted to excusable neglect and that the judgment should be set aside. The court found that since
    the defendant received notice of the hearing and had retained the attorney on a limited basis, that the limited
    representation attorneys conduct did not constitute excusable neglect. The lower court decision was affirmed.
    Johnson v. Board of County Comm'rs, 868 F.Supp. 1226 (D. Colo. 1994)
    Former sheriff department workers bring sexual harassment suit against county sheriff in his individual and official
    capacities. Attorney representing sheriff enters limited appearance on behalf of his official capacity. Court finds
    that attorney cannot enter limited appearance on behalf of sheriff's official capacity. Attorney representing sheriff
    must act for the entire person, including individual and official capacities. Entering such limited appearance is not
    competent and zealous representation as required by ethical rules as it leaves officer undefended on individual
    capacity claims. Court further finds that ghostwriting of documents for pro se litigants may subject lawyers to
    contempt of court. Ghostwriting gives litigants unfair advantage in that pro se pleadings are construed liberally
    and pro se litigants are granted greater latitude in hearings and trials. Ghostwriting also results in evasion of
    obligations imposed on attorneys by statute, code, and rule, and involves lawyers in litigants' misrepresentation of
    pro se status in violation of ethical rules.
    Ricotta v. California, 4 F.Supp.2d 961 (S.D. Cal. 1998)
    Attorney licensed in the State of California did not violate procedural, substantive, and professional rules of a
    federal court by lending some assistance to friends, family members, and others with whom she shared specialized
    knowledge. Attorney performed research and prepared rough drafts of portions of pro se litigant's pleadings in an
    action against various official defendants, but did not sign the documents. Because attorney did not gather and
    anonymously present legal arguments with the actual or constructive knowledge that plaintiff would use them in
    court, and because attorney did not engage in extensive, undisclosed participation that permitted plaintiff to falsely
    appear as being without professional assistance, attorney had not violated any rules.
    Sharp v. Sharp, 2006 WL 3088067 (Va.Cir.Court)
    000857
    Complainant and respondent were co-tenants of real estate property. The respondent appeared pro se during a
    hearing before the commissioner in chancery, but then hired an attorney who appeared in a limited capacity at
    several other hearings. On appeal, the court sought to determine whether or not the attorney could appear in a
    limited capacity and whether the attorneys appearance qualified him as official "attorney of record". The court
    found that it was not bound by agreements made between client and attorney and that a court may "require more of
    an attorney than mere compliance with the ethical constraints of the Rules of Professional Conduct". The court
    found that the attorney could make a motion to withdraw once he completed the tasks agreed upon, but that the
    court had ultimate discretion in granting the withdrawal.
    Streit v. Covington & Crowe, 82 Cal.App. 4th 441 (2000)
    In a lawsuit, plaintiffs counsel of record requested that another firm make a "special appearance" at a summary
    judgment motion, appearing on behalf of counsel of record. Plaintiff filed a legal malpractice suit after a summary
    judgment was entered against her, arguing that the special appearance created an attorney-client relationship. The
    appellate court found that an attorney making a special appearance represents the clients interests and has a
    professional attorney-client relationship with the client. Further, the voluntary appearance created a limited
    representation status and not a true "special appearance".
    Court Rules
    Alaska
    Alaska Rule of Civil Procedure 81, expressly permits limited appearances and governs attorney withdrawal.
    Arizona
    Arizona Rules of Family Law Procedure 9(B), governs limited representation and attorney withdrawal in family
    law proceedings.
    Arizona Rules of Civil Procedure 5.2, governs limited representation and attorney withdrawal in vulnerable adult
    exploitation actions. California
    California Family and Juvenile Rules 5.71, governs application to be relieved as counsel.
    California Civil Rule 3.36, governs notice and application to be relieved as attorney.
    Colorado
    Colorado Rule of County Court 311(b), requires lawyers to disclose assistance in document preparation but
    clarifies that such disclosure does not create an entry of appearance.
    Delaware
    Delaware Family Court Rule of Civil Procedure 5(b)(2), governs limited appearance, service and attorney
    withdrawal in family law matters.
    Florida
    Florida Family Law Rules of Procedure, Rule 12.040, governs Limited Appearance, Withdrawal or Limiting
    Appearance, Scope of Representation, Preparation of Pleadings or Other Documents, Notice of Limited
    Appearance, and Service.
    Florida Family Law Rules of Procedure 12.750, governs the operation of self-help programs within family courts.
    Iowa
    Iowa Rules of Civil Procedure enabling unbundled services include:
    RCP 1.404(3), expressly permitting limited appearances so long as the court is notified;
    RCP 1.404(4), governing termination of limited appearance;
    RCP 1.423, requiring lawyers who prepare pleadings in limited representation to sign them and clarifying
    that signing a pleading does not constitute an appearance;
    RCP 1.442(2), establishing the requirements for service on attorney who has made a limited appearance.
    Maine
    Maine Rule of Professional Conduct 1.2(c), explicitly allows limited representation and allows a lawyer to file a
    limited appearance if the client consents in writing.
    Maine Rule of Civil Procedure 11 governs limited appearances.
    Missouri
    Missouri Rules of Professional Conduct 1.16 (c), governs attorney withdrawal for limited representation.
    000858
    Missouri Rules of Civil Procedure 55.03, permits a lawyer to draft pleadings without disclosure and clarifies
    appearance and withdrawal of attorney in limited representation.
    Nebraska
    Nebraska RPC 501.2, governs limited representation, attorney assisted document preparation and attorney
    withdrawal.
    Nevada
    Rules of Practice of the Eighth Judicial District Court of the State of Nevada, Rule 5.28 requires signed pleadings,
    notice of the limited representation to the court and governs the procedure for withdrawal.
    New Hampshire
    New Hampshire Rules of Civil Procedure enabling unbundled services include:
    RCP 3, requiring that pleadings and communication be furnished to both client and limited representation
    attorney until withdrawal of limited appearance;
    RCP 17, governing appearance, attorney withdrawal and document preparation assistance.
    New Mexico
    New Mexico Rules of Professional Conduct 16-303(E), requires lawyer to disclose scope of representation to
    court.
    Utah
    Utah Rules of Civil Procedure 74(b), governs attorney withdrawal following limited appearance.
    Utah Rules of Civil Procedure 75, expressly permits limited appearances after client consents in writing.
    Vermont
    Vermont Rules of Civil Procedure 79.1(1), governs appearance, withdrawal and service.
    Vermont Rule of Family Procedure 15(h) governs limited appearances, withdrawal and service in family law
    matters.
    Washington
    Washington Civil Rule 4.2, expressly permits a limited entry of appearance.
    Washington Civil Rule of Limited Jurisdiction 4.2, governs limited appearances.
    Washington Civil Rule 11, permits a lawyer who assists with drafting to rely on the self-represented party's
    representation of facts.
    Washington Civil Rule of Limited Jurisdiction 11, permits a lawyer who assists with drafting to rely on the self-
    represented party's representation of facts.
    Washington Civil Rule 70.1, expressly allows limited appearances in litigation.
    Washington Civil Rule of Limited Jurisdiction 70.1, expressly allowing limited appearances in litigation.
    Wisconsin
    Milwaukee County Family Division Rule 5.6 expressly permits limited appearances.
    Wyoming
    The Uniform Rules of the District Court of the State of Wyoming, Rule 102 governs appearance and withdrawal for
    unbundled representation.
    Ethics Opinions
    Los Angeles Cnty Bar Ass'n Prof. Resp. and Ethics Comm. Ethics Op. 483
    An attorney may limit the attorney's services by agreement with a pro per litigant to consultation on procedures
    and preparation of pleadings to be filed by the client pro per. A litigant may be either self-represented or
    represented by counsel, but not both at once, unless approved by the court. In order for attorney to specially appear
    on behalf of the litigant before the court for a limited purpose, the attorney should comply with all applicable court
    rules and procedures of the particular tribunal.
    Delaware State Bar Assn Op 2006-1
    A lawyer may be required to perform beyond the term of a limited scope representation agreement if the Court
    requested, or the Clients circumstance warranted such action. In most circumstances, an agreement to
    withdraw from representation would not violate any ethics requirement, as long as the lawyer provides adequate
    advice to Client concerning the scope of representation. In family court, the Courts permission may be needed
    000859
    to withdraw from simple divorce petitions in certain circumstances.
    D.C. Bar Op. 330 (2005)
    Unbundling of legal services is permissible under D.C. Rule 1.2 ( c ), provided the client is fully informed of the
    limits on the scope of the representation and these limits do not prevent the provision of competent service. If a
    party is proceeding pro se, opposing counsel should treat that party as unrepresented unless and until that counsel
    receives reasonable notice of representation from the party or her lawyer.
    Illinois State Bar Ass'n Prof. Conduct Comm. Op. 849 (1983; Affirmed 1991)
    An attorney may agree in advance with his or her client to limit the scope of the attorney's representation and draft
    pleadings without appearing or taking any part in any of the proceeding itself, provided that the client gives his or
    her fully informed consent to such limitation of employment and the attorney takes whatever steps may be
    necessary to avoid foreseeable prejudice to the client's rights.
    Maine State Bar Ethics Opinion No. 89 (1988)
    A lawyer is not required to sign a complaint or enter an appearance as counsel of record when representation is
    solely limited to preparation of the complaint.
    Missouri Bar Ass'n Advisory Op. 940161
    It is impermissible for a lawyer to draft responsive pleadings to an unrepresented opposing party in a divorce.
    However, a lawyer may draft an entry of appearance if the lawyer includes a letter indicated that he or she
    represents the opposing party and that the unrepresented party should obtain counsel.
    New York State Bar Ass'n Op. 613 (1990)
    A lawyer who does not appear as counsel of record for a pro se litigant may prepare responsive pleadings and
    demands for financial disclosure, provided the lawyer investigates the matter adequately.
    North Carolina State Bar RPC 114 (1991)
    Legal services attorneys may provide legal advice and drafting assistance to pro se litigants without appearing as
    counsel of record. If court approved pleading forms exist, attorneys may make them available to individuals
    wishing to proceed pro se.
    Bd. of Prof. Resp. of the Sup. Ct. of Tenn. Op. 2005-F-151
    Attorneys may offer limited representation through a pro se clinic if they obtain clients consent, preferably in
    writing. Attorneys may draft proceedings for clients, if the attorney notifies the Court that counsel has assisted a
    pro se litigant. The phrase "Prepared with Assistance of Counsel" is recommended for inclusion on such pleadings
    in a prominent manner. Attorneys who draft proceedings need not appear and represent the client.
    Utah State Bar Ethics Advisory Op. Comm. Op. 08-01 (2008)
    A lawyer may provide legal assistance to litigants appearing before tribunals pro se and help them prepare written
    submissions without disclosing or ensuring the disclosure to others of the nature or extent of such assistance.
    Undertaking to provide limited legal help does not generally alter any other aspect of the attorneys professional
    responsibilities to the client.
    As to the ghostwriting, its tough, because, for clients who want to pay very little (after, say, in Gessin's case he
    paid McKenna allegedly $15K to wind up with an Order from an Arbitrator and District Court Judge denying a
    Trial De Novo based upon a bad faith failure to participate in litigation in one case, then in the other, Gessin paid
    Hill something like $20K only to be slammed car crash style into settlement by Hill's advice when Gessin couldn't
    stomach paying anymore of HIll's fees, settling for the amount originally sought by Mr. Hall's client). So, clients
    like that want a deal, want to pay piece meal or go the unbundled route, but filing all those Motions to Withdraw,
    and Proposed Orders, and Affidavits, add to the costs where the fee is not really being increased any. There is
    much literature dealing with this:

    Please accept this as a supplement to the grievance filed by Richard Hill, Esq. My recollection of my
    involvement with Gessin is that I filed two Answers to very similar Adversary Complaints in NVB and two
    Motions to Dismiss in those same cases, involving the two women represented by Glade Hall, Esq., both on an
    "unbundled services" basis, and the pleadings themselves indicated the were filed as an "unbundled service".
    This was my first filign in NVB, and I was not registered or trained as an electronic filer at that point. Further,
    Gessin hired me to provide other unbundled services, inlcuding writing (and, to my understanding at the time,
    000860
    filing under my own signature) something in the vein of a NRCP Rule 60(b) Motion for Relief from Judgment
    from judgments in cases involving the same two women Taitano ne Moore, and Rissone, both, again, represented
    by Glade Hall, Esq.

    It may be the case that Richard Hill is correct that I was goign against some rule or law by sending one demand
    letter to Glade Hall concerning an outstanding $500 sanction aware. I believe I drafted an Order To Show
    Cause for this, but am not sure it was filed by me. About the time I provided Gessin my signed final draft of
    that and a few other closely related motions, he pretty much wanted to part ways, I believe. I think this was
    around mid-November and there was some issues with Richard HIll withholding my client files, some of which
    may have included Gessin's, then Hill would say he would give me my client files without any demands or lien
    needing satisfying prior to doing so, and that he would do the same with my wallet and identification, but then he
    would change his mind and demand what to me seems that I satisfy a rent distraint that has been outlawed by NRS
    118A.520 (though there is a very old BK case, circa 1980 or so that may suggest such distraints are still
    permissible against commercial tenants, and my hybrid, home law office situation, plus the fact that I do still have
    a business license for Zachary Coughlin's Memory Foam Mattresses (something I started during the 4 years I was
    hoping to get a law license and finding employment very, very difficult to obtain, during which Mike Rowe wrote
    me stern letters, Pete Christiansen and Mike Sanft -ignored me and shewed me to their legal assistant Kelly Huff,
    and Director of Admissions Patrice Eichmann made the unilateral decision to ignore the Request for
    Reconsideration of my Application for Admission that I timely submitted on 9 15 03 in connection with the end of
    the deferment period set forth in the Court's December 2002 Order....) and at least some research and development
    was ongoing in that regard. Whether I was a commercial or residential tenant was an important issue in the
    eviction matter and the mixed use of the property likely only made the statute all the more difficult to interpret.

    However, I do recall that Gessin told me he withdrew his bankruptcy, so that may negate Hill's assertion that I was
    wrongful in sending a demand letter to Hall regarding the old sanction and or filing a Motion for Order To Show
    Cause. Gessin is a crafty guy, though I am not sure I entirely share Hill's view of him. However, Hill
    apparently received about $20-25K in attorney's fees from Gessin in a case that the plaintiff was only seeking
    about $25K in to begin with, and upon Gessin ceasing to be willing to pay Hill and Baker for more litigating, they
    promptly suggested he settle for something near $30K (which, of course, was upsetting to Gessin, in a manner that
    is similar to how Dr. Merliss seems to feel in the eviction matter). But, to be fair to Hill, those parties likely
    bare some responsibility for choosing to take the risky path that is litigation.

    Gessin also became a registered efiler about the time he basically terminated my representation of him. My
    email to Gessin below shows that I was somewhat suspicious of the fact that he seemed to all the sudden want to
    go our separate ways after I had been working on these very involved (to me at the time they seemed really
    involved) NRCP 60(b) Motions, and it is ironic, somewhat that Hill accuses me of ghostwriting because my email
    to Gessin essentially anticipates that, and, to some extent, my later filing Notices of Appearance as Attorney of
    Record in several of Gessin's various cases involving these two women was done to attempt to counteract any
    appearance of that. Gessin seemed upset that I filed those appearances, and actually got very pushy about me
    trying to undo them, and eager to avoid prejudicing his ability to file timely 60(b) motions, I undertook to do what
    I could to make it so he could file on his own (ie, having an Attorney of Record on one's case often results in the
    filing office refusing to let them file anything on their own...).

    On Wed, Dec 7, 2011 I wrote to John Gessin's email address the following:

    "To: John Gessin <jd.gman@yahoo.com>


    John,
    Here is Van Lydegraf's voice message. Again, I have not talked to him and I forwarded you the only email or writing I ever sent
    him. I am leaning towards filing an Errata on your cases today to get it so I am not attorney of record. Which do you prefer? I am
    not sure which would accomplish your goals quicker, but keep in mind, I believe a Motion to Withdraw is the typical thing, not a Notice
    of Withdrawal? Have you found any research in this regard? Please indicate in writing which you prefer or the preferred manner
    you would like to see me pursue accomplishing your goals, which, to my understanding, include being in pro per on this case. I sense
    you are uncomfortable, but please know I maintain extremely high fidelity to my clients, unbundled or otherwise, okay? I am unsure
    000861
    how me filing the 60b's etc would have been much different with respect to what you seem upset about...did you never intend for me to
    file? Were you looking for a "ghost writer"? I was not of the understanding that I was being hired as a "ghostwriter" and I do recall
    some indication that such a thing is either prohibited or discouraged by the Rules of Professional Responsibility....Regardless, the most
    important thing is to avoid prejudicing your case, and I feel I have made great efforts to achieve that. If you want to file something,
    just do it, don't wait for any withdrawal, etc. I will make all reasonable efforts to see that you are allowed to file whenever and
    whatever you want, and not be weighed down by any attorney of record designation.
    Sincerely,"
    I currently have a Motion to Withdraw pending in the two Adversary Proceedings where I believe I was incorrectly listed as Attorney of
    Record for Gessin.
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    --Forwarded Message Attachment--
    Print Close
    copying you to avoid any ex parte accusations
    From:Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 1/13/12 7:41 AM
    rhill@richardhillaw.com; cdbaker@richardhillaw.com; sgallagher@richardhillaw.com;
    To:
    knielsen@richardhillaw.com; shill@richardhillaw.com
    1 attachment
    SUPPLEMENTAL REPLY TO OPPOSITION CV08-01709 1 13 12.pdf (162.9 KB)
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may
    contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to
    the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and
    000862
    Print Close
    supplement to Richard Hill thing
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/16/12 3:14 PM
    To: glennm@nvbar.org; davidc@nvbar.org; patrickk@nvbar.org
    15 attachments
    final motion to dismiss 11 cr 26405 3 3 12.pdf (698.4 KB) , hill is lying about thinking I accidentally
    filed the wrong thing in carpentier case.pdf (45.4 KB) , 3 16 12 fax to wcso re eviction park terrace
    hill etc.pdf (1761.7 KB) , CV11-03628-2633891 (Reply...).pdf (164.9 KB) , CV11-03628-2625640
    (Mtn for TRO).pdf (153.5 KB) , 6.4.10 letter to Hall from Casey Baker describing same things
    Richard HIll does.pdf (57.1 KB) , CR11-2064-2676094 (Exhibit 2).pdf (130.1 KB) , CR11-2064-
    2676094 (Opposition to Mtn ...).pdf (171.6 KB) , CR11-2064-2682479 (Supplemental ...).pdf (153.7
    KB) , from nv supreme court website on eviction stay packet instructions.pdf (28.0 KB) , Eviction
    Procedure - Washoe County Sheriff's Office - 911 Parr Blvd, Reno, Nevada.pdf (80.9 KB) , CV11-
    03628_2750229 Machem up to his old tricks again.pdf (26.9 KB) , What Every Civil Litigator Needs
    to Know About Criminal Law.pdf (122.8 KB) , 3 7 12 11 TR 26800 rmc NOTICE OF APPEALS
    ETC MOTION.pdf (1301.3 KB) , JOHN TARTER TransparentNevada year city failed to report.pdf
    (25.7 KB)
    Dear Bar Counsel,

    Material in this supplement also serves to fulfill my own RPC 8.3 duty with respect to the
    misconduct of any other attorney's (or those who are licensed as attorneys but maybe are employed in
    some alternate capacity currently) whose conduct in these materials is so deserving. I will try to
    phone into Mr. King as he requested, though Judge Nash Holmes recently converted my phones to
    the Reno Municipal Court after they were booked into property at the Washoe County Jail, who
    thereafter made several contradictory statements as to whether the City of Reno Marshals came and
    took those and other items out of secured property or evidence and did what they may or whether
    such materials remained with the Jail and or whether the Jail actually even considers whether there
    might be a conflict of interest in releasing such property to these Marshals or the RMC. One thing
    I do know is that I did not offer those materials into evidence and am not sure Judge Nash Holmes
    should be doing so on my behalf, or on behalf of the prosecutor. When I say prosecutor, I should
    clarify, I mean Deputy City Attorney Ormaas, and not Judge Holmes.

    I have other materials I will be providing to supplement this and other grievances in short order.

    Sincerely,

    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000863
    Print Close
    more on the way
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/16/12 2:59 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    5 attachments
    hill is lying about thinking I accidentally filed the wrong thing in carpentier case.pdf (45.4 KB) ,
    CV11-03628-2633891 (Reply...).pdf (164.9 KB) , CV11-03628-2625640 (Mtn for TRO).pdf (153.5
    KB) , CR11-2064-2676094 (Opposition to Mtn ...).pdf (171.6 KB) , CR11-2064-2682479
    (Supplemental ...).pdf (153.7 KB)
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000864
    Print Close
    Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/16/12 1:48 PM
    To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
    Dear Bar Counsel,
    I write respectfully asking an inquiry be conducted into whether Kevin Kelly indicated
    at my June 2002 hearing that 3 pro bono attorney's name would be provided to me, but
    that only one was, Peter S. Christiansen, and that, despite Christiansen saying he was
    doing my case on a pro bono basis, he was paid at least $5,000, and pretty much the
    only work he or his office did was attend the June 2002 hearing, and that Christiansen
    and Kelly are very, very close, and that they sent me to a psychologist who specializes
    in gambling addictions (I have never really even gambled) who cost approximately
    another $2,000....Then Ms. Eichman failed to submit my application for admission or
    my Request For Reconsideration (sent to her and Christiansen's office on September
    15th, 2003, as confirmed by my fax records, in additional to being mailed to them) to
    the Nevada Supreme Court. There are numerous other issues that deserve a grievance
    there, including whether Christiansen supervised the newly licensed Sanft in any way,
    whether a writing wherein I addressed alcoholism was forward to the Bar despite the
    express dictate that it not be, whether second Consent Agreement sent to the
    Christiasens on 9/27/04 was ever forwarded to the Bar. Additionally, Mike Rowe
    wrote very stern letters to me basically telling me not to follow up on things, whereupon
    my attorney's and Ms. Eichman failed to follow up on things, essentially tying my hands
    in the matter. I intend to supplement this grievance with additional matters soon, but
    wish it to begin now.
    Sincerely,
    Zach Coughlin
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000865
    Print Close
    RE: Contact
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/16/12 1:39 PM
    To: patrickk@nvbar.org; clarkd@nvbar.org; glennm@nvbar.org
    1 attachment
    THE 2 11 12 email to WCSO RPD Reno City Attorney Hill NPUC Hill et al b.pdf (137.8 KB)
    Mr. King,
    I have not sent you my Reply to the Grievance. You gave me until today, and I am finishing it up.
    Additionally, I was subject to what I believe is a wrongful eviction yesterday, and would like
    additionaly time to respond to Richard HIll's grievance, which he appears to be filing on behalf of
    various third parties, and his associate, who doesn't bother to sign it. Basically, Mr. HIll constantly
    seeks to leverage courts, police, and now, Bar Counsel, to further his nefarious approach to litigation,
    rather than roll up his sleeves and find some law in favor of his positions and apply actual facts to
    them, rather than make up things or quote to third parties and other hearsay (I never made contact
    with or touched Mr. Hill, I never climbed on anyone's truck, Mr. Hill is not a licensed mental health
    professional, yet he sounds like a walking DSM-IV when he writes of me). I will submit something
    to you today in response to Hill's grievance, with the caveat that I am requesting more time, in part
    due to the fact that the Washoe County Sheriff's Deputies have just yesterday, minutes before my
    hearing in Judge Beesley's courtroom, unlawfully stormed into my location at 1422 E. 9th St, #2,
    with guns drawn and pointed at me, without previously identifying themselves as law enforcement in
    any way, and demanding I grab a few things in a couple minutes and leave. This unlawful eviction
    was pursuant to an eviction hearing held that morning by Reno Justice Court Judge Jack Shroeder,
    the same Judge who screamed at me "do you want to go to jail" when I attempted to address in any
    way whatsoever Richard Hill's abuse of process in getting a Order of Protection from Judge
    Schroeder in a scant 40 minutes, and having me arrested on 1/12/12 (two days before Hill's grievance
    was sent to you), at the extension hearing on January 31, 2012, where Hill admitted he didn't have a
    good reason for seeking an extension and withdrew his application. I wanted to address Hill's abuse
    of process for the record, Judge Schroeder decided to scream at me instead. It was reminscent of
    Judge Nash Holmes telling me, on the record, in Reno Municipal Court case 11 TR 26800 that she
    would have me arrested and placed in jail if I said Richard G. Hill's name one more time. I cross
    examined RPD Sargent Tarter about whether he had a retaliatory motive in ticketing me outside Hill's
    office on 11/15/11 after Hill refused to give me my driver's license, and I reported to Sargent Tarter
    that RPD Officer Chris Carter had admitted to taking bribes from Richard Hill.
    Actually, there is some footage of the "terror" Richard G. Hill was exposed to that necessitated him
    seeking a Protection Order (the "RPD made him" do it, honest): http://www.youtube.com/watch?
    v=gBu9zflGALE
    I don't know why Sargent Sifre (whom makes more money than a District Court Judge) should be so
    upset with lawyers like me, who work in the foresclosure defense field (you might see if Geof Giles,
    000866
    Esq. thinks I am quite the "Yosemite Sam" caricature of a cartoon villian that Richard G. Hill paints
    me to be, or if Thomas J. Hall thinks that much of Rich and his "tactics", which are like those of a
    malignant frat boys armed with daddy's pleadings). After all, Sargent Sifre has benefitted from
    foresclosure defense work: http://stopforeclosurefraud.com/2011/01/29/nevada-dist-court-quiet-title-
    viable-sifre-v-wells-fargo-bank/
    Regardless, I have not "ghostwritten" any pleadings for Mr. Gessin or anybody else. I am listed as
    attorney of record on adversary proceedings for Gessin, though the only things I ever filed for him
    clearly indicated that I was not appearing as attorney of record and that the Answers to the
    Complaints in those two adversary proceedings were being submitted on an "unbundled services"
    arrangement. The bankruptcy court nonetheless listed me as attorney of record and I have been and
    am in the process of having that changed. I have communicated with clerk Holly Estes and filing
    office supervisore Debbie Gallagher in those regards.
    I need more time to research and investigate the other allegations Hill makes, though I do not wish
    you to infer and admission on my part to any allegation by Hill.
    I have researched this service of eviction Order issues extensively, it relates to the Hill matter, and I
    believe the WCSO and Hill are not following the law.
    I am not sure why you wrote what you did at 9:09 am this morning considering you granted me until
    3:00pm today to file my response, which I intend to along with a request for more time to
    supplement it:
    From:Patrick King (PatrickK@nvbar.org)
    Sent: Mon 3/12/12 9:15 AM
    To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
    Cc: David Clark (DavidC@nvbar.org); Glenn Machado (GlennM@nvbar.org)
    March 12, 2012
    To: Zach Coughlin
    Dear Mr. Coughlin,
    I am in receipt of your e-mail below, requesting additional time to respond. Please be advised that your response to the
    grievance, including the e-mail letter below, become part of the record and may eventually be reviewed by a disciplinary
    panel. With that said, it is important that we receive your response. Pursuant to your request, you are granted until
    Friday, March 16, 2012 by 3:00pm to deliver your written response to the State Bar Office in Reno.
    000867
    Thank you for your cooperation.
    Patrick King, Assistant Bar Counsel
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Friday, March 09, 2012 5:45 PM
    To: Patrick King; Glenn Machado; David Clark
    Subject: response to grievance from NV Attorney
    Zach Coughlin, Esq.
    Nevada Bar No: 9473
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    775 328 6045 fax: 949 667 7402
    ZachCoughlin@hotmail.com
    State Bar of Nevada
    P.O. Box 50
    Las Vegas, NV 89125-0050
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    sent by fax and email only to:
    Reno Office: 775 329 0522
    Las Vegas Office: 702 385 2878
    DavidC@nvbar.com, PatrickK@nvbar.com, GlennM@nvbar.com
    000868
    March 9, 2012,
    Dear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
    I only just now received the letter, dated February 14th, 2012 that Assistant Bar Counsel King sent me, wherein the
    grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please respond in writing to this grievance within ten
    (10) days from the date of this letter."
    I am requesting an extension of time to respond to this matter. I literally just received this mailing from you within the
    last hour, and was unaware of this prior to that. Further, I hope I can demonstrate to you and the State Bar of Nevada
    that circumstances at least somewhat beyond my control have prevented me from receiving my mail in an orderly and
    consistent fashion. These circumstances resulted in two different Domestic Violence Protection Orders being granted to
    me against my former housemates by Master Edmondson of the Second Judicial District Court in FV12-00188 and FV12-
    00187. Further, the electricity to my location was interrupted from one week (though I attempted to get NV Energy to
    accept payment from me for services) from February 3rd to February 20th, 2012, incident to one of the individuals
    against whom a protection order was issued attempting to prevent me from obtaining electrical service. Additionally, the
    same individuals against whom these protection orders were issued interfered with my access to my mail from the USPS,
    and it has taken some time to get the USPS Postal Inspectors to release my mail to me and or allow me to receive mail at
    my location.
    Please note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn Machado a written request
    that the State Bar of Nevada please help me in remaining aware of any correspondence being sent me from the State Bar
    while I work to get my mailbox situation settled (please see below):
    On February 22nd, 2012 I wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that "I had to move recently and
    moved in with two individuals who I ultimately wound up getting Protection Orders against, and they have interfered
    with my ability to receive my mail with absolute certainty (I have received much of my mail, and have pending
    correspondences/requests with the Postmaster for Reno, NV to obtain a permanent and newly rekeyed lock and key to
    access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister that if I fax him proof of my
    location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call him again
    tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an
    electronic filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any
    correspondences/notices etc. that you or the State Bar of Nevada may have for me or may have mailed to me be, if
    possible, copied to me via my fax number or email address."
    I feel strongly that Mr. Hill's allegations are ones I will wish to contest vigorously, and I hope I am afforded an opportunity
    to do so. There is a lot more to this situation than Mr. Hill indicates.
    000869
    Sincerely,
    Zach Coughlin"
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
    No: 9473
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: lstuchell@washoecounty.us; mkandaras@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov;
    cdbaker@richardhillaw.com; jboles@callatg.com; bbuckley@lacsn.org; daolshan@yahoo.com;
    jsoderlund@nlslaw.net; jdelikanakis@swlaw.com; jgoodnight@washoecounty.us;
    jbosler@washoecounty.us; bdogan@washoecounty.us; mechols@maclaw.com; mclarkson@puc.nv.gov
    Subject: Evictions RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Date: Fri, 10 Feb 2012 12:14:01 -0800
    Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Date: Tue, 7 Feb 2012 11:40:39 -0800
    From: LStuchell@washoecounty.us
    To: zachcoughlin@hotmail.com
    CC: mkandaras@da.washoecounty.us
    Mr. Coughlin
    000870
    Our records indicate that the eviction conducted on that day was personally served by Deputy Machen
    by posting a copy of the Order to the residence. The residence was unoccupied at the time.
    Liz Stuchell, Supervisor
    WCSO Civil Section
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, February 06, 2012 2:58 AM
    To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov;
    fourthestate@gmail.com; jamesandreboles@msn.com
    Subject: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Dear IA Supervisor Stuchell and DDA Kandaras,
    I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
    confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order on
    me at 121 River Rock St., Reno 89501 on November 1, 2011 at 4:30 pm, in connection with
    performing the lockout. It is my position that I was not "personally served" and I am trying to figure
    out whether Deputy Machem is lying or whether the phrase "personally served" means something
    other than what I believe it means, etc., etc. I appreciate your attention to this.
    I am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
    WCSO Deputy Machem with respect to the service of a Order Granting Summary Eviction against
    me (in my law office where non-payment of rent was not alleged, no less in violation of NRS 40.253
    and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6), especially
    where a stay of eviction was not granted even while the RJC held on to most all my money...).
    My issue with the WCSO is that Machem's Affidavit of Service indicates that he "personally served"
    me, which kind of reminds me of all that robo-signing and MERS fraud I come across in my day job
    (and do you wonder how many attorneys in the foreclosure defense game I am in constant contact
    with who are watching and witness the potential RICO violations this writing mentions?), which
    includes being a foreclosure defense attorney. So which is it? Did Machem "personally serve" me the
    Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was "served" in compliance with
    all time related rules because it was done in the "usual custom and practice of the WCSO. What,
    exactly, is the "usual custom and practice of the WCSO? I hear a lot about this "within 24 hours"
    000871
    stuff. So, I go hunting for some black letter law to support what those at the RJC and in the clueless
    community at large (which often includes Nevada Legal Services and Washoe Legal Services, the
    people you guys had such trouble actually serving in the lawsuits I filed, which may have actually
    helped improved legal services in this community, if they were not dismissed due to insufficiency of
    service of process, even where the IFP required the WCSO to served the defendants....). Anyway,
    back to the "within 24 hours" phraseology: "
    This whole business about The court may thereupon issue an order directing the sheriff or constable
    of the county to remove the tenant within 24 hours after receipt of the order... is inapplicable to this
    situation, where an Order Granting Summary Eviction was signed by October 27th, 2011. That
    language is only found in situations inapplicable to the current one. NRS 40.253(3)(b)(2), and NRS
    40.253(5)(a) are the only sections of NRS 40 where this within 24 hours language occurs, and
    those situations only apply where, in:
    40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
    (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue a
    summary order for removal of the tenant or an order providing for the nonadmittance of the tenant,
    directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of
    the order
    and,
    40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords agent may
    apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
    apartment, mobile home or commercial premises are located or to the district court of the county in
    which the dwelling, apartment, mobile home or commercial premises are located, whichever has
    jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or constable
    of the county to remove the tenant within 24 hours after receipt of the order. The way these
    summary eviction proceedings are being carried out in Reno Justice Court presently shocks the
    conscience and violates Nevada law. There is not basis for effectuating a lockout the way WCSO's
    Deputy Machem did in this case. The above two sections containing the within 24 hours of receipt
    language are inapplicable, as those situations do not invoke the present circumstances, where the
    Tenant did file an Affidavit and did contest this matter to a degree not often seen. To require
    Nevada's tenants to get up and get out within 24 hours of receipt of the order (what does that
    even mean? The use of terms like rendition, rendered, notice of entry, pronounced, is absent
    here, and this receipt of the order language is something rarely found elsewhere in Nevada law-see
    attached DMV statutory citations, and in employment law litigations where one must file a Complaint
    within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b), and
    NRCP 6(e) in imputing receipt of such a letter, when actual receipt is not shown, by applying a
    constructive notice standard that relies upon the days for mailing extension of time for items served
    in the mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir.
    2009), the record did not reflect when the plaintiff received his right-to-sue letter. The letter was
    issued on November 24, 2006. The court calculated that the 90-day period commenced on November
    30, 2006, based on three days for mailing after excluding Saturdays and Sundays. In order to bring a
    claim under either Title VII or the ADA, a plaintiff must exhaust administrative remedies and sue
    within 90 days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin County
    Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)(granting
    000872
    plaintiff an additional three days for mailing pursuant to Rule 6).... ...
    Dear Washoe County Sheriff's Office,
    http://en.wikipedia.org/wiki/Service_of_process
    "Substituted service
    When an individual party to be served is unavailable for personal service, many jurisdictions allow
    for substituted service. Substituted service allows the process server to leave service documents with
    another responsible individual, called a person of suitable age and discretion, such as a cohabiting
    adult or a teenager. Under the Federal Rules, substituted service may only be made at the abode or
    dwelling of the defendant.[4] California, New York,[5] Illinois, and many other United States
    jurisdictions require that in addition to substituted service, the documents be mailed to the
    recipient.[5] Substituted service often requires a serving party show that ordinary service is
    impracticable, that due diligence has been made to attempt to make personal service by delivery, and
    that substituted service will reach the party and effect notice.[5]"
    I am pretty sure "personally served" means you served the person in person, not that a person named
    Machem went and posted a notice on a door, personally himself. See, I think you guys are thinking
    of the "person" in the word personally as applying to the server, when in all instances I have ever
    seen it used in the law, the "person" part of "personally" applies to the person being served. Help me
    out here, Mary.
    https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1897&parid=root
    Also, does the WCSO have a position on what type of service is required of eviction orders prior to
    the WCSO or whoever does it, being able to conduct a lockout?
    http://www.leg.state.nv.us/courtrules/nrcp.html
    NRCP RULE 60. RELIEF FROM JUDGMENT OR ORDER... (c) Default Judgments: Defendant
    000873
    Not Personally Served. When a default judgment shall have been taken against any party who was not
    personally served with summons and complaint, either in the State of Nevada or in any other
    jurisdiction, and who has not entered a general appearance in the action, the court, after notice to the
    adverse party, upon motion made within 6 months after the date of service of written notice of entry
    of such judgment, may vacate such judgment and allow the party or the partys legal representatives
    to answer to the merits of the original action. When, however, a party has been personally served
    with summons and complaint, either in the State of Nevada or in any other jurisdiction, the party
    must make application to be relieved from a default, a judgment, an order, or other proceeding taken
    against the party, or for permission to file an answer, in accordance with the provisions of
    subdivision (b) of this rule.
    Okay, so, really, you guys do this for a living, right...you serve people things....and sign Affidavits
    under penalty of perjury and stuff, and you are telling me you believe "personally served" can
    included situations where the person was not there? Okay.....You do know that, like, a Summons and
    Complaint need to be "personally served" in the sense that, say Machem, would need to see that
    person and serve it on them (I don't think they have to take the paper, they don't need to agree to
    accept service, but Machem does need to see that person, in person, personally when he is swearing
    under penalty of perjury that he "personally served" somebody. Usually "personally served" is only
    done in the case of the first thing filed (unless there is an IFP) in a case, the Summons and
    Complaint. Thereafter, typically, people just effect "substituted service" because its cheaper, less of a
    hassle, and "personal service" is only required for serving the pleadings that start a case, the
    Summons and Complaint. Wow....Okay, so this is my whole point, these state sponsored lockouts
    under color of state law should not be being done so fast, unless you guys "personally serve" the
    tenant, I feel the law is quite clear, you have to effect "substituted service" which, under NRCP 6(a)
    and NRCP 6(e) and NRCP 5(b)(2) (and NRCP, not JCRCP is applicable to eviction matters
    according to NRS 118A) the tenant cannot be deemed to have received or constructively received the
    Order until the 3 days for mailing has passed.
    Personal service by process server
    Personal service is service of process directly to the (or a) party named on the summons, complaint or
    petition. In most lawsuits in the United States, personal service is required to prove service. Most
    states allow substituted service in almost all lawsuits unless you are serving a corporation, LLC, LLP,
    or other business entity; in those cases, personal service must be achieved by serving (in hand) the
    documents to the "Registered Agent" of a business entity. Some states (Florida) do not require that
    the documents actually be handed to the individual. In California and most other states, the
    documents must be visible to the person being served, i.e., not in a sealed envelope. If the individual
    refuses to accept service, flees, closes the door, etc., and the individual has been positively identified
    as the person to be served, documents may be "drop" served, and it is considered a valid service.
    000874
    Personal service of process has been the hallmark for initialing litigation for nearly 100 years,
    primarily because it guarantees actual notice to a defendant of a legal action against him or her.
    Personal service of process remains the most reliable and efficacious way to both ensure compliance
    with constitutionally imposed due process requirements of notice to a defendant and the opportunity
    to be heard. [2]^ The National Law Review: The Continuing Relevance of Personal Service of
    Process
    And even if something indicates Coughlin "knew" about the Order, much like in the case of
    Coughlin's that was dismissed where the Washoe County Sheriff's didn't manage to get the "personal
    service" of the Summons and Complaint done in time, or "sufficiently", opposing counsel in that
    matter could tell you that "actual notice" is not a substitute for compliance with the service
    requirements.
    Which is nice because folks like Richard G. Hill, Esq. have less of an opportunity to game the system
    and swoop in with lockout then assert a bunch of hooey about NRS 118A.460 "reasonable storage,
    moving, and inventorying expenses" subjecting the tenant's personal property to a lien. Richard G.
    Hill insisted on throwing away the last thing my beloved grandmother gave me before she died 2
    years ago in the town dump. He and his contractor lied about so many things, including the fact that
    they used my own damn plywood to board up the back porch of the property, then submitted a bill to
    the court in an exhibit for $1,060 for "securing" the property (which doesn't really apply to NRS
    118A.460's "reasonable storage moving and inventorying expenses" like it is required to...further, the
    charged me $900 a month for storage and sent me a bill for such prior to my arrest for trespassing at
    the 121 River Rock location,...well if they charged me $900 to have a home law office there, then
    how is it someone could be trespassing if they are being charged the full rental value for "use and
    occupancy of the premises"? Further, even if it was a storage situations, there are sections of NRS
    118A devoted to evicting someone from a storage facility, not arresting them for trespass, and
    certainly not a custodial arrest where the RPD Officer Carter and Sargent Lopez admit they never
    issued a warning to me or asked me to leave prior to conducting a custodial arrest (which required
    $800 of bail, great!, and 3 days in jail, no less). This is especially poor form where Officer Carter
    admitted to me that he takes bribes from Richard Hill. Hey, if Officer Carter did not say that to me,
    go ahead and sue me, my man....I'm waiting.....that's what I thought.
    He can say he was joking all he wants, but it ain't no joking ass situation to me when you are
    arresting me and causing a google search result for my name to show an arrest....that's damaging the
    only thing I have of monetary value (my professional reputation and name). It ain't no stand up hour
    when you are putting me in cuffs, bro. And Officer Carter and Sargent Lopez refused to properly
    query Hill as to whether he had sent me, prior to the trespassing arrest, a bill for the "full rental
    000875
    value" of the property, a value that, at $900, was the same charge for the full "use and occupancy" of
    the premises. And Richard G. HIll, Esq. was too busy chortling and filling out the Criminal
    Complaint to bother setting them straight, despite my cues, I guess.
    Now, add to that malfeasance the fact that Judge Sferrazza let Casey Baker, Esq. prepare the Order,
    which means faithfully put to writing what the Judge announced, not attempt to steal $2,275 for your
    Californian Beverly Hills High School graduate neurosurgeon client by slipping in something the
    judge never said, ie, that the neurosurgeon gets to keep the $2,275 that Judge Sferrazza order the
    tenant to pay into the Reno Justice Court as a "rent escrow" deposit required to preserve the right to
    litigate habitability issues. Now, nevermind the fact that Judge Sferrazza actually did not have the
    jurisdiction to require that (there is not JCRLV 44 in Reno, that's a Vegas rule, and if Reno wants a
    rule like that of its own JCRCP 83 requires the RJC to publish it and get it approved by the Nevada
    Supreme Court first....period.). Okay, so, to take it a step even further, Baker's order goes on to say
    "but the $2,275 won't be released to the neurosurgeon yet, "instead that sum shall serve as security
    for Coughlin's cost on appeal, pursuant to Nevada JCRCP 73...". But wait, doesn't that mean
    Coughlin then gets a Stay of Eviction during the pendency of the Appeal? Isnt' that was a security
    that large must be for? Because the "Appeal Bond" is set by statute at only a mere $250....so holding
    on to 10 times that much of Coughlin's cash must have been for the "Supersedeas Bond" mentioned a
    yielding one a Stay of Eviction in NRS 40.380 and 40.385.
    I know, I know, its confusing because actually those sections force the landlord, his attorneys and the
    RJC to choose between viewing Coughlin as a residential tenant whose rent is less than $1,000, and
    whom therefore is only required to post a measly supersedeas bond of $250 (and remember, a
    supersedeas bond equals a stay of eviction equals not trespassing) or the the other choice is to view
    Coughlin as a commercial tenant, which would allow charging a higher supersedeas bond (except for
    that pesky part about his rent being under the $1,000 required by the statute to do so, his rent being
    only $900), except, darn it, old Richard G. Hill, Esq. and Casey Baker, Esq. elected to pursue this
    summary eviction proceeding under a No Cause Eviction Notice, which is not allowed against a
    commercial tenant (ie, you can't evict a commercial tenant using the summary eviction procedures set
    forth in NRS 40.253 unless you alllege non payment of rent and serve a 30 Day Non Payment of
    Rent Notice To Quit, which they didn't because they "are just taking the path of least resistance here,
    Your Honor (insert their smug chuckling and obnoxious/pretentious "can you believe this guy?"
    laughter and head shaking...).
    NRS 40.380 Provisions governing appeals. Either party may, within 10 days, appeal from the
    judgment rendered. But an appeal by the defendant shall not stay the execution of the judgment,
    unless, within the 10 days, the defendant shall execute and file with the court or justice the
    defendants undertaking to the plaintiff, with two or more sureties, in an amount to be fixed by the
    court or justice, but which shall not be less than twice the amount of the judgment and costs, to the
    000876
    effect that, if the judgment appealed from be affirmed or the appeal be dismissed, the appellant will
    pay the judgment and the cost of appeal, the value of the use and occupation of the property, and
    damages justly accruing to the plaintiff during the pendency of the appeal. Upon taking the appeal
    and filing the undertaking, all further proceedings in the case shall be stayed.
    So, why on earth is the City Attorney's Office still trying to try Coughlin on the trespass charge for
    which he endured a custodial arrest and for which old Richard Hill is still filing Motion's to Show
    Cause on in the appeal of the summary eviction matter in CV11-03628? Why, oh why? Does the
    Reno City Attorney's Office have some sort of vested interest in keeping Coughlin down, busy,
    besotted, encumbered, or otherwise? It, why, it couldn't be because Coughlin has a really good
    wrongful arrest cause of action against the Reno Police Department, could it?
    http://www.youtube.com/watch?v=5PR7q4OI5b0
    And, well, yeah the Washoe County Sheriff's Office didn't quite get those Summons and Complaints
    served in that one case Coughlin was suing his former employer in, the one where Coughlin was
    granted an Order to Proceed In Forma Pauperis, which required the Washoe County Sheriff's Office
    to serve the Summons and Complaints....But what does that have to to with the 6 days Coughlin
    spent in jail on the arrest shown in the youtube video above? Its not like the Washoe County jailed
    videotaped a scene where they were forcing Coughlin to get naked and put on a green dress. What's
    that? It is? They did do that? Really? No...What? They also forced him to simulate oral and anal sex
    with deputies, in the guise of some ridiculous "procedure" necessary to insure Deputy safety? Oh,
    wow. And they retaliated against him for failing to answer their religious preference interrogation
    questions by placing him in an icy cold cell for hours at a time, refusing him medical care despite his
    plaintive cries for help, while wearing a thin t-shirt? Wow. They didn't jam a taser needle in his spine
    for extended periods of time, though, did they? Your kidding! Whats next, your going tell me Sargent
    Sigfree of the Reno PD ordered a custodial arrest on Coughlin for "jaywalking" while Coughlin was
    peacefully filming, from a public spot, Richard G. Hill's fraudulent contractor Phil Howard
    destroying and taking to the town dump items of enormous sentimental value to Coughlin that he was
    prevented from retrieving from the property during the scant time he was allowed to (after he paid
    $480 worth of a lien for what he knew not, because, despite, ol' Contractor Phil's fraudulent $1,060
    bill for "securing" the back porch (with screws facing the outside, inexplicably, and a window unit
    a/c left in the window facing the sidewalk near the Lakemill Lodge, secured by nothing but duct tape
    It is kind of a combo neon sign that says "Burglarize this Place, Everybody!"), Coughlin's former
    home law office was burglarized on December 12, 2011 while Richard G. Hill was holding its
    contents (including, tackily, Coughlin's client's files, like the ones for the foreclosure defense actions,
    etc.), asserting his "lien". A lien for "storage" where the charge for storage, $900, was the same as the
    charge for "full use and occupany" was. However, that $900 a month for "storage" also included
    another $1,060 charge for "securing" (and that bill actually listed "fixing a leak in the
    000877
    basement...neither of which seem to have much to do with the "reasonable storage, moving, and
    inventorying" expenses such a lien is provided for under NRS 118A.460....). Jeez, your probably
    going to tell me Sargent Sigfree ordered another custodial arrest on Coughlin just two days after the
    jaywalking arrest, for the same fact pattern that Master Edmondson granted Coughlin's applications
    for Protections Orders against based upon the battery and assaults that his former housemates
    committed. Because, Sargent Sigfree thinks its "misuse of 911" for Coughlin to call when he returns
    home at night and his dog has mysteriously disappeared, and his housemates make menacing
    commentary about it. Surely, Coughlin, a former domestic violence attorney would have nothing
    helpful to add to Sargnet Sigfree's expert opinion that "animal abuse is not domestic violence" (tell
    that to NRS 33.010, Sarge) and that its, rather, "a matter for animal control" and that Sargent Sigfree
    was "trying to help" Coughlin by arresting him, again, and necessitating the $1,500 bail associated
    with the gross misdemeanor charge, "Misuse of 911" because, as Sargent Sigfree told Coughlin "you
    keep putting yourself in situations where you are victimized" so it was necessary to arrest Coughlin
    in that regard.
    But hey, at least NV Energy hasn't refused to let Coughlin get any electrical service for the past week
    since those with the Protection Orders against them cancelled the service and NV Energy shut it off,
    without providing any notice to Coughlin, right. Nevermind. But...but surely when NV Energy shut
    of the power to Coughlin's home law office on October 4th, 2011, just hours prior to the bad faith
    "inspection" with videographer of Coughlin' s home law office that Casey Baker, Esq. thought so
    very necessary one day before Coughlin's Tenant Answer was due...surely NV Energy did not leave
    the back gate to Coughlin's home law office open and speed off, Coughlin's beloved mountain bike
    suddenly missing (the one the parents of his girlfriend of 5 years gave him)? Well, NV Energy is
    probably not retaliating against Coughlin for complaining about that by refusing him electric service
    for the past seven days, you would have to assume....
    NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of premises to pay
    rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253:
    1. Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with
    the trial court a bond in the amount of $250 to cover the expected costs on appeal. A surety upon the
    bond submits to the jurisdiction of the appellate court and irrevocably appoints the clerk of that court
    as the suretys agent upon whom papers affecting the suretys liability upon the bond may be served.
    Liability of a surety may be enforced, or the bond may be released, on motion in the appellate court
    without independent action. A tenant of commercial property may obtain a stay of execution only
    upon the issuance of a stay pursuant to Rule 8 of the Nevada Rules of Appellate Procedure and the
    posting of a supersedeas bond in the amount of 100 percent of the unpaid rent claim of the landlord.
    2. A tenant who retains possession of the premises that are the subject of the appeal during the
    pendency of the appeal shall pay to the landlord rent in the amount provided in the underlying
    000878
    contract between the tenant and the landlord as it becomes due. If the tenant fails to pay such rent, the
    landlord may initiate new proceedings for a summary eviction by serving the tenant with a new notice
    pursuant to NRS 40.253.
    NRS 40.390 Appellate court not to dismiss or quash proceedings for want of form. In all cases of
    appeal under NRS 40.220 to 40.420, inclusive, the appellate court shall not dismiss or quash the
    proceedings for want of form, provided the proceedings have been conducted substantially according
    to the provisions of NRS 40.220 to 40.420, inclusive; and amendments to the complaint, answer or
    summons, in matters of form only, may be allowed by the court at any time before final judgment
    upon such terms as may be just; and all matters of excuse, justification or avoidance of the allegations
    in the complaint may be given in evidence under the answer.
    NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and Nevada
    Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they are not
    inconsistent with the provisions of NRS 40.220 to 40.420, inclusive, apply to the proceedings
    mentioned in those sections.
    But, back to the Sheriff's Office. And, I am not really buying the idea that you guys don't know
    NRCP 4 through 6 like the back of your hand, but....hell, maybe you don't. But, clearly the language
    in NRS 40 about how the Sheriff may "remove tenant from the property within 24 hours of receipt of
    the Order" do not apply where the Tenant filed a Tenant's Answer and showed up to the Hearing and
    litigated the matter. Especially where, as here the lease had not terminated, by its terms, but was
    rather renewed. This is particularly true where NRS 118A prevents so terminating a holdover tenant's
    lease for a retaliatory or discriminatory purpose.
    I would hate to see people start to think the Washoe County Sheriff's Office is cutting corners on the
    whole "personally served" thing (just so a landlord could get what they want quicker), just like I
    would hate for people to think the Reno Municipal Court is letting the bottom line get in the way of
    providing that whole Sixth Amendment Right To Counsel where jail time is even a possibility thing.
    And, hey, if the RMC denies an indigent attorney the Sixth Amendment Right To Counsel, the finds
    him guilty of NRS 22.030, Summary Contempt Commited in the Presence of the Court, and the puts
    him in cuffs when the Trial ends, summarily sentencing him to 3 days in jail for violating NRS
    22.030, well....that's no big deal, right, I mean, the RMC technically kept its promise that the
    underyling charge, though technically it could result in incarceration would not...because the
    incarceration was for a whole dang different charge, ie, Summary Contempt in the presence of the
    Court....and so what if the whole zealous advocate thing and the denying the Sixth Amendment
    Right to Counsel thing and the Summary Contempt thing don't go so well together....Or if 6 court
    employees had to stay til 9pm getting paid overtime at the RMC to get 'r done...
    000879
    NRCP 4: "(d) Summons: Personal Service. The summons and complaint shall be served together.
    The plaintiff shall furnish the person making service with such copies as are necessary. Service shall
    be made by delivering a copy of the summons attached to a copy of the complaint as follows:...(6)
    Service Upon Individuals. In all other cases to the defendant personally, or by leaving copies thereof
    at the defendants dwelling house or usual place of abode with some person of suitable age and
    discretion then residing therein, or by delivering a copy of the summons and complaint to an agent
    authorized by appointment or by law to receive service of process. [As amended; effective January 1,
    2005.] (e) Same: Other Service. (1) Service by Publication. (i) General. In addition to methods of
    personal service, when the person on whom service is to be made resides out of the state, or has
    departed from the state, or cannot, after due diligence, be found within the state, or by concealment
    seeks to avoid the service of summons, and the fact shall appear, by affidavit, to the satisfaction of
    the court or judge thereof, and it shall appear, either by affidavit or by a verified complaint on file,
    that a cause of action exists against the defendant in respect to whom the service is to be made, and
    that the defendant is a necessary or proper party to the action, such court or judge may grant an order
    that the service be made by the publication of summons. Provided, when said affidavit is based on the
    fact that the party on whom service is to be made resides out of the state, and the present address of
    the party is unknown, it shall be a sufficient showing of such fact if the affiant shall state generally in
    such affidavit that at a previous time such person resided out of this state in a certain place (naming
    the place and stating the latest date known to affiant when such party so resided there); that such
    place is the last place in which such party resided to the knowledge of affiant; that such party no
    longer resides at such place; that affiant does not know the present place of residence of such party or
    where such party can be found; and that affiant does not know and has never been informed and has
    no reason to believe that such party now resides in this state; and, in such case, it shall be presumed
    that such party still resides and remains out of the state, and such affidavit shall be deemed to be a
    sufficient showing of due diligence to find the defendant. This rule shall apply to all manner of civil
    actions, including those for divorce"
    I guess it don't matter much to me which one of you pays me my damages for the wrongful eviction,
    illegal lockout, whether its the landlord, his attorney, or the Sheriff's Office. Your money is always
    good with me.
    Zach Coughlin, Esq.
    Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Date: Tue, 7 Feb 2012 11:40:39 -0800
    From: LStuchell@washoecounty.us
    000880
    To: zachcoughlin@hotmail.com
    CC: mkandaras@da.washoecounty.us
    Mr. Coughlin,
    Our records indicate that the eviction conducted on that day was personally served by Deputy Machen
    by posting a copy of the Order to the residence. The residence was unoccupied at the time.
    Liz Stuchell, Supervisor
    WCSO Civil Section
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, February 06, 2012 2:58 AM
    To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov;
    fourthestate@gmail.com; jamesandreboles@msn.com
    Subject: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
    Dear IA Supervisor Stuchell and DDA Kandaras,
    I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
    confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order on
    me at 121 River Rock St., Reno 89501 on November 1, 2011 at 4:30 pm, in connection with
    performing the lockout. It is my position that I was not "personally served" and I am trying to figure
    out whether Deputy Machem is lying or whether the phrase "personally served" means something
    other than what I believe it means, etc., etc. I appreciate your attention to this.
    I am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
    WCSO Deputy Machem with respect to the service of a Order Granting Summary Eviction against
    me (in my law office where non-payment of rent was not alleged, no less in violation of NRS 40.253
    and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6), especially
    where a stay of eviction was not granted even while the RJC held on to most all my money...).
    000881
    My issue with the WCSO is that Machem's Affidavit of Service indicates that he "personally served"
    me, which kind of reminds me of all that robo-signing and MERS fraud I come across in my day job
    (and do you wonder how many attorneys in the foreclosure defense game I am in constant contact
    with who are watching and witness the potential RICO violations this writing mentions?), which
    includes being a foreclosure defense attorney. So which is it? Did Machem "personally serve" me the
    Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was "served" in compliance with
    all time related rules because it was done in the "usual custom and practice of the WCSO. What,
    exactly, is the "usual custom and practice of the WCSO? I hear a lot about this "within 24 hours"
    stuff. So, I go hunting for some black letter law to support what those at the RJC and in the clueless
    community at large (which often includes Nevada Legal Services and Washoe Legal Services, the
    people you guys had such trouble actually serving in the lawsuits I filed, which may have actually
    helped improved legal services in this community, if they were not dismissed due to insufficiency of
    service of process, even where the IFP required the WCSO to served the defendants....). Anyway,
    back to the "within 24 hours" phraseology: "
    This whole business about The court may thereupon issue an order directing the sheriff or constable
    of the county to remove the tenant within 24 hours after receipt of the order... is inapplicable to this
    situation, where an Order Granting Summary Eviction was signed by October 27th, 2011. That
    language is only found in situations inapplicable to the current one. NRS 40.253(3)(b)(2), and NRS
    40.253(5)(a) are the only sections of NRS 40 where this within 24 hours language occurs, and
    those situations only apply where, in:
    40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise the tenant: .
    (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may issue a
    summary order for removal of the tenant or an order providing for the nonadmittance of the tenant,
    directing the sheriff or constable of the county to remove the tenant within 24 hours after receipt of
    the order
    and,
    40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the landlords agent may
    apply by affidavit of complaint for eviction to the justice court of the township in which the dwelling,
    apartment, mobile home or commercial premises are located or to the district court of the county in
    which the dwelling, apartment, mobile home or commercial premises are located, whichever has
    jurisdiction over the matter. The court may thereupon issue an order directing the sheriff or constable
    of the county to remove the tenant within 24 hours after receipt of the order. The way these
    summary eviction proceedings are being carried out in Reno Justice Court presently shocks the
    conscience and violates Nevada law. There is not basis for effectuating a lockout the way WCSO's
    Deputy Machem did in this case. The above two sections containing the within 24 hours of receipt
    language are inapplicable, as those situations do not invoke the present circumstances, where the
    Tenant did file an Affidavit and did contest this matter to a degree not often seen. To require
    Nevada's tenants to get up and get out within 24 hours of receipt of the order (what does that
    even mean? The use of terms like rendition, rendered, notice of entry, pronounced, is absent
    here, and this receipt of the order language is something rarely found elsewhere in Nevada law-see
    attached DMV statutory citations, and in employment law litigations where one must file a Complaint
    within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b), and
    000882
    NRCP 6(e) in imputing receipt of such a letter, when actual receipt is not shown, by applying a
    constructive notice standard that relies upon the days for mailing extension of time for items served
    in the mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir.
    2009), the record did not reflect when the plaintiff received his right-to-sue letter. The letter was
    issued on November 24, 2006. The court calculated that the 90-day period commenced on November
    30, 2006, based on three days for mailing after excluding Saturdays and Sundays. In order to bring a
    claim under either Title VII or the ADA, a plaintiff must exhaust administrative remedies and sue
    within 90 days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin County
    Welcome Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)(granting
    plaintiff an additional three days for mailing pursuant to Rule 6).
    Further, despite what the inaccurate handouts of Nevada Legal Services may say about this 24
    hours and the applicability of the JCRCP to cases like these, NRS 40.400 Rules of practice, holds
    that :The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate
    Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with the
    provisions of NRS 40.220 to 40.420, inclusive, apply to the proceedings mentioned in those sections.
    As such NRCP 6(a),(e) applies to the Order of Summary Eviction that WCSO Deputy Machem
    alleged, under penalty of perjury, that he "personally served" upon me on November 1, 2011. That is
    a lie by Mr. Machem, unless "personally served" is defined in a rather impersonal way and or
    Machem and I have totally different understanding of the definition of "personally served", which
    may be the case. Or, perhaps the Sheriff's Office is busy and doesn't want to wait around to
    "personally serve" every tenant it wishes to evict. Fine, then just use the "mail it and allow three
    days" rule in NRCP 6(e)...the landlord's might not like it, but they can use that frustration as an
    incentive not to jump to litigating every disagreement about habitability that a tenant brings to them.
    You may not realize how ridiculous some landlord's get. In my case, I offered to fix basic things that
    clearly implicated the habitability rules in NRS 118A.290 and the Californian neurosurgeon, Beverly
    Hill High School graduate landlord balked and complained then hired and attorney four days into a
    dispute.....at which point the rules against contacting represented parties prevented much in the way
    of real settlement discussion, particularly where opposing counsel has continuously demonstrated a
    complete indifference to pursuing settlement (why would he at the rates he bills hours at?). I just
    don't think the Sheriff's Office needs to sully its image or damage the citizen tenants of Washoe
    County in the name of pleasing people like Dr. Matt Merliss or Richard G. Hill, Esq.
    I AM REQUESTING, IN WRITING, THAT BOTH OF YOUR OFFICES INVESTIGATE THIS
    AND PROVIDE A SWORN AFFIDAVIT FROM MR. MACHEM THAT ADMITS THAT I WAS
    NOT PERSONALLY PRESENT WHEN HE SERVED THE ORDER FOR SUMMARY EVICTION
    IN RJC REV2011-001708 ON 11/1/12 AT 4:30 PM (ACCORDING TO HIS AFFIDAVIT OF
    SERVICE). YOU NEVER KNOW, I MIGHT HAVE IRREFUTABLE PROOF THAT I WAS
    SOMEWHERE ELSE AT THAT TIME, SO, BE CAREFUL. There simply is not anything specific
    in Nevada law addressing how such Summary Eviction Orders are to be served and carried out. The
    sections dealing with
    NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant
    000883
    for default in payment of rent....
    6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the
    information contained in the affidavit, and the filing by the landlord of the affidavit permitted by
    subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the
    hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice
    provided for in this section. If the court determines that there is no legal defense as to the alleged
    unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a summary
    order for removal of the tenant or an order providing for the nonadmittance of the tenant....
    7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a motion,
    file a motion with the court, on a form provided by the clerk of the court, to dispute the amount of
    the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 for the inventory,
    moving and storage of personal property left on the premises. The motion must be filed within 20
    days after the summary order for removal of the tenant or the abandonment of the premises by the
    tenant, or within 20 days after:
    (a) The tenant has vacated or been removed from the premises; and
    (b) A copy of those charges has been requested by or provided to the tenant,
    whichever is later.
    8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the
    motion. The hearing must be held within 10 days after the filing of the motion. The court shall affix
    the date of the hearing to the motion and order a copy served upon the landlord by the sheriff,
    constable or other process server. At the hearing, the court may:
    (a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 and
    any accumulating daily costs; and
    (b) Order the release of the tenants property upon the payment of the charges determined to be due
    or if no charges are determined to be due...."
    I also want to know why NRS 40. 253(8) was not followed with respect to my November 17th, 2011
    filing of a Motion to Contest Personal Property Lien. Why didn't the WCSO serve notice, as required
    by NRS 40.253(8) upon the landlord's attorney Richard Hill? Why didn't I get a hearing within the 10
    days called called for by that section (to get back my client's files no less), but rather, I had to wait a
    full 33 days to get a hearing, and service of notice of the hearing was not effectuated, as required by
    NRS 40.235(8), by the WCSO. Why?
    Please provide an indication, in writing, of the names and case numbers for the last 20 incidences
    when the WCSO has served notice of a hearing set pursuant to NRS 40.253(8). What's that? The
    WCSO has NEVER served such notice? Yet the WCSO is there with bells on (or Machem is) to lie
    in Affidavits of Service to lock out the citizen tenants of Washoe County impermissilby early vis a
    vis NRCP 5(b)(2) and NRCP 6(e)? Why is that? Is it a conspiracy? Does money talk? When I was
    arrested for trespassing on November 12th, 2011 by RPD Officer Chris Carter and Sargent Lopez,
    Carter admitted to me that "Richard Hill pays him a lot of money and therefore he arrests whom
    000884
    Richard Hill says to and does what Richard Hill says to do...." Both Carter and Sargent Lopez
    refused to investigate, despite prompting, whether Richard Hill has sent the tenant/arrestee a bill or
    demand letter in bill for the full rental value of the property, $900 per month, under some
    interpretation of the "reasonable storage, moving, and inventorying expenses" collectable by a
    landlord under a personal property line set forth in NRS 118A.460 (one could also interpret such a
    bill as Hill's withdrawing or eradicating the Order of Summary Eviction itself, which was not
    "personally served" by the Washoe County Sheriff (despite what their Affidavit of Service says...I
    wasn't even there at the time they changed the locks...and so the Summary Eviction Order was not
    properly served under NRCP 6, and despite the Reno Justice Court impermissibly converting $2300
    of my money under a "rent escrow" Order its required I comply with in order to litigate habitability
    issues in a summary eviction proceeding under NRS 40.253, despite NRS 40.253(6)'s express dicate
    against such an Order (unless, pursuant to JCRCP 83, a justice court gets such a rule, like Justice
    Court Rule of Las Vegas (JCRLV) Rule 44, published and approved by the Nevada Supreme Court,
    which the RJC has not, rather, the RJC applies all these insidious secret "house rules" (like forcing
    tenants to deliver themselves to the filing office to submit to personal service notice of a summary
    eviction hearing within, like, 12 hours of the Tenant filing a Tenant's Answer or Affidavit in response
    to an eviction Notice, rather than the service requirements of such notice following NRCP 6 (days for
    mailing, etc., etc., in other words, in the RJC everything is sped up imperissilby to help landlord's
    out, and the NV. S. Ct ruling in Glazier and Lippis clearly contemplate personal liability against the
    Court and or Judges themselves for so doing)....A Qui Tam action or something a la Mausert's in
    Solano County, I believe, in California, would be very interesting...Still haven't heard anything from
    the Reno PD about the various complaints I have filed with them in writing related to the wrongful
    arrests, excessive force and other misconduct committed against me, though they did arrest me the
    other day for calling 911incident to some domestic violence for which I was granted to Extended
    Protection Orders against my former housemates....old Sargent Sigfree ordered that arrest, as he did
    two days prior when he ordered a custodial arrest of me for "jaywalking".
    Funny thing, I never heard anything back from the RPD about complaints like the following one:
    From:
    NvRenoPd@coplogic.com
    Sent:
    Wed 9/07/11 10:51 PM
    To: zachcoughlin@hotmail.com
    ****DO NOT RESPOND TO THIS E-MAIL****
    000885
    We're sorry the following problem was found during review
    of your submitted report T11005956:
    THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS REPORT
    WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL BE
    ADDRESSED.
    Thank you,
    Officer WOZNIAK,
    Reno Police Department
    What is interesting there is that at least I was provided the name of an officer, a "Wozniak" (though I
    have been unable to confirm the existence of
    such an RPD Officer...
    or whether " THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS
    REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL
    BE
    ADDRESSED."
    What is more strange is that I submitted several online police reports to the Reno PD (a couple of
    which asserted complaints against various Reno PD officers, or asked why RDP Officer Carter,
    whom admitted taking bribes from Richard G. Hill, Esq. at the time of my custodial arrest for
    trespassing (the one where Richard Hill signed a Criminal Complaint for trespass, then Officer Carter
    and Sargent Lopez refused to follow up on my imploring them to ask Hill whether he has recently
    sent me a bill for the "full rental value" of the property, the same amount that had been charged for
    the "use and enjoyment" of the premises, $900, in comparision to what NRS 118A.460 may deem
    "reasonable storage" expenses for which a lien is available to a landlord, though NRS 118A.520 has
    outlawed rent distraints upon tenant's personal property....Regardless, between January 8 - 12th, 2012,
    and was arrested twice by the Reno PD shortly after submitting these written complaints to the Reno
    PD.
    Actually, upon being released from jail on November 15th, 2011, incident to the custodial trespass
    arrest, I went to Richard HIll's office to get my wallet and driver's license. He refused to provide it to
    me until late November 22nd, 2011. Hill called the Reno PD on the 15th (or maybe I did because he
    was withholding my state issued ID, the one I would need to rent a room, drive my car, and my
    wallet, which is kind of useful in such situations....). Anyways, Sargent Tarter of the Reno PD
    showed up, he went inside Hill's office with Hill for quite some time and the result was Tarter telling
    me to leave. I did, but while driving down St. Laurence towards S. Virginia (Hill's office is at 652
    000886
    Forrest St. 89503 and would have required turning down the wrong way of a one way street, Forrest,
    to go back to Hill's Office (so clearly I was not headed to Hill's office) Sargent Tarter began tailing
    me, then he pulled me over, then he gave me a ticket, in retaliation if you ask me for reporting RPD
    Officer Carter admitting that he takes bribes from Hill to Sargent Tarter minutes earlier. Uh, well,
    anyways, another Sargent calls me later that night, taking the "good cop" role. But upon informing
    him of what RPD Officer Carter told me about Hill paying him money to arrest people during the
    11/12/11 trespassing arrest, that Sargent immediately informed me that, despite this being the first he
    heard of that, he was sure that was not happening....I guess RPD Officer Carter is trying to explain
    away his comments about Richard Hill paying him money to arrest people by dismissing them as
    sarcasm, a joke, said in jest, whatever....but I don't see how that situation (a license attorney getting
    arrested for a crime, a conviction for which would result in that attorney being required to report said
    conviction to the State Bar of Nevada under SCR 111, etc., and possibly resulting in a suspension of
    that attorney's license to practice law, or worse...) is all that jocular of a situation. Combine that with
    the too quick to dismiss my reports of bribery by Richard Hill to officer Carter to the RPD Sargent
    who called me on 11/15/11 regarding the retaliation by Sargent Tarter that I complained of, and I
    don't think it is all that unreasonable for anyone to take RPD Officer Carter at his word regarding
    Richard G. Hill, Esq. paying him money to arrest whom Hill says to arrest. Add to that Sargent
    Sigfree ordering my arrest for jaywalking (by a trainee RPD Officer) on January 12th, 2011
    (custodial arrest, bail of $160 emptied my bank account out, or pretty close to it) while I was
    peacefully filming from a public spot Richard G. Hill, Esq's contractor Phil Howard, whom had
    submitted bills in courts records and filings under the lien for "reasonable storage moving and
    inventorying" found in NRS 118A.460, even where old Phil used my own plywood at the property to
    board up the back porch (curiously leaving the screws holding up the plywood exposed to exterior of
    the property where anyone could easily unscrew them, and also leaving in a window unit ac secured
    only by ducttape in a window facing a sidewalk by the LakeMill Lodge....which resulted in $8,000 at
    least of my personal property being burglarized from my former home law office on Decmeber 12th,
    2011 while Hill was asserting a lien on all my personal property found therein (and my client's files,
    which arguably are not even my property, but rather, the client's property). Hill went on to place
    what he believes to be my social security number in court records, on purpose, despite his signing an
    Affirmation pursuant to NRS 239B.030 that that was not the case (attaching a two page report to the
    RPD as an Exhibit). Then Hill and his contractor Phil Howard both committed perjury when the
    signed Declarations attesting that I had climbed on the contractors truck or ever touched Hill. Hill lies
    constantly, whether under penalty of perjury or now, so I don't have time to rebut every little lie he
    makes (he makes me out to comes across as a Yosemite Sam caricature of a human being in his
    filings when he describes me...).
    Further, why am I arrested for trespassing and not those from Nevada Court Services where they
    went behind closed gate the the backyard of my home law office and banged on window extremely
    loudly for 40 minutes at a time 3 times a day, one guy ringing the doorbell, one guy moving around
    all other sides of the property banging on the windows, peering in closed blinds, and affecting a
    phony "color of law" tone, resemblance, and verbal communications, misleadingly announcing that
    they were "Court Services, come out now!", wearing their pretend Sheriff outfits, big equipment
    saddled belts (including firearms, I believe, and radios), etc. ,etc.
    http://www.youtube.com/watch?v=jQ132q2O7DY
    000887
    Add to that that Nevada Court Services Jeff Chandler drives by in his Monster Truck baring his
    personalized "NCS" license plate while I am in the RPD squad car, handcuffed, outside my former
    law office at 121 River Rock, at the time of the 1/12/12 jaywalking arrest and the appearances are
    troubling. Now, add to that that Lew Taitel, Esq. was my court appointed public defender in the Reno
    Municipal Court in the trespass case, and that Judge Gardner had refused to provide me the names of
    prospective appointed defense counsel (I wanted to run a conflicts check) at my arraignment (where
    Marshal Mentzel barked at me in a threatening tone, using menacing language), whereupon Taitel
    was appointed as my defense attorney and filed a notice of appearance, and received my confidential
    file, pc sheet, arrest reports, ssn, etc....only its turns out that Taitel shares and office and a receptionist
    with Nevada Court Services and they list him and his picture on their website as "associated with"
    their Process Server corporation, despite the prohibition lawyers face against fee sharing with non-
    lawyers. Then, Taitel somehow manages to get out of defending my case without filing a Motion to
    Withdraw as Counsel, despite that being required by the Reno Municipal Court Rule 3(B):
    RMCR Rule 3(B): Authorization to Represent (B): An attorney desiring to withdraw from a case
    shall file a motion with the court and serve the City Attorney with the same. The court may rule on
    the motion or set a hearing.
    But, perhaps most troubling of all is the implication that the Reno City Attorney's Office, which
    defends actions against the City of Reno Police Department and its Officers, has a vested interest in
    discrediting me in advance of the wrongful arrest lawsuit that the Reno City Attorney's office knew
    was imminent at the time of all of the above incidents, relating to the following August 20th, 2011
    wrongful arrest by RPD Officer's Duralde and Rosa. http://www.youtube.com/watch?
    v=5PR7q4OI5b0 So, that's what attempting to coerce a suspect's consent to an impermissible search
    sounds like? Add to that that the trespassing case is before Judge Gardner, whom most recently was
    employed with the Reno City Attorney's Office.
    And, you know what is funny? Officer Del Vecchio cuffed me and placed me in his squad car last
    summer after he terrified me and another gentleman who had bicycles. He veered across the road and
    screeched his squad car to a halt, jumped out, and did some other stuff, then demanded my name and
    ID...and the lawyer in me didn't like that that much, and he didn't like me not wanting to give it to
    him. This occurred right in front of my home law office in the summer of 2011. He cuffed me and
    told me I was going to jail for something about a light on the front of my bicycle (the one NV
    Energy likely stole when the shut off my power, unnoticed, on October 4, 2011) despite my bike
    actually having such a light....but then Del Vecchio's partner did him a solid and talked some sense
    into him, and I humbled it up for Del Vecchio and we both let it go, and I didn't go to jail....Until Del
    Vecchio was present supervising some Officer's training at the scene of my custodial (9 hour)
    jaywalking arrest) on 1/12/12. But Del Vecchio, I guess either didn't want to or wasn't able to talk
    some sense into Sargent Sigfree.....and then Sargent Sigfree (the spelling is likely off) had me
    arrested and charged with a gross misdemeanor, "Misuse of 911" just two days later, on January
    14th, 2011 when I called 911 to report that my roommates were laughing menacingly when I asked
    000888
    them why my dog was missing (I had also been chased up to my room numerous times since moving
    in with these people, something I had to do because so much of my money had been taken up with
    bail or lost earnings due to all these wrongful arrests and abuse of processes mentioned above...also
    these housemates had chased me with a ten inch butcher knife, two of my tires were slashed, I was
    locked out all night on New Years Even when these changed the locks at around midnight, had my
    furniture thrown in the street, property stolen, coffee thrown on me, destroying my smart phone in
    the process, etc., etc...And despite the housemate having an outstanding arrest warrant, and animal
    abuse being listed amongst the elements of domestic violence, Sargent Sigfree told me he was
    arresting me because I "keep putting yourself in these situations", like, where I am a victim, and that
    he was "trying to help you", he said with a smirk and a laugh to his fellow RPD Officers, whom then
    proceeded to use excessive force against me. I guess he was helping me by saddling me with a gross
    misdemeanor with a $1,500 bail, especially where its been arranged for Court Services, or pre-Trial
    Services to forever deny me an OR, despite my meeting the factors for such set forth in statute (30
    year resident, entire immediate family lives here, licensed to practice law in Nevada, etc., etc)...I
    guess it should not be too much of a surprise to me that Reno City Attorney Pam Roberts failed to
    address the perjury of all three of her witnesses or that her fellow Reno City Attorney Christopher
    Hazlett-Stevens lied to me about whether or not the Reno City Attorney's Office even had any
    documentation related to my arrest or whether it would in the month before my arraignment, despite
    that fact that subsequent productions of discovery tend to indicate that the Reno City Attorney's
    Office did have those materials at the time. I could be wrong about some of this...But that would
    require and awful lot of coincidences.
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic
    Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information
    intended for the specified individual (s) only. If you are not the intended recipient or an agent
    responsible for delivering it to the intended recipient, you are hereby notified that you have received
    this document in error and that any review, dissemination, copying, or the taking of any action based
    000889
    on the contents of this information is strictly prohibited. This message is confidential, intended only
    for the named recipient(s) and may contain information that is privileged, attorney work product or
    exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified
    that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the
    contents of this information is prohibited and may be unlawful. If you receive this message in error,
    or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and
    destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is
    not a waiver of any attorney-client, work product, or other applicable privilege.
    From: PatrickK@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: Contact
    Date: Fri, 16 Mar 2012 16:10:24 +0000
    March 16, 2012
    Zachary Coughlin
    Dear Zach,
    Thank you for sending me your reply to the grievance filed by Richard Hill. From your
    explanation it is clear that things are not as they should be. Please call me ASAP so that we can
    take the appropriate action to help you and to stop these types of disturbing complaints.
    Patrick King, Assistant Bar Counsel (775) 328-1384
    000890
    Print Close
    response to grievance from NV Attorney
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Fri 3/09/12 5:44 PM
    To: patrickk@nvbar.org; glennm@nvbar.org; davidc@nvbar.org
    1 attachment
    3 9 12 fax to State Bar of Nevada Bar Counsel requesting extension of time to respond to
    Richard G. Hill, Esq. grievance.pdf (61.6 KB)
    Zach Coughlin, Esq.
    Nevada Bar No: 9473
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    775 328 6045 fax: 949 667 7402
    ZachCoughlin@hotmail.com
    State Bar of Nevada
    P.O. Box 50
    Las Vegas, NV 89125-0050
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    sent by fax and email only to:
    Reno Office: 775 329 0522
    Las Vegas Office: 702 385 2878
    DavidC@nvbar.com, PatrickK@nvbar.com, GlennM@nvbar.com
    000891
    March 9, 2012,
    Dear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
    I only just now received the letter, dated February 14th, 2012 that Assistant Bar Counsel King sent me, wherein
    the grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please respond in writing to this
    grievance within ten (10) days from the date of this letter."
    I am requesting an extension of time to respond to this matter. I literally just received this mailing from you
    within the last hour, and was unaware of this prior to that. Further, I hope I can demonstrate to you and the State
    Bar of Nevada that circumstances at least somewhat beyond my control have prevented me from receiving my
    mail in an orderly and consistent fashion. These circumstances resulted in two different Domestic Violence
    Protection Orders being granted to me against my former housemates by Master Edmondson of the Second
    Judicial District Court in FV12-00188 and FV12-00187. Further, the electricity to my location was interrupted
    from one week (though I attempted to get NV Energy to accept payment from me for services) from February 3rd
    to February 20th, 2012, incident to one of the individuals against whom a protection order was issued attempting
    to prevent me from obtaining electrical service. Additionally, the same individuals against whom these protection
    orders were issued interfered with my access to my mail from the USPS, and it has taken some time to get the
    USPS Postal Inspectors to release my mail to me and or allow me to receive mail at my location.
    Please note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn Machado a written
    request that the State Bar of Nevada please help me in remaining aware of any correspondence being sent me from
    the State Bar while I work to get my mailbox situation settled (please see below):
    On February 22nd, 2012 I wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that "I had to move
    recently and moved in with two individuals who I ultimately wound up getting Protection Orders against, and they
    have interfered with my ability to receive my mail with absolute certainty (I have received much of my mail, and
    have pending correspondences/requests with the Postmaster for Reno, NV to obtain a permanent and newly
    rekeyed lock and key to access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr.
    Heister that if I fax him proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key
    made...I faxed him proof and will call him again tomorrow to see how much longer I must wait....if its much
    longer I will make alternate arrangments, however, I am an electronic filer in both courts that I am appearing in
    (NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State Bar of
    Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax number or
    email address."
    I feel strongly that Mr. Hill's allegations are ones I will wish to contest vigorously, and I hope I am afforded an
    opportunity to do so. There is a lot more to this situation than Mr. Hill indicates.
    Sincerely,
    000892
    Zach Coughlin
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
    ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000893
    Print Close
    SCR 78.5 & SCR 217 ACKNOWLEDGEMENT AND CERTIFICATION OF COMPLIANCE AND
    CONSENT TRUST ACCOUNT
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 11:00 PM
    To: glennm@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    I am writing with regard to a question I encountered in my yearly compliance forms. I do not believe I "handle any client or third party funds", I
    am trying to grow my practice and it has not come up heretofore. However, recently I had a situation where I may have so handled such funds... I
    am not sure. One client referred a friend of hers to me who was in jail, and now is in jail again after being released. This individual was/is
    essentially homeless or staying with friends and had an issue with getting her mail, as it was being delivered to different family members of hers,
    who were apparently unhappy about that and seemed to be refusing to cooperate in passing this individuals mail on to her.
    To assist this individual I went to the jail to meet with her at her request, as relayed to me by the client who referred her to me. I had moved
    recently and was unable to find my bar card, and as such was not allowed a "face to face" meeting with the individual, and further the "webcam"
    interaction we were afforded lacked audio on her end, so the whole situation was hampered by communication problems, though I did utilize pen
    and paper and mouthing out words, etc...and it was my impression that the individual agreed for me to do a Change of Address and receive her
    mail until such time as she could make other arrangments. I spoke with her brother and the client/friend we had in common also in making this
    assessment. This was prior to my difficulties in receiving my mail became clear. I did ultimately receive some of her mail, and she is aware of
    that. I went up to the jail and met with her again recently and it was agreed that I would pass the mail of hers I had (which did include what
    appeared to be two checks totalling about $300 from the US Treasury (this individual opened the mail that I brought her in jail and her request that
    I have the amounts put on her "books" or commissary at the jail was not possible or ill advised given the jail's policies with respect to checks that
    inmates receive that may be deemed "government benefits"...as such the individual advised me to give this mail to her "Power of Attorney" friend,
    and I did shortly thereafter. The individual, in my second trip to the jail informed me that she just could not afford an attorney. During the first
    visit I had with her at the jail she had seemed to indicate I could get her mail via filing a Change of Address on her behalf, and cash the checks
    and take $500 for my fees to commence some sort of representation of her, however, again, the severe communications difficulties attendant to
    our very limited "web cam at the jail" interaction made it seem rather dubious that a true agreement was reached and I utlimately decided not to
    cash any of her checks, especially considering the lack of a signed retainer, etc., etc. This individual go out of jail shortly after my first visit and my
    attempts to communicate with her went unresponded to. My subsequent attempts to track her down resulted in my becoming aware that she was
    back in jail again...whereupon I went to visit her and brought the mail of hers that I had..
    Sorry this is so long winded, but filling out these online forms resulted in my not knowing quite how to answer the question posed below. To the
    extent having some of her mail for a few weeks (which included a couple checks) is considered "handling client or third party funds", I am writing
    to inform you of the above events. However, for my compliance report I marked that I do not handle client or third party funds, though, should
    this change, I will follow the rules applicable to such situations and create the necessary trust accounts.
    The reporting form indicated:
    SCR 78.5 & SCR 217 ACKNOWLEDGEMENT AND CERTIFICATION OF COMPLIANCE AND CONSENT TRUST ACCOUNT Every active member of the
    State Bar of Nevada must acknowledge compliance and consent to the Rule annually. Please do not report financial institutions outside of Nevada.
    By submitting below you agree to follow and acknowledge you are in compliance with and consent to the provisions of SCR 78.5. I am exempt from
    having a trust account pursuant to SCR 78.5 because I handle no client or third party funds in the state of Nevada. If you check this box, you are
    done with this section. I or my firm maintain(s) a trust account/s listed below. Please list all trust account maintained by you or the law firm in
    which you work.
    At the time of the relevant events in question it was not clear to me how these facts play out in relation to the above rules, and I resolved to
    ascertain the appropriate course of action in the context of the somewhat exigent circumstances attendant to this individual being in jail, having
    family that was no cooperative in holding her mail for her, and her not having much in the way of a fixed address....To be clear, I have received no
    money whatsoever in connection with any of this, I have not cashed any check belonging to her or endorsed any financial instrument, etc., etc.
    This individual informed me that she has subsequently had a new Change of Address filed with the USPS to have the mail forwarded to the man
    she referred to as her "Power of Attorney" and I do not believe I am receiving any of her mail any longer. I can provide her name and information
    if that is prudent to do, however, I refrained from doing so her in an abundance of caution vis a vis any confidentiality issues that may be present.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: glennm@nvbar.org; davidc@nvbar.org
    Subject: SCR 111
    Date: Wed, 22 Feb 2012 22:19:12 -0800
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    I contacted you and the State Bar of Nevada recently (about a month ago) in regard to SCR 111. I had to move recently and moved in with two
    individuals who I ultimately wound up getting Protection Orders against, and they have interferred with my ability to receive my mail with
    absolute certainty (I have received much of my mail, and have pending correspondences/requests with the Postmaster for Reno, NV to obtain a
    000894
    permanent and newly rekeyed lock and key to access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister
    that if I fax him proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call
    him again tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an electronic
    filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State
    Bar of Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax number or email address.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    SCR 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 10:19 PM
    To: glennm@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    I contacted you and the State Bar of Nevada recently (about a month ago) in regard to SCR 111. I had to move recently and moved in with two
    individuals who I ultimately wound up getting Protection Orders against, and they have interferred with my ability to receive my mail with
    absolute certainty (I have received much of my mail, and have pending correspondences/requests with the Postmaster for Reno, NV to obtain a
    permanent and newly rekeyed lock and key to access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister
    that if I fax him proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call
    him again tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an electronic
    filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State
    Bar of Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax number or email address.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    reporting forms able to be complete online?
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 9:51 PM
    To: suzannew@nvbar.org
    Dear Suzanne,
    I paid my bar dues online today, yet I have been unable to figure out where or have to complete my reportings forms for the year...Maybe I
    already did so, and therefore the option to do so is not available online? Can you tell me if I have so reported or whether the ability to do so is no
    longer available online? I am sorry for any inconvenience this may cause, but I am writing in an abundance of caution.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    need a duplicate bar card
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 2/09/12 4:07 PM
    To: suzannew@nvbar.org
    Dear Suzanne,
    Hello, I had to move a couple times recently and cannot locate my NV bar card. The Washoe County jail requires one to see
    inmates/clients....Or, at least they do until they can verify that one is actually an attorney and my driver's license and member
    information link at www.nvbar.com is not sufficient. Can I get a replacement/duplicate bar card?
    Sincerely,
    000895
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    supplemental FW: Attorney reporting under SCR 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 1/23/12 4:19 PM
    To: davidc@nvbar.org
    Dear Bar Counsel Clark,
    I am not sure it applies under SCR 111, but I was also found guilty (in the same matter in Reno Municipal Court 11 CR 22176) of NRS 22.030:
    "NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court;affidavit or statement to be filed when
    contempt committed outside immediateview and presence of court; disqualification of judge.
    1. If a contempt is committed in the immediate viewand presence of the court or judge at chambers, the contempt may be punishedsummarily. If the court or judge
    summarily punishes a person for a contemptpursuant to this subsection, the court or judge shall enter an order that:
    (a) Recites the facts constituting the contempt in theimmediate view and presence of the court or judge;
    (b) Finds the person guilty of the contempt; and
    (c) Prescribes the punishment for the contempt.
    2. If a contempt is not committed in the immediateview and presence of the court or judge at chambers, an affidavit must bepresented to the court or judge of the
    facts constituting the contempt, or astatement of the facts by the masters or arbitrators.
    3. Except as otherwise provided in this subsection, ifa contempt is not committed in the immediate view and presence of the court, thejudge of the court in whose
    contempt the person is alleged to be shall notpreside at the trial of the contempt over the objection of the person. Theprovisions of this subsection do not apply in:
    (a) Any case where a final judgment or decree of thecourt is drawn in question and such judgment or decree was entered in suchcourt by a predecessor judge
    thereof 10 years or more preceding the bringing ofcontempt proceedings for the violation of the judgment or decree.
    (b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family courthas been established in the judicial district."
    My understanding of the expressed rationale for the Contempt finding is that it related to my saying "Wow" in relation to a particular ruling of the
    Court, and continuing lines of inquiry after the Court rule against me on a particular objection, as well as, I believe, "derogating the authority of the
    Court".
    Sincerely,
    Zach Coughlin
    000896
    From: zachcoughlin@hotmail.com
    To: davidc@nvbar.org
    Subject: Attorney reporting under SCR 111
    Date: Mon, 23 Jan 2012 15:17:52 -0800
    Dear Bar Counsel Clark,
    It has recently come to my attention that Nevada Supreme Court Rule 111 may apply to a criminal conviction I received (and for which an appeal
    is currently pending) in Reno Municipal Court in case RMC 11 CR 22176 for the offense of petit larceny of a chocolate bar and some cough drops.
    Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
    determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada v. Claiborne,
    1988, 756 P.2d 464, 104 Nev. 115.
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    Attorney reporting under SCR 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 1/23/12 3:17 PM
    To: davidc@nvbar.org
    Dear Bar Counsel Clark,
    It has recently come to my attention that Nevada Supreme Court Rule 111 may apply to a criminal conviction I received (and for which an appeal
    is currently pending) in Reno Municipal Court in case RMC 11 CR 22176 for the offense of petit larceny of a chocolate bar and some cough drops.
    Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
    determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada v. Claiborne,
    1988, 756 P.2d 464, 104 Nev. 115.
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    000897
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    member attorney address change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 12/31/11 12:09 AM
    To: suzannew@nvbar.org
    Dear Ms. Walters,
    Sorry to have to do this again, but I am writing to update my address again, it is:
    PLEASE NOTE, I HAVE A NEW, NEW ADDRESS for all purposes and to please be listed at www.nvbar.org:
    Zach Coughlin, Esq.
    1422 E. 9TH ST. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    RE: member attorney address change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/28/11 11:36 AM
    To: suzannew@nvbar.org
    Dear Suzanne,
    Please list my address on the www.nvbar.org website as:
    Zach Coughlin
    817 N. Virginia St. #2
    Reno, NV 89501
    tel: 775 338 8118
    fax: 949 667 7402
    website: www.ZachCoughlinEsq.wordpress.com
    If it is possible to list patent law as a specialization (I am licensed before the USPTO) I would appreciate that.
    000898
    Thank You,
    Zach Coughlin
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: SuzanneW@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: member attorney address change
    Date: Mon, 28 Nov 2011 16:11:37 +0000
    Hi Zach,
    Please let me know how your address should be listed on your profile.
    Thank you
    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 4:28 AM
    To: Suzanne Walters
    Subject: FW: member attorney address change
    Dear Suzanne,
    I forgot to included my Suite number earlier, #2:
    817 N. Virginia St., suite #2, Reno NV 89501.
    From: zachcoughlin@hotmail.com
    To: suzannew@nvbar.org
    Subject: member attorney address change
    Date: Mon, 21 Nov 2011 03:51:34 -0800
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    000899
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    member attorney address change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/21/11 3:51 AM
    To: suzannew@nvbar.org
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    RE: Jackson Pawluck
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 10/18/11 4:05 PM
    To: nvlawyer@nvbar.org
    Dear Ms. Carten,
    I am contacting you on behalf of my client, Jackson Pawluck. We feel your stated "first come, first serve" policy is facially discriminatory and unduly
    burdensome to individuals belonging to the rarely cited Pekingnese protected class found in Title K9. Mr. Pawluck descends from a regal procession
    of lion monkey dogs kept as warmers in the Peking (now Beijing) Emperor's robe sleaves, and as such, he is used to not needing to do anything in
    a hurry, like pose for a picture to be included in a submission to a legal periodical, even one as august as yours. As such, Mr. Pawluck's includion
    in this protected class has a causal relation to the damages incurred incident to your application of this discriminatory "first come first serve"
    selection criteria. The damages incurred by my client are such that no less than $2,000,000 in compensatory and $2,000,000 in punitive damages
    are appropriate. We will settle this matter, however, in exchange for the cover fo the December issue.
    Sincerely,
    000900
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited.
    CONFIDENTIALITY NOTICE
    This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under
    applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the
    contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail
    from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or
    other applicable privilege.
    IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this
    communication (including any attachments) was not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding tax-related penalties or (ii)
    promoting, marketing or recommending to another person any transaction or matter addressed in this communication.
    > From: nvlawyer@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: RE: Jackson Pawluck
    > Date: Tue, 18 Oct 2011 15:41:11 +0000
    >
    > Thank you so much for your submission. We will do our best to get this in, but it is dependent on how much space we have left at this point;
    we're kind of taking a "first come, first serve" approach. But I'm hoping we'll have room for everyone who submitted.
    >
    > Thank you again!
    >
    > Melinda Catren
    > State Bar of Nevada
    > Nevada Lawyer Coordinator
    >
    > -----Original Message-----
    > From: ZC [mailto:zachcoughlin@hotmail.com]
    > Sent: Sunday, October 16, 2011 1:20 AM
    > To: nvlawyer
    > Subject: Jackson Pawluck
    >
    > Hi NV Lawyer! Great idea for an animal issue. I wish I had a dog or some pet in my twenties. Now I have Jackson, I got him about 6 months ago
    from the SPCA shelter in Reno as a three year old Pekingnese. My ex took our toy pomeranian, Palin. Just Palin. Jackson stayed with me and we
    have a great time going on rides in the car, barking at ducks and only the meanest and biggest looking dogs, and playing chase around the office.
    Jackson is not as affectionate as my female pomeranian Palin was and not as willing to jump up in any strangers lap and soak up attention and
    petting. It took a while but he seems to have warmed up to me. He ran away at any opportunity at first and I nearly collapsed chasing him half a
    mile once. However, recently I forgot that I had tied him up in the front yard so he could get some fresh air and sun, driving off for hours. I was
    worried sick when I arrived home and realize I had left him out and he had broken his rope. However, I heard strange noises coming from the back
    gate and found him there clawing at it and whimpering. He didn't want to run away and I was so glad he was okay.
    >
    > Sincerely, Zach Coughlin, Esq.
    Jackson Pawluck
    From: ZC (zachcoughlin@hotmail.com)
    Sent: Sun 10/16/11 1:20 AM
    To: nvlawyer@nvbar.org
    1 attachment
    IMG_20111016_010711.jpg (772.1 KB)
    Hi NV Lawyer! Great idea for an animal issue. I wish I had a dog or some pet in my twenties. Now I have Jackson, I got him about 6
    months ago from the SPCA shelter in Reno as a three year old Pekingnese. My ex took our toy pomeranian, Palin. Just Palin. Jackson
    stayed with me and we have a great time going on rides in the car, barking at ducks and only the meanest and biggest looking dogs,
    and playing chase around the office. Jackson is not as affectionate as my female pomeranian Palin was and not as willing to jump up
    in any strangers lap and soak up attention and petting. It took a while but he seems to have warmed up to me. He ran away at any
    opportunity at first and I nearly collapsed chasing him half a mile once. However, recently I forgot that I had tied him up in the
    front yard so he could get some fresh air and sun, driving off for hours. I was worried sick when I arrived home and realize I had
    left him out and he had broken his rope. However, I heard strange noises coming from the back gate and found him there clawing at it
    and whimpering. He didn't want to run away and I was so glad he was okay.
    Sincerely, Zach Coughlin, Esq.
    000901
    >
    > Thank you,
    > State Bar of Nevada
    >
    >
    >
    Hotmail: Free, trusted and rich email service. Get it now.
    Address Change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 7/07/09 6:48 PM
    To: suzannew@nvbar.org
    1 attachment
    Change of Address for Zach Coughlin Esq.pdf (16.3 KB)
    Dear Suzanne,
    Please accept the attached Change of Address (which I sent as a fax as well, just in case). Please note it now includes a fax number.
    Sincerely,
    Zach Coughlin, Esq.
    Windows Live: Keep your life in sync. Check it out.
    RE: Address Change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 5/28/09 11:08 AM
    To: suzannew@nvbar.org
    2 attachments
    state bar change of address pdf.pdf (245.8 KB) , state bar change of address.jpg (165.9 KB)
    Dear Ms. Walters,
    I have looked through my email and do not see such an email. I did reply to an email from you indicating that my earlier fax only contained the
    notice of insurance, and not the Change of Address form. So, I emailed you my signed Change of Address form. I hope there was not a problem
    with it. I am attaching another copy to this email. Please let me know if there is any problems with these attachments.
    Sincerely,
    Zach Coughlin, Esq.
    My new contact information is:
    Zach Coughlin, Esq.
    945 W. 12th St.
    Reno, NV 89503
    Tel: 775 338 8118
    email: zachcoughlin@hotmail.com
    I do not have a fax at this time.
    Subject: Re: RE: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Tue, 26 May 2009 20:06:58 +0000
    Hi Zach,
    000902
    Did you receive my last email regarding your scanned change of address form?
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    On Wednesday, May 20, 2009 12:32:28 PM, Zach Coughlin wrote:
    Dear Suzanne,
    Thank you for letting me know. Please accept the attachment to this email as it contains my change of address form, signed.
    Sincerely,
    Zach Coughlin, Esq.
    tel 775 338 8118
    Subject: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Mon, 18 May 2009 17:31:10 +0000
    Good Morning, Zach,
    I received your professional liability via fax, but did not receive your change of address form.
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    RE: Address Change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 5/20/09 12:32 PM
    To: suzannew@nvbar.org
    000903
    1 attachment
    state bar change of address.jpg (165.9 KB)
    Dear Suzanne,
    Thank you for letting me know. Please accept the attachment to this email as it contains my change of address form, signed.
    Sincerely,
    Zach Coughlin, Esq.
    tel 775 338 8118
    Subject: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Mon, 18 May 2009 17:31:10 +0000
    Good Morning, Zach,
    I received your professional liability via fax, but did not receive your change of address form.
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    FW: member attorney address change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/21/11 4:27 AM
    To: suzannew@nvbar.org
    Dear Suzanne,
    I forgot to included my Suite number earlier, #2:
    817 N. Virginia St., suite #2, Reno NV 89501.
    From: zachcoughlin@hotmail.com
    To: suzannew@nvbar.org
    Subject: member attorney address change
    Date: Mon, 21 Nov 2011 03:51:34 -0800
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    000904
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    000905
    Close Print
    RE: Address Change
    RE: Address Change
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 5/20/09 12:32 PM
    To: suzannew@nvbar.org
    1 attachment
    state bar change of address.jpg (165.9 KB)
    Dear Suzanne,
    Thank you for letting me know. Please accept the attachment to this email as it contains my change of address form, signed.
    Sincerely,
    Zach Coughlin, Esq.
    tel 775 338 8118
    Subject: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Mon, 18 May 2009 17:31:10 +0000
    Good Morning, Zach,
    I received your professional liability via fax, but did not receive your change of address form.
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 5/28/09 11:08 AM
    To: suzannew@nvbar.org
    2 attachments
    state bar change of address pdf.pdf (245.8 KB) , state bar change of address.jpg (165.9 KB)
    Dear Ms. Walters,
    I have looked through my email and do not see such an email. I did reply to an email from you indicating that my earlier fax only contained the
    notice of insurance, and not the Change of Address form. So, I emailed you my signed Change of Address form. I hope there was not a problem
    with it. I am attaching another copy to this email. Please let me know if there is any problems with these attachments.
    Sincerely,
    Zach Coughlin, Esq.
    My new contact information is:
    000906
    Zach Coughlin, Esq.
    945 W. 12th St.
    Reno, NV 89503
    Tel: 775 338 8118
    email: zachcoughlin@hotmail.com
    I do not have a fax at this time.
    Subject: Re: RE: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Tue, 26 May 2009 20:06:58 +0000
    Hi Zach,
    Did you receive my last email regarding your scanned change of address form?
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    On Wednesday, May 20, 2009 12:32:28 PM, Zach Coughlin wrote:
    Dear Suzanne,
    Thank you for letting me know. Please accept the attachment to this email as it contains my change of address form, signed.
    Sincerely,
    Zach Coughlin, Esq.
    tel 775 338 8118
    Subject: Address Change
    From: suzannew@nvbar.org
    To: zachcoughlin@hotmail.com
    CC:
    Date: Mon, 18 May 2009 17:31:10 +0000
    Good Morning, Zach,
    I received your professional liability via fax, but did not receive your change of address form.
    Suzanne Walters
    Member Services Assistant
    suzannew@nvbar.org
    State Bar of Nevada
    600 E. Charleston Blvd.
    Las Vegas, NV 89104
    (702) 317-1430 direct
    (702) 382-2075 fax
    (702) 382-2200 main
    (800) 254-2797 toll free
    000907
    Address Change
    RE: Your requested password
    Re: E-Newsletter: August 4, 2011 - State Bar of Nevada
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    Hotmail has ever-growing storage! Dont worry about storage limits. Check it out.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 7/07/09 6:48 PM
    To: suzannew@nvbar.org
    1 attachment
    Change of Address for Zach Coughlin Esq.pdf (16.3 KB)
    Dear Suzanne,
    Please accept the attached Change of Address (which I sent as a fax as well, just in case). Please note it now includes a fax number.
    Sincerely,
    Zach Coughlin, Esq.
    Windows Live: Keep your life in sync. Check it out.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 1/04/10 10:20 PM
    To: support@nvbar.org
    Dear State Bar of Nevada,
    Thank you for sending my password and username, however, I still am not able to log in to submit my annual reporting forms. I tried three times
    with the username and password below. Should I fax or mail these forms instead?
    Sincerely,
    Zach Coughlin
    > From: support@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: Your requested password
    > Date: Mon, 4 Jan 2010 22:10:51 -0800
    >
    > Dear User,
    >
    > The username you have requested is: NV9473
    > The password you have requested is: 4380
    >
    > Thank you,
    > State Bar of Nevada
    >
    >
    >
    Hotmail: Free, trusted and rich email service. Get it now.
    From: ZC (zachcoughlin@hotmail.com)
    Sent: Thu 8/04/11 9:04 PM
    To: melindac@nvbar.org
    000908
    Melinda Catren <melindac@nvbar.org> wrote:
    >Having trouble viewing this email?
    >Click here
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    >E-Newsletter for the week of August 4, 2011
    >
    >NEWS:
    >
    >* Appointment of Alternate Commissioner of the Commission on Judicial Discipline
    >* Las Vegas Justice Court Civil Division Begins Mandatory E-Filing
    >* Legislative Update Week: A Series of CLE Webinars
    >* State Bar of Nevada Career Center
    >* Members Invited to Attend Reception for Oregon School of Law Dean
    >
    >-----
    >
    >Appointment of Alternate Commissioner of the Commission on Judicial Discipline
    >
    >The Commission on Judicial Discipline has an opening for an alternate commissioner in Clark County beginning August 22, 2011. The
    appointment term is for four years. There are no term limits. The Board of Governors of the State Bar of Nevada shall appoint an
    attorney member to fill the vacancy.
    >
    >The commission was created by a constitutional amendment to investigate allegations of judicial misconduct in office, violations of
    the Code of Judicial Conduct or disability of judges. The commission meets approximately six times per year in regularly scheduled
    meetings and as necessary by telephone conference meetings. The commission also conducts formal hearings as a Court of Judicial
    Discipline. The commissions main office is located in Carson City. Some travel is required.
    >
    >If you are interested in applying for this position, please complete this application form
    (http://nvbar.org/sites/default/files/AttorneyApplication.pdf) and return to Gale Skala, 600 E. Charleston Blvd., Las Vegas, NV 89104,
    gales@nvbar.org. All applications must be received no later than August 10, 2011.
    >
    >
    >
    >-----
    >
    >Las Vegas Justice Court Civil Division Begins Mandatory E-Filing
    >
    >Effective August 1, the civil division of the Las Vegas Justice Court implemented mandatory e-filing. To make the transition to e-
    filing easier, the Justice Court is offering one-hour, free e-filing training sessions.
    >
    >The sessions will take place in the Jury Assembly Room on the third floor of the Regional Justice Center, 200 Lewis Ave., Las Vegas,
    Nevada. Sessions are limited to 50 participants. A schedule of training sessions (http://www.clarkcountycourts.us/clerk/electronic-
    filing.html) is available on the courts website.
    >
    >Those who would like to attend should e-mail their preferred session date, along with their name, address and law firm or company
    name to berna@clarkcountycourts.us.
    >
    >
    >
    >-----
    >
    >Legislative Update Week: A Series of CLE Webinars
    >
    >The CLE department of the State Bar of Nevada is hosting a webinar series on legislative updates during the week of August 22-26.
    Online registration is now open. Sign up for three or more webinars and save 25 percent. All webinars are one to one and a half hours
    in length and take place around the lunch hour.
    >
    >Take this opportunity to find out whats new in your practice area as a result of the most recent legislative session. For a list of
    available webinars and to register, visit the state bars website (http://www.legalspan.com/nvbar/cart.asp?UGUID=&AddItem=20110713-
    166130-154550&ItemLocationID=116268&NextPage=http%3A%2F%2Fwww.legalspan.com%2Fnvbar%2Ftelephone.asp%3FUGUID%3D).
    >
    >
    >-----
    >
    >State Bar of Nevada Career Center
    >
    >The State Bar of Nevadas career center is a valuable search and recruitment resource for legal professionals and employers in
    Nevada. The bars career center offers simple and easy-to-use tools to make your search for career opportunities and qualified
    professionals fast, efficient and successful. Visit the career center on the state bars website to begin your search
    (http://l.nv.bar.associationcareernetwork.com/Common/HomePage.aspx).
    >
    >
    >-----
    >
    >Reno Members Invited to Attend Reception for Oregon School of Law Dean
    >
    >Alumni of Oregon Law invite Reno area attorneys to meet the new dean of the University of Oregon School of Law during his visit to
    Nevada. Michael Moffitt will attend a reception in his honor on Thursday, August 11 from 5 p.m. to 7 p.m. The reception will take
    place in the offices of Armstrong Teasdale, LLP, Bank of America Building, 50 West Liberty St., Ste. 950, Reno, Nevada.
    >
    >If you plan to attend, please RSVP by August 8, to Louis Bubala at (541) 346-3970 or dmt@uoregon.edu.
    >
    >
    >-----
    >
    >BAR PRODUCTS
    >
    >* Live CLE: http://64.77.93.72/content/live-seminars
    >* Online CLE (http://www.legalspan.com/nvbar/intro.asp)
    >* Audio CLE: http://www.legalspan.com/nvbar/self-study.asp?UGUID=
    >* Publications: http://64.77.93.72/node/24
    >
    >Featured CLE Seminar
    >
    >Refuse to Work for Free: How to Shrink Lawyer Receivables
    >It is a myth that all good clients pay on time when satisfied with good and timely legal work. Join Gary Richards as he discusses
    accounts receivables. Learn how to collect existing, past due receivables using professional, proven methods while still maintaining
    good client relationships.
    >
    >Thursday, September 15, 2011
    >Reno: NNBC
    >Friday, September 16
    >Las Vegas: UNLV Stan Fulton Bldg.
    >
    >9:00 a.m. - 12:15 p.m.
    >3 CLE Hours (.5 Ethics)
    >
    >Register Online (http://www.legalspan.com/nvbar/catalog.asp?ItemID=20110323-166130-123209)
    >
    000909
    Jackson Pawluck
    RE: Jackson Pawluck
    >_______________________________________________
    >
    >View past E-Newsletters: http://www.nvbar.org/publications/enews/archives.htm
    >
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    http://www.nvbar.org
    >
    >E-Newsletter submissions: Melinda Catren, melindac@nvbar.org
    >
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    >600 E. Charleston Blvd.
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    >1-800-254-2797
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    From: ZC (zachcoughlin@hotmail.com)
    Sent: Sun 10/16/11 1:20 AM
    To: nvlawyer@nvbar.org
    1 attachment
    IMG_20111016_010711.jpg (772.1 KB)
    Hi NV Lawyer! Great idea for an animal issue. I wish I had a dog or some pet in my twenties. Now I have Jackson, I got him about 6
    months ago from the SPCA shelter in Reno as a three year old Pekingnese. My ex took our toy pomeranian, Palin. Just Palin. Jackson
    stayed with me and we have a great time going on rides in the car, barking at ducks and only the meanest and biggest looking dogs,
    and playing chase around the office. Jackson is not as affectionate as my female pomeranian Palin was and not as willing to jump up
    in any strangers lap and soak up attention and petting. It took a while but he seems to have warmed up to me. He ran away at any
    opportunity at first and I nearly collapsed chasing him half a mile once. However, recently I forgot that I had tied him up in the
    front yard so he could get some fresh air and sun, driving off for hours. I was worried sick when I arrived home and realize I had
    left him out and he had broken his rope. However, I heard strange noises coming from the back gate and found him there clawing at it
    and whimpering. He didn't want to run away and I was so glad he was okay.
    Sincerely, Zach Coughlin, Esq.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Tue 10/18/11 4:05 PM
    To: nvlawyer@nvbar.org
    000910
    member attorney address change
    Dear Ms. Carten,
    I am contacting you on behalf of my client, Jackson Pawluck. We feel your stated "first come, first serve" policy is facially discriminatory and unduly
    burdensome to individuals belonging to the rarely cited Pekingnese protected class found in Title K9. Mr. Pawluck descends from a regal procession
    of lion monkey dogs kept as warmers in the Peking (now Beijing) Emperor's robe sleaves, and as such, he is used to not needing to do anything in
    a hurry, like pose for a picture to be included in a submission to a legal periodical, even one as august as yours. As such, Mr. Pawluck's includion
    in this protected class has a causal relation to the damages incurred incident to your application of this discriminatory "first come first serve"
    selection criteria. The damages incurred by my client are such that no less than $2,000,000 in compensatory and $2,000,000 in punitive damages
    are appropriate. We will settle this matter, however, in exchange for the cover fo the December issue.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited.
    CONFIDENTIALITY NOTICE
    This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under
    applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the
    contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail
    from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or
    other applicable privilege.
    IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this
    communication (including any attachments) was not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding tax-related penalties or (ii)
    promoting, marketing or recommending to another person any transaction or matter addressed in this communication.
    > From: nvlawyer@nvbar.org
    > To: zachcoughlin@hotmail.com
    > Subject: RE: Jackson Pawluck
    > Date: Tue, 18 Oct 2011 15:41:11 +0000
    >
    > Thank you so much for your submission. We will do our best to get this in, but it is dependent on how much space we have left at this point;
    we're kind of taking a "first come, first serve" approach. But I'm hoping we'll have room for everyone who submitted.
    >
    > Thank you again!
    >
    > Melinda Catren
    > State Bar of Nevada
    > Nevada Lawyer Coordinator
    >
    > -----Original Message-----
    > From: ZC [mailto:zachcoughlin@hotmail.com]
    > Sent: Sunday, October 16, 2011 1:20 AM
    > To: nvlawyer
    > Subject: Jackson Pawluck
    >
    > Hi NV Lawyer! Great idea for an animal issue. I wish I had a dog or some pet in my twenties. Now I have Jackson, I got him about 6 months ago
    from the SPCA shelter in Reno as a three year old Pekingnese. My ex took our toy pomeranian, Palin. Just Palin. Jackson stayed with me and we
    have a great time going on rides in the car, barking at ducks and only the meanest and biggest looking dogs, and playing chase around the office.
    Jackson is not as affectionate as my female pomeranian Palin was and not as willing to jump up in any strangers lap and soak up attention and
    petting. It took a while but he seems to have warmed up to me. He ran away at any opportunity at first and I nearly collapsed chasing him half a
    mile once. However, recently I forgot that I had tied him up in the front yard so he could get some fresh air and sun, driving off for hours. I was
    worried sick when I arrived home and realize I had left him out and he had broken his rope. However, I heard strange noises coming from the back
    gate and found him there clawing at it and whimpering. He didn't want to run away and I was so glad he was okay.
    >
    > Sincerely, Zach Coughlin, Esq.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/21/11 3:51 AM
    To: suzannew@nvbar.org
    000911
    FW: member attorney address change
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/21/11 4:27 AM
    To: suzannew@nvbar.org
    Dear Suzanne,
    I forgot to included my Suite number earlier, #2:
    817 N. Virginia St., suite #2, Reno NV 89501.
    From: zachcoughlin@hotmail.com
    To: suzannew@nvbar.org
    Subject: member attorney address change
    Date: Mon, 21 Nov 2011 03:51:34 -0800
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    000912
    RE: member attorney address change
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 11/28/11 11:36 AM
    To: suzannew@nvbar.org
    Dear Suzanne,
    Please list my address on the www.nvbar.org website as:
    Zach Coughlin
    817 N. Virginia St. #2
    Reno, NV 89501
    tel: 775 338 8118
    fax: 949 667 7402
    website: www.ZachCoughlinEsq.wordpress.com
    If it is possible to list patent law as a specialization (I am licensed before the USPTO) I would appreciate that.
    Thank You,
    Zach Coughlin
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: SuzanneW@nvbar.org
    To: zachcoughlin@hotmail.com
    Subject: RE: member attorney address change
    Date: Mon, 28 Nov 2011 16:11:37 +0000
    Hi Zach,

    Please let me know how your address should be listed on your profile.

    Thank you

    From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
    Sent: Monday, November 21, 2011 4:28 AM
    To: Suzanne Walters
    Subject: FW: member attorney address change
    000913
    member attorney address change
    Dear Suzanne,
    I forgot to included my Suite number earlier, #2:
    817 N. Virginia St., suite #2, Reno NV 89501.
    From: zachcoughlin@hotmail.com
    To: suzannew@nvbar.org
    Subject: member attorney address change
    Date: Mon, 21 Nov 2011 03:51:34 -0800
    Dear Suzanne,
    I am writing to indicate that I have changed my address. I don't know whether it will be a temporary or permanent change. I
    am seeking a stay of an eviction order in Reno Justice Court from my home law office, where I argued a retaliatory eviction
    defense, amongst others....for now I am set up at the Silver Dollar Motor Lodge at 817 N. Virginia St., Reno NV 89501.
    Richard G. Hill, Esq. is withholding my cell phone, my registered contact number of 775 338 8118, but I have a temporary
    cell of 775 229 6737, though email is probably more reliable and quicker, it remains zachcoughlin@hotmail.com. Further, I
    still have my voxox.com fax number of 949 667 7402.
    Sincerely,
    Zach Coughlin, Esq.
    121 River Rock St.
    Reno, NV 89501
    775 338 8118
    Licensed in Nevada
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Sat 12/31/11 12:09 AM
    To: suzannew@nvbar.org
    Dear Ms. Walters,
    Sorry to have to do this again, but I am writing to update my address again, it is:
    PLEASE NOTE, I HAVE A NEW, NEW ADDRESS for all purposes and to please be listed at www.nvbar.org:
    Zach Coughlin, Esq.
    1422 E. 9TH ST. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    000914
    Attorney reporting under SCR 111
    supplemental FW: Attorney reporting under SCR 111
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the
    specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error
    and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
    recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
    notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
    you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
    immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 1/23/12 3:17 PM
    To: davidc@nvbar.org
    Dear Bar Counsel Clark,
    It has recently come to my attention that Nevada Supreme Court Rule 111 may apply to a criminal conviction I received (and for which an appeal
    is currently pending) in Reno Municipal Court in case RMC 11 CR 22176 for the offense of petit larceny of a chocolate bar and some cough drops.
    Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
    determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada v. Claiborne,
    1988, 756 P.2d 464, 104 Nev. 115.
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 1/23/12 4:19 PM
    To: davidc@nvbar.org
    Dear Bar Counsel Clark,
    I am not sure it applies under SCR 111, but I was also found guilty (in the same matter in Reno Municipal Court 11 CR 22176) of NRS 22.030:
    "NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court;affidavit or statement to be filed when
    000915
    contempt committed outside immediateview and presence of court; disqualification of judge.
    1. If a contempt is committed in the immediate viewand presence of the court or judge at chambers, the contempt may be punishedsummarily. If the court or judge
    summarily punishes a person for a contemptpursuant to this subsection, the court or judge shall enter an order that:
    (a) Recites the facts constituting the contempt in theimmediate view and presence of the court or judge;
    (b) Finds the person guilty of the contempt; and
    (c) Prescribes the punishment for the contempt.
    2. If a contempt is not committed in the immediateview and presence of the court or judge at chambers, an affidavit must bepresented to the court or judge of the
    facts constituting the contempt, or astatement of the facts by the masters or arbitrators.
    3. Except as otherwise provided in this subsection, ifa contempt is not committed in the immediate view and presence of the court, thejudge of the court in whose
    contempt the person is alleged to be shall notpreside at the trial of the contempt over the objection of the person. Theprovisions of this subsection do not apply in:
    (a) Any case where a final judgment or decree of thecourt is drawn in question and such judgment or decree was entered in suchcourt by a predecessor judge
    thereof 10 years or more preceding the bringing ofcontempt proceedings for the violation of the judgment or decree.
    (b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family courthas been established in the judicial district."
    My understanding of the expressed rationale for the Contempt finding is that it related to my saying "Wow" in relation to a particular ruling of the
    Court, and continuing lines of inquiry after the Court rule against me on a particular objection, as well as, I believe, "derogating the authority of the
    Court".
    Sincerely,
    Zach Coughlin
    From: zachcoughlin@hotmail.com
    To: davidc@nvbar.org
    Subject: Attorney reporting under SCR 111
    Date: Mon, 23 Jan 2012 15:17:52 -0800
    Dear Bar Counsel Clark,
    It has recently come to my attention that Nevada Supreme Court Rule 111 may apply to a criminal conviction I received (and for which an appeal
    is currently pending) in Reno Municipal Court in case RMC 11 CR 22176 for the offense of petit larceny of a chocolate bar and some cough drops.
    Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
    determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada v. Claiborne,
    1988, 756 P.2d 464, 104 Nev. 115.
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    000916
    need a duplicate bar card
    reporting forms able to be complete online?
    SCR 111
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Thu 2/09/12 4:07 PM
    To: suzannew@nvbar.org
    Dear Suzanne,
    Hello, I had to move a couple times recently and cannot locate my NV bar card. The Washoe County jail requires one to see
    inmates/clients....Or, at least they do until they can verify that one is actually an attorney and my driver's license and member
    information link at www.nvbar.com is not sufficient. Can I get a replacement/duplicate bar card?
    Sincerely,
    Zach Coughlin, Esq.
    1422 E. 9th St. #2
    RENO, NV 89512
    tel: 775 338 8118
    fax: 949 667 7402
    ZachCoughlin@hotmail.com
    Nevada Bar No: 9473
    ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If
    you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any
    action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product
    or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
    reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from
    your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
    privilege.
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 9:51 PM
    To: suzannew@nvbar.org
    Dear Suzanne,
    I paid my bar dues online today, yet I have been unable to figure out where or have to complete my reportings forms for the year...Maybe I
    already did so, and therefore the option to do so is not available online? Can you tell me if I have so reported or whether the ability to do so is no
    longer available online? I am sorry for any inconvenience this may cause, but I am writing in an abundance of caution.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 10:19 PM
    To: glennm@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    000917
    SCR 78.5 & SCR 217 ACKNOWLEDGEMENT AND CERTIFICATION OF COMPLIANCE AND
    CONSENT TRUST ACCOUNT
    I contacted you and the State Bar of Nevada recently (about a month ago) in regard to SCR 111. I had to move recently and moved in with two
    individuals who I ultimately wound up getting Protection Orders against, and they have interferred with my ability to receive my mail with
    absolute certainty (I have received much of my mail, and have pending correspondences/requests with the Postmaster for Reno, NV to obtain a
    permanent and newly rekeyed lock and key to access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister
    that if I fax him proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call
    him again tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an electronic
    filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State
    Bar of Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax number or email address.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Wed 2/22/12 11:00 PM
    To: glennm@nvbar.org; davidc@nvbar.org
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    I am writing with regard to a question I encountered in my yearly compliance forms. I do not believe I "handle any client or third party funds", I
    am trying to grow my practice and it has not come up heretofore. However, recently I had a situation where I may have so handled such funds... I
    am not sure. One client referred a friend of hers to me who was in jail, and now is in jail again after being released. This individual was/is
    essentially homeless or staying with friends and had an issue with getting her mail, as it was being delivered to different family members of hers,
    who were apparently unhappy about that and seemed to be refusing to cooperate in passing this individuals mail on to her.
    To assist this individual I went to the jail to meet with her at her request, as relayed to me by the client who referred her to me. I had moved
    recently and was unable to find my bar card, and as such was not allowed a "face to face" meeting with the individual, and further the "webcam"
    interaction we were afforded lacked audio on her end, so the whole situation was hampered by communication problems, though I did utilize pen
    and paper and mouthing out words, etc...and it was my impression that the individual agreed for me to do a Change of Address and receive her
    mail until such time as she could make other arrangments. I spoke with her brother and the client/friend we had in common also in making this
    assessment. This was prior to my difficulties in receiving my mail became clear. I did ultimately receive some of her mail, and she is aware of
    that. I went up to the jail and met with her again recently and it was agreed that I would pass the mail of hers I had (which did include what
    appeared to be two checks totalling about $300 from the US Treasury (this individual opened the mail that I brought her in jail and her request that
    I have the amounts put on her "books" or commissary at the jail was not possible or ill advised given the jail's policies with respect to checks that
    inmates receive that may be deemed "government benefits"...as such the individual advised me to give this mail to her "Power of Attorney" friend,
    and I did shortly thereafter. The individual, in my second trip to the jail informed me that she just could not afford an attorney. During the first
    visit I had with her at the jail she had seemed to indicate I could get her mail via filing a Change of Address on her behalf, and cash the checks
    and take $500 for my fees to commence some sort of representation of her, however, again, the severe communications difficulties attendant to
    our very limited "web cam at the jail" interaction made it seem rather dubious that a true agreement was reached and I utlimately decided not to
    cash any of her checks, especially considering the lack of a signed retainer, etc., etc. This individual go out of jail shortly after my first visit and my
    attempts to communicate with her went unresponded to. My subsequent attempts to track her down resulted in my becoming aware that she was
    back in jail again...whereupon I went to visit her and brought the mail of hers that I had..
    Sorry this is so long winded, but filling out these online forms resulted in my not knowing quite how to answer the question posed below. To the
    extent having some of her mail for a few weeks (which included a couple checks) is considered "handling client or third party funds", I am writing
    to inform you of the above events. However, for my compliance report I marked that I do not handle client or third party funds, though, should
    this change, I will follow the rules applicable to such situations and create the necessary trust accounts.
    The reporting form indicated:
    SCR 78.5 & SCR 217 ACKNOWLEDGEMENT AND CERTIFICATION OF COMPLIANCE AND CONSENT TRUST ACCOUNT Every active member of the
    State Bar of Nevada must acknowledge compliance and consent to the Rule annually. Please do not report financial institutions outside of Nevada.
    By submitting below you agree to follow and acknowledge you are in compliance with and consent to the provisions of SCR 78.5. I am exempt from
    having a trust account pursuant to SCR 78.5 because I handle no client or third party funds in the state of Nevada. If you check this box, you are
    done with this section. I or my firm maintain(s) a trust account/s listed below. Please list all trust account maintained by you or the law firm in
    which you work.
    At the time of the relevant events in question it was not clear to me how these facts play out in relation to the above rules, and I resolved to
    ascertain the appropriate course of action in the context of the somewhat exigent circumstances attendant to this individual being in jail, having
    family that was no cooperative in holding her mail for her, and her not having much in the way of a fixed address....To be clear, I have received no
    money whatsoever in connection with any of this, I have not cashed any check belonging to her or endorsed any financial instrument, etc., etc.
    This individual informed me that she has subsequently had a new Change of Address filed with the USPS to have the mail forwarded to the man
    she referred to as her "Power of Attorney" and I do not believe I am receiving any of her mail any longer. I can provide her name and information
    if that is prudent to do, however, I refrained from doing so her in an abundance of caution vis a vis any confidentiality issues that may be present.
    Sincerely,
    000918
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    From: zachcoughlin@hotmail.com
    To: glennm@nvbar.org; davidc@nvbar.org
    Subject: SCR 111
    Date: Wed, 22 Feb 2012 22:19:12 -0800
    Dear Bar Counsel Clark and Assistant Bar Counsel Machado,
    I contacted you and the State Bar of Nevada recently (about a month ago) in regard to SCR 111. I had to move recently and moved in with two
    individuals who I ultimately wound up getting Protection Orders against, and they have interferred with my ability to receive my mail with
    absolute certainty (I have received much of my mail, and have pending correspondences/requests with the Postmaster for Reno, NV to obtain a
    permanent and newly rekeyed lock and key to access my mailbox...I have been informed by USPS Reno Postmaster agent named Mr. Heister
    that if I fax him proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made...I faxed him proof and will call
    him again tomorrow to see how much longer I must wait....if its much longer I will make alternate arrangments, however, I am an electronic
    filer in both courts that I am appearing in (NVB and WCDC)...). I am writing to ask that any correspondences/notices etc. that you or the State
    Bar of Nevada may have for me or may have mailed to me be, if possible, copied to me via my fax number or email address.
    Sincerely,
    Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
    000919

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