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Document Code:
Zach Coughlin, Esq.
Nevada Bar No: 9473
1422 E. 9th St. #2
Reno, NV 89512
Tele: 775-338-8118
ZachCoughlin@hotmail.com
Attorney for Appellant
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ZACHARY COUGHLIN;
Appellant,
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vs.
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Electronically
01-14-2012:12:07:28 AM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2700423
MATTHEW MERLISS
Respondent.
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) CASE NO: CV11-03628
) DEPT: D7
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) Opposition to Motion for Attorney's Fees
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for Appellant, Zach Coughlin. The undersigned has been a victim of domestic violence, beginning
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with his move, on or about December 27th, 2011 until the present, with the Reno Police needed to
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visit the 1422 E. 9th St. #2 address the undersigned is currently stationed at on at least 6 occasions.
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Further, for NRCP 59 and NRCP 60 basis, this Court's recent Order is clearly inaccurate to the extent
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is purports to find that the undersigned made any agreement to waive his security deposit in exchange
for additional access to the property. Hill and Baker have an established practice, in this case
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especially of moving for attorney's fees where no basis in fact or law exists, See RJC 2011-001708
Memorandum of Fees for some $20,000 based upon a controlled substance manufacture statute that
clearly was completely inapplicable to this matter, then a similar motion they filed under NRS 69.030
despite "summary eviction proceedings" not being "civil actions" under N JCRCP 3, which identifies
four types of cases in justice courts, an only one, "civil actions" come within the purview of NRS
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69.030. To the extent the attorneys fees issue is not made moot by this Court's recent order, it is
hereby opposed.
PLEASE NOTE THAT THE UNDERSIGNED COUNSEL APOLOGIZES FOR THE
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AFTER THE RENO POLICE DEPARTMENT (WITH THE HELP OF OPPOSING COUNSEL IN
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THE UNDERSIGNED EVICTION FROM HIS LAW OFFICE CASE, RICHARD G. HILL, ESQ)
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GAVE HIM BEFORE SHE DIED, LIKE THE CARICTURE DRAWING OF THE
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YEAR OLD COUSIN JUST DIED IN A CAR ACCIDENT DAYS AGO) PEACEABLY AND ON
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PUBLIC PROPERTY AND AFTER A RENO PD OFFICER WHO ACTUALLY HAS SOME
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CLASS INFORMED RICHARD HILL THAT THE UNDERSIGNED WAS NOT DOING
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ANYTHING ILLEGAL. BUT THEN IN COMES OFFICER DEL VECHIO WHO ACTUALLY
"DREW DOWN" AFTER SCREACHING TO A HALT AND VEERING ACROSS THE LANE OF
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FOR JAYWALKING (DESPITE THE FACT THAT RICHARD HILL'S CREW OF MOVERS
HAD THEIR TRUCK PARKED IN THE MIDDLE OF THE SIDEWALK THE UNDERSIGNED
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WAS ON) RICHARD HILL WENT BACK TO A PLACE HE REALLY, REALLY LIKES, THE
RENO JUSTICE COURT, AND APPARENTLY GOT HIMSELF A PROTECTION ORDER,
THEN DROVE OFF IN ONE OF HIS APPROXIMATELY 11 PORCHES WEARING A SHIRT
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UNDERSIGNED WAS DENIED ANY PHONE CALLS AT THE WASHOE COUNTY JAIL FOR
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OFFICER LEEDY THAT OFFICER DEL VECHIO WAS "TRAINING", THEN MONEY WAS
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STOLEN FROM THE UNDERSIGNED BY THE JAIL STAFF, A DEPUTY ADAMS, IN FRONT
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DIPSHIT LIKE YOU HAS LIFE THREATENING MEDICAL ISSUES" AND REFUSED TO
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FINALLY RELEASE THE UNDERSIGNED FROM JAIL AFTER MAKING HIM PAY SOME OF
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THE LAST MONEY HE HAD FOR "BAIL", TAKING MOST OF THE REST OF THE MONEY
THE UNDERSIGNED HAD AND CLAIMING IT WAS EITHER "LOST" OR THAT "THEY
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WERE WRONG EARLIER WHEN THE SWORE THAT THAT AMOUNT WAS ALL YOU
WOULD NEED TO BAIL OUT" WHEREUPON THE JAIL STAFF DECIDED TO POCKET
CASH FROM THE UNDERSIGNED, WITHOUT HIS CONSENT, PRIOR TO RELEASE. THE
JAIL SAW FIT TO RELEASE THE UNDERSIGNED ONLY MINUTES AFTER THE LAST BUS
FOR THE NIGHT LEFT PARR BLVD, AND AT 11:00 AT NIGHT, WITH THE UNDERSIGNED
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INFORMED THE UNDERSIGNED THAT SHE KNEW EVERYTHING THE RENO PD COULD
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OR WOULD DO AND THAT THEY WOULDN'T DO ANYTHING WRONG, AND THEN KARI
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REFUSED TO DIVULGE THE IDENTITY OF THE 911 OPERATORS WHO INFORMED THE
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OFFICERS WHOM CITED THE FACT THAT THE UNDERSIGNED LICENSE PLATE WAS
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SOMETHING RICHARD HILL, ESQ. DID IN FRONT OF THESE VERY SAME OFFICERS
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SEVERAL TIMES WHILE THE UNDERSIGNED WAS IN THE PATROL CAR), INCLUDING
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RENO PD JUST DAYS BEFORE, OFFICER NICHOLAS DURALDE, WHOM WAS PRESENT
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THE UNDERSIGNED THAT "RICHARD HILL PAYS HIM A LOT OF MONEY AND
THEREFORE HE WILL ARREST WHO RICHARD HILL SAYS TO AND HE WILL DO WHAT
RICHARD HILLS SAYS". PREVIOUSLY, RENO PD SARGENT TARTER HAS TICKETED
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THE UNDERSIGNED FOR FAILURE TO STOP COMPLETELY BEFORE THE WHITE LINE
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RICHARD HILL, ESQ.S OFFICE, WHERE RICHARD HILL HAD BEEN REFUSING TO TURN
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OVER THE UNDERSIGNED STATE OF NEVADA DRIVER'S LICENSE FOR OVER ONE
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BOARD UP AND "FIX A LEAK IN THE BASEMENT" (THE LEAK, HE INFORMED THE
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FACT THAT THE CONTRACTOR USED THE UNDERSIGNED'S OWN WOOD AND
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MATTHEW JOEL MERLISS, MD.'S CARPET, WHILE RICHARD HILL WAS APPARENTLY
READYING HIMSELF TO SUE THE UNDERSIGNED BOTH FOR THE COST OF DISPOSING
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CROSSING THE BAR TO PASS POST IT NOTES TO CASEY BAKER (DESPITE JUDGE
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PROOF OF SERVICE
I, Zach Coughlin, declare:
On January 13th, 2012, I, Mr. Zach Coughlin served the foregoing Opposition to
Motion for Attorney's Fees by faxing and serving upon registered efilers and depositing a
true and correct copy in the US Mail addressed to:
Richard G. Hill, Esq. and
Casey Baker, Esq.
652 Forest St.
Reno, NV 89503
Attorneys for Respondent Matt Merliss, MD
----------------------------Zach Coughlin
AGENT OF APPELLANT