more of the formal grievance against Skau, Young, Leslie, and Dogan RE:

formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911
calls missing from what was produced by City Attorney Skau
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 12/04/12 3:08 PM
To: complaints@nvbar.org (complaints@nvbar.org); patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org
(davidc@nvbar.org); je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com);
cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net
(eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); rosec@nvbar.org (rosec@nvbar.org);
laurap@nvbar.org (laurap@nvbar.org); philp@nvbar.org (philp@nvbar.org); glennm@nvbar.org
(glennm@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org
(schornsby@nvdetr.org)
Dear Office of Bar Counsel, NNDB, Panel, and President Flaherty,
Please forward 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 for all the dirty deeds done not so cheap by his cadre of
malevolent, corrupt, deputy city attorneys.
Clerk of Court Peters has been refusing to allow me to have a file stamp copy of my filings, save an introductory few instances...please Order her to do so.

While I was never sent the 10/9/12 Affidavit of Laura Peters that the SBN and Peters slipped into the Formal Disciplinary File, incongruously, inserted, bate
stamped, after the 10/30/12 Order by Chairman Susich (strange...how could it be file stamped October 10th, 2012, yet be filed after Chairman Susich's 10/30/12
Order? Eventually that Affidavit was provided to me on 11/8/12 (6 days before the formal disciplinary hearing, buried within 3,000 or more pages of documents (so
instead of the 27 days to review them called for by SCR 105(2)(c), I was affored 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 definately not my understanding that any Cease and Desist Order by Chair Echeverria or "stay away" letter by Patrick King means I can no longer file documents
in this matter, or that any failure by Clerk of Court Peters to provide me a file stamped copy of my filings means they are not filed or that the SBN is failing to abide
by its express declaration and agreements and pronouncements of the procedural policies and rules applicable to this matter wherein King, Peters, the
SBN/Panel/Board have failed to provide me any written adopted procedural rules, have made numerous declarations and express indications of specific policies
and rules attendant to my utilizing subpoenas (which King fraudulently mislead the Panel as to in his Motions to Quash and in his argument during the 11/14/12
Hearing...noticeably absent is an Affidavit from King regarding what he communicated to Coughlin respecting David Clark's ruling on Coughlin's use of subpoenas
and the procedural mechanics attendant thereto, or, even more noticeable, is an mention by Laura Peters in her 10/9/12 Affidavit respecting the permission to fax
file granted to Coughlin in this matter.
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.
110812coughlin 063341 Reno City Attorney Skaur at 25 minute mark violates duty of candor to tribunal and fairness to opposing counsel considering 11 9 12 email by
Skau.wmv
From: zachcoughlin@hotmail.com
To: homerj@reno.gov; skauc@reno.gov; zyoung@da.washoecounty.us; complaints@nvbar.org; patrickk@nvbar.org; davidc@nvbar.org; je@eloreno.com;
skent@skentlaw.com; cvellis@bhfs.com; mike@tahoelawyer.com; eifert.nta@att.net; nevtelassn@sbcglobal.net; rosec@nvbar.org; laurap@nvbar.org;
philp@nvbar.org; glennm@nvbar.org; fflaherty@dlpfd.com; fflaherty@dyerlawrence.com; tsusich@nvdetr.org; schornsby@nvdetr.org;
bdogan@washoecounty.us; jleslie@washoecounty.us
Subject: formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing from what was produced by City Attorney Skau
Date: Tue, 4 Dec 2012 14:07:52 -0800
Dear Office of Bar Counsel,
This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
To: zachcoughlin@hotmail.com
Cc: Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been
effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments.
However, they consisted mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to
obtain the documents, as set forth hereafter.
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 office and were directed to leave the Judges Order and the City's
motion at the front of that address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these
items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However,
they consisted mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the
documents, as set forth hereafter.
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 office and were directed to leave the Judges Order and the City's motion
at the front of that address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that
address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau fraudulently
procurred Couglin's attendance at the 11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting contstructive service
prior to the 11/13/12 hearing date set...This prejudiced not only Coughlin's formal disciplinary hearing but also the petty larceny trial of 11/19 and 11/20 and is a straight
scum bag move by Creig Skau.
Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the JAVS
audio transwcript of 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 fails to inform the court of the waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez (whom, somehow, Judge
Sferrazza was apparently aware of and had opinions on....curiously).
Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341 (really,
everything Jim Leslie did in this case or any other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is dragging his feet,
your honor...He's wasting county assets."...Really, Jim, this is a grievance against you for seeking to coerce a waiver of Coughlin's fifth amendment rights incident to
your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression Hearing or the Trial..and a greivance against DDA Young for similarly
coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the first for 11/20 to get an idea of the hysterics DDA
Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep Coughlin's laptops over night...but there is some really bad
audio on there with Judge Sferrazza and DDA Young getting completely coercive with respect to a waiver of Coughlin's Fifth 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 of custody on the condition
that he testify! If he won't do it TAKE HIM BACK INTO CUSTODY!"
add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive any
reports from dispatch of "a possible fight" where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and therefore, such
allegations of a report from dispatch of "a possible fight" did not bare on Duralde's probable cause/reasonable suspicion analysis. further 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
inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant Tibbals or anyone with the
WCPD.
And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon arriving...yet,
every bit of 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 if someone doesn't claim it right now" was continually excluded as "hearsay"....
A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):
Dear Judge Sferrazza and DDA Young,
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial
directed to my issues with Mr. Leslie's representation (I am too tired to fully 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 of the burglary charged in Count 2. Since a thief cannot receive from himself the fruits of his larceny, the jury
must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to
Leslie's failure to utilize any of the work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and
Rosa could not have received the dispatch text of 11:27:11 pm reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to
Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the Dispatch recordings (and those provided by City
Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid of anything for the 6 minutes in
which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which
required production of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a
possible fight" was the main justification for the pat down and search incident to arrest and led to a justification for 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 therefore 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 further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge Sferrazza
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 of the 911 calls are missing. There is no audio of 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 filming/recording the arrest. Had I not captured a recording of 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 Officer 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 testify to seeing the phone light up in Coughlin's
pocket...but wait...yeah, that's it...he saw it light up from all the way across the skate park...but wait...come November
19th, 2012 he changes his story and decides he saw it light up from "2 to 3 feet away from Coughlin"....There a movie
floating around somewhere out there that does a timeline of 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 for DDA
Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the
pat-down search of the Defendant was proper under the totality of the circumstances. 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." And, of course, Officer Duralde responded splendidly to Coach Young's, er, DDA
Young's training regime and sang the "possible fight...report from dispatch of a possible fight" tune all the live long
day...which was the basis for the reasonable suspicion for the pat-down (and Judge Sferrazza 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 testifying to a multitude of 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 of the players in
the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document,
a footer indicating a "printed on" date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more
specific, particularized facts in support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney whom dared to
answer one of the officer's questions by asking a question seeking clarification as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a
finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the Officer's did not receive the text from dispatch reporting Goble's second 911 call
wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year old Austin Lichty (who is captured on the video of the
moments(file named: VID_20110820_232423 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 from being deemed "reliable citizen witnesses" and Officer
Duralde indeed did have, and admitted to in his testimony at trial to being aware of, the "gross inconsistencies"
Goodnight pointed out between the hearsay and double hearsay Duralde testified to at trial after "refreshing his
recollection" upon a review of 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 of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to (the
password for the phone)...and when Goble alleges Duralde gave him back the phone...and the call into the iPhone at
11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for 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) testified that RPD Officer
Duralde committed misconduct by lying about the purported order or point in time in relation to the arrest and search of
Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde removed the phone from
Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask question related to the
phone and to verify ownership of the phone (which would include gathering the phone number for the iPhone, which
necessarily would mean that Duralde's allegation of only searching Coughlin after performing some call to the iPhone
and hearsaying it vibrate (even though multiple witness (Templeton, Zarate, Goble, Lichty testified that they heard no such
buzzing or vibrating of the phone, hostile witnesses all) Goble testified that Duralde already had the iPhone prior to
Goble conferring with Duralde or otherwise giving Duralde any phone number to call in an attempt to verify 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 from the date of conviction to report a conviction to the State Bar of Nevada and the United States Patent
and Trademark Office (USPTO) for 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 of record for 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 Sferrazza's contention that Coughlin "has had forever to get his defense ready in
this case" and that "no continuance will be granted on account of the formal disciplinary hearing before the State Bar of
Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge
Sferrazza indicated some canon preventing him from testifying at the formal disciplinary proceeding...that didn't stop
063341 being specifically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's
case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori Townsend from sending into the SBN
Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the SBN Coughlin's
2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie
finally released them o October 30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case.
Coughlin had to pull together a defense in his formal disciplinary hearing before the SBN despite the SBN gipping him
out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on 11/14/12 after service of the Complaint
and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point
is, if the RJC and both of you want to be associate with a Schaeffer style Mirch-ing, then this may be your chance. But
you won't be able to say you didn't have plenty of 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 failure to turn over anything to me in the "hand off transmittal" he insisted upon (despite a digital transmission
being required per the Order of Judge Sferrazza, I believe) requires some explanation.
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith attempt
to comply with Judge Sferrazza 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 of 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 frame picture culled from a video Coughlin took of the moments prior to the arrival of the RPD, being
handed by the "man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton
testifying that they do not know that man and did not know him prior to that night at all....Coughlin respectfully demanded
of the RPD Officers, at the time of his arrest, that they gather the identify of the "man with the gauged ears", however,
Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to steal his
bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were
"unsubstantiated"). Oddly, in the attached still frame, 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 first (if the file 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 of 11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls
for Service Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911 entry for
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 from me for at least 5 years, if not forever....and DDA Young...over some alleged
"skater sets his iPhone down on the concrete in the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in
Reno, "man with a six pack of beer" picks it up, offers it up, receiving no response threatens to "throw it in the river if
someone doesn't claim it immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's
Narrative of unknown origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing
from Goble in his Narrative)
contain the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on
him" one can hear Officer Duralde indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the video
Coughlin filmed of the arrest, title:

Then, Offi cer Rosa i s proven to be on the bri dge and not i n hi s squad car readi ng texts from di spatch n the fol l owi ng ti me stamped fi l e: "PRI MARY RADI O TRAFFI C Start_Ti me = Saturday,
August 20, 2011 11-26-30 PM Source_I D = 12 RPD Rosa sayi ng charl es 396 on the other end"
Further, Offi cer Dural de's arri val on the scene i s notated i n the di spatch l og at the
I ts not at al l cl ear why Goodni ght onl y apparentl y recei ved then forwarded to hi s cl i ent on November 30th, 2011 the "Ori gi nal Suppl emental " contai ni ng Offi cer Dural de's Narrati ve, that
i s sti l l of i ndetermi nate date of ori gi n (there are a number of "date of pri nti ng" vari ati ons...).
That I know of, there were three 911 calls (two by Gobl e, one by Coughl i n, i n that order):
1. 082011 112252pm to 112530pm 911 by Gobl e di spatch Weese l og l arc of phone susps os l eft on post l i ghti ng up i n sups pock RP screami ng at susp
2. 082011 112620pm to 112740pm 911 by Gobl e di spatch Montgomery l ogs rp cal l back re someone just socked a mi nor, wai ve that cop down 10 10 wi th open l i ne
3. 082011 112645pm to 112752pm 911by Coughl i n Di spatch Weese l ogs cal l from phone wi th open l i ne yel l i ng re steal i ng phone peopl e cheeri ng cops are here then cal l di sconnects
And Coughl i n fi l med three videos that ni ght of the arrest that are rel evant, two just pri or to the RPD arri vi ng (and actual l y, whi l e Rosa and Dural de were al ready on the scene and out of
thei r vehi cl es after teh 11:26:00 pm mark as i ndi cated by the Ecomm recordi ngs and di spatch l ogs...
1. VI D_20110820_232413 your al l on tape now gobl e and fri ends.3gp 8 seconds l ong
2. VI D_20110820_232423 austi n l i chty templ eton gobl e zarate chan rpd i phone assaul ti ng and battery Coughl i n jusrt pri or to RPD rcr.3gp 46 seconds
3. VI D_20110820_232801 offi cer dural de and rosa 8 20 11 arrest.3gp 5 mi nutes 52 seconds l ong
And the AT&T cal l records for the i Phone reveal onl y four cal l s occurred i n or out duri ng the rel evant ti me frame:
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 successfully kept every single witness from specifically identifying who made what call and when and where to any
extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh, that's
Colton" 8 feet from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the
misconduct of 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 four hours later by a 3 Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's
wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look at the
circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property
taxes appeal due on 3/10/12 for Paul Elcano, and had a Trial before Judge Linda Gardner in a divorce case on 3/12/12...and
the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues printing it out and
bringing it with me (my legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for subpoena fees....the
usual)...
Somehow at the Heari ng on the Suppressi on Moti on DDA Young was abl e to get i nto evi dence excl usi vel y hearsay testi mony (often unattri buted to anyone i n parti cul ar) to support hi s
wi n on the "suffi ci ent probabl e cause to support a search i nci dent to arrest" despi te NRS 171.136 forbi ddi ng such an arrest (where Dural de obvi ousl y overcharged the al l eged cri me as a
"fel ony grand l arceny"...even maki ng smug commentary about the "certai n benefi ts of chargi ng thi s as a fel ony" and sayi ng "oooh, that's a fel ony", both matters that Lesl i e i nsi sted
refrai ni ng from getti ng i nto whi l e he was attorney of record, and further, despi te Coughl i n compl yi ng wi th NRS 174.345 (even spl urgi ng on the return recei pt requested to go al ong wi th
the certi fi ed mai l for Dural de) Coughl i n was deni ed the ri ght to cross exami ne the arresti ng offi cer...whi ch i s too bad consi deri ng hi s Narrati ve al ternatel y cl ai ms that Gobl e tol d hi m
they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen
property charge.
COUNT I I . POSSESSI ON OF STOLEN PROPERTY, a vi ol ati on of NRS 205.275, a mi sdemeanor, i n the manner fol l owi ng, to wi t:
That the sai d defendant on or about the 20th day of August, 2011, at Reno Townshi p, wi thi n the County of Washoe, State of Nevada, di d wi l l ful l y and unl awful l y possess or wi thhol d
stol en goods havi ng a val ue l ess than Two Hundred Fi fty Dol l ars ($250.00), to wi t: an i Phone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property bei ng owned
by CORY GOBLE, for hi s own gai n or to prevent the true owner from agai n possessi ng sai d property, knowi ng that the property was obtai ned by means of l arceny or under such
ci rcumstances as shoul d have caused a reasonabl e man to know that such goods were so obtai ned.
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 from someone other than the defendant: 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 of violating 18 U.S.C. 2113(a), (b), and
(d) cannot also be convicted of receiving or possessing the robbery proceeds in violation of 2113(c). Heflin, supra, 358 U.S.,
at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff in
error, a...The next assignment of error is that the State failed to prove beyond all reasonable doubt that the automobile in
question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the
proof must show (1) that the property has, in fact, 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 for his own gain or to prevent the
owner from possessing it. (People v. Piszczek,404 Ill. 465.) Proof of these essential elements constituting the crime of
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 if 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 of the offense in order that the defendant may fully prepare a defense and be afforded
the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the
instant case, the indictment, drawn upon the conclusional premise that the property was stolen, fails 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 himself. Since one person cannot be both the thief and the receiver of stolen property nor receive
stolen property from himself, the fact 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 failed to charge the offense of receiving stolen property under section 16-1(d). A
conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant.
The omission of the words "stolen by another" in the indictment does not create the presumption that defendant had himself
stolen the property from the owner. The use of the words "* * * knowingly obtain control of 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 defendant obtained control of the property in question (in any manner whatsoever), the
property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what
may be implied from the clear phrasing of the indictment. At trial it is not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the
defendant was in possession of that property in order to prove the offense of theft under 16-1(d) (the former offense of
receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of
stolen property soon after a theft is evidence that the defendant stole the property himself but is not evidence of defendant'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 of the indictment herein permits a reader of the indictment to find, even
after only a cursory reading, the necessary elements of the offense, i.e., that the property was already stolen by another when the
defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of
these words would only be grammatically redundant and mere surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the
defendant guilty beyond a reasonable doubt. For this reason I, too, would reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in "larceny"
and "theft" cases. He erroneously urges that the state failed 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 for the value of property taken is the fair market value of
the property at the time and place it was stolen if 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 of the burglary charged in Count 2. Since a thief cannot receive from himself the fruits of his larceny, the jury
must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of 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 of handling the error effectively cured it. The error was not cured by the
setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found
the defendant guilty of 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 of the
crime of receiving stolen goods..17. Criminal Law. In prosecution for receiving stolen goods, where instruction given by
court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner
from again possessing property, defendant was not entitled to instruction which told jury that goods must have been
received with fraudulent intent of depriving owner of the immediate possession thereof. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary
examination, Henny Bernier was ordered to stand trial for possession of stolen property, a violation of NRS 205.275.1 Bernier
then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish
probable cause that she had committed the charged offense. 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 proof did not show that she knew the property was
stolen and that such knowledge cannot be inferred from mere possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a
conviction for possessing stolen property on the ground that the legislature did not intend to compound the punishment for
larceny or robbery by permitting a conviction for receipt or possession of 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 for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden
of proof of 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 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.
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 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 for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following two timestamped recordings finally 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 of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away
approximately two months prior to the 8/20/11 arrest, incident to the theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on the regard,
arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet" incident to the inappropriat placement by Judge Sferrazza of Leslie as "stanby
counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of avenging the criticisms
Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did,
deposit a "rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich man's opposing
counsel Casey Baker, Esq. coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon Judge Sferrazza . You
are to his constituency by remixing is previous order regardless of 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 of a summary proceeding that in year to the landlords benefit were adhered to where is all of the
procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to bring counterclaims were matters Coughlin was precluded from
accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on
November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff
Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it
Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury
that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County
public defender applying good nicely peers deciding that the night was doing too much to assist Coughlin in defending himself 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 filling in for Goodnight with and indication Goodnight's December 19, 2011 file stamp
discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the Defendant,
ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the following discovery
pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or confessions made by the Defendant
or any witness, or copies thereof, within the possession, custody or control of the State, the existence of which is known or by the exercise of due diligence may become
known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including those preserved on pocket recording devices, 9-1-1
emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling the extent to which on the record at that July 16
trial date Washoe County public defender 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 for 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 of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim Leslie felt that the judges of
the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr. Leslie has any skin in this game whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and
malpractice and apparently willing disregard for the rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe County
District Attorney's Office and therein secure added boys from local law enforcement District Attorney's Office and perhaps the Reno justice court itself. Further Reno
Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders office in connection with February 27, 2012 clandestine
status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted 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 confiscation without a search warrant or court
order of any kind (or at least one ever served on Coughlin in any manner) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt
finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on February 27, 2012 in RMC case 11 TR 26800 for which
Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict between that traffic citation trial in the Reno Muni court which stemmed
from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno employees of and
admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a
criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal trespass conviction has now become the subject of a Nevada Supreme Court case
in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and
his landlord client, and a summary eviction matter that judge Sferrazza presided over wherein judge Sferrazza purportedly controlled the civil division of the Reno justice
court to the extent that Coughlin's notice of appeal on December 26 submitted for filing December 26, 2011 was not file stamped by the civil division staff of the Reno
justice court. This impropriety is further problematic where Coughlin had served upon the Reno justice court's custodian of records and she civil clerk Karen Stancil (whom
Richard Hill references in his January 12, 2012 letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against Coughlin to
the State Bar of Nevada, which ultimately became one of the three grievances depicted numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105
Complaint filed 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 of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being
held with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal
complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in
a criminal trespass conviction of 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 officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial arrest on that day in where Lopez also admits none of
those individuals or anyone present that day identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about 5 feet high
underneath the former home law office wherein Coughlin was found at a time when Coughlin still had not receive back from the Reno justice court the impermissible $2275
rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza'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 fact in the civil division of the Reno justice court wherein tenants were in summary eviction matters were subject to forced rent escrow deposit in
violation of 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 of corollary
to justice court rule Las Vegas rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the Washoe
County Sheriff's office deputy Machen filed a false affidavit on November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction Decision
and Order and the October 27th Findings of Fact, Conclusion of Law, and Order of Summary Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal
trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact that his sister judge Linda Gardner is listed as the grievant (and him
goes to Pat King's awkward assertions that the "Clerk of 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 of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former
prosecutor judge Linda Gardner in comparison to the extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy
district attorney Young's repeated malfeasance misconduct violations stays pending competency or evaluations failure to turn over exculpatory materials failure to propound
discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions of
Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint
from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after
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 faith effort to achieve a
plea-bargain and resolve what is a messy case the city of 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 of the Reno justice court against Coughlin in the extremely quick like
40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false
statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that
Coughlin had already lost his appeal of summary eviction matter in 1708 Barber which judge Sferrazza presided and which was then on appeal before judge Flanagan
(whom subsequently had Coughlin with an outrageous $42,000 attorney fee award against Pro per appellant Coughlin in the appeal of the summary eviction order issued by
Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's office on April 19, 2012 which just happened to
coincide with the same day that deputy Dist. Atty. young fastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was assigned to
Coughlin appeal of the petty larceny conviction of a candy bar and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary
suspension of his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law
where tribal police officers affected a custodial arrest for a misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate
against doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom
testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar and some cough drops in
connection with Coughlin's selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact
that that Walmart alleges to have had absolutely no video footage supportive of 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 of Walmarts policies and where John Ellis of the W. 7th St., Walmart in any as yet unknown loss prevention associate specifically and expressly threatening abuse of
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 of
whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from the policy which
Walmart holds out to the public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at
Walmart.com no matter what the convenient for getting in misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher
he nor anyone with Wal-Mart on September 9th, 2011 affected a citizen"s arrest of Coughlin on that date in connection with the alleged petty larceny by Coughlin of a
candy bar and some cough drops which conveniently for the Reno Police Department just days after Coughlin filed a written complaint detailing the police misconduct by
Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20, 2011 in 063341 a justice court criminal
petty larceny and receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American jurisprudence that one cannot be
charged with both petty larceny and receiving stolen property of the same item particularly where the receiving of the item is alleged to have been from oneself after one
had larceny is the item lending an inference that Joe Sferrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as possible to affect the leverage over
Coughlin to mitigate the liability Reno justice court may face in connection with its numerous since is violating about law respecting the manner in which evictions are
carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory arrest and prosecution of Coughlin where the judiciary in Washoe
County is off criticizes being overly influenced by the District Attorney's Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court
judge Kenneth Howard (a 1981 graduate McGeorge school of law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the
Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed defender there despite his express failure 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 malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 reviews
Coughlin for causing the November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion of the hearing which are trial which judge Howard
down such a matter of public concern that he Five city of Reno employees at the courthouse until nine o'clock at night to get it done that in fact judge Howard admitted he
was wrong with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault that all and where the Reno Municipal Court had previously
granted a continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's criminal trespass
complaint (connected to the summary eviction matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the
city of Reno prosecutor's a continuance in light of 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 Sferrazza to denying Coughlin a hearing on his motion to contest
personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest personal property lien on November 17, 2011 even
where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as
Janice admitted when judge Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally 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 from his six-week vacation in late December
2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of
the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed 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 bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a violation of
the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court
filing office for something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate McGeorge
school law along with wash County Dist. Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently granted 2004
graduate McGeorge school of law deputy district attorney Zach young in order taking away the ability to file by fax from Coughlin a privilege that is accorded any other
criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 hearing at which Coughlin's then attorney public
defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young alleged who filed on November
26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that
Coughlin had merely comply with judge Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her
by the advocacy zealous are not of any sort whatsoever incident to his quote representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the
State Bar of Nevada communicated he and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the
State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org) (former law practice partners with an individual from Washoe Legal Services
whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed Coughlin's work before him and in Nevada Bankruptcy Court at
Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the hearing and in violation of
Supreme Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in any matters relative to
the ultimate Supreme Court rule 105 complaint against Coughlin for over six months at least and so in no way can be said to just stuff I his last-minute supplementing judge
Beesley and milquetoast attempts to provide Coughlin S supplemental designation of witness and summary of evidence and regard to both judge Beesley's testimony at the
hearing and Washoe legal services Executive Director Paul TESTIMONY at the hearing (both of those gentlemen attended McGeorge school of law in 1977 along with
Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of Coughlin's competency as an attorney at the hearing despite
the fact that neither of them could provide anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or
judge Beesley's case filings in judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is
interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/
Harris Esquire whom admitted to misappropriating some $755,000 from 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 for my client where it be $14 worth of candy bars and cough drops from
Coughlin and Coughlin's March 30, 2012 filing 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 affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by
Gail Kern Esquire Brown judge Schroeder of the Reno justice court wherein the audio record from 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 different order of hearing the cases
planned for that morning docket and despite the fact that the fax header on the summary eviction order that was hurriedly moved through indicates a time stamping of a
8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental
sometime shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they entered with their guns and/or pagers drawn in
and immediately placed Coughlin in handcuffs and told him he was detained in contrast to the typical procedures carried out by the Sheriff's office 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 for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for seeking an eviction to one for
non-payment of rent (seemingly in response to Coughlin Pre Hearing Brief pointing out the difficulties they would face 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 forming SCR 105 complaint for which a formal disciplinary hearing, the
grievance filed by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw
Coughlin under the bus at Coughlin's 11/14/12 formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will
claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy bar conviction that resulted in the current now 5 month long suspension of Coughlin's license to
practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of
SAMANTHA L. HALL, ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit
of Counsel Coughlin for Keller in Support of 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 fax to rmc regarding deficiency 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 inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR
26800 whereby she Order Coughlin's property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the Washoe
County Jail to release to Coughlin the property that it alternately admitted to having released to the City of 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 Sferrazza's former tribal court Bailiff and former 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 for Coughlin's dog Jackson Pawluck to be fed and cared for
during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro
sd card confiscating without a warrant/5 day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the Richard G.
Hill, Esq. retaliatory issuance of three traffic citations outside Hill's law office, where RPD Sargent John Tarter told Coughlin to leave after Coughlin presented upon being
released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department officers and managing caught to get Coughlin subject to custodial
trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin reporting to Sargent John Tarter at
that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him as he too was on
Richard Hill's payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he
says to do..." and where both officer Carter and Sargent Marcia Lopez refused to undertake any diligent inquiry response to Coughlin's imploring them to query Hill as to
whether he had just sent Coughlin a Bill for the full rental value of the 121 River rock property for the month of November that was commiserate with the same $900 that
Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any diligence by both officer Carter and Sargent
Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10,
2012 trial date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin
despite the fact that at that time he had filed a grievance with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge
Dorothy Nash Holmes filed
Judge Beesley formerly 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 confiscating Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of 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 for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS 22.100, but characterizing her Order as finding Coughlin guilty
of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in nature, and therefore 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" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a
Summary Contempt Order under NRS 22.030 (which is civil in nature) for conduct not committed in the immediate presence of the Court (such as the alleged conduct
involving a restroom and disassembling a smart phone or recording device and hiding some component part thereof in the restroom that Judge Nash Holmes murkily, hazily,
and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she rendered in that traffic citation case stemming from
Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly after being released from a 3 day
custodial arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter
presided over by Judge Sferrazza). 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 Sferrazza attempted to characterize the Order he entered on 12/21/12 following a very contentious six hour
hearing on Coughlin's November 17th, 2011 filed 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 Sferrazza 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 bailiffs radius in chief bailiff Sexton as to the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents
where Reno justice court bailiffs had either as bailiff arrested told Coughlin that he would put his foot of Coughlin's ass or made commentary as chief Sexton did to Coughlin
respecting Sexton's indication of Coughlin on two different occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file
documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. 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-girlfriend. The lease expired in February 2011. The girlfriend left 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 justified his withholding rent. All of his clahns were decided adversely to his position at the eviction hearing. Justice of the Peace
Peter Sferazza ordered Coughlin evicted from the premises effective November 1, 2011. On that date, the Washoe County Sheriffs Department performed their
normal eviction procedure: locks were changed and the eviction notice was posted on the front door. We videotaped the home and its contents at that
time. Upon inspection over the next few 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 for 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 for Hill to write "Coughlin had not paid rent or utilities since
May." One, the landlord assented to an arrangement with Coughlin's former co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment payments
to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011 and June 2011 and only sent the landlord Merliss $550
for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr. Merliss's assent to Ulloa's
repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges Coughlin faced shortly after 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 from the landlord Merliss). Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss
(though, originally, not Hill or Baker in their demands and eviction notices, in violation of NRCP 11) admitted, under oath, that he had expressly, in writing,
assented to an agreement with Coughlin for a rent deduction of $350 going forward in exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the
weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for 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 former home law office. "Dealing with the weeds", to Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street
causing Coughlin's law office substantial losses lost profits time away from work and expenses associated with immediately mitigating the criminal conduct of
green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for 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 for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law
office 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 of 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days before. Dr. Merliss discovered that the basement door was barricaded (not locked) from the inside.
The Reno Police Department was summoned. They tried to coax whoever was in the basement out, without success. After 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 facing criminal trespass charges in Reno Municipal Court.
See case no. 11 CR 26405 21. He is also facing a contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the
resolution of the criminal trial. That was scheduled for January 10, 2012, but was continued at the request of 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 of the eviction process, a lien
was asserted against the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the
Reno Justice Court. The court tried to promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then
reinitiated that process and a hearing was held in December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing.
You may also want to contact Reno Justice Court staff, and in particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her
staff. After the hearing, the court issued an Order granting Coughlin a two-day time window to remove his personal property. The first day was Thursday, December
22, 20 11. After Coughlin was allowed into the home that first day, he sent out an e-mail to the effect that because he had appealed Judge Sferazza's order, he was
entitled to a stay of proceedings and was to resume in the home. As a result, he did very little to remove any of his personal property that day. On Friday, December
23, 2011, after he learned, again, that his stay had been denied, Coughlin assembled a small crew and they were able to remove a substantial amount of his personal
property. (You need to understand that Mr. Coughlin is a hoarder. We have the photos and videos if you would like to see them.) However, Mr. Coughlin did not get
all of his property out. For example, I counted 13 car seats that he had somehow managed to get down into the basement.
Having failed to remove all of his belongings, Mr. Coughlin then moved before Judge Flanagan for a temporary restraining order to prevent the disposal of his
abandoned property in accordance with Judge Sferazza's order. Attached is Mr. Coughlin's motion, my office'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 for a temporary restraining order. On January 12, 2011, the contractor hired to clean the house
commenced work. Mr. Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the
house. Coughlin called the police, who arrived at the transfer station. Coughlin was falsely 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, finally) can be described thusly:
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the Center
St. Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a
male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b
clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break
151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still one
file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4 break
union 9 to reno.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female
dispatcher saying go ahead with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com

--Forwarded Message Attachment--
Close Print
in compliance with Judge Sferrazza Order of 9/5/12 FW: Zach Coughlin has shared a folder with you
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/27/12 8:26 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
re:rcr2011-063341
Dear Judge Sferrazza and DDA Young,
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance
of counsel claim and or the coerced waiver of my Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note
the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent faxing of numerous filings to the wrong fax number by myself.
https://skydrive.live.com/redir?resid=43084638F32F5F28!5141&authkey=!APibWiVXTMSWkw0
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
in compliance with
Judge Sferrazza
Order of 9/5/12
FW: Zach Coughlin
has shared a folder
with you
View photos Download all
You are invited to view Zach's album. This album has 43 files.
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf
4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
11 21 12 Notice of Irregularities 063341 with ex 1 started revised.pdf
11 30 11 063341 Coughlin_Discovery Received_11.30.11 rotated.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdf
11 13 12 063341 submission of materials and motion for order dmv and cell records or subpoena.pdf
11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text of motion no exhibits.pdf
2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed pdffactpro more nuance.pdf
final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341 - Copy.pdf
pre trial brief state of nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd and tagged jbig2 lossy.pdf
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf
pre trial brief state of nevada v coughlin rcr2011-063341.pdf
rcr11-063341 notice of appearance coughin file 3 3 2012.pdf
rcr11-063341 affidavit in support of motion to file pre-trail motions late bw - Copy.pdf
11 27 12 complete with ex 1 063341 notice of developments.pdf
11 26 12 0204 Notice of Hill and Baker Malfeasance for Motion for New Disciplinary Hearing or Trial 063341 1708 60331 61383.pdf
6 25 12 Order for Sanctiosn 03628 0204 Flanagan $40K in attorneys fees summary eviction appeal.pdf
10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order to Baker 1708 0204.pdf
From: stuttle@washoecounty.us
To: zachcoughlin@hotmail.com
CC: CWood@washoecounty.us; RBaker@washoecounty.us
Subject: RE: Zach Coughlin has shared a folder with you
Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:

Reno Justice Court has no record of your attempted filing on 10/18/12. If you choose to pursue this filing action, you will need to bring the documents in
because we do not accept filings via email. Any documents filed with the court will be retained by the court and we will not make copies for you, the DA or
PD. Providing the appropriate parties copies of your filing is your responsibility, not the court. You may also bring in your confirmation of transmission from
the 10/18/12 filing attempt and we will retain that receipt as part of the court record. Steve

Steve Tuttle

Court Administrator
Reno Justice Court

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Saturday, November 03, 2012 9:39 PM
To: Tuttle, Steve
Subject: Zach Coughlin has shared a folder with you

Dear Mr. Tuttle,
I perused the file in RCR2011-063341 and noticed that the document I submitted for filing on or about 10 18 12 was not file stamped or even in the file, though I have
confirmation of receipt of transmission. Can you please indicate why it is not appearing in the file and find attached another copy of the exhibit 1 thereto.
https://skydrive.live.com/redir?resid=43084638F32F5F28!3600
Zach has 460 files 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
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

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IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND
IN CASE ANYTHING GOES MISSING AGAIN
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/29/12 4:57 PM
To:
stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us
(psferrazza@washoecounty.us); rjcweb@washoecounty.us (rjcweb@washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 43 files 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.pdf
EX1 063341 FINAL.pdf
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
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911 calls missing from what was produced by City Attorney Skau
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 12/03/12 2:53 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
Dear Judge Sferrazza and DDA Young,
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the
trial directed to my issues with Mr. Leslie's representation (I am too tired to fully 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 of the burglary charged in Count 2. Since a thief cannot receive from himself the fruits of his larceny, the
jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to
Leslie's failure to utilize any of the work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde
and Rosa could not have received the dispatch text of 11:27:11 pm reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to
Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the Dispatch recordings (and those provided by City
Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid of anything for the 6
minutes in which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and
subpoena which required production of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report
from dispatch of a possible fight" was the main justification for the pat down and search incident to arrest and led to a justification for 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 therefore 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 further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge
Sferrazza 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 of the 911 calls are missing. There
is no audio of 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 filming/recording the arrest. Had I
not captured a recording of 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 Officer 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 testify
to seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw it light up from all the way across
the skate park...but wait...come November 19th, 2012 he changes his story and decides he saw it light up from "2 to 3
feet away from Coughlin"....There a movie floating around somewhere out there that does a timeline of 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 for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5,
wherein Young writes: "In the instant case, the pat-down search of the Defendant was proper under the totality of the
circumstances. 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." And, of course, Officer
Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and sang the "possible
fight...report from dispatch of a possible fight" tune all the live long day...which was the basis for the reasonable
suspicion for the pat-down (and Judge Sferrazza 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 testifying to a multitude of 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 of the players in the
arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page
document, a footer indicating a "printed on" date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement
more specific, particularized facts in support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney
whom dared to answer one of the officer's questions by asking a question seeking clarification as to Coughlin's constitutional rights....which clearly is not a
permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the Officer's did not receive the text from dispatch
reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year old Austin
Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 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 from being deemed
"reliable citizen witnesses" and Officer Duralde indeed did have, and admitted to in his testimony at trial to being
aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and double hearsay Duralde
testified to at trial after "refreshing his recollection" upon a review of 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 of declaring a mistrial or at least not,
as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to
(the password for the phone)...and when Goble alleges Duralde gave him back the phone...and the call into the
iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for 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) testified that RPD Officer
Duralde committed misconduct by lying about the purported order or point in time in relation to the arrest and search
of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde removed the
phone from Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask
question related to the phone and to verify ownership of the phone (which would include gathering the phone number
for the iPhone, which necessarily would mean that Duralde's allegation of only searching Coughlin after performing
some call to the iPhone and hearsaying it vibrate (even though multiple witness (Templeton, Zarate, Goble, Lichty
testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all) Goble testified that Duralde
already had the iPhone prior to Goble conferring with Duralde or otherwise giving Duralde any phone number to call
in an attempt to verify 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 from the date of conviction to report a conviction to the State Bar of Nevada and the United States
Patent and Trademark Office (USPTO) for 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 of record for 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 Sferrazza's contention that Coughlin "has had forever to get his
defense ready in this case" and that "no continuance will be granted on account of the formal disciplinary hearing
before the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-
063341 (and despite Judge Sferrazza indicated some canon preventing him from testifying at the formal disciplinary
proceeding...that didn't stop 063341 being specifically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v.
Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and
offering to send into the SBN Coughlin's 2/15/12 filing in 063341). Add to that the fact that Coughlin never received
from Leslie Goble's call records until Leslie finally released them o October 30th, 2012...and it really is not accurate
to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his formal disciplinary
hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of
the hearing on 11/14/12 after service of the Complaint and Designation of Witnesses and Summary of Evidence is
affected pursuant to SCR 109 and SCR 105(4)...But the point is, if the RJC and both of you want to be associate with
a Schaeffer style Mirch-ing, then this may be your chance. But you won't be able to say you didn't have plenty of
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 failure to turn over anything to me in the "hand off transmittal" he insisted upon (despite a digital transmission
being required per the Order of Judge Sferrazza, I believe) requires some explanation.
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith
attempt to comply with Judge Sferrazza 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 of 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 frame picture culled from a video Coughlin took of the moments prior to the arrival of the
RPD, being handed by the "man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and
Templeton testifying that they do not know that man and did not know him prior to that night at all....Coughlin
respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of the "man with the
gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him
and attempting to steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the
Center Street bridge were "unsubstantiated"). Oddly, in the attached still frame, 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
first (if the file 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 of 11:23:36 pm (its unknown whether the exact time a 911 call
comes in is designated on the "Calls for Service Inquiry Response" Coughlin was provided recently). The EComm
text logs reveals a second E911 entry for 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 from me for at least 5 years, if
not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in the middle of the
ice rink plaza downtown on 8/20/11 at 11:20 pm ish in Reno, "man with a six pack of beer" picks it up, offers it up,
receiving no response threatens to "throw it in the river if someone doesn't claim it immediately" whereupon Goble's
friend Nate Zarate apparently (according to RPD Duralde's Narrative of unknown origin date") told Goble he saw
Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in his Narrative)
contain the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be
out on him" one can hear Officer Duralde indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the
video Coughlin filmed of the arrest, title:

Then, Offi cer Rosa i s proven to be on the bri dge and not i n hi s squad car readi ng texts from di spatch n the fol l owi ng ti me stamped fi l e: "PRI MARY RADI O TRAFFI C Start_Ti me =
Saturday, August 20, 2011 11-26-30 PM Source_I D = 12 RPD Rosa sayi ng charl es 396 on the other end"
Further, Offi cer Dural de's arri val on the scene i s notated i n the di spatch l og at the
I ts not at al l cl ear why Goodni ght onl y apparentl y recei ved then forwarded to hi s cl i ent on November 30th, 2011 the "Ori gi nal Suppl emental " contai ni ng Offi cer Dural de's Narrati ve,
that i s sti l l of i ndetermi nate date of ori gi n (there are a number of "date of pri nti ng" vari ati ons...).
That I know of, there were three 911 calls (two by Gobl e, one by Coughl i n, i n that order):
1. 082011 112252pm to 112530pm 911 by Gobl e di spatch Weese l og l arc of phone susps os l eft on post l i ghti ng up i n sups pock RP screami ng at susp
2. 082011 112620pm to 112740pm 911 by Gobl e di spatch Montgomery l ogs rp cal l back re someone just socked a mi nor, wai ve that cop down 10 10 wi th open l i ne
3. 082011 112645pm to 112752pm 911by Coughl i n Di spatch Weese l ogs cal l from phone wi th open l i ne yel l i ng re steal i ng phone peopl e cheeri ng cops are here then cal l di sconnects
And Coughl i n fi l med three videos that ni ght of the arrest that are rel evant, two just pri or to the RPD arri vi ng (and actual l y, whi l e Rosa and Dural de were al ready on the scene and
out of thei r vehi cl es after teh 11:26:00 pm mark as i ndi cated by the Ecomm recordi ngs and di spatch l ogs...
1. VI D_20110820_232413 your al l on tape now gobl e and fri ends.3gp 8 seconds l ong
2. VI D_20110820_232423 austi n l i chty templ eton gobl e zarate chan rpd i phone assaul ti ng and battery Coughl i n jusrt pri or to RPD rcr.3gp 46 seconds
3. VI D_20110820_232801 offi cer dural de and rosa 8 20 11 arrest.3gp 5 mi nutes 52 seconds l ong
And the AT&T cal l records for the i Phone reveal onl y four cal l s occurred i n or out duri ng the rel evant ti me frame:
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 successfully kept every single witness from specifically identifying who made what call and when and where to
any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh,
that's Colton" 8 feet from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the
misconduct of 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 four hours later by a 3 Justice Panel (including Justice Hardesty, whom recused himself from
Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look
at the circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private
landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a Trial before Judge Linda Gardner in a divorce
case on 3/12/12...and the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues
printing it out and bringing it with me (my legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for
subpoena fees....the usual)...
Somehow at the Heari ng on the Suppressi on Moti on DDA Young was abl e to get i nto evi dence excl usi vel y hearsay testi mony (often unattri buted to anyone i n parti cul ar) to support
hi s wi n on the "suffi ci ent probabl e cause to support a search i nci dent to arrest" despi te NRS 171.136 forbi ddi ng such an arrest (where Dural de obvi ousl y overcharged the al l eged
cri me as a "fel ony grand l arceny"...even maki ng smug commentary about the "certai n benefi ts of chargi ng thi s as a fel ony" and sayi ng "oooh, that's a fel ony", both matters that
Lesl i e i nsi sted refrai ni ng from getti ng i nto whi l e he was attorney of record, and further, despi te Coughl i n compl yi ng wi th NRS 174.345 (even spl urgi ng on the return recei pt
requested to go al ong wi th the certi fi ed mai l for Dural de) Coughl i n was deni ed the ri ght to cross exami ne the arresti ng offi cer...whi ch i s too bad consi deri ng hi s Narrati ve
al ternatel y cl ai ms that Gobl e tol d hi m they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen
property charge.
COUNT I I . POSSESSI ON OF STOLEN PROPERTY, a vi ol ati on of NRS 205.275, a mi sdemeanor, i n the manner fol l owi ng, to wi t:
That the sai d defendant on or about the 20th day of August, 2011, at Reno Townshi p, wi thi n the County of Washoe, State of Nevada, di d wi l l ful l y and unl awful l y possess or
wi thhol d stol en goods havi ng a val ue l ess than Two Hundred Fi fty Dol l ars ($250.00), to wi t: an i Phone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property
bei ng owned by CORY GOBLE, for hi s own gai n or to prevent the true owner from agai n possessi ng sai d property, knowi ng that the property was obtai ned by means of l arceny or
under such ci rcumstances as shoul d have caused a reasonabl e man to know that such goods were so obtai ned.
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 from someone other than the defendant: 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 of violating 18 U.S.C. 2113(a), (b),
and (d) cannot also be convicted of receiving or possessing the robbery proceeds in violation of 2113(c). Heflin, supra,
358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff
in error, a...The next assignment of error is that the State failed to prove beyond all reasonable doubt that the automobile in
question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property
the proof must show (1) that the property has, in fact, 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 for his own
gain or to prevent the owner from possessing it. (People v. Piszczek,404 Ill. 465.) Proof of these essential elements
constituting the crime of 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 if 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 of the offense in order that the defendant may fully prepare a defense and
be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433
(1967).) In the instant case, the indictment, drawn upon the conclusional premise that the property was stolen, fails 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 himself. Since one person cannot be both the thief and the receiver of
stolen property nor receive stolen property from himself, the fact 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 failed to charge the offense of receiving
stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v.
Edge,406 Ill. 490 (1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the
defendant. The omission of the words "stolen by another" in the indictment does not create the presumption that defendant
had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of 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 defendant obtained control of the property in question (in any manner
whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with
what may be implied from the clear phrasing of the indictment. At trial it is not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that
the defendant was in possession of that property in order to prove the offense of theft under 16-1(d) (the former offense of
receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained
possession of stolen property soon after a theft is evidence that the defendant stole the property himself but is not evidence
of defendant'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 of the indictment herein permits a reader of the
indictment to find, even after only a cursory reading, the necessary elements of the offense, i.e., that the property was
already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition
of these words would only be grammatically redundant and mere surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the
defendant guilty beyond a reasonable doubt. For this reason I, too, would reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in
"larceny" and "theft" cases. He erroneously urges that the state failed 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 for the value of property taken is the fair
market value of the property at the time and place it was stolen if 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 of the burglary charged in Count 2. Since a thief cannot receive from himself the fruits of his larceny, the
jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of 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 of handling the error effectively cured it. The
error was not cured by the setting aside of the receiving conviction since there is no way of knowing whether a properly
instructed jury would have found the defendant guilty of 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 of
the crime of receiving stolen goods..17. Criminal Law. In prosecution for receiving stolen goods, where instruction
given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page
336] owner from again possessing property, defendant was not entitled to instruction which told jury that goods must
have been received with fraudulent intent of depriving owner of the immediate possession thereof. Comp. Laws, sec.
10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a
preliminary examination, Henny Bernier was ordered to stand trial for possession of stolen property, a violation of NRS
205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was
insufficient to establish probable cause that she had committed the charged offense. 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 proof did not show that she knew the property
was stolen and that such knowledge cannot be inferred from mere possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a
conviction for possessing stolen property on the ground that the legislature did not intend to compound the punishment for
larceny or robbery by permitting a conviction for receipt or possession of 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 for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the
burden of proof of 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 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.
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 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 for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following two timestamped recordings finally 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 of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just
blocks away approximately two months prior to the 8/20/11 arrest, incident to the theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on
the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet" incident to the inappropriat placement by Judge Sferrazza of Leslie
as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of avenging the
criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he,
in fact did, deposit a "rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich
man's opposing counsel Casey Baker, Esq. coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon
Judge Sferrazza . You are to his constituency by remixing is previous order regardless of 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 of a summary proceeding that in year to the landlords benefit were
adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to bring counterclaims were matters
Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in
which service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office
no less (and that is the same bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the
Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to those
filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County
public defender applying good nicely peers deciding that the night was doing too much to assist Coughlin in defending himself 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 filling in for Goodnight with and indication Goodnight's December 19,
2011 file stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW,
the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the
following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of the State, the existence of which is known or by the
exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including those
preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling
the extent to which on the record at that July 16 trial date Washoe County public defender 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 for 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 of concern for his client, ability to zealously advocate on his client behalf or
willingness to do so, or indication that Jim Leslie felt that the judges of the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr.
Leslie has any skin in this game whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and
malpractice and apparently willing disregard for the rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe
County District Attorney's Office and therein secure added boys from local law enforcement District Attorney's Office and perhaps the Reno justice court itself.
Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders office in connection with February 27,
2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted 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 confiscation without a
search warrant or court order of any kind (or at least one ever served on Coughlin in any manner) of Coughlin smart phone and micro SD card incident Judy
impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on February 27, 2012 in
RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict between that traffic citation trial
in the Reno Muni court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30
highest-paid city of Reno employees of and admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in
handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal trespass conviction has
now become the subject of a Nevada Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of the
misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that judge Sferrazza presided over wherein
judge Sferrazza purportedly controlled the civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December 26 submitted for filing
December 26, 2011 was not file stamped by the civil division staff of the Reno justice court. This impropriety is further problematic where Coughlin had served upon
the Reno justice court's custodian of records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012 letter her grievance against
Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar of Nevada, which ultimately became one of the three
grievances depicted numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed 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 of NRS 178.405 by way of NRS 5.071
(RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including then Administrativ
Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former
law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of 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 officer Carter issued
caught Coughlin a trespass warning prior to effectuating a custodial arrest on that day in where Lopez also admits none of those individuals or anyone present that day
identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about 5 feet high underneath the former home law office
wherein Coughlin was found at a time when Coughlin still had not receive back from the Reno justice court the impermissible $2275 rent escrow deposit judge
Sferrazza ordered in violation of Nevada law considering judge Sferrazza'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 fact in the civil division of the Reno justice court wherein tenants were in summary eviction matters were subject to forced rent escrow deposit in violation
of 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 of corollary to
justice court rule Las Vegas rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the
Washoe County Sheriff's office deputy Machen filed a false affidavit on November 7, 2011 alleging to have personally served Coughlin with both the October 25
Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of Law, and Order of Summary Eviction (which Casey D. Baker, Esq. lied about his
testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact that his sister judge Linda Gardner is
listed as the grievant (and him goes to Pat King's awkward assertions that the "Clerk of 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 of domestic violence on behalf of our Washoe legal services (a
rather interesting approach by former prosecutor judge Linda Gardner in comparison to the extremely light touch demonstrated by judge Sferrazza and judge Clifton of
the Reno justice court incident to deputy district attorney Young's repeated malfeasance misconduct violations stays pending competency or evaluations failure to turn
over exculpatory materials failure to propound discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in conjunction with
scattershot three, count them three prosecutions of Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR)
111(6) (in 065630 young amended the criminal complaint from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer
and/or patent agent by amending the charge nearly a year after 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 faith effort to achieve a plea-bargain and resolve what is a messy case the city of 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 of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill
on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on
January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of summary eviction matter in 1708 Barber
which judge Sferrazza presided and which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee
award against Pro per appellant Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for
attorneys fees filed by Casey D Baker of Hill's office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he
violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was assigned to Coughlin appeal of the petty larceny conviction of a candy bar
and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license incident to bar counsel's SCR
111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a
misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should
especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at
which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard just
seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that Walmart alleges to have had
absolutely no video footage supportive of 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 of Walmarts policies
and where John Ellis of the W. 7th St., Walmart in any as yet unknown loss prevention associate specifically and expressly threatening abuse of 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 of whom have
had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from the policy which Walmart
holds out to the public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at
Walmart.com no matter what the convenient for getting in misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted
neiher he nor anyone with Wal-Mart on September 9th, 2011 affected a citizen"s arrest of Coughlin on that date in connection with the alleged petty larceny by
Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days after Coughlin filed a written complaint detailing the
police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20, 2011 in 063341
a justice court criminal petty larceny and receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American
jurisprudence that one cannot be charged with both petty larceny and receiving stolen property of the same item particularly where the receiving of the item is alleged
to have been from oneself after one had larceny is the item lending an inference that Joe Sferrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's
light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in connection with its numerous since is violating about law
respecting the manner in which evictions are carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory arrest and
prosecution of Coughlin where the judiciary in Washoe County is off criticizes being overly influenced by the District Attorney's Office. That Walmart petty larceny
conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of law whom Coughlin's twice former Reno
Municipal Court appointed public defender Keith Loomis (not in the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed defender there
despite his express failure 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 malfeasance in connection with that conviction of Coughlin extends
further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing the November 14 trial setting to have been continued only to in a
3 min. add-on at the conclusion of the hearing which are trial which judge Howard down such a matter of public concern that he Five city of Reno employees at the
courthouse until nine o'clock at night to get it done that in fact judge Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial
that was not Coughlin fault that all and where the Reno Municipal Court had previously granted a continuance to the city of Reno prosecutor's in the very criminal
trespass prosecution of Coughlin stemming from Richard G Hill Esquire's criminal trespass complaint (connected to the summary eviction matter over which judge
Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of 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 Sferrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction matter 1708 required by
law within 10 days of Coughlin filing his motion to contest personal property lien on November 17, 2011 even where is extremely suspect that the justice court is now
alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as Janice admitted when judge Sferrazza called her is of
his own witness at the December 20, 2012 hearing that was finally 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 from his six-week vacation in late December 2011.... It incident to that same hearing on
Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in
unsworn statements purporting to prove that Coughlin somehow failed 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 bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a violation of the courthouse
century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office
for something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate
McGeorge school law along with wash County Dist. Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently
granted 2004 graduate McGeorge school of law deputy district attorney Zach young in order taking away the ability to file by fax from Coughlin a privilege that is
accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 hearing at which Coughlin's
then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young
alleged who filed on November 26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or
perhaps Tom despite the fact that Coughlin had merely comply with judge Clifton's request that he provide judge Clifton something supportive of Coughlin's contention
that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of
the State Bar of Nevada communicated he and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley
(the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org) (former law practice partners with an individual from Washoe Legal
Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed Coughlin's work before him and in Nevada
Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the hearing
and in violation of Supreme Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in
any matters relative to the ultimate Supreme Court rule 105 complaint against Coughlin for over six months at least and so in no way can be said to just stuff I his last-
minute supplementing judge Beesley and milquetoast attempts to provide Coughlin S supplemental designation of witness and summary of evidence and regard to both
judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY at the hearing (both of those gentlemen attended
McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of Coughlin's
competency as an attorney at the hearing despite the fact that neither of them could provide anything in the way of specificity with regard to what issues they would
take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's department in the NVB.) in early May 2012 in
violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of
recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 from 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 for
my client where it be $14 worth of candy bars and cough drops from Coughlin and Coughlin's March 30, 2012 filing 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 affected by the fraudulently procured order for summary
eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice court wherein the
audio record from 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 different order of hearing the cases planned for that morning docket and despite the fact that the fax header
on the summary eviction order that was hurriedly moved through indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and
where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without
announcing themselves as law enforcement and where they entered with their guns and/or pagers drawn in and immediately placed Coughlin in handcuffs and told him
he was detained in contrast to the typical procedures carried out by the Sheriff's office 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 for an eviction all the
sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for seeking an eviction to one for non-payment of rent (seemingly in response to
Coughlin Pre Hearing Brief pointing out the difficulties they would face 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 forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge
Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw
Coughlin under the bus at Coughlin's 11/14/12 formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel
will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy bar conviction that resulted in the current now 5 month long suspension of Coughlin's
license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of
SAMANTHA L. HALL, ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit
Affidavit of Counsel Coughlin for Keller in Support of 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 fax to rmc regarding deficiency 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 inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11
TR 26800 whereby she Order Coughlin's property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the
Washoe County Jail to release to Coughlin the property that it alternately admitted to having released to the City of 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 Sferrazza's former tribal court Bailiff and former 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 for Coughlin's dog Jackson Pawluck to
be fed and cared for during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and
micro sd card confiscating without a warrant/5 day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the
Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's law office, where RPD Sargent John Tarter told Coughlin to leave after Coughlin
presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department officers and managing caught to get Coughlin
subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin reporting
to Sargent John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin
querying him as he too was on Richard Hill's payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who
he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia Lopez refused to undertake any diligent inquiry response to
Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121 River rock property for the month of November
that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with
any diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate
McGeorge school of law told Coughlin at an April 10, 2012 trial date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to
recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed a grievance with the State Bar of Nevada against Coughlin by way
of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed
Judge Beesley formerly 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 confiscating Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of 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 for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS 22.100, but characterizing her Order
as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in
nature, and therefore 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" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and
Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030 (which is civil in nature) for conduct not committed in the immediate presence of the
Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and hiding some component part thereof in the restroom
that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she
rendered in that traffic citation case stemming from Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and
client's files shortly after being released from a 3 day custodial arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former
home law office (in RJC2011-001708, the eviction matter presided over by Judge Sferrazza). 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 Sferrazza attempted to characterize the Order he
entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed 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 Sferrazza 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 bailiffs radius in chief bailiff Sexton as to the fact that he to quote would
like to stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court bailiffs had either as bailiff arrested told Coughlin that he would
put his foot of Coughlin's ass or made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on two different occasions the week of
Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached
in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. 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-girlfriend. The lease expired in February 2011. The girlfriend left 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 justified his withholding rent. All of his clahns were decided adversely to his position at the eviction hearing.
Justice of the Peace Peter Sferazza ordered Coughlin evicted from the premises effective November 1, 2011. On that date, the Washoe County Sheriffs
Department performed their normal eviction procedure: locks were changed and the eviction notice was posted on the front door. We videotaped the
home and its contents at that time. Upon inspection over the next few 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 for 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 for Hill to write "Coughlin had not paid rent or utilities
since May." One, the landlord assented to an arrangement with Coughlin's former co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment
payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011 and June 2011 and only sent the landlord
Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr.
Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges
Coughlin faced shortly after 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 from the landlord Merliss). Merliss admitted to assenting to the repayment plan with Ms.
Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in
violation of NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an agreement with Coughlin for a rent deduction of $350
going forward in exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artificial turf installation
Coughlin had installed in an enterprising approach which the landlord's landscaper for 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 former home
law office. "Dealing with the weeds", to Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing
Coughlin's law office substantial losses lost profits time away from work and expenses associated with immediately mitigating the criminal conduct of
green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for
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 for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin
put into place of his former law office 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 of 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days before. Dr. Merliss discovered that the basement door was barricaded (not locked) from the
inside. The Reno Police Department was summoned. They tried to coax whoever was in the basement out, without success. After 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 facing criminal trespass charges in Reno
Municipal Court. See case no. 11 CR 26405 21. He is also facing a contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that
matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012, but was continued at the request of 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 of the eviction process, a
lien was asserted against the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien
in the Reno Justice Court. The court tried to promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar.
Coughlin then reinitiated that process and a hearing was held in December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the
November hearing. You may also want to contact Reno Justice Court staff, and in particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive
treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time window to remove his personal property. The first day
was Thursday, December 22, 20 11. After Coughlin was allowed into the home that first day, he sent out an e-mail to the effect that because he had appealed
Judge Sferazza's order, he was entitled to a stay of proceedings and was to resume in the home. As a result, he did very little to remove any of his personal
property that day. On Friday, December 23, 2011, after he learned, again, that his stay had been denied, Coughlin assembled a small crew and they were able to
remove a substantial amount of his personal property. (You need to understand that Mr. Coughlin is a hoarder. We have the photos and videos if you would like to
see them.) However, Mr. Coughlin did not get all of his property out. For example, I counted 13 car seats that he had somehow managed to get down into the
basement.
Having failed to remove all of his belongings, Mr. Coughlin then moved before Judge Flanagan for a temporary restraining order to prevent the disposal of his
abandoned property in accordance with Judge Sferazza's order. Attached is Mr. Coughlin's motion, my office'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 for a temporary restraining order. On January 12, 2011, the contractor hired to clean the
house commenced work. Mr. Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property
from the house. Coughlin called the police, who arrived at the transfer station. Coughlin was falsely 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, finally) can be described thusly:
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and
center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the
Center St. Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a
male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a
level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station
break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still
one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4
break union 9 to reno.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female
dispatcher saying go ahead with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 24 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 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell
phone susp os also loud verb disturb.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the Center St.
Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear
that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-16-41 AM Source_ID = 13 Duralde indicated he will be en route to main station to drop off
Coughlin's smartphone for copying data prior to depart.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151
unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4 break union 9 to
reno.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-41 AM Source_ID = 6 Duralde's wife Jessica c151 reno, Alaksa can you switch to share some
information call please.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher
saying go ahead with that.wav
11 30 12 063341 updated motion for new trial with ex 1 attached in 2 pages per format.pdf
Download all

--Forwarded Message Attachment--
Close Print
Case No. RCR2011-063341
From:Jeannie Homer (HomerJ@reno.gov)
Sent: Thu 11/08/12 2:48 PM
To: zachcoughlin@hotmail.com
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order
toQuash Subpoenas and for Protective Order Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte Emergency Order PendingHearing.pdf
(81.0 KB)
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
(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 are protected by the attorney-client privilege and/or work
product doctrine. If you are not the intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying,
dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in
error, please immediately notify us by forwarding 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 (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
To: zachcoughlin@hotmail.com
Cc: Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments.
However, they consisted mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to
obtain the documents, as set forth hereafter.
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 office and were directed to leave the Judges Order and the City's
motion at the front of that address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these
items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of 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,

Plaintiffs,

vs.

COUGHLIN, ZACHARY BARKER

Defendant.















CASE NO.: RCR2011-063341

DEPT. NO.: 2


EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (RCAO) represents a number of City of Reno employees who have been named in subpoenas. The RCAO contacted
Court personnel on November 7, 2012 to request a time to appear for an order shortening time regarding a motion to quash and for protective order. Due to the
proximity of the trial date in this matter, November 19, 2012, the Court directed the RCAO to file and serve its substantive motion and provide notice that the
matter would be heard on November 8, 2012 at 9:00 am. The City of Reno filed its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared on behalf of the RCAO and the City employees
requesting protective relief. Zack Young was present in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public
Defenders office represented Mr. Coughlin, that the Public Defender was served believing this was service upon Mr. Coughlin, that he learned Mr. Coughlin
represented himself this morning and attempted to call and left a voice mail message with a phone number believed to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy City Attorney, Dan Wong, may also have
received subpoenas and filed requests for relief similar to the RCAOs requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr. Coughlin, no argument was received on the merits
of the motion. However, the Court finds that the RCAOs motion and supporting materials present a sufficient evidentiary basis to issue this Order.

The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 13, 2012. Oral presentations shall be limited to 10
minutes each. The Clerk shall notify Mr. Bosler and Mr. Wong of the hearing.
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), effective until the hearing on this matter on November 13, 2012, to the effect that
upon service of this Order on Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter 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 first presented the proposed subpoena or subpoena duces tecum to the
Court for the Courts review regarding adequacy, relevancy and necessity of the subpoena or subpoena duces tecum, and sufficiency of the proposed method of
service.
4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order and the RCAOs motion and any supplements
by personal service upon Zachary Barker Coughlin at the address in the Courts file, 1471 E. 9
th
Street, Reno, NV 89512, with a copy mailed to said address.
Service shall also be attempted by email at zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.

/s/
JUSTICE OF THE PEACE



The City of 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 for City of Reno


IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTYOF WASHOE, STATE OF NEVADA

STATE OF NEVADA, Case No. RCR2011-063341
Plaintiffs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
__________________________________/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER REGARDING ISSUANCE OF
SUBPOENAS

COMES NOW, City of Reno (City), as the employer and on behalf of Reno Police Department Officers 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 of record, John J. Kadlic, Reno City Attorney, and Creig Skau,
Deputy City Attorney, and hereby moves this Court for an order to quash the subpoenas claimed to have been served on for these City employees in violation of
Justice Court Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
///

JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and any additional or further evidence the Court deems
just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. On October 26, 2012, City of Reno Emergency Communication Center employees (ECOMM) Suzy Rogers and Kelley Odom received emails from Zach
Coughlin containing nine (9) Subpoenas, copies of which are attached as Exhibit 1 and incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among other things, the City of Reno Police Report and
City of Reno ECOMM materials regarding Case Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno
for $108. A copy of the letter is attached as Exhibit 2 and incorporated herein by reference. On November 5, 2012, this same letter was sent again to
Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served regarding the appearance of the City employees Ron
Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b).
The letter indicated because service of the subpoenas for these four (4) individuals was ineffective, these individuals would not be appearing on November
19, 2012. (Exhibit 2).
4. On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a Notice of Errata and Revised Supplemental Motion For a New Trial by
sliding them
through the security glass in the front office of the Reno Police Department at approximately 4:50 p.m. after being told the office 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 of this packet is attached as Exhibit 3 and incorporated herein by reference.
5. 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 of requests for materials
unrelated to Case RMC RCR2011-063341. A copy of these documents is attached as Exhibit 4 and incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin regarding the letter this office mailed on November
2, 2012. Among other things, Mr. Coughlin did not indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery
and Scott Weese. Mr. Coughlin did state to have these witnesses ready for trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing seventeen (17) pages of blended documents
regarding matters pending before Reno Justice Court on November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the
Reno Police Department. The subpoena duces tecum on the first page of the packet contains many unreadable names. A copy of the packet is attached as
Exhibit 5.
1. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of materials from an unidentified person. The cover sheet of the packed is
entitled Subpoena Duces Tecum regarding Case RCR2011-063341. This document also appears to contain names of other individuals but the handwriting
is unreadable. It is not known if the other individuals on this subpoena are City employees. A headnote on the Subpoena indicates that if the requested
documents are e-mailed to Mr. Coughlin, personal appearance may not be required. A copy of 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 of age. Service of a subpoena upon a person named therein shall
be made by delivering a copy thereof to such person and, if the person's attendance is commanded, by tendering to that person the fees for one day's attendance
and the mileage allowed by law. When the subpoena is issued on behalf of the State or an officer or agency thereof, fees and mileage need not be tendered. Prior
notice, not less than 15 days, of any commanded production of documents and things or inspection of premises before 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 of the many different City employees above
are deficient and ineffective as they fail to comply with personal service requirement of JCRCP 45(b). Accordingly, service was ineffective and all of the subpoenas
should be quashed.

In addition to the failure of personal service, all of Mr. Coughlins subpoenas referenced in Exhibits 1, 3, 4 and 5, also:
1. Violate JCRCP 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP 45.
2. 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 of 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.
1. Violate JCRCP 45(b)(1) which states that service of a subpoena commanding attendance requires that payment for one days attendance and the mileage
allowed by law. No witness fee or mileage fee has been submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance and service of 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 of 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 of other cases and
proceedings that are unrelated to the instant action. These subpoenas are unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing,
seek information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for 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 off the same subpoenas (some of 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 confusion and leading to a
waste of time and resources of public safety employees. As an attorney, Mr. Coughlin should be aware of the subpoena process. This is not the first matter in
which Mr. Coughlin has abused a court procedural matter. For this Courts information, Reno Municipal Court Judge Holmes issued a Sua Sponte Order Denying
Relief Sought in Improper Document on March 13, 2012 finding, among other things, that Mr. Coughlin failed to follow proper legal procedure in preparing and
filing motions in a matter pending before that Court and that Mr. Coughlin blatantly abused that Courts fax filing process. As such, that Court ordered that Mr.
Coughlin be prohibited from faxing any documents to that Court. A copy of this Order is attached as Exhibit 7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from this Court requiring Mr. Coughlin to submit any
subpoena he intends to serve in this matter to this Court for review prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a
specific case and is following the appropriate legal process.


III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel Harley or any other City employee whose names were
unreadable in the subpoenas for failure to comply with JCRCP Rule 45;
2. 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 failed to comply with JCRCP Rule 45.
3. 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 for
review prior to issuance and service to ensure Mr. Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney

By:
CREIGTON SKAU
Deputy City Attorney
P.O. Box 1900
Reno, NV 89505
Attorneys for City of 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



-----Ori gi nal Message-----
From: Jeanni e Homer <homerj@reno.gov>
To: "'bonyr@reno.gov'" <bonyr@reno.gov>, "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri , 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Thursday, November 08, 2012 8:36 PM
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

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 follo wing 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 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
utbound fax report
Inbox x
Voxox noreply@voxox.com
Jun 27

to me
Hi zachcoughlin,
You r 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? Get Voxox: http://download.voxox.com
and adjust your Notifications in the Settings/Preferences window. Voxox by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Voxox noreply@voxox.com
Jun 27

to me
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 09:16:58 PM on 2012-06-27.
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 @ 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.
Voxox noreply@voxox.com
Jun 28

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
(775)334-2050
(775)334-2420/fax
homerj@reno.gov

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