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Document Code:
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Zach Coughlin

Nevada Bar No: 9473 (temporarily suspended as of 617112 Order in
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Tele and Fax: 949-667-7402 .
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pro per indigent requesting court appoInt co-counsel only, Ifnot permItted to re
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primary counsel. then seeks heanng on co-counse ng t ay on, e c.

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A
IN THE RENO MUNICIPAL COURT OF THE STATE OF NEVADA
IN AND FOR THE COUNTY OF WASHOE
CITY OF RENO;
PLAINTIFF.
vs.
ZACH COUGHLIN:
DEFENDANT.
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Case No: 13 CR 3913, and 13 CR 3914
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Dept No: not aware of an assignement yet
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MOTION TO DISMISS. MOTION FOR CONTINUANCE OF ARRAIGNMENT. MOTION
TO COMPEL POLICE REPORTS
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COMES NOW. Defendant, Zach Coughlin, by and through himself and fles the above title
document on his own behalf
FACTS. LAW AND ARGUMENT
1. Coughlin has not been served the Summons in this matter. It is believe service of a criminal
summons by mail in Nevada requires mailing such both by certified mail and frst class mail in
tandem and that any such summons in these matters may have only been mailed by certifed mail.
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MOTION FOR NEW TRIAL; NOTICE OF NONRECEIPT OF 2 28 12 CONTEMPT/SANCTION ORDER; NOTICE
OF VIOLATION OF NRS 178.405!5.010;MOTION FOR ARREST OF JUDGMENT
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#) /he *tate Bar of Nevada failed to meet a Durisdictional prere3uisite to receiving any such
Aor5place harassment protection order in that no Bond Aas posted Aith the "#!#%!"# /;$ application
in +CC +C;"#2%7 or at any time thereafter)
3) Coughlin has Aor5ed diligently to attain a copy of the complete police report incident to Both 39"3
and 39"4, re3uesting such in Ariting from the +9C (or attempting to', the +eno City <ttorney4s
$ffice and the +eno ;olice Department But has Been denied access to anythign Beyond the ;C *heet
and <rrest +eport and Declaratio of ;roBaBle Cause (ie, no Aitness statements, no Narrative, etc)')
4) Coughlin Aas never appropriately served either the "#!#%!"# /;$!(;$ applciation By ;at Eing
(and its inappropriate for Eing to continue as counsel on #337, the appeal of the "#!"4!"# 0$0C$l
recommending permanent disBarment, Ahile applying for a /;$!(;$ on his oAn Behalf (his
employer must do it for him', or feigning to on Behalf of some unnamed others at the *BN (and there
is no Durisdiction to grant an Finsitutional protection orderG, such order must Be assigned to one
person in particular per order, not an entire intitution))
Coughlin hereBy reserves any rights or arguments as to the insufficiency of service of process,
failure to state a crime, insufficiency of process, etc), etc)
Do to the important, especially as to the Bail analysis, of Coughlin Being permitted to vieA the
entire police report, Coughlin re3uests a continuance of the 4!"7!"3 arraignment in Both 39"3 and
39"4) Coughlin Aas already suBDect to a H.,%%% Bail incident to the #!&!"3 arrest for gross
misdemeanor tpo violation and felony epo violation re3uiring H7.% cash to Bail out)
/he criminal complaints and amended in this matter do not accurately state that rationale
offered By the >CD<4s $ffice for deciding that Fno crimina lcomplaint Aill issueG incident to the
#!&!"3 arrest, as detailed in the 3!"!"3 letter from DD< Zach =oung to +;D =turBide) 0urther, the
locus of the alleged violation seems to Be outside +eno city limits proper, and therefore not Aithin
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$0 -7$6</7$N $0 N+* "7&)4%.!.)%"%?9$/7$N 0$+ <++(*/ $0 C:D@9(N/
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any Fconcurrent DurisdictionG argument sufficient to invo5e the +9C4s Durisdiciton over the decision
By the >CD<4s $ffice not to press charges)
Coughlin re3uests proof to support +C< *oodui4s statments in the complaints that FCourt)
/he >ashoe County District <ttorney4s $ffice indicated that the violation
is misdemeanor and since it occurred Aithin city limits the proper court of Durisdiction is the +eno
9unicipal CourtG)
: F/he Nevada Constitution guarantees the people of Nevada the right to Bail in non2capital offenses
and prohiBits the district court from imposing e1cessive Bail) *ee Nev) Const) art) ", II and 7? see
also N+* "7&)4&4("' (FJ<K person arrested for an offense other than murder of the first degree must
Be admitted to Bail)G (emphasis added''? *t) ;ierre v) *heriff, 9% Nev) #&#, #&, .#4 ;)#d "#7&, "#&%
("974' (FJ$Kur Constitution does not encompass inclusion of a non2capital offense as non2BailaBle)G')
F/his traditional right to freedom Before conviction permits the unhampered preparation of a defense,
and serves to prevent the infliction of punishment prior to conviction)G *tac5 v) Boyle, 34# :)*) ", 4
("9."') 7n deciding a reasonaBle amount for Bail the district court may consider Fthe nature of the
offense charged, the penalty Ahich may Be inflicted, the proBaBility of the appearance of the accused,
his pecuniary condition, his character and reputation, and the circumstances surrounding the case
relative to the li5elihood of conviction)G (1 parte Cagles and -arnes, 44 Nev) 37%, "9. ;) &%& ("9#"'?
see also N+* "7&)49&? N+* "7&)4&.3) 8oAever, FBail must not Be) ) ) more than the accused can
reasonaBly Be e1pected under the circumstances to give, for if so it is suBstantially a denial of Bail)G
(1 parte 9alley, .% Nev) #4&, #.3, #. ;) ."#, ."4 ("9#7') $ur revieA of the record reveals that the
district court violated the Nevada Constitution in tAo Aays) 7t denied the petitioner Bail for fifteen
days and then imposed a Bail amount Ahich greatly e1ceeded the amount the petitioner could
reasonaBly Be e1pected to pay) <s the real party in interest notes in its ansAering Brief, the district
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$0 -7$6</7$N $0 N+* "7&)4%.!.)%"%?9$/7$N 0$+ <++(*/ $0 C:D@9(N/
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court imposed a Bail amount that Aas fifty times greater than the Clar5 County standard Bail schedule
for category B felonies) 7n light of the district courtLs failure to consider all of the relevant factors, see
N+* "7&)49&, its stated reason for remanding petitioner to custody, petitionerLs indigent status, and
the amount of Bail, Ae can only conclude that the district court Aas attempting to punish petitioner
for his attitude Aithout utiliMing the procedures provided for in Nevada laA) *ee N+* ##)%3%("'
(e1plaining Ahen a person may Be punished summarily for contempt'? N+* ##)%"% (defining
contempt') 0or these reasons, Ae conclude that the district court manifestly aBused its discretion By
remanding petitioner to custodyAithout Bail for fifteen days and imposing e1cessive Bail) *ee *tate
v)Dist) Ct) (<rmstrong', "#7 Nev) , #7 ;)3d 777, 7792&% (#%""' (discussing Ahen a Arit of
mandamus Aill issue')G
:nder NRS 33.240, harassment in the Aor5place occurs Ahen:
") < person 5noAingly threatens to cause or commits an act that causes:
(a' Bodily inDury to himself or another person?
(B' Damage to the property of another person? or
(c' *uBstantial harm to the physical or mental health or safety of a person?
#) /he threat is made or the act is committed against an employer, an employee of the
employer Ahile the employee performs his duties of employment or a person present at the
Aor5place of the employer? and
3) /he threat Aould cause a reasonaBle person to fear that the threat Aill Be carried out or the
act Aould cause a reasonaBle person to feel terroriMed, frightened, intimidated or harassed)
/he Complaints in Both case fail to state any facts that Aould amount to a violation) Coughlin
is and has Been involved in a litigation Aith the *BN, in the trial court formal disciplinary matter and
on appeal) Both re3uire Coughlin to file documents, and serve them and the *BN e1pressly
consented to service of such By fa1 and has never, at any point, disputed that fact, But rather, has
coyly s5irted ac5noAledging it Beyond the intial e1pressions and suBse3uent ratifications thereof,
especially considering NNDB *usich4s 7!#7!"# letter to Coughlin directing him to pusue *C+ "%.(4'
in3uiries Aith the *BN, rather than the NNDB)
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$0 -7$6</7$N $0 N+* "7&)4%.!.)%"%?9$/7$N 0$+ <++(*/ $0 C:D@9(N/
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/his has cost Coughlin and enormous amoutn of time, money, and energy already, and no
Bond Aas put up
(8) How m!" #o$% &' !o%' 'o (&)$ (o* + ,*o'$!'&o- o*#$* +.+&-%' "+*+%%m$-' &- '"$ wo*/,)+!$0
:nli5e other types of protection orders there is a filing fee to oBtain a protection order against harassment
in the Aor5place) /he amount of the filing fee varies By Durisdiction) 8oAever, in this court, the filing fee
is H4)%%)
7n addition, there is an additional 1200.00 (cash or e3uivalent' that must Be posted as Fsecurity)G :nder
NRS 33.230, a temporary $rder for ;rotection <gainst 8arassment in the >or5place cannot Be issued
unless the <pplicant posts this amount) /he purpose of this security is to compensate the <dverse ;arty
for Fsuch costs and damages as may Be incurred or sufferedG By the <dverse ;arty if that person is Ffound
to have Been Arongfully enDoined or restrained)G
<n <dverse ;arty may file a 9otion to increase the amount of security if that person feels he may Be
suBDect to e1cessive damages) 8oAever, an <pplicant may not file a 9otion to decrease the amount to
less than H"%%
courthouse sanctuary rule and litigant attorney immunity from service in the courthouse Aere
violated By the attempts to served coughlin the tpo and e1cessive force By the >C*$ on "!.!"3 vitiates
any attempted service there)
/he sBn failed to meet Durisdicitonal prere3uisits (and the +CC' and such orders are void Ahere none of
the folloAing Aere met or done
(4) A*$ '"$*$ -&5$ *)$% (o* '"&% '6,$ o( ,*o'$!'&o- o*#$* '"+' #o -o' +,,)6
'o '"$ o'"$* '6,$% o( ,*o'$!'&o- o*#$*%0
7ES. *ome of these uni3ue rules are highlighted BeloA:
(<' <n $rder for ;rotection <gainst 8arassment in the >or5place !+--o' Be issued against more
than one person)
(B' :nder NRS 33.280, if an employer has 5noAledge that a specific person is the target of
harassment in the Aor5place and the employer intends to see5 a temporary or e1tended order for
protection against such harassment, the employer must ma5e + .oo# (+&'" $((o*' 'o -o'&(6 the
person Aho is the target of the harassment that the employer intends to see5 such an order)
(C' :nder NRS 33.320, an employer or an authoriMed agent of an employer may *$.&%'$* a
temporary or e1tended $rder for ;rotection <gainst 8arassment in the >or5place issued By the
court of another state By presenting a certified copy of the order to the cler5 of the court in a
Dudicial district in Ahich the employer Believes that enforcement may Be necessary) < temporary
or e1tended $rder for ;rotection <gainst 8arassment in the >or5place that is registered has the
same effect and must Be enforced as if it Aere issued in Nevada) 9oreover, the cler5 of the court
Aill maintain a record of all orders that are registered)
(D' /he court may aAard !o%'% +-# *$+%o-+9)$ +''o*-$6:% ($$% to the prevailing party in this
type of case)
((' :nder NRS 33.330, any person Aho enforces an $rder for ;rotection <gainst 8arassment in
the >or5place Based upon a reasonaBle Belief that the order is valid is immune from civil and
criminal liaBility for any action ta5en Based upon that Belief)
(0' :nder NRS 33.330, any person Aho refuses to enforce an $rder for ;rotection <gainst
8arassment in the >or5place Based upon a reasonaBle Belief that the order is -o' valid is immune
from civil and criminal liaBility for any action ta5en or not ta5en Based upon that Belief)
(@' :nder NRS 33.340, an (mployer is immune from civil liaBility for:
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(a' *ee5ing a temporary or e1tended $rder for ;rotection <gainst 8arassment in the
>or5place, if the employer acts in good faith in see5ing the order? or
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(B' 0ailing to see5 a temporary or e1tended $rder for ;rotection <gainst 8arassment in
the >or5place)
(8' :nder NRS 33.340, an action ta5en or a statement made By an employer pursuant to N+*
33)#%% to 33)#%, inclusive (the statutes addressing $rders for ;rotection <gainst 8arassment in
the >or5place':
(a' *hall not Be deemed an admission By the employer of any fact? and
(B' 9ay Be used for the purposes of impeachment)
(7' /he statutory provisions relating to $rders for ;rotection <gainst 8arassment in the
>or5place do not:
(a' 9odify the duty of an employer to provide a safe Aor5place for the employees of the
employer and other persons present at the Aor5place of the employer?
(B' ;rohiBit a person from engaging in any constitutionally protected e1ercise of free
speech, including, Aithout limitation, speech involving laBor disputes concerning
organiMed laBor? or
(c' ;rohiBit a person from engaging in any activity that is part of a laBor dispute)
(20) W"+' &% '"$ ,*o!$#*$ (o* (&)&-. (o* + ,*o'$!'&o- o*#$*0
=ou must fill out tAo different types of documents and suBmit them to the court) <ll documents must Be
completed LEGI;L7) 7f you need additional pages Because you need more space to Arite, you may
re3uest a CONTINUATION PAGE in order to continue Ariting)
/he first document to Be completed is called an APPLICATION. ;lease refer to the courtLs LINE<;7<
LINE INSTRUCTION SHEET for detailed instructions in completing the APPLICATION.
<s you are filling out the APPLICATION, you should 5eep the folloAing things in mind:
("' :nder NRS 200.=82, harassment is deemed to have Been committed FAhere the conduct occurredG or
FAhere the person Aho Aas affected By the conduct Aas located at the time that the conduct occurred)G
0or e1ample, if the <dverse ;arty causes physical damage to a Business in this toAnship, or threatens
employees in this toAnship, you may file here) 7f the <dverse ;arty is ma5ing threatening phone calls to
your Business or its employees, and you received those phone calls in this toAnship, you may file here)
7f another court has Durisdiction over your protection order filing, you Aill need to contact that court in
order to apply for a protection order)
(#' =ou need to Be as specific as possiBle) 0or e1ample, it is important to include all relevant dates,
locations, Aitnesses, etc), so that the revieAing Dustice of the peace Aill have the most complete
information to consider) 7t is also helpful to present your story in a chronological fashion so that the
Dustice of the peace Aill understand a clear se3uence of events)
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(3' =ou may include any supporting documents that you have gathered, such as:
N Documentation of phone calls By the <dverse ;arty
N Notes!Aritten threats left By the <dverse ;arty
N ;ictures of property damage caused By the <dverse ;arty
N <ny other Aritten documents that help to suBstantiate your allegations)
(4' <lthough you are not re3uired to file a police report prior to see5ing a protection order, if you have
filed a police report, you may attach a copy of the police report along Aith your APPLICATION.
A##&'&o-+))6, &( '"$*$ +*$ o'"$* ,*o'$!'&o- o*#$*% 9$'w$$- '"$%$ ,+*'&$%, ,)$+%$ +''+!" !o,&$%, &(
+>+&)+9)$.
(.' /o apply for a protection order, you must Be at least 28 6$+*% o( +.$. 8oAever, the protection order
may Be issued against someone Aho is under "& years of age)
(' /he APPLICATION and any supporting documents that you provide are puBlic records and may Be
vieAed By any memBer of the puBlic, including the <dverse ;arty, e1cept as specified in these
instructions)
(7' /he APPLICATION as5s you to list specific locations Ahere you are see5ing protection) 7f you are
afraid to divulge that information to the <dverse ;arty, you may indicate that such information is
C$N07D(N/7<6 and should not appear on the protection order) 8oAever, please Be advised that this
may limit the aBility of laA enforcement to enforce your order effectively) 0or e1ample, if the court orders
the <dverse ;arty to stay aAay from Fyour Business,G Aith no specific Business addresses listed in the
protection order, police may Be reluctant to arrest the <dverse ;arty if that person shoAs up at a specific
Business location) A)'"o." '"&% o*#$* o( ,*o'$!'&o- +,,)&$% %'+'$w&#$, 6o +*$ %'*o-.)6 $-!o*+.$#
'o )&%' '"$ %,$!&(&! 9%&-$%% +##*$%%$% w"$*$ ,*o'$!'&o- w&)) mo%' )&/$)6 9$ -$$#$#.
(&' <s part of the APPLICATION, you Aill Be as5ed if you Aould li5e the court to set a hearing date for
an e1tended order) 7f you chec5 the yes Bo1, you Aill Be as5ed to file a separate application for an
e1tended order along Aith your application for the temporary order) 7f you chec5 the no Bo1, you may
apply for an e1tended order later, But the e1tended order can only Be re3uested Ahile the temporary order
is still in effect)
0or either option, the temporary order Aill remain in effect until the hearing on the e1tended order is held)
(9' =ou are signing the APPLICATION under penalty of perDury, so you must rememBer that
intentionally false or misleading statements may suBDect you to criminal penalties)
/he second document to Be completed is called a CONFIDENTIAL INFORMATION SHEET. /his
document is not availaBle to the general puBlic or to the <dverse ;arty)
0or several reasons, it is critical that you fill out this document as completely as possiBle:
("' /his document Aill provide information to the court so that the court can contact you and provide
information aBout upcoming hearings or activities in your case)
(#' /his information is needed By laA enforcement agencies for purposes of service) P*o'$!'&o- o*#$*%
m%' 9$ %$*>$# ,*%+-' 'o R)$% o( C&>&) P*o!$#*$.

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<fter you have completed the APPLICATION and the CONFIDENTIAL INFORMATION SHEET,
your paperAor5 Aill Be assigned a case numBer, and the case Aill Be assigned to a Dustice of the peace
Aho Aill revieA your information)
7f the Dustice of the peace denies your re3uest for a protection order, the Dustice of the peace Aill sign a
Aritten order denying your re3uest and e1plaining Ahy the protection order is not Aarranted)
7f the Dustice of the peace grants your re3uest, a Aritten protection order Aill Be prepared, and the parties
Aill each receive a free copy of the order) /he order Aill also Be forAarded to the appropriate laA
enforcement agencies for service upon the <dverse ;arty) :nli5e other types of protection orders, there &%
a fee for having laA enforcement agencies serve this type of protection order in Nevada)
;lease note that if the <dverse ;arty resides outside this County or in another state, it Aill Be your
responsiBility to contact the proper laA enforcement agencies Ahere the <dverse ;arty resides, in order to
have the protection order served) :nder NRS 33.300, a laA enforcement agency must enforce an $rder
for ;rotection <gainst 8arassment in the >or5place Aithout regard to the county in Ahich the order Aas
issued)
I( 6o +*$ + ,+*'6 'o + TPO +!'&o-, 6o, m+6 -o' %$*>$ '"+' TPO 6o*%$)( o- '"$ +#>$*%$ ,+*'6.
7nstead, the /;$ must Be served By a deputy constaBle, deputy sheriff, or person Aho is not a party and
Aho is over "& years of age)
=ou may also use a private process server to serve the <dverse ;arty at your oAn e1pense) 7f you choose
to do so, you must file Aith the court a document called a F+eturn of *erviceG Ahich shoAs that the
<dverse ;arty Aas properly served)
(22) Do$% '"$ A#>$*%$ P+*'6 "+>$ +-6 *$m$#&$% o-!$ '"$ ,*o'$!'&o- o*#$* &% &%%$#0
/he <dverse ;arty has three (3' options once the protection order is issued)
(<' $n 2 #+6%: -o'&!$ to the <pplicant, or on such shorter notice as the court may re3uire, the <dverse
;arty may file a Mo'&o- 'o D&%%o)>$ the protection order, and the court may schedule a hearing on the
9otion) 7f the 9otion is granted, the protection order Aill Become immediately void and unenforceaBle)
< protection order can only Be dissolved By a court)
(B' $n 2 #+6%: -o'&!$ to the <pplicant, or on such shorter notice as the court may re3uire, the <dverse
;arty may file a Mo'&o- 'o Mo#&(6 the protection order, and the court may schedule a hearing on the
9otion) /his commonly occurs Ahen the <dverse ;arty Believes that the protection order is too Broad or
that the protection order is unduly Burdensome) < protection order can only Be modified By the court)
(C' 7f an e1tended order is issued, the <dverse ;arty may file an +,,$+) to District Court, and the District
Court may affirm, modify or vacate the order in 3uestion) /he <dverse ;arty may appeal Aithout filing a
Bond, But the appeal itself does not stay the effect or enforcement of the e1tended order)
CONCLUSION
Based upon the foregoing the undersigned respectfully re3uests that this Court *et <side the
*ummary Contempt $rder incident to the 0eBruary #7, #%"# /rial, return all of the undersigned
;ersonal ;roperty, and Dismiss this Criminal Complaint, and any other relief this Court deems Dust)
AFFIRMATION PURSUANT TO NRS 234;.030
/he undersigned does hereBy affirm that the preceding document does not contain the social
security numBer of any person)
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Dated: 9arch , #%"#
!*! Zach CoughlinOOOOOOOO
Zach Coughlin, Defendant
- 10 -
9$/7$N 0$+ N(> /+7<6? N$/7C( $0 N$N2+(C(7;/ $0 # #& "# C$N/(9;/!*<NC/7$N $+D(+? N$/7C(
$0 -7$6</7$N $0 N+* "7&)4%.!.)%"%?9$/7$N 0$+ <++(*/ $0 C:D@9(N/
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PROOF OF SER?ICE
;ursuant to N+C; .(B', 7 certify that 7 served a copy of the foregoing document upon the
folloAing party By fa1ing, emailing, dropping +f at their office, and placing a true and correct copy
of the foregoing document in the us mail) addressed tp:
<lison 9) $rmaas, (s3)
$ne (ast 0irst *treet, 3rd 0loor
0a1 numBer: 77.233424##
ormaasaPreno)gov, 5adlicDPreno)gov
Cohn Eadlic, (s3)
+eno City <ttorney4s $ffice 2 Criminal Divison
;)$) Bo1 "9%% +eno , N- &9.%.
/el: 77.23342#%.% 0a1: 77.23342#4#%
<ttorney for City of +eno 77. 334 3&#4
+eno 9unicipal Court filed By fa1 to :
Date this 9arch , #%"#
!*! Zach Coughlin
Zach Coughlin, Defendant
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9$/7$N 0$+ N(> /+7<6? N$/7C( $0 N$N2+(C(7;/ $0 # #& "# C$N/(9;/!*<NC/7$N $+D(+? N$/7C(
$0 -7$6</7$N $0 N+* "7&)4%.!.)%"%?9$/7$N 0$+ <++(*/ $0 C:D@9(N/
xxxx
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xxxxx
4/17/13 /s/ zach couglin