7 18 13 0204 62337 Stamped 759 Pages Notice of Irregs 13-21067

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IN THE SUPREME COURT OF THE STATE OF NEVADA
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Electronically Filed
ZACH COUGHLIN;
Appellant.
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Jul 18 2013 10:21 a.m.

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Tracie K. Lindeman
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Clerk of Supreme Court
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) Supreme Court No: 62337
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vs.
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SBN
Respondents
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NOTICE OF IRREGULARITIES
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Coughlin hereby files this and Declares under penalty of perjury pursuant to
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NRS 53.045 that everything within this filing and attached to it is true to the best of
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his knowledge, and that any matters stated upon information and belief herein
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Coughlin reasonably believes them to be true and that all materials attached are true
and correct copies of what they purport to be.
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Dated this 7 17 13
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/s/ Zach Coughlin, signed

electronically
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Zach Coughlin, Esq.
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Appellant
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NOTICE
Docket 62337 Document 2013-21067
Proof of Service:
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On this date, I, Zach Coughlin electronically served a true and correct copy of the
foregoing document to all registered efilers, and to those whom are not I placed a
true and correct copy of the foregoing document in the usps mail on this date:
David Clark via Eflex
mailed to Pat King at Bar's Northern Office, EPO permitting
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DATED THIS: Dated thi 7 17 13
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/s/ Zach Coughlin

Zach Coughlin
Appellant
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NOTICE
INDEX TO EXHIBITS:
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1. Exhibit 1: various relevant materials.
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NOTICE
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ZACH COUGHLIN;
Appellant.
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vs.
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SBN
Respondents
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NOTICE AND DECLARATION AS TO SBN CLERK OF COURT PETERS

AND ASSISTANT BAR COUNSEL KING'S PICK AND ROLL COMBO;
MOTION TO PROCEED IN FORMA PAUPERIS IN THIS APPEAL AND ANY
PROCEEDINGS TO BE CONDUCTED IN THE TRIAL COURT; MOTION TO
REQUIRE KING TO BECOME AND EFILER SUFFICIENT TO AMELIORATE
CURRENT CIRCUMSTANCES WHERE RPD AND CITY OF RENO
ATTORNEYS ARREST AND PROSECUTE COUGHLIN FOR EVEN
ALLEGEDLY SERVING FILING ON THE SBN (WHICH IS AN ARM OF THE
COURT UNDER WATERS, ANYWAYS)
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Petitioner, ZACHARY BARKER COUGHLIN, representing himself files

this Notice for the de novo review, noting to the failure of NNDB Chairman
Susich, apparently, to follow SCR 110(3)-(4)'s requirement that he notify a District
Court judge of the contempt attendant to a variety of individuals and entities failing
to respond to Coughlin's SCR 110 subpoenas for the 11/14/12 formal disciplinary
hearing
And to give, uh, credit, where it is due, City of Reno Prosecutor Dan Wong,
Esq. is Glass Plus on the boards...currently subjecting Coughlin to two different
baseless prosecutions in the Reno Municipal Court, even where Wong "happily"
admits that he would prosecute Coughlin for alleged violation of the jurisdictional
prerequisites devoid Reno Justice Court Workplace Harassment TPO/EPO obtained
against Coughlin by the SBN on 12/20/12 in RCP2012-000607
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NOTICE AND DECLARATION

MOTION FOR LEAVE TO FILE OPPOSITION TO SCR 111(4) PETITION IN 61901,
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7 C.J.S. Attorney & Client

IV. Professional Conduct and Supervision Thereof
41. Generally
42. Canons of ethics and codes of professional responsibility
43. Standards of conduct
44. Aiding administration of justice
45. Solicitation of clients
46. Advertising, letterheads, and listings
47. Protection and representation of clients
48. Exercise of independent judgment; conflicting interests
49. Preserving funds and property of client
50. Preserving confidences and secrets
51. Zealous advocacy; assertion of frivolous claims
52. Making of extrajudicial statements
53. Dealings with opposing counsel, parties, witnesses, and jurors
54. Dealings with opposing counsel, parties, witnesses, and jurorsComm. with
repd party
55. Dealings with opposing counsel, parties, witnesses, and jurorsEmployees of
parties
56. Influencing official action; prior public employment
57. Fees, compensation, and sale of practice
58. Miscellaneous activities or conduct
59. Methods of enforcement; disqualification
60. Determination of grounds for disqualification
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V. Discipline, Suspension, and Disbarment

A. In General
61. Generally
62. Power of particular courts, committees, and agencies
63. Defenses
64. --Limitations and laches
65. --Personal problems or mental disabilities
66. --Settlement with, or absence of objection by, client
B. Grounds
1. In General
67. Generally
68. Moral turpitude, dishonesty, and corruption
69. Want or loss of moral character
70. Mental or physical illness, alcoholism, or drug addiction
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71. Fraud in procuring admission

72. Criminal offenses and conviction thereof
73. --Effect of pendency of criminal proceedings
74. --Effect of acquittal or pardon
75. --Effect of appeal and reversal; post-conviction relief
76. Misconduct in nonprofessional capacity
77. Misconduct as public officer or judge
2. Professional Misconduct
78. Generally
79. Misconduct in relation to client
80. --Disregard of client's interests; representation of conflicting interests
81. --Improper dealing with funds; misappropriation
82. Misconduct in relation to other attorneys
83. Misconduct in relation to court
84. Deception of court and obstruction of justice
85. Misuse, falsification, or alteration of records and papers
86. Misconduct in relation to disciplinary authorities
87. Solicitation of clients and advertising
88. Miscellaneous grounds
C. Proceedings, Disciplinary Order, and Punishment
1. In General
89. Generally
90. Nature, form, and purpose of proceedings
91. Functions and qualifications of persons conducting proceedings
92. Applicable forms and rules of procedure
93. Notice
94. Preliminary investigations and proceedings
95. Disclosure, discovery, and examination; confidentiality of proceedings
2. Parties and Pleadings
96. Persons entitled to prosecute; parties
97. Charges; issues, proof, and variance
98. Answer
3. Evidence and Burden of Proof
99. Generally
100. Presumptions and burden of proof
101. Admissibility of evidence
102. --Weight and sufficiency
103. Degree of proof
104. Evidence of particular misconduct
4. Trial or Hearing
a. In General
105. Generally
106. Questions of law and fact; dismissal
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107. Deliberations, scope of inquiry, and verdict or findings

b. Disciplinary Board Hearing and Judicial Review
108. Hearing and determination by referee, committee, or board
109. Review by court
110. --Scope of review
5. Disciplinary Order and New Trial
111. Decision and judgment or order
112. --On review of action of referee, commissioner, committee, or board
113. New trial and rehearing
6. Appellate Review
114. Review of judgment on appeal
115. Scope of review and determination of case
7. Punishment
116. Generally
117. Circumstances considered in fixing punishment
118. Particular offenses or misconduct
119. --Misconduct in relation to client
8. Costs and Effect of Judgment
120. Costs
121. Operation and effect of judgment or order
122. --Practice in other jurisdictions
D. Reinstatement After Disbarment or Suspension
1. In General
123. Generally
124. Discretion of court and scope of inquiry
125. --Controlling factors
126. Effect of pardon or reversal of conviction
2. Procedure
127. Application for reinstatement
128. --Evidence and burden of proof
129. --Findings, conclusions, and judgment
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How ironic it is that the allegation Merliss's counsel made in his 2/24/12
Answering Brief in the Appeal to the Dist. Ct. that Coughlin "failed to raise" the
issues of his being a commercial tenancy sufficient to prohibit, under NRS 40.254,
the use of the summary procedures in NRS 40.253 where a no cause eviction was
plead (and clearly, at no point did Merliss amend his pleadings or "unlawful
detainer affidavit" sufficient to make his action for possession one based on nonpayment of rent, and the trial court may not amend the landlord's pleadings for him,
especially where the landlord's attorney, fearful of the NRCP Rule 11 implications
attendant to making any such claims of rent owing and expressly indicating that he
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was pursuing a "no-cause eviction" under NRS 40.254 (with such statutory section
specifically cited in the very "unlawful detainer affidavit" admitted as one of the
landlord's exhibits during the 10/25/11 proceeding, in addition to in the landlord's
attorney's 10/19/11 Declaration (which expressly indicated it was being filed in an
attempt to satisfy the requirements of NRS 40.254(2)) and decidedly not alleging
any rent was owed, nor seeking an award of any rent. Dubiously (and a fine review
of this matter likely reveals an alarming degree of judicial misconduct), the RJC, in
addition to appearing to attempt to plead non-payment on behalf of the landlord
(incident to conducting a sua sponte interrogation of Coughlin at the initial
10/13/11 proceeding upon the problem of the landlord failing to show up and his
counsel not being an appropriate witness sufficient to permit Coughlin an
opportunity to "test the truthfulness and sufficiency" of some "unlawful detainer
affidavit" which had not even been filed (or, apparently, even provided to Coughlin
until, at the earliest, the day before the 10/25/11 proceeding), also seemed to
attempt to coax the landlord into seeking an award of past rent out of the "rent
escrow" deposit ordered pursuant to NRS 118A.355(5) (and Coughlin's pleading a
commercial tenancy clearly precluded any such application). Such brings up the
illegitimacy of requiring a tenant (particularly a commercial tenant) to make such a
rent escrow deposit (based upon a statutory section found in NRS 118A, the
"Residential Landlord Tenant Act") especially where the "unlawful detainer
affidavit" manifest from the record (not "you failed to raise it" bar where it is
manifest from the record that Coughlin did in fact raise such issues in the trial
court)...ironic considering that Merliss's attorney's are the one's against whom the
"you failed to raise it" or DCR 13(3) bar (which was applied, mistakenly to
Coughlin in the appeal in Flanagan's 6/25/12 award of attorney's fees, to which an
excusable neglect analysis is required (to whatever extent Coughlin's 1/14/12
"standing order going forward" Opposition to any attorney fee motion ever brought
by Hill or his associate is not recognized) considering the inequity attendant to the
summary 8 day incarceration by Judge Elliott in CR12-0376 starting the very day,
4/19/12 that the Motion for Attorney Fees/Sanctions in the appeal to the Dist Ct.
appealed herein was filed, not to mention the NRS 178.405 mandatory stay
violations committed by the WCPD, WCDA's Office, and, however coincidentally,
Judge Sferrazza where they attempted to hold a trial on the very day the deadline to
file an Opposition to that 4/19/12 Motion for Atty Fees/Sanctions feel due, 5/7/12
in the convictions now on appeal in CR12-2025 (that trial was within the criminal
prosecution of Coughlin for some half-baked "lost, mislaid, or abandoned property"
as not only petit larceny (but, ridiculously,considering a "thief cannot receive from
himself the fruits of his larceny", a "receiving stolen property" charge an
subsequent conviction for both charges as well, despite Judge Sferrazza being
provided both Shepp and Staab sufficient to undermine the receiving charge,
especially where there was zero allegation that the man allegedly finding the phone
on the ground had "stolen" it, much less any assertion that Coughlin "knew" such
man had "stolen" any such item Coughlin thereafter was said to have been freely
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given by said man) allegedly retrieved by Coughlin from one finding an iPhone on
the ground in downtown Reno, whom then loudly announced to all in the plaza in
front of City Hall that he would "throw it in the river" if someone did not
immediately claim the phone).
While Coughlin filed many documents which may appropriately be viewed as
functional equivalents thereof, any view that Coughlin failed to timely file, or
otherwise seek to address later an such failure to file, a Reply to the 2/24/12
Answering Brief in the appeal clearly must view any such failure as satisfying the
"good cause" or "excusable neglect" standard. This is particularly true where at the
time such Reply would have been due Coughlin was incarcerated, wrongfully,
incident to the summary contempt 5 day incarceration he was subjected to (even
where he pleaded with Judge Holmes (not to mention the prejudice to his case
brought by a similar refusal (consider NCJC Rule 2.15) by RMC Judge Howard to
grant a stay of any sort as to his own 3 day summary contempt incarceration of
Coughlin between 11/30/11 and 12/3/11) that a failure to accord a stay of any
length at all would not only prejudice him (especially where self representing as a
license attorney in a number of matters (and if In Re Schaeffer allows for applying
RPC's against attorneys where proceeding pro se, then the traditional rule
essentially requiring a stay of any summary contempt incarceration of an attorney
(to avoid prejudice to his clients/interference with the orderly administration of
justice in the other matters wherein the attorney is appearing) should have applied
to the summary incarceration of Coughlin on 2/27/12 not only in light of Coughlin
representing clients other than himself, but also in light of the matters wherein
Coughlin was self representing, as a licensed attorney whom subsequently had a
bevy of RPC's applied scattershot to his self representation therein. To hold
otherwise would be tantamount to the SBN and Bench seeking to have it both
ways. (During the relevant times involved herein, Coughlin was represneting
clients, including a single father living in Florida in UIFSA and custody matters, in
Jones v. Harris; foreclosure defense clients in Carpentier v. Aames; debtors in
adversary proceedings in the NVB before the same Judge Beesley (hard to cross
examine a "judge as witness" (wait, SBN/Panel, didn't the 11/2/12 Motion to Quash
Coughlin's subpoenas on judges and the 11/7/12 Ex Parte Order granting it rule one
couldn't "question judges as to their though processes"? Law of the case? How
then were Judge Beesley and Judge Holmes able to testify about their thought
process (but only to the extent doing so suited the agenda of the SBN/Panel) at that
hearing:
HEARING - Vol. I, (Pages 135:22 to 138:9) BY MR. KING: Q -- paragraph 3,
and this is partly for the purpose of laying a foundation, did you actually write it? It
says, "He has not practiced law in this case in a manner that demonstrates his
competence, professionalism, preparation, consideration for the court, the witnesses
or his opposing counsel. He has been very disrespectful to the court." Did you write
that? A Yes, I did write that. Q And then you made a list, you actually went so
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far as on Page 4 as to be very specific in listing the rules of professional conduct

that you were saying he violated? A Yes, I did. Q You listed 8.4, engaged in
dishonesty, fraud, deceit or misrepresentation. Because I'm limited in time, I'm
not going to read them all, but I'm going to ask that Exhibit Number 5 be admitted.
MR. ECHEVERRIA: Objection, Counsel? MR. COUGHLIN: Yeah. This looks
totally different than the one that's in the file. What's going on here? Why is this
one all blurry and illegible, and this one like pristine clean, Pat? MR.
ECHEVERRIA: What is the objection, Mr. Coughlin? MR. COUGHLIN: If this
wasn't propounded. MR. ECHEVERRIA: This wasn't what? MR. COUGHLIN:
This version wasn't propounded earlier. MR. ECHEVERRIA: It was attached
to the complaint. MR. COUGHLIN: This is clear. The problem is the one he's
always attached to the complaint is not clear. THE WITNESS (JUDGE HOLMES):
Mr. Echeverria, that was also provided to Mr. Coughlin. At the time that order
was entered, I had him served up in jail when he was being held for
contempt -- MR. COUGHLIN: No, you didn't. THE WITNESS: -- mailed to his
house as well. MR. COUGHLIN: No, she didn't. MR. ECHEVERRIA: Thanks,
Judge. I'm going to admit Exhibit 5. It was the order attached to the complaint. It
was provided as Bates numbers 1804 through 1809 to the documents copied and
produced for Mr. Coughlin. So Exhibit 5 is admitted. (Exhibit 5 admitted into
evidence.) BY MR. KING: Q Judge Holmes, was it your intention -- you made
these findings by clear and convincing evidence, which is the standard of proof
necessary for disciplinary proceedings. Was it your intention that this order be
accepted by the panel as proof of his -- as irrefutable proof of his violation of
these rules? A Yes, it was. And I'm not intending to substitute myself for the
panel. I understand, and did understand, that it was their job to conclude that. But I
did want to tell them that in my experience, and based on my judicial position, I
did find that established by that particular level of proof. And I do believe that it
has that, in my experience with him".
Regardless of the fact that it is not true, and the the Certificate of Service for
that 2/28/12 Order contains no indication that Coughlin was served any such Order
"at the jail", the SBN in no way notice-pled the idea or factual contention that the
RMC's failure to serve Coughlin the 2/28/12 Order (the RMC received as "return to
sender" the one version it mailed to Coughlin, which was mailed to an address that
the RMC knew was no longer good, and where the RMC thereafter failed to remail
such Order to the address which it had been informed by Coughlin was current)
would somehow be countered by Judge Nash Holmes, curiously, and conveniently,
all the sudden remembering that she had this one Order from nine months prior
served on Coughlin while he was in jail, over, above, and beyond having it "mailed
to his house as well" (glossing over the bit about having it mailed to an address
Judge Holmes knew was outdated, and the failure to attempt any alternate service
thereof upon receiving such wrongly address mailing back marked "no longer at
this address".
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Also, it is particularly rich that immediately after the SBN's King address
some undefined "finding" in the 3/12/12 Order by Judge Holmes that Couglin had
violated RPC 8.4 that King himself then immediately thereafter engages in just
such misconduct where he attempts to slip into the record a version of that Order
that excises all the notice/legibility issues inherent to his attaching to the 8/23/12
Complaint a far different version of that Order, one that represents a very off center
photocopying of such order replete with the last five lines or so of every page
completely illegible due to being incredibly faint and blurry (which is especially
problematic when considering those parts of that Order which were illegible in the
version attached the the Complaint by King (ironic this legibility issue pops up here
considering the wholesale dismissals of Coughlin's suit against witness Elcano's
own WLS, et al in 60302, and 60317) comprise a major percentage of those
excerpts from that Order relied upon by the Panel in its 12/14/12 FOFCOL or
testified to by Judge Holmes. Due process. Notice. Opportunity to be heard.
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Judge Beesley whom testified at Coughlin's 11/14/12 formal disciplinary

hearing (though Beesley could not remember much of anything in the way of
specifics to support his outrageously negligent contention that Coughlin resulting in
a ridiculous and shameful recommendation by the SBN and NNDB Panel to
permanently disbar Coughlin now appeal in 62337 (consider the inequity of the
events of March 2012 in Coughlin's life and practice in comparison to the actions
and testimony at his 11/14/12 formal disciplinary hearing of Judge Beesley and
RMC Judge Holmes (in addition to her 3/14/12 greivance letter against Coughlin to
the SBN.
HEARING - Vol. I, (Pages 10:6 to 11:7) BRUCE BEESLEY Having been first
duly sworn, testified as follows: DIRECT EXAMINATION BY MR. KING: Q
Judge Beesley, can you explain to the panel your knowledge in this relevant time
frame 2011-2012 regarding Mr. Coughlin and his conduct in your court? A Mr.
Coughlin appeared in my court a couple of times, at least two or three times. The
first time I recall him coming to my court he came in, he was wearing, I think, a Tshirt and a tie, and no jacket. And he indicated that he had been evicted from his
residence or his office, indicating it was not because of not paying the rent, and that
that was why he wasn't what I would consider appropriately dressed. I apologize. I
don't have my letter in front of me. But my recollection is that he had filed a
pleading on behalf of his client in regard to some aspect of a bankruptcy case, and
that the pleading was lengthy, didn't make any sense, and just sort of rambled
through a great deal of irrelevant stuff. I had him a couple other times in my court
and had the same experience, that -- he was dressed appropriately the other times I
had him there, and he was very polite and appeared to be a very intelligent man.
But his pleadings didn't make any sense. His arguments didn't make any sense."
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HEARING - Vol. I, (Page 24:14 to 24:19) Q You would be referring to the T-shirt
and tie incident? A Yes. Q With a suit jacket on though? A Yeah. And your
apology was satisfactory, although I thought your appearance was odd."
HEARING - Vol. I, (Page 15:10 to 15:20) BY MR. KING: Q Have you formed an
opinion, your Honor, as to whether or not Mr. Coughlin is competent to practice
law? A (Judge Beesley): Yes. Q And what is that opinion? A I don't believe he
is, unfortunately. MR. KING: Thank you very much. I have no further questions. I
really appreciate your time. The panel in these settings may ask you questions or
they may have questions for you, as well as, I suspect, Mr. Coughlin."
Note the SBN's complete and utter lack of effort to gather a single shred of
specific factual testimony or documentation to support the testimony it elicited
from Judge Beesley.
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HEARING - Vol. I, (Page 16:1 to 16:18) CROSS-EXAMINATION BY MR.

COUGHLIN: Q Good morning, Judge Beesley, your Honor. A Morning. Q I'm
sorry to hear you feel that way about me, sir, but I would like to ask you a few
questions. A Certainly. Q I would bet that your statements are made out of
concern. A They are. Q So I appreciate that, sir. And I don't mean for my
reactions this morning to indicate anything other than a complete and utter... -- a
complete and utter respect for you, sir. A I don't take it any other way. Q Thank
you, sir. But it's out of a profound respect for the law and due process that I'm
acting the way I am."
HEARING - Vol. I, (Pages 22:10 to 23:18) ow that I did that. Q What review did
you undertake of my work product and filings in your court to come to your
opinions? A I looked through two or three pleadings that you had filed in, I think
you had one or perhaps two cases, and read them. And I observed you arguing in
court. Q When specifically? A I don't recall. Q Was your testimony earlier
today that the first time you recall being aware of me was when I appeared at the
March 15th hearing in Cado Company v. Keller at 2:30 P.M. shortly after being
evicted at gunpoint by the Washoe County Sheriffs -- A I actually think you had
appeared in front of me one time before that. But that was my first strong
recollection of you appearing in front of me. Q And it was that brief interaction
whereupon you formed your opinion that I wasn't fit to practice? A No. I thought
it was odd, but I do understand that people have adversity in their lives sometimes,
which happens -- Q You took it to be adversity rather than misconduct by the
sheriff? MR. ECHEVERRIA: Mr. Coughlin, you interrupted the witness. MR.
COUGHLIN: Yes. MR. ECHEVERRIA: Go ahead, Judge. THE WITNESS: And
I believe that you had filed some pleading in that case. And I went to the pleadings,
and they frankly didn't make any sense. And I think you subsequently filed
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pleadings in other cases which also didn't make any sense, and I became
concerned."
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HEARING - Vol. I, (Pages 22:10 to 23:18) ow that I did that. Q What review did
you undertake of my work product and filings in your court to come to your
opinions? A I looked through two or three pleadings that you had filed in, I think
you had one or perhaps two cases, and read them. And I observed you arguing in
court. Q When specifically? A I don't recall. Q Was your testimony earlier
today that the first time you recall being aware of me was when I appeared at the
March 15th hearing in Cado Company v. Keller at 2:30 P.M. shortly after being
evicted at gunpoint by the Washoe County Sheriffs -- A I actually think you had
appeared in front of me one time before that. But that was my first strong
recollection of you appearing in front of me. Q And it was that brief interaction
whereupon you formed your opinion that I wasn't fit to practice? A No. I thought
it was odd, but I do understand that people have adversity in their lives sometimes,
which happens -- Q You took it to be adversity rather than misconduct by the
sheriff? MR. ECHEVERRIA: Mr. Coughlin, you interrupted the witness. MR.
COUGHLIN: Yes. MR. ECHEVERRIA: Go ahead, Judge. THE WITNESS: And
I believe that you had filed some pleading in that case. And I went to the pleadings,
and they frankly didn't make any sense. And I think you subsequently filed
pleadings in other cases which also didn't make any sense, and I became
concerned."
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HEARING - Vol. I, (Pages 24:20 to 25:17) Q Do you recall a hearing prior to that
in that same Cado Company v. Keller wherein Cado sought to amend their
adversary proceeding charges, and there was maybe a five- to ten-minute hearing
on that incident to which I submitted about a 15-page motion addressing the salient
points of law in that setting? A I cannot place it in the context of that case. But I
do remember you submitting a motion describing some points of law on something,
and I didn't think that that was competent work, frankly. Q You're referring to
which motion? A I don't know. I don't have any motion in front of me. Q So you
have a fairly strong opinion on it, yet you don't recall any specifics. Would that be
an accurate assessment of your testimony? A What I recall is that your appearance
in court was odd, and your pleadings were not truly comprehensible, and that and
further inquires made me concerned that you were having some difficulties that
prevented you from serving your client appropriately. Q Did you find any of my
work competent? A I don't believe I did."
HEARING - Vol. I, (Pages 26:25 to 28:1) BY MR. COUGHLIN: Q Your Honor,
I'd like to narrow down some of these assessments you've made vis-a-vis when they
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occurred. A Unless you can show me the document, I don't think I can help
you with that. (NOTE: that may have been an attempt at humor by Judge Beesley
considering he was testifying by phone, as did Judge Holmes...similarly, King
alluded to Judge Holmes "authenticating" an Order over the phone) Q But you've
testified pretty definitively here today. So wouldn't that indicate some negligence
on your behalf in that regard? MR. KING: Objection. Argumentative. MR.
ECHEVERRIA: Sustained. BY MR. COUGHLIN: Q Your Honor, do you have
any specific points of law or issues with which you can elucidate why you question
my competency to practice in your court? MR. KING: Objection. Asked and
answered. MR. ECHEVERRIA: Sustained. BY MR. COUGHLIN: Q Do you
recall any of my work product in Cadle Company? A Not specifically, no. I
remember a fairly lengthy brief that you filed which, I think, was that case,
that I thought was rambling, addressing points of law which weren't relevant.
I think had some discussions of historical matters and some discussions of
perhaps constitutional law, but it wasn't really relevant to the matter that was in
front of me."
HEARING - Vol. I, (Pages 28:11 to 29:17) BY MR. COUGHLIN: Q Your Honor,
on Cadle Company, wouldn't it indicate a fairly high level of skill, particularly
for one who hadn't been practicing in a bankruptcy setting for very long at all
for, one, to deduce that in that case Cadle had issues with respect to the fact
that they had not renewed a dormant foreign judgment in that under the Texas
statute at issue, given the fact that the judgment was over ten years old, and
within the two years under the statute within which they had to take some act
to revive a dormant judgment, they failed to do so. Wouldn't the fact that I
pointed that out in a brief, and specifically cited to relevant legal research with
respect to what particular acts would qualify as reviving a dormant
judgment in that respect, wouldn't that indicate some level of competency? A
(Judge Beesley): I did not ever say that I did not think you are highly intelligent. I
think you are. But intelligence and legal competence are not the same thing. I think
you have a significant lack of ability to focus on the issues at hand, but you're very
smart. Q If I pointed out, which I believe I did in that case, that Cadle Co., by
having a vice president file an affidavit seeking to register a foreign judgment,
that their doing so violated NRCP 11, in that a corporation such as Cadle Co.
is not entitled to appear pro se, to wit through a vice president who is not an
attorney, wouldn't that evince some level of capability as an attorney sufficient
to avoid having a federal judge respond to Mr. King's imploring him to badmouth
me at a hearing? MR. KING: Objection. Argumentative. MR. ECHEVERRIA:
Sustained. MR. KING: Thank you."
HEARING - Vol. I, (Page 3:15 to 3:18) Formal Hearing Exhibits:... Ex. 2 (3/30/12
Order in appeal of summary eviction from former home law office involving Hill's
firm awarding $42,065 attorney fee award)...Ex.3 4/13/09 Order After Trial
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("received" as a greivance in the SBN on 3/15/12)... Ex. 6 - Letter dated February

14, 2012 to Mr. Coughlin from SBN's Mr. King pages 159 165... Ex.7 - Twopage letter dated March 9, 2012 from Mr. Coughlin to State Bar pages 165 169 8
- Two page letter dated March 14, 2012 from Judge Holmes to Mr. Clark (SBN)
pages 171 175..."
HEARING - Vol. I, (Page 49:11 to 49:16) MR. COUGHLIN: The rule says I'm to
have no less than 30 days from service of the notice of the hearing to inspect, up to
within three days of the hearing, these materials. Mr. King refused to let me see
these materials for months, going all the way back to March."
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HEARING - Vol. I, (Pages 96:17 to 98:6) Q Which judge signed that order? A
Judge Linda Gardner, who is a family court judge in Washoe County, Nevada. Q
What is the date that she signed the order? MR. COUGHLIN: You say it's been
marked, Pat, you haven't entered it yet? MR. KING: That's correct. MR.
ECHEVERRIA: He hasn't offered it yet. MR. COUGHLIN: Just a -- BY MR.
KING: Q The date next to her signature? A April 10th, 2009. MR. KING: I'm
going to move that this order, a certified copy of which has been produced, be
admitted as Exhibit No. 3. MR. COUGHLIN: I'll object, sir. It just looks
substantially different than what I have seen of this order. Further, the received on
it is not certified, and that goes to a material issue here to the extent that this is
purportedly a ghost grievance. We don't know how this materialized at the State
Bar. We don't know if it involves some brother and sister judicial -- well, we
actually kind of do know that Judge Linda Gardner passed it to her brother, the
administrator of muni court who presided over the trespass conviction. And he
admits passing to Judge Nash Holmes -- MR. ECHEVERRIA: What's the
objection? MR. COUGHLIN: -- the day before March 15th on this filed her
grievance with the State Bar. MR. ECHEVERRIA: What is the objection? MR.
COUGHLIN: I want to know exactly where and how Mr. King got this order. Why
the 5 on this March 15th looks so odd and different than the previous versions
where -- it looks like somebody drew the 5 in a little darker, Pat. MR.
ECHEVERRIA: So your objection is what, sir? MR. COUGHLIN: He's talking
about it being certified, and all this and that. I would like some more information
about that. How is it certified?"
HEARING - Vol. I, (Pages 98:7 to 105:9) MR. KING: I asked the witness -- I was
going to ask the witness -- the witness identified this as a document he
recognized that was signed by the judge. The witness testified that he heard the
hearing. BY MR. KING: Q Why did this matter to you -- MR. COUGHLIN:
No, he said it's certified. .... MR. ECHEVERRIA: What's the objection? MR.
COUGHLIN: It's not certified,... MR. COUGHLIN: Well, he said it was
certified. So my objection is, let's see the proof. Did you get it from Joey or
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Gina Hastings or did you get it from the clerk of court of the muni court? MR.
ECHEVERRIA: Mr. Coughlin. I'm not going to entertain questions between and
among the lawyers. If you have a question, direct it to the panel or the witness. The
objection is this lacks foundation? MR. COUGHLIN: No. That this certification
hadn't been proved or even spoken to besides ... MR. COUGHLIN: -- certified.
MR. ECHEVERRIA: -- position that only legal documents can be admitted that
are certified? MR. COUGHLIN: Well, I didn't make a position on that. My
position is he said it was certified. So I'm contesting that. MR. ECHEVERRIA:
Is this certified? MR. KING: Let me get the clerk to bring the certification
copies, unless she gave them to you already, which I understood she did. Did she
bring you copies? MR. ECHEVERRIA: This particular one is not certified. Do you
have one that's certified? MR. KING: I have already introduced -- the copies do
not show that it's certified. MR. COUGHLIN: Your Honor, if I can quickly
interject for the record, I mean that not disrespectful. MR. ECHEVERRIA: Are we
on the record? Are you getting this, Ms. Reporter? THE COURT REPORTER:
Yes. MR. ECHEVERRIA: Go ahead. MR. KING: Mr. Chairman, I'll lay -- I
understood, and since this has been filed with the courts that we have certified
copies. Since the copy I gave you is not certified, I'm going to lay a foundation a
different way and withdraw the representation that the copy I gave is a certified
copy. MR. COUGHLIN: Yeah. And that's just another basis for all -- the 13th time
on the clock. I'm going to say formally yes, I think a recusal is appropriate. And I
think, Pat, you need to consider whether that's fraud, to be saying it's certified,
backtracking once you get caught on it. But I'm just going to put that out for the
record. MR. ECHEVERRIA: Let's deal with this. Are you now making a motion
that I should recuse myself? MR. COUGHLIN: Do you think you should? MR.
ECHEVERRIA: No. Are you making that motion? MR. COUGHLIN: Yeah, I
think so. Probably. MR. ECHEVERRIA: Well, then articulate your position. I'd
like to hear it. MR. COUGHLIN: I think it's been set forth enough. MR.
ECHEVERRIA: Set forth what? MR. COUGHLIN: You've admitted to being
childhood friends. There's a rather odd suggestion that you didn't know you both
went to Stanford in 1966 despite being childhood friends, and being in northern
Nevada practicing law or members of the legal community. And I would like to
know any other relevant nexus between the two of you. MR. ECHEVERRIA: So
your basis for moving that I should recuse myself is that I knew Mr. Elcano as a
childhood friend, and we were at the same school together? MR. COUGHLIN:
And the fact that Mr. King has worn every different hat he's wanted to wear here.
The fact he just said something was certified, then he backtracks and -- you asked
me for my basis. MR. ECHEVERRIA: Mr. Coughlin, I'm asking you to focus on
your motion for recusal. Is it your position that legally any judicial officer must
recuse themselves if he happens to have -- MR. COUGHLIN: I'm not going to get
narrowed down into if you were childhood friends. I'm telling you my basis, and
that is that there is too much funny business going on here. MR. ECHEVERRIA:
Overruled. MR. COUGHLIN: I'd like to set forth specifically. MR.
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ECHEVERRIA: I've asked you to three times, and you won't do it. MR.
COUGHLIN: You want to narrow it down just if you were childhood friends, and I
want to go with the totality of the circumstances. MR. ECHEVERRIA: Articulate
your case, sir. I've asked you to. THE WITNESS: SCR 105's been thrown out the
window. You've ruled on motions before I've even had a chance to oppose them or
file a reply to an opposition. You claim that NRCP is applicable here. Yet under
NRCP when I file a motion to bifurcate, and he filed an opposition, and I get three
days for mailing under 6-C, and he purports to file it on the 24th, and you rule on it
when? On the 30th? Don't I get five days, plus three for mailing to file my
opposition to preserve for appeal? MR. ECHEVERRIA: So should we disregard
the motions you filed without giving the State Bar the opportunity to respond
timely? I had two motions shoved under my door last night. Should those be
disregarded under your legal reasoning? Because you did not offer the State Bar
the opportunity to respond. MR. COUGHLIN: Well, that -- MR. ECHEVERRIA:
Yes or no, Mr. Coughlin? MR. COUGHLIN: It's not a yes or no. MR.
ECHEVERRIA: Yes, it is. MR. COUGHLIN: That would entail figuring out
whether or not 30 days prior to the hearing -- MR. ECHEVERRIA: Let's focus on
the issues back. You've made a motion now to require me to recuse myself. MR.
COUGHLIN: Yeah. MR. ECHEVERRIA: You made it on the basis that, one, Mr.
Elcano and I knew each other as childhood friends. And two, that we attended the
same school together, apparently. And you say it's suspicious that I did not know
that. Anything else? MR. COUGHLIN: Every -- MR. ECHEVERRIA: Anything
else? MR. COUGHLIN: Every aspect of SCR 1052(c) has been violated by your
orders. And the way this thing has been run, you have thrown out every last
procedural due process substantive protection accorded me for my property right
under the 14th Amendment. You have insulted me by the way you have run this
panel. MR. KING: Mr. Chairman -- MR. COUGHLIN: And I find out you're
childhood friends with a guy I'm suing. MR. ECHEVERRIA: I'm childhood
friends with justice -- MR. COUGHLIN: And you went to Stanford together in '66,
and you didn't know that. And let me guess. Are you on the Basque board too for
UNR? And Paul tells us he's Basque every five minutes you talk to him. MR.
KING: Mr. Chairman. My experience with Mr. Coughlin is if this is allowed to
continue, he will be thrilled, and it will go on for eight hours. My witness has a
limited time. MR. COUGHLIN: And your office is a stone's throw from the State
Bar. MR. KING: I need to move forward, because the witness has limited time,
with your permission. MR. COUGHLIN: I like you personally. I think you're a
charming guy. I do, your Honor. Just like Mr. Elcano. But the clock chimed 13
times. And if I don't put into the record what is it going to say on appeal? They are
trying to merge me here. Let's be honest. So if it's a merging that's going on here,
I'm going to preserve everything for the record. MR. ECHEVERRIA: I'm going to
overrule your motion for recusal. The supreme court has already ruled that the fact
that a judge knows a witness or a lawyer is not, in and of itself, grounds for recusal.
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That's been decided and litigated in this state. So the motion for recusal is
overruled. Mr. King, proceed to lay the foundation for Exhibit 3."
SBN Asst Bar Counsel Patrick O. King, Esq. and his SBN "Clerk of Court"
Laura Peters run a heck of a pick and roll. Similar to the old bait and switch they
ran vis a vis Peters representing to Coughlin that he could file and serve the Clerk
of Court and SBN via faxing documents to the SBN (and Peters specifically
indicated that she would file stamp in such documents submitted for filing by
Coughlin via fax (9/11/12), only to have Peters subsequently, if not lie (she was
allowed to avoid answering any tough questions in that regard by virtue of the
11/7/12 Panel Chair Echeverria Order granting King's Ex Parte Emergency Motion
to Quash Coughlin's subpoenas on both King and Peters)
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HEARING - Vol. I, (Pages 154:3 to 156:1) BY MR. COUGHLIN: Q Did you or

anybody with your court, the Reno Municipal Court, transmit or otherwise deliver
Judge Linda Gardner's April 2009 order sanctioning me to the State Bar of Nevada?
A (Judge Holmes): I'm sorry. Deliver to whom? MR. ECHEVERRIA: The State
Bar, Judge. THE WITNESS: Oh. After -- let me explain quickly. My trial was my
first experience in exposure to Mr. Coughlin. After everything happened, and I
held him in contempt, then Judge Gardner told me that his sister, Judge
Gardner, has a life experience with Mr. Coughlin, and he provided me a copy
of her opinion from a couple years earlier. And that may have been in the
package I forwarded to the court. I forwarded everything I could possibly
include that would show Mr. Coughlin's ability to practice law. Including Mr.
Coughlin's 200-page motion that he faxed to the court. MR. ECHEVERRIA:
Thank you, Judge. It's now 12:22, and we'll excuse you. And we appreciate you
taking the time -- MR. COUGHLIN: Can I ask one more question about the
pending -- MR. ECHEVERRIA: Mr. Coughlin -- MR. COUGHLIN:
-- competency evaluation or -- MR. ECHEVERRIA: Mr. Coughlin. MR.
COUGHLIN: -- with the trial? It's a good question. MR. ECHEVERRIA: It's an
interruptive question, and it's improper conduct. MR. COUGHLIN: You're not
going to let her answer that, huh? You are not going to make her answer that?
MR. ECHEVERRIA: I'm sorry. I continue to talk while you're trying to interrupt.
Judge, thank you for your testimony. MR. COUGHLIN: She held a trial with a
pending competency evaluation in violation of law. MR. ECHEVERRIA: Quit
interrupting, Mr. Coughlin."
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(It was Judge Nash Holmes whose 5 day summary incarceration of Coughlin
between 2/27/12-3/2/12 prevented Coughlin from filing a Reply to the 2/24/12
Answering Brief hearing (to which Hill, in testifying at Coughlin's formal
disciplinary proceeding on 11/14/12 claimed Coughlin's "failure to oppose" matters
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alleged in his associates Answering Brief (which, as manifest from the record, are
completely untrue, like in 60302 vis a vis the service of process issue) (such as the
patently incorrect allegations therein that Coughlin "never raised" the issue of his
commercial tenancy prohibiting the use of summary eviction procedures where
such action was plead as a NRS 40.254 "no-cause summary eviction" (much less
the incredible attempts Judge Holmes and the SBN/NNDB Panel to find Coughlin
violated RPC 1.1 "the duty of competence within "Part 1 Lawyer-Client
Relationship" of the NRPC), and RPC 1.2 or 1.3 (speaking of competence, its hard
to tell which rule the SBN/Judge Holmes alleged Coughlin violated given the
mixing of the numeric identifier of RPC 1.3 with the title of RPC 1.2 (expediting
litigation versus Diligence) found in the SBN's 8/23/13 Complaint (see 62337)
(much less, in transmogrifying a "simple traffic citation" trial into some absurd
summary disciplinary hearing (see the 3/12/12 Order in RMC 11 TR 26800 and
62337... "Judges Gone Wild").
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As to judges refusing stays to practicing attorneys representing clients where the

seek to summarily incarcerate such attorney's (in a remarkably similar display of
the kind of negligence born only of a steady diet of absolute immunity (what's
next? Surgical immunity?), the overwhelmingly majority viewpoint in the law is
that such is highly disfavored. In her 3/14/12 grievance against Coughlin to the
SBN, Judge Holmes is completely blase as to whether or not Coughlin's indications
to her on the record on 2/27/12 that he was representing clients and had hearings
upcoming the would be prejudiced and disordered as a result of the denial of any
stay at all were true or not (and if you have ever been to the Washoe County Jail,
you known how completely unrealistic it is to think one will be able to conduct
business from there, 10 days for your stamps, paper, and calling cards to arrive in
the mail, one may not access their own credits card, in their possession at the time
of arrest and booking, to add money to their commissary "books". One may not
receive even a single sheet of paper from a Deputy. Coughlin was routinely place
directly into "Administrative Segregation" sufficient to sharply curtail his "tier
time", preventing his making any phone calls to arrange for the avoidance of
prejudice or disorder to the clients he was representing and in the case such
representation arose). Laughably, Judge Holmes feigns being "fearful" that if
Coughlin's representations to her that he was actively representing clients were true
(she glossed over Coughlin's indications that the denial of a stay of such summary
contempt incarceration would damage their interests and disorder the matters in
which such representation arose in) that Coughlin could "be doing real damage to
their liberty or property interests".
Probably not as much damage as denying a stay of a summary contempt
incarceration of an outrageous five days (we are not talking Houston being
handcuffed for an hour in the 8JDC Family Court) to an attorney actively
representing clients would cause, no? But then, as with the denial of any such stay
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under the exact same circumstances (summary contempt incarcerations or

unnoticed revocation of Couglin's bail (the one on 4/19/12 is not all that clear, as
asking a HIPAA question about seeking to know to just what extent the
"competency" evaluators at Lake's Crossing have a blank check into the entirety of
one's medical/mental health care records where simply performing a NRS 178.425
evaluations that really fails to necessitate the inordinately invasive/retaliatory
approach taken by Bill Davis, Ph.D. and Sally Farmer, Ph.D.) by RMC Judge
Howard between 11/30/11-12/3/11 and Judge Elliott between 4/19/12-4/26/12, and
RJC Judge Clifton between 2/12/13-2/16/13 (5 days in jail for allegedly being late
to court where Coughlin was, again, summarily incarcerated between 2/1/132/5/13 incident to a warrantless arrest after 7 pm in violation of NRS 171.136
premised upon a NRS 211A.125 allegation of having violated his probation by
failing to check in with DAS on 1/23/13 where DAS wrote Coughlin on 1/24/13
admitting that Coughlin had checked in, but that the RJC Bailiff's in their
overstepping application of an already completely specious 12/20/12
Administrative Order 2012-01 by, wait for it....Judge Sferrazza (whom, in that
order, remixed the State of Nevada's Constitution where that Order indicated Art.6
Sec. 6 imbued "Nevada courts" with the jurisdiction therein that is only accorded to
"District courts", which is a signficant distinction when considering that Order was
entered (not in a "case" per se, with an opposing party in the caption, or upon a
complaint and subsequent motion made by a "party") by a justice court judge...with
such jurisdictional largesse being apparent again in a 11/28/12 summary "Order" in
"ALL CASES ALL DEPARTMENTS" that purported to base its summary
revocation of Coughlin's right to submit filings by fascimile (a privilege,
apparently, the RJC accords unequally among litigants and ), had prevented
Coughlin from accessing the DAS Office).
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HEARING - Vol. I, (Pages 99:21 to 100:21) MR. ECHEVERRIA: Is this certified?

MR. KING: Let me get the clerk to bring the certification copies, unless she gave
them to you already, which I understood she did. Did she bring you copies? MR.
ECHEVERRIA: This particular one is not certified. Do you have one that's
certified? MR. KING: I have already introduced -- the copies do not show that it's
certified. MR. COUGHLIN: Your Honor, if I can quickly interject for the record, I
mean that not disrespectful. MR. ECHEVERRIA: Are we on the record? Are you
getting this, Ms. Reporter? THE COURT REPORTER: Yes. MR. ECHEVERRIA:
Go ahead. MR. KING: Mr. Chairman, I'll lay -- I understood, and since this has
been filed with the courts that we have certified copies. Since the copy I gave you is
not certified, I'm going to lay a foundation a different way and withdraw the
representation that the copy I gave is a certified copy. MR. COUGHLIN: Yeah.
And that's just another basis for all -- the 13th time on the clock. I'm going to say
formally yes, I think a recusal is appropriate. And I think, Pat, you need to consider
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whether that's fraud, to be saying it's certified, backtracking once you get caught on
it. But I'm just going to put that out for the record..."
While the 12/24/12 ROA places the 10/9/12 Affidavit of Laura Peters at
pages 38-39, the 2/13/13 version of the ROA places the same at pages 33-34, which
is especially odd considering that the file stamp on that Affidavit of Laura Peters on
at ROA 38 is earlier in time than the file stamp on the Notice of Formal Hearing
and DoWSoE on page 33. This is even more odd given that the original placement
in the ROA of 12/14 put such 10/9/12 Affidavit of Laura Peters in a position after a
later dated document (the Notice of Formal Hearing, that is, of 10/12/12 was place
after the 10/9/12 Affidavit of Laura Peters, which, was actually placed in the OBC's
11/7/12 production of documents in lieu of SCR 105(2)(c)'s jurisdictional
requirements being met. In that 11/7/12 production (which Coughlin sought to
introduce as evidence at the formal hearing, but was not even allowed to have
marked), that 10/9/12 Affidavit of Laura Peters was placed after the 10/24/12
Opposition to Respondent's Motion to Bifurcate Hearing/Motion to Dismiss, and
after the 10/30/12 Order Appointing Formal Hearing Panel and 10/31/12 Order,
indicating that, regardless of when it was filed stamped or notarized, it was not
placed in the formal pleadings file until, at the earliest, 10/31/12. This is
extremely prejudicial (especially where the SBN/Panel are now asserting a default
basis/admission of misconduct theory) when view in combination with the SBN's
refusal to allow Coughlin to take advantage of the right to inspect, up to 3 days
prior to the hearing (which, arguably meant up to and through November 9th,
2012), all that to which he was entitled to inspect under SCR 105(2)(c) (the waiver
of service of and Subpoenas on Elcano and Beesley would have been helpful to see,
Beesley's supposed letter to the OBC and dating thereof, etc., and all the suspect
redactions or privileged and withheld ommissions from what was actually
produced to Coughlin on 11/7/12 (which only included materials up to 10/31/12, as
such was sent to the printers the morning of 11/1/12, as admitted to verbally by
Peters and in writing by King). The second ROA persists with inserting at bates 32
some quasi-Affidavit of Attempted service that is neither signed (and was not,
given the lack of any Index to Exhibits or cover page for any exhibit) attached to
that 10/9/12 Notice of Intent to Take Default found immediately preceding it in the
ROA (Coughlin, of course, only first received any version of that 10/9/12 NOITTD
upon finding it bates stamped among some 3,200 other pages of documents in the
production of 11/7/12). As such, page 32 of the ROA should be stricken.
There is not even a name assigned to the various statements (unsworn, of
course) made therein for the various dates detailed. Especially with regard to the
lack of notice to Coughlin that such would be put forward as evidence (that found
on page 32 of the ROA makes another appearance within FHE 1 at page 1736...and
now it becomes clear why the Index on page 1699 to FHE 1 has been photocopied
in a manner to completely obscure what it details...that was done to obfuscate the
reality that the SBN held out to the Panel page 1736 as being included in that which
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was originally mailed to Coughlin (with insufficient postage placed thereon

resulting in the USPS refusing to release it to Coughlin, which Coughlin promptly
notified the SBN of and placed the SBN on a Litigation Hold Notice with respect to
the contents and envelope of that mailing, which was returned to sender with a
handwritten notation detailing the insufficiency of postage placed thereon, made by
USPS Downtown Postal Station longtime employee Tim (tall, fifties, glasses).
Coughlin is filing herewith a version of what the SBN did file with this Court on
12/24/12 (though, in an apparent attempt to coerce payment up front for the
Transcript and certified copy of the Formal Hearing Exhibits (including Exhibit 16,
that Coughlin was not provided the day of the hearing, and where none of the
Exhbits were marked as provided to Coughlin), and has affixed bates stamping
thereto, such that the 574 page Volume 3 of 12/14/12 is bates stamped to continue
where page 1098 of Volume 2 left off. As such, the Index to the FH1 Index of
Documents that is too blurry to read on the second ROA's page 1699 is much more
readable at what would have been bates stamp page 2001 in the first ROA filed.
And therein is revealed an attempt by the SBN to hold out that quasi-Affidavit of
Service found at page 32 of the second ROA, included again, as an Exhibit to the
10/9/12 Notice of Intent to Take Default. However, as detailed above, it is not at all
clear that such Reno/Carson Messenger Service receipt was actually included
therewith, (though, a review of pages 2001 from the first ROA and page 1736 of
the second ROA would give one that impression, despite the unlikelihood of that,
given the RCMS receipt is dated 10/6/12, adn does nto appear to have been faxed to
the SBN, and would, therefore, unlikely have made its way to the SBN in time to be
affixed to the 10/9/12 purported mailing of the 10/9/12 NOITTD.
And, it is important to recall, as admitted to on page 1098 of the first ROA
of 12/24/12, that SBN Clerk of Court Laura Peters only mailed the first 2 of 3
volumes of that ROA to Coughlin (and that ROA and the second ROA failed to
comply with the requirement in NRAP that the Clerk of Court certify the contents
of such ROA, and, regardless, the SBN's negligent, at best, preparation of the ROA
here is risable. And, really, in the 2/13/13 ROA, what would purportedly be Exhibit
1, starting at page 1699, is not marked in any way to indicate that it is Exhibit 1,
and as such, should be stricken in its entirely. It appears from reviewing the first
ROA filed (since stricken by the 2/7/13 Order) that the SBN excised an essentially
blank (though ink wasting dark red or black page) that had affixed to it an Exhibit
1 sticker from the ROA filed on 2/13/13. You can be entirely certain that the Panel
and SBN applied every single ticky tack little reason for striking something or
ruling as inadmissible something Coughlin sought to introduce into evidence, and
such an approach should be applied to the SBN's Exhibit 1 beginning on page 1699
in the 2/13/13 ROA, through 1750 (or if not stricken, at perhaps ruled as
inadmissible, particularly given the apparent Sierra Glass violation incident to
pages 1727 and 1736 as detailed above). The SBN failed to include a 60 page Index
in the Volume 3 that it never provided me incident to the 12/24/12 filing. Further,
many cd/dvd attachments to my filings in that matter, I am told, by Clerk Castillo,
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are not in the ROA. I believe the ROA is deficient in this matter, perhaps
fraudulently so. All of the SBN's histrionics and melodrama related to the Extended
Order of Protection obtained from an RJC that is entirely to conflicted here to be
making rulings limiting the means by which I am able to communicate with an
opposing party and or file documents or seek extensions or stipulations where time
is of the essence...and not just with an opposing party, but with a "Clerk of Court"
as the SBN's Laura Peters hold herself out to be, as does the SBN and OBC hold
her out. In an effort to avoid an ex parte communications accusations (though Bar
Counsel King readily admits to having those all the time with the Panel...and to
controlling the Clerk of Court Peters (coercing her into the 10/9/12 Affidavit of
Laura Peters, which, according to the bates stamps of the "file" provided by the
SBN on 11/8/12 was only placed into the "file" on 10/31/12, as the filings in the
interim between those dates have a bates stamping indicating that 10/9/12 Affidavit
of Laura Peters (which lacks a caption and is not attached to any filing by the SBN
or Panel). If the SBN and or Clerk of Court Peters is going to be eliminating a 60
page index from the Official Transcript, or dropping in page 216 on Volume 1
(which is hugely inappropriate considering the fact that page 216 of Volume 1 is a
USPS Track & Confirm printout the SBN printed just after Coughlin alerted it to
the fact that the downtwon Reno postal station at first failed to find, then refused to
provide Coughlin with the SBN's 10/9/12 mailing to Couglhin given the
insufficiency of the postage attached thereto, and the circumstances related to the
SBN placing insufficient postage on that 10/9/12 Notice of Intent to Take Default
and receiving it back from the USPS with a "insufficient postage"/return to send
handwritten note that Coughlin personally saw USPS downtown station counter
clerk "Tim" affix to that large manilla package (which brings up the fact that the
Reno Carson Messenger Service unsworn quasi-Affidavit of Attempted service was
not a part of that 10/9/12 NOITD, either, meaning that page 32 of Volume 1 (the
Reno Carson Messenger Service Receipt) of the 12/24/12 ROA is another instance
of the SBN/OBC/Clerk of Court Peters/NNDB/Panel (my point is...there is no point
of distinction between any of those entities...they all bleed together completely,
with the main characteristic they share being that Bar Counsel Pat King is permitted
to fraudulent and coerce them around into doing his bidding as an attack dog for the
rich and powerful....Peters signs the Certificates of Service for all involved....Chair
Echeverria's Office is in the SBN's back parking lot...Peter's grants Coughlin
permission to file by fax on 9/11/12 at 4:48 pm (and a review of all emails and fax
confirmations involved, and, uh...some other things makes clear that Peters 10/9/12
Affidavit of Laura Peters is an extremely troubled document, as is Bar Counsel's
holding out the 8/23/12 Complaint and Affidavit of Service therein by Peters as
something other than a fraudulent assertion of service violative of RPC 3.3, 3.4, and
many of the provisions in the Model Code of Conduct for Judicial Employees in the
State of Nevada: http://www.courtethics.org/Nevada%20Model%20Code%20of
%20Conduct.pdf In that Model Code the appearance of impropriety is referenced at
length.
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On that note, I reference the "Dispositional Order' entered by Clerk

Lindeman that Richard G. Hill, Esq. conveniently referenced in his testimony at the
formal disciplinary 11/07/2012 Order/Dispositional - Order Dismissing Appeal
Filed Order Dismissing Appeal. To date, appellant has not paid the filing feeor
otherwise responded to this court's notice. Accordingly, cause appearing, this
appeal is dimissed. 12-35194 Further, why is Coughlin's Motion for Order to Show
Cause on page 44 of Vol 1 not file stamped, even where the Panel Chair ruled on it
in his 10/31/12 Order? Is it permissible to issue a Briefing Schedule on 12/24/12
where Motion for New trial, NRCP 52, NRCP 59 tolling motions are pending?
Also, while the 2/13/13 version of the ROA indicates that from pages 797-1347 is
Coughlin's Motion for Mistrial (Notice that 10/9/12 Affidavit of Laura Peters is
Whopper Chocked, etc. (again, for some totally unexplained reason the SBN
merely indicates such filing was Not Filed in the entry for such in the
Alphabetical Index, despite such filing being properly submitted for filing on
12/3/12). So, so, the 2/13/13 ROA's version of that filing totals 550 pages, while
the 12/24/12 version extends from 613-1068, therefore totalling only 455
pages...the SBN fails to explain at all where from or why there is now an
additionaly 95 pages associated with such filing. Beyond all of that, the multitude
of Coughlin's filing have been rendered illegible due to the SBN's fraudulent
fiddling with the scanner and copier settings. NRAP 11 requires the output of such
to be equal to that of a laser printer, which requires at least 300 dpi, and clearly, the
SBN has gone beyond just scanning Coughlin's filings in at the lowest setting
possible (75dpi), but rather has taken to adjusting the resolution, sharpness,
contrast, shrinking and also settings available to those whom wish to obscure the
record to achieve an impermissible advantage. Beyond this, King has sought to
obviate the due process problems (lack of notice, insufficiency of service of
process, and of the process itself...see 60302) associated with his attaching to his
8/23/12 Complaint Orders wherein portions thereof are entirely illegible.
Also missing from both versions of the ROA filed by the OBC is Couglhin's
11/9/12 AFFIDAVIT OF ZACH COUGHLIN AND SUPPLMENTAL TO
DESIGNATION OFWITNESS AND SUMMARY OF EVIDENCE; MOTION
FOR RECUSAL OF PANEL CHAIR ECHEVERRIA; and EMERGENCY EX
PARTE MOTION TO DISMISS THE 11/14/12 HEARING OR OTHERWISE
RECOGNIZE THE LACK OF JURISDICTION TO HOLD IT GIVEN THE
NUMEROUS VIOLATIONS OF SCR 105 BY THE PANEL AND THE SBN (6
pages with Exhibit 1 attached as disc). Defendant Zachary Coughlin (hereinafter
"Defendant") is charged with Violation of a Temporary or Extended Order for
Protection Against Harassment in the Workplace, a violation of NRS 33.350 as
incorporated by Reno Municipal Code Section 1.04.015. See Amended Criminal
Complaint filed March 7, 2013. It is alleged, interalia, that: The Reno Justice Court
issued a Temporary Order for the Protection Against Harassment in the Workplace
on December 20, 2012, with an expiration date of January 4, 2013 (RJC RCP2012000607). The TPO Order prohibited the Defendant or an agent of the Defendant
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from Contacting (versus prohibiting Coughlin from "harassing") the State Bar of
Nevada's Northern Office only (going so far as to prevent Coughlin from even
mailing in the US mail harassing materials to the SBN, and, perhaps, any
materials), and failed to list the SBN's Northern Officer's fax number therein (and
the TPO Application upon which such Order issued failed to list the fax number for
the Northern Office as well). The Defendant was not served this Order on
December 26, 2012, contrary to the RCA's assertions in its Motion. For an RCA
seeking to take Coughlin to task over phenomenally suspect, and de minimis, at
best, alleged violations of this TPO/EPO, it sure is willing to overlook a number of
deficiencies in the performance of the RJC, the RJC Bailiffs, the SBN and its Clerk
of Corut, RPD Detective Ytrubidde, the arresting RPD officers, etc., etc. as they
relate to their respective roles in this matter and the void and voidable nature of the
two protection orders in question. Sort of a do what we say not as we do type
approach. A "we're above the law, ourselves, see" kind of attitude. Further, the
RCA failed to turn over the Brady material attendant to the missing Proof of
Service page for such 12/20/12 TPO in RCP12-607, in the RCA's initial purported
(yet still not technically served) discovery to Coughlin, wherein the 12/26/12 Proof
of Service by the RJC's Bailiff Anthony English was missing therefrom, in a tacit
admission by the RCA that it knows such purported service was woefully
insufficient (the order itself directed specific members of law enforcement (not
among them were the RJC Bailiff, whom by the way, as parties, also purported to
effect service of a TPO against Coughlin by "Washoe County", and really, the
Public Defenders Office is an independent contractor, as such, Washoe County has
no standing to move on its behalf or on behalf of any of the WCPD's employees for
a Workplace TPO), and therefore the RCA is violating RPC 3.8 and Brady in
maintaining both of these prosecutions in addition to being a willing accomplice to
the criminal misconduct being committed by the State Bar of Nevada's OBC Asst.
Bar Counsel King and "Clerk of Court"/Investigator/Paralegal, Laura Peters, whom
admit to throwing away or otherwise failing to fulfill her duties as "Clerk fo Court"
for the State Bar of Nevada in formal disciplinary proceedings (as both Peters and
King have held Peters out to be "Clerk of Court of the State Bar of Nevada).
Further, the TPO application was violative of the requirement that one's
employer file it on behalf of a specific employee (as Laura Peters filled it out
originally in her own handwriting then used white out over her signature...replacing
it with Pat King's, and regardless, the TPO/EPO sought to protect them both, and
authority to so file such an application necessarily needed to be issued by a member
of the SBN's Board of Directors (or possibly, even, Watters and SCR 99, the
Nevada Supreme Court, as the SBN is merely an "arm of the Court", not merely
upon Pat King, or even David Clark's permission), whom would then need to file
such application on behalf of such employees as King or Peters or whatever
unnamed employee the RCP12-607 application purports to, in all its unattributed
hearsay and vagueness, seek protection for (NNDB Panel Chair Echeverria's staff,
non-sensically, seems to be the party for whom the SBN is seeking protection, for
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which, clearly, its lacks standing to apply for one on behalf of Echeverria, his staff,
or anyone with the NNDB), beyond that the SBN's TPO application fails to comply
with the statutory requirement that it specifically name which employees it seeks to
protect and why, or provide an factual specifics as to why such an application is
justified). Further, the SBN's TPO Application failed to contain a verification and
or a sworn Declaration as to any facts whatsoever, much less of the level necessary
to satisfy NRS 33.250. Simply put, nothing in any of the Exhibits or the Exhibit 1
"Summary" attached to the SBN's TPO is incorporated by reference into the 8 page
TPO Application's verfication (neither the required incorporating language is
included, nor are the materials contained in the Exhibit 1 placed on the statutorily,
court mandated "Continuation" Page, not to mention that the Application and
Exhibit 1 contain absolutely no attribution as to whom purportedly wrote the
"Summary" in Exhibit 1 to the TPO Application (and curiously, especially where
the employee for whom the employer is purportedly seeking the protection
(apparently Laura Peters?) is precluded from applying for such protection on their
own behalf, the "Summary" in Exhibit 1 of the TPO Application refers to Pat King
in the third person, which is strange considering its is Kign signing the verification
on page 8 of the TPO Application and there is otherwise no attribution for the
writer of the "Summary" included in Exhibit 1 of the TPO applciation (which
consists almost of unattributed hearsay alluding to unnamed non SBN employees in
vague, unsupported terms). Further, by virtue of the admissions made by both the
SBN and its Clerk of Court Peters and RCA Chief Criminal Deputy City Attorney
Wong, a level of complicity and prosecutorial misconduct is evinced in Clerk of
Court Peters failure to include the two purported filings in question in the record on
appeal transmitted from NG12-0204,0434,0435 to the NSCT in 62337 (ie, those
purported filings of 1/3/13 and 1/17/13):
"III. Title, Tenure, Removal, or Suspension C. Removal or Suspension from
Office 1. Removal from Office 21. Grounds for removalParticular
applications , Clerks of Courts k8 Examples of sufficient grounds for removing a
clerk of court from office include: misappropriation of funds to the clerk's
personal use[FN1] a conviction of theft in office giving rise to a statutory
disqualification[FN2] the failure to maintain proper records and accounts[FN3]
making disparaging statements about a judge[FN4] an offense involving moral
turpitude[FN5] willful misconduct in office[FN6] failure to follow to the letter
and in the utmost good faith the direction of the judge[FN7] misfeasance in office
or neglect of official duty tantamount to fraud[FN8] [FN1] Lewis v. State ex rel.
Evans, 387 So. 2d 795 (Ala. 1980). [FN2] State ex rel. Corrigan v. Haberek, 35
Ohio St. 3d 150, 518 N.E.2d 1206 (1988). [FN3] In re Overstreet, 851 S.W.2d 458
(Ky. 1993). [FN4] Voigt v. Savell, 70 F.3d 1552 (9th Cir. 1995). [FN5] Lewis v.
State ex rel. Evans, 387 So. 2d 795 (Ala. 1980). [FN6] In re Antonelli, 429 Mass.
644, 711 N.E.2d 104 (1999). [FN7] State ex rel. Core v. Merrifield, 202 W. Va.
100, 502 S.E.2d 197 (1998). [FN8] Commonwealth ex rel. Attorney General v.
Furste, 288 Ky. 358, 156 S.W.2d 198 (1941).
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AMJUR CLERKSOFCT 21" 44. Breach of duty affecting rights of

litigants West's Key Number Digest West's Key Number Digest, Clerks of Courts
k64.1 A court clerk's breach of a duty to perform the ministerial functions of the
clerk's office will not prejudice the rights of those dealing with the court concerning
an action or matter then pending. This principle frequently applies where a party
seeks enforcement of,[FN1] or relief from a judgment affected by some mistake or
default of the clerk,[FN2] or where the clerk's failure affects compliance with filing
or recording deadlines critical to the party's matter.[FN3] In the absence of a duty,
[FN4] or when the negligence of another intervenes,[FN5] relief is denied, even
with reliance on the clerk's promises or statements,[FN6] particularly those
gratuitous in nature with no relation to the clerk's duties.[FN7] A clerk of court may
be liable personally and on an official bond,[FN8] subject to the constraints of
potential immunity.[FN9] [FN1] Gilliam v. Gilliam, 43 So. 3d 615 (Ala. Civ. App.
2010). [FN2] McGee v. Hicks, 303 Ga. App. 130, 693 S.E.2d 130 (2010), cert.
granted, (Sept. 20, 2010) and aff'd but criticized on other grounds, 11 Fulton
County D. Rep. 2069, 2011 WL 2610368 (Ga. 2011). [FN3] Williams v. T.D.C.J.I.D., 142 S.W.3d 308 (Tex. 2004). [FN4] Trala v. Melmar Industries, Inc., 254
A.2d 249 (Del. Super. Ct. 1969). [FN5] Maginn v. City of Glendale, 72 Cal. App.
4th 1102, 85 Cal. Rptr. 2d 639 (2d Dist. 1999). [FN6] Libert v. Turzynski, 129 Ill.
App. 2d 146, 262 N.E.2d 741 (1st Dist. 1970). [FN7] Trala v. Melmar Industries,
Inc., 254 A.2d 249 (Del. Super. Ct. 1969). [FN8] 55, 61. [FN9] 58 to 60.
AMJUR CLERKSOFCT 44 2. Custody and Care of Records Topic Summary
Correlation Table References 50. Generally West's Key Number Digest West's
Key Number Digest, Clerks of Courts k69 Trial Strategy Locating Public Records,
2 Am. Jur. Trials 409 12 to 15 (records of county clerk) The clerk of court is the
custodian of court records,[FN1] with the duty or function to make and keep an
accurate record[FN2] and docket[FN3] of the proceedings in the court,[FN4] the
court's orders and judgments,[FN5] all documents submitted to the clerk,[FN6]
records used in appeals,[FN7] and all documents used by the court in its decisionmaking capacity.[FN8] A clerk of court does not have independent ownership of
court records,[FN9] and has a ministerial duty to permit the inspection and copying
of the court's records in civil cases.[FN10] [FN1] Lapeer County Clerk v. Lapeer
Circuit Court, 469 Mich. 146, 665 N.W.2d 452 (2003); State v. McCraine, 214 W.
Va. 188, 588 S.E.2d 177 (2003). [FN2] In re Strickhausen, 994 S.W.2d 936 (Tex.
App. Houston 1st Dist. 1999). Clerk is responsible for maintaining traffic files for
the judge or magistrate. Speight v. Presley, 2008 OK 99, 203 P.3d 173 (Okla.
2008). Clerk must maintain an accurate record of the date of filing. Laidlaw Energy
and Environmental, Inc. v. Town of Ellicottville, 60 A.D.3d 1284, 875 N.Y.S.2d
668 (4th Dep't 2009). [FN3] Stewart v. Kentucky Lottery Corp., 986 S.W.2d 918
(Ky. Ct. App. 1998) (electronic computerized "case history" or docket sheet).
[FN4] Copley Press, Inc. v. Superior Court, 6 Cal. App. 4th 106, 7 Cal. Rptr. 2d
841 (4th Dist. 1992). [FN5] State ex rel. Core v. Merrifield, 202 W. Va. 100, 502
S.E.2d 197 (1998). [FN6] Sullivan v. Eighth Judicial Dist. Court In and For County
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of Clark, 111 Nev. 1367, 904 P.2d 1039 (1995). [FN7] In re Strickhausen, 994
S.W.2d 936 (Tex. App. Houston 1st Dist. 1999). [FN8] In re Search Warrant
#5077/91, 96 Ohio App. 3d 737, 645 N.E.2d 1304 (10th Dist. Franklin County
1994). [FN9] Lapeer County Clerk v. Lapeer Circuit Court, 469 Mich. 146, 665
N.W.2d 452 (2003). [FN10] Lapeer County Clerk v. Lapeer Circuit Court, 469
Mich. 146, 665 N.W.2d 452 (2003). Clerk acted in judicial capacity when making
court records available to the public. Rieger v. Montgomery Cty. Clerk of Courts,
2009-Ohio-426, 2009 WL 242668 (Ohio Ct. App. 2d Dist. Montgomery County
2009).
AMJUR CLERKSOFCT 50 49. Documents deficient in form, substance,
or timeliness West's Key Number Digest West's Key Number Digest, Clerks of
Courts k69 When a court clerk receives documents which are not in proper form,
the clerk must file and stamp those documents with the date on which they were
received.[FN1] A clerk of a court may not reject a pleading for form,[FN2] general
informality,[FN3] originality,[FN4] lack of statutory authorization for the filing,
[FN5] or on substantive grounds,[FN6] unless the clerk acts under specific rule or
statutory authority to reject pleadings that lack certain documents.[FN7] The lack
of a civil case cover sheet is not a sufficient omission to reject a filing.[FN8] A
filing, untimely on its face, is nonetheless a filing that requires action by the court
clerk, leaving to the court the ultimate question of timeliness or other merit.[FN9]
[FN1] Glauner v. State, 107 Nev. 482, 813 P.2d 1001 (1991). The clerk of court
properly assigned new case number to a claim where the complaint did not identify
itself as a renewal of a prior counterclaim. Meyer v. Minster Farmers Coop.
Exchange Co., Inc., 2009-Ohio-4933, 2009 WL 2986971 (Ohio Ct. App. 3d Dist.
Shelby County 2009). [FN2] Hooker v. Sivley, 187 F.3d 680 (5th Cir. 1999); Cave
v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010). [FN3] In re Smith, 270 S.W.3d 783
(Tex. App. Waco 2008). [FN4] Gehring v. Goodman, 25 Misc. 3d 802, 884
N.Y.S.2d 646 (Sup 2009) (copies of affidavits). [FN5] Estate of Johnson v.
Ciarpelli, 71 A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010) (filing within clerk's
authority without guidance by law). [FN6] Hooker v. Sivley, 187 F.3d 680 (5th Cir.
1999); McKeown v. Bailey, 731 A.2d 628 (Pa. Super. Ct. 1999). [FN7] Blundon v.
Taylor, 364 Md. 1, 770 A.2d 658 (2001); Cable v. Hatfield, 202 W. Va. 638, 505
S.E.2d 701 (1998). [FN8] Maginn v. City of Glendale, 72 Cal. App. 4th 1102, 85
Cal. Rptr. 2d 639 (2d Dist. 1999). [FN9] In re Smith, 270 S.W.3d 783 (Tex. App.
Waco 2008). AMJUR CLERKSOFCT 49 V. Powers and Duties C. Particular
Powers and Duties 1. Filing and Recording of Papers Topic Summary Correlation
Table References 47. Generally West's Key Number Digest West's Key Number
Digest, Clerks of Courts k64 to 69 Forms Am. Jur. Legal Forms 2d 58:4, 58:6 to
58:8 (Certificate of Clerk Recordation or Authentication of Document) Am. Jur.
Pleading and Practice Forms, Clerks of Court 7, 11 to 19 (Clerk's Certificate or
AffidavitFiling or Recording of Documents) It is the official duty of the clerk of
a court to record[FN1] or file all the papers in a cause presented by the parties, and
to indorse the correct date of the filing on them.[FN2] The duty is purely
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ministerial[FN3] and the clerk may not refuse to perform except on the order of the
court.[FN4] Caution: A clerk may refuse to accept a filing for nonpayment of filing
fees unless a credit or waiver is allowed,[FN5] or where certain necessary
documents are omitted from the filing,[FN6] and statutes or court rules may
expressly authorize the clerk to refuse to accept papers for filing where a complaint
is submitted by a person who has been found to be a "vexatious litigator."[FN7]
Observation: A policy adopted by a clerk of court, that papers submitted for filing
after regular hours would not be filed until the following day, complied with
statutory guidelines and was within the clerk's discretion.[FN8] [FN1] Nash v.
Campbell County Fiscal Court, 2011 WL 1620587 (Ky. 2011). [FN2] Estate of
Johnson v. Ciarpelli, 71 A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010); In re
Simmonds, 271 S.W.3d 874 (Tex. App. Waco 2008). [FN3] Benson v. District
Clerk, 331 S.W.3d 431 (Tex. Crim. App. 2011) (writ of habeas corpus). [FN4]
Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010); In re Smith, 270 S.W.3d 783
(Tex. App. Waco 2008). [FN5] 37, 38. [FN6] 49. [FN7] In re Smith, 270
S.W.3d 783 (Tex. App. Waco 2008). [FN8] Hartford Citizens for Responsible
Government v. City of Hartford Bd. of Zoning Appeals, 313 Wis. 2d 431, 2008 WI
App 107, 756 N.W.2d 454 (Ct. App. 2008).. AMJUR CLERKSOFCT 47
It is important to note that the SBN's Laura Peters emailed Couglin a version
of the TPO Application that was materially different than the one it utlimately filed
in that on page 6 of 6 of Form B-3 (the 12/20/12 TPO Application), the version
Peters emailed Coughlin did not check the I FURTHER REQUEST that this Court
set a hearing date for an Extended Order as soon as possible. ?? Yes ?? No (NOTE:
neither box was checked on the copy of the application Laura Peters emailed to
Coughlin on 12/19/12, however, the version the SBN filed did check the Yes box
requesting a hearing date for an Extended Order as soon as possible). Further, the
SBN never actually filed the EPO Application that one is directed to (by the form)
and required to (under the statute) Further, King's DECLARATION on page 6
thereof fails to actually identify just whom it is that King is apparently the
AUTHORIZE AGENT of, ie, whether it be he is the SBN's authorized agent or,
perhaps, the authorized agent of some particular employee (even himself) for which
he seeks to file such application. Such lack of specificity fails to satisfy the
jurisdictional prerequisite presented in NRS 33.250(1) where such requires King
specify that he is the authorized agent of the employer. Perhaps the biggest
failure of King's TPO application resides where it completely fails to identify
anything sufficient to meet the requirements of NRS 33.250(2)(c), which requires
that such verified application must included, without limitation: (c) A detailed
description of the events that allegedly constituted harassment in the workplace and
the dates on which these events occurred. A few glaring problems with King's
application appear where he fails to list any other location for the SBN beyond its
Reno office. As such, would that not imply Coughlin is permitted to call, email,
fax, or venture to the Las Vegas main office of the SBN? Further, King lists the
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main phone number of the SBN under the fax number section, and completely
fails to list the Northern Office of the SBN's fax number at all, which could be
taken as an exclusion thereof from those numbers to which Coughlin was,
apparently not to contact the SBN by fax...However, given that Chair
Echeverria's own use of the term contact in his 11/16/12 Order would, to be legal,
necessarily need to at least allow for Coughlin to obtain a transcript of the 11/14/12
formal disciplinary hearing under the procedures set out in SCR 119, which require
Coughlin to SCR Rule 119. Additional rules of procedure. 1. Record. The record
of a hearing shall be made available to the attorney at the attorneys expense on
request made to bar counsel... 3. Other rules of procedure. Except as otherwise
provided in these rules, the Nevada Rules of Civil Procedure and the Nevada Rules
of Appellate Procedure apply in disciplinary cases. Perhaps Clerk of
Court/Paralegal/Investigator Laura Peters is not aware of NRCP 52, or NRCP 59,
or NRCP 60, or DCR 13(7), etc., etc., or NRAP 10, and NRAP 11, or all the other
various reasons why opposing counsel and the filing office of the SBN would
necessarily continue to have business (which would, obviously, involve Coughlin
contacting the SBN, the Clerk of Court of the Northern Office of the SBN, and
the Office of Bar Counsel, in addition to the NNDB and Panel) to conduct even
after the 11/14/12 hearing, and even after the 12/14/12 entry of the Panel's
Findings of Fact; Conclusions of Law which lacks any indication in the title
thereof that it is a decision sufficient to invoke SCR 105(3)'s procedural
mechanisms. (It is ironic, that lack of congruity between the title of the 12/14/12
FOFCOL and the FOFCOL citing to Hill and Judge Holmes criticisms of
Coughlin's work to the effect that the titles of his filings, at times, bore little to no
relation to the content therein). Further, the transcript of the 11/14/12 formal
disciplinary hearing itself establishes that Chair Echeverria granted Coughlin his
request to file post-hearing briefs on various issues.
SCR 105...(3). Review by supreme court. (a) Time and manner of appeal. A
decision of a hearing panel shall be served on the attorney, and service shall be
deemed Notice of Entry of Decision for appeal purposes. Except as provided in
Rule 105(3)(b), a decision is final and effective 30 days from service, unless an
appeal is taken within that time. To the extent not inconsistent with these rules, an
appeal from a decision of a hearing panel shall be treated as would an appeal from a
civil judgment of a district court and is governed by the Nevada Rules of Appellate
Procedure. (b) De novo review of public discipline. ...a decision recommending...
disbarment shall be automatically reviewed by the supreme court. Review under
this paragraph shall be commenced by bar counsel forwarding the record of the
hearing panel proceedings to the court within 30 days of entry of the decision... The
attorney and bar counsel shall have 30 days from the date the supreme court
acknowledges receipt of the record within which to file an opening brief or
otherwise advise the court of any intent to contest the hearing panels findings and
recommendations. If an opening brief is filed, briefing shall thereafter proceed in
accordance with NRAP 31(a). Extensions of time to file briefs are disfavored and
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will only be granted upon a showing of good cause. The parties shall not be
required to prepare an appendix, but rather shall cite to the record of the
disciplinary proceedings... 4. Rules of procedure. The chairs, after consulting with
their respective disciplinary boards, may adopt rules of procedure, subject to
approval by the board of governors. SCR Rule 120. Costs; bar counsel conflict or
disqualification.... 2. If, for any reason, bar counsel is disqualified or has a conflict
of interest, the board of governors shall appoint an attorney, ad hoc, to act in the
place of bar counsel. Further, King clearly needs to be removed from 62337 and
607 in light of not only SCR Rule 120, but also in light of the dictates of RPC 3.7:
Rule 3.7. Lawyer as Witness. (a) A lawyer shall not act as advocate at a trial in
which the lawyer is likely to be a necessary witness unless: (1) The testimony
relates to an uncontested issue;... King's testimony absolutely does relate to a
contested issue, many of them, as further detailed herein, including, but not limited
to, the insufficiency of postage the SBN affixed to the 10/9/12 Notice of Intent to
Take Default in the SCR 105 disciplinary matter wherein the SBN and NNDB so
egregiously overstepped to jurisdiction accorded it by SCR 111(8) and the Court's
6/7/12 Order in 60838. Thereafter, as is King's consistent practice, he fails to attach
an Index to Exhibits or any cover pages to his various exhibits. Further, while the
first page following the last page of the From B-3 12/20/12 TPO Application
bares a heading of Exhibit 1, it is not clear whether Exhibit 1 is a broad
heading encompassing the 39 pages therafter or some lesser portion thereof. There
is nothing to indicated any particular aspect of the exhibits following the
application is a Summary as referenced on page 2 of the application. The first
two pages of the 39 page Exhibit 1 consists of just over one page of an unsworn,
unattributed, recounting of mostly irrelevant (relating largely to non-SBN
employee's of the Washoe County Public Defender or of the Panel Chair assigned
to Coughlin's formal disciplinary hearing by the Northern Nevada Disciplinary
Board, which is not a part of the SBN) details largely consisting of unattributed
hearsay and double unattributed double hearsay, which refers to King in the third
person...leading one to wonder just whom wrote such statement. Further, while
King's application fails to satisfy NRS 33.250(2)(c)'s requirements, its failure to
come any where near to satisfy any reasonable burden of proof divined from a
reading of NRS 33.270(1) in a free and just society makes void both the TPO and
EPO issued herein. (NRS 33.270(1), which requires: The court may issue a
temporary order for protection against harassment in the workplace if it appears to
the satisfaction of the court from specific facts shown by a verified application filed
pursuant to NRS 33.250 that harassment in the workplace has occurred. Such a
showing that harassment in the workplace has occurred requires an application
and analysis of: NRS 33.240 Acts that constitute harassment in workplace.
Harassment in the workplace occurs when: 1. A person knowingly threatens to
cause or commits an act that causes: (a) Bodily injury to the person or another
person; (b) Damage to the property of another person; or (c) Substantial harm to the
physical or mental health or safety of a person; 2. The threat is made or the act is
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committed against an employer, an employee of the employer while the employee

performs the employees duties of employment or a person present at the workplace
of the employer; and 3. The threat would cause a reasonable person to fear that the
threat will be carried out or the act would cause a reasonable person to feel
terrorized, frightened, intimidated or harassed.
Even if a court were to view all of that which is contained in the 39 page
Exhibit 1 to King's 12/20/12 TPO application as verified (which, clearly, it is
not), nothing asserted therein suffices to constitute harassment in the workplace
under NRS 33.240 for a multitude of reasons. One, nothing contained therein
provides any support for the view that Coughlin knowingly did anything that
could be said to threaten to cause or or commit and act that causes any of the ills
detailed in NRS 33.240(a)-(b), and neither the 12/20/12 TPO Order or the 1/4/13
EPO Order specify in any way whatsoever just which, if any, of those subsections
the court found to have been dispositive as to. There has been absolutely no
assertion by anyone that Coughlin actually committed any act which cause any
bodily injury to anyone or damage to anyone's property. Only the most attenuated
hypchondriac, histrionic fit thrower would assert Coughlin committed any act
sufficient to have already caused substantial harm to the physical or mental health
or safety of a person. So, one must assume that the court's justification for issuing
both the TPO and EPO was based upon a finding that Couglin threatened to cause:
bodily injury to the person or another person, or, damage to the property of
another person; or, substantial harm to the physical or mental health or safety of a
person Neither TPOs nor EPOs may be granted on a default basis. Even if an
adverse party fails to oppose any such application or attend any such hearing, the
court is still required to evaluate whether the requirements of NRS 33.240, 33.250,
and 33.270 are met. So, just what, if anything in King's TPO application may
suffice to meet those standards? Again, nothing, as the 8 page application is
completely devoid of any factual assertions, much less any with any degree of
specificity, and nothing in any part of the 39 page Exhibit is verified sufficient to
satisfy NRS 33.250. Even had such Exhibit 1 in its entirety been sufficiently
verified, nothing therein satisfies those standards either. What possibly could?
King's 39 page Exhibit 1, including Exhibit 1A-1D follows: "Exhibit
1 On November 14, 2012, the Office of Bar Counsel held a disciplinary hearing at
its Reno office with two sheriff personnel in attendance as a measure of protection.
As a result of the hearing the panel unanimously agreed to permanently disbar Mr.
Coughlin from the practice of law. On Friday, December 14, 2012 the Panel's Order
was filed and copies were mailed to Mr. Coughlin both by regular and certified
mail. Mr. Coughlin continues to make repeated calls to the State Bar demanding
copies and information. He is getting increasingly antagonistic and will not listen to
our attempts to reason with him. This morning he announced that he "would be
there in 15 minutes" It is our fear that if he shows up we won't be able to get rid of
him - we are not able to satisfy his demands and that just seems to aggravate the
situation. He has shown up after hours presumably to file documents; eventually he
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has used the mail slot for the documents but has sat in his car in front of the office
flashing his lights to get attention. Employees have been afraid to leave and, on a
couple of occasions, the police have been called - we don't know if they have
shown up because once he leaves, we leave. On one particular occasion, a female
employee was in the office alone. Mr. Coughlin knocked on her window and
gestured to the front door so he could gain access to the building. Eventually the
employee was able to get him to leave and the police were called but did not arrive
before Mr. Coughlin left the premises. This past Monday Assistant Bar Counsel Pat
King did dispatch the police because Mr. Coughlin again announced that he was
coming to the office - two officers did show up and one was dispatched to the Panel
Chair's office (9432 Double R Blvd.) because Coughlin has also threatened and
intimidated John Echeverria's office staff. When Coughlin called the Echeverria
law firm that particular day he stated that he needed some "face time" with John.
Mr. King has received numerous e-mails detailing what Mr. Coughlin perceives to
be a miscarriage of justice in his discipline matter and has indicated that he will
"expose him as a liar and a fraud". In a letter dated November 7, 2012, prior to the
discipline hearing, the Office of Bar Counsel sent Mr. Coughlin a letter asking that
he refrain from coming to the State Bar offices without calling beforehand. On
November 17, 2012, after the discipline hearing, the Panel Chair issued an Order
instructing Mr. Coughlin to refrain from contacting any member of the Panel, the
Court Reporter (whom Mr. Coughlin had contacted by phone at her residence), any
of the Panel Chair's office staff, or either office of the State Bar of Nevada. On one
occasion, an e-mail was sent to several recipients, including four (4) employees of
the State Bar, which included a link to a violent scene from the movie "Cape Fear".
The State Bar feels that this is a direct suggestive threat to office staff and
Bar personnel. Therefore, the State Bar requests that a Protective Order be and that
Mr. Coughlin be prohibited from contacting the Bar's Reno and/or Las Vegas
Office by telephone, by e-mail or by fax. Because he is currently temporarily
suspended from the practice of law and his disciplinary hearing has concluded Mr.
Coughlin has no business on State Bar property (9456 Double R Blvd or 600 E.
Charleston Blvd., Las Vegas, NV). The record of his disciplinary matter will soon
be submitted to the Nevada Supreme Court for a de novo review at which time he
will receive a complete set of all of the pleadings, both filed and unfiled, in this
matter. It should be noted that the State Bar and its Reno staff find it very difficult
to work under these conditions. Mr. Coughlin continues to monopolize our time
and resources and is causing an unnecessary amount of stress." (NOTE: the above
Summary fails to indicate Coughlin is causing fear of that required by NRS
33.240, but rather that the State Bar and its renot staf find it very difficult to work
under these conditions (such as Coughlin requesting copies of documents, seeking
the copy of the record/transcript of the 11/14/12 proceeding that he is entitled to
under SCR 119, which requires that he contact Bar Counsel to obtain such, which
Coughlin attempted to do on numerous occasions immediately after the 11/14/12
disciplinary hearing both by telephone and in writing, which the Bar and King
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failed to respond to until 12/19/12, with Chair Echeverria's 11/17/12 Order

seemingly void in that it, depending on one's interpretation of contact or
contacting would have precluded Coughlin from so seeking a copy of the
transcript pursuant to SCR 119 where such 11/17/12 Order reads. Further, it
appears that Laura Peters herself from the Summary which would not only vitiate
any first hand knowledge requirement being met even assuming the illogical leap
to incorporate by reference that contained in Exhibit 1 is made, despite the failure
of King's Declaration on page 8 of his TPO Application to so incorporate or even
reference such materials, and the failure of King to check the box on page 2
(applicants are directed to do so if the wish to incorporate by reference that
contained in the mandatory Form B-4 Continuation Page, which itself
contains language specifically incorporating by reference that which is contained
therein on such Continuation Page into the Application itself sufficient to make
the contents of such Continuation Page verified in compliance with NRS
33.250. This is not a case of a pros se non-attorney filling out the application, or
presumably, even, the Summary included in in Exhibit 1 of King's application.
As such, King must be held to the technical requirements of the statutes, include
NRS 33.250 and NRS 15 Exhibit 1A consists of an 11/7/12 letter from King to
Coughlin, which reads:
Dear Mr. Coughlin: Yesterday you arrived at the State Bar office after 5:00
p.m. to file several documents. When you discovered that the front door was
locked, and although there is a mail slot in the door, you elected to walk around the
outside of the building until you found someone inside. You stood outside an
employee's window, got her attention and asked to he let in. This employee
unlocked the door and took receipt of your documents after which you continued to
ask further assistance. Your behavior is becoming increasingly disturbing and
harassing. Therefore, except for your formal hearing, which will take place on
November 14, 2012, beginning at 8:45 a.m., you are not to arrive at the Reno
Office of the State Bar unannounced. If you have papers or pleadings to present tor
filing, you are hereby instructed to either mail them or to call the office (329-4100)
prior to your arrival. Please be advised that if you appear at the State Bar in the
future, except for the November 14, 2012, hearing or in the case of your need to liIe
a document (fOf which you must call ahead), the police wilt be summoned
immediately. Sincerely, /s/ Patrick O. King, Esq. Asst Bar Counsel.
Exhibit 1B consists of NNDB Panel Chair John Echeverria's 11/16/12 Order
in Case No: NG12-0204, NG12-0434, and NG12-0435, which reads: It has
come to the attention of the Panel Chair that Zachary B. Coughlin ("Respondent")
has been contacting the Reno and Las Vegas Offices of Bar Counsel, the Panel
Chair's law office and the Court Reporter who recorded the disciplinary
proceedings at the State Bar office. Therefore, IT IS HEREBY ORDERED: That
Respondent immediately cease and desist contacting anyone at the State , Bar
offices, the Panel Chair, the panel chair's staff, any of the Panel Members or their
staffs, or the Court Reporter including her employer, Sunshine Reporting while this
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matter IS pending decision Respondent is hereby reminded that the Panel will be
deliberating at a future date and may take this conduct into consideration. DATED
this 16th day of November, 2012. by John P. Echeverria, Esq., Chair, Formal
Hearing Panel. (The Certificate of Service attached thereto is signed by Laura
Peters, an employee of the State Bar of Nevada
Exhibit 1C consists of the twenty-four page 12/14/12 FOFCOL in Case
No: NG12-0204, NG12-0434, and NG12-0435. It does not contain a single
assertion of any threatening on Coughlin's part, so it is rather unclear why King felt
it appropriate to attach it to his 12/20/12 TPO Application in 607. Similarly, King
and Peters felt it appropriate to attach filings in 607 to their initial attempt at an
Record on Appeal in 62337 of 12/24/12, but apparently were either scolded for
doing so or thought better of it (likely the former) and refrained from including any
such materials in their second attempt to file a somewhat professional, competent,
and ethical ROA on 2/13/13. Exhibit 1D consists of a printout of a webpage at
www.harm.com (ie, not even the url linked to in the email King alleges Coughlin
sent to various individuals (including some, like Coughlin's then Washoe County
Public Defender, Jim Leslie, whom then forward that same email to individuals
listed amongst the recipients of the original email itself (ie, the SBN's King), in a
class Leslie-style bit of pointless, insipid melodrama, along the lines of his adorable
jibberish stylings such as the phrase hand-off transmittal, which he originally
fashioned in his resistance to being stuck with the digital accountability attendant to
email a client their discovery, versus, what Leslie and his junior associate WCPD
Biray Dogan, are wont to do, which is have Dogan he himself handed the client his
discovery several weeks prior, only to change his story a couple minutes later to say
he saw Leslie hand it to the client, only to have Leslie then idiotically email the
client and indicate that the client failed to ever pick it up, and identifying such as
discovery of a 7/27/12 date, while failing to explain why neither Leslie nor Dogan
released to there then former client Coughlin the 8/13/12 and 8/17/12 updated 911
call discovery discs propounded to them by WCDA Zach Young while Dogan and
Leslie were still representing Coughlin (ie, Leslie taking over Goodnight and
Dogan's cases, and in an attempt to get a raise, setting out to purposefully deliver
the cheapest, quickest, convictions of Coughlin in all three of the baseless,
retaliatory prosecutions brought by the WCDA's Office after Leslie had succeeded
in depriving Coughlin of his right to accept a plea bargain disposing of all three
matters then pending on 8/27/12, which would have resulted in no SCR 111(6)
convictions in any of those matters. Getting beyond the fact that the printout of a
page with an audio clip only (played over a still frame photo of actor Robert De
Niro in a placid stance) comes from a different url than the one included in the
12/12/12 email King largely basis his decision to seek a TPO and an EPO on, such
audio only file and the quotation transcribed beneath it contain the following bit of
dialogue from the 1991 remake by Martin Scorsese of the film Cape Fear: I ain't
no white trash piece of sh*t. I'm better than you all. I can out leam you. I can out
read you. I can outthink you, and I can out philosophize you. And I'm going to
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outlast you. You think a couple of whacks to my good old boy guts gonna get me
down? Ifs going to take a hell of a lot more than that, Counselor, to prove you're
better than me! Max looks around in an attempt to find where Sam is hiding. (the
web page is adorned with a number of links to other materials and advertisements
as well). Exhibit 1D continues on with a 12/13/12 email from Pat King to obc;
Kimberly Farmer; fflaherty@dlpfd.com; David Clark printed from Laura Peters
email account as, apparently, King's forwarding an email he received from
Couglin's then WCPD Jim Leslie (which itself forwards to King and email Leslie
alleges Coughlin sent to Leslie, which, as Leslie would necessarily be able to
discern from reading a list of the recipients such email purports to be addressed to,
was also addressed to Pat King, making Leslie forwarding such to King rather
redundant, apparently).
The email from King that Peters printed out via her Microsoft Outlook
utility reads: Subject: FW: The Three E's;wcpd failure to provide essential 91 call
cd discovery of 8/13/ and 8/17, 2012 to Coguhlin in rcr2012-065630 This attorney
feels that his law firm staff was threatened by Zach Coughlin. I am concerned for
our staff. Please advise. Patrick King Thereafter, King's email forwards or
contains what purports to be an email to King from Coughlin's then WCPD Jim
Leslie, of 12/12/12, addressed only to King, which reads: Mr. King: The below
email from Mr. Cogulhin contains a reference at the end of the first paragraph to a
website containing a video clip from the movie Cape Fear. Please advise whether
any action is required of our office or yours regarding this possible veiled or
indirect threat of violence against attorneys in this office by Mr. Coughlin. Thank
You, James B. Leslie, Esq., Chief Deputy Public Defender, Washoe County Public
Defenders Office King's petition, allegedly for the SBN, contains no proof that
King was given any authority by anyone possessing the authority to give it, to file
his TPO/EPO Applicaiton in 607. Further, while King attaches and email from
himself the the President of the State Bar, Francis Flaherty, Kimberly Farmer, and
Bar Counsel David Clark, he fails to attach any sort of response from any of those
figures. Further, it would seem the SBN Board of Governors would need to vote on
such a thing. Additionally, the Office of Bar Counsel (OBC) should be considered a
distinct, separate office or entity, apart from the SBN. Without more, King fails to
prove that he has any standing to file his petition, particularly where the evidence
strongly suggest that King filed it for his own benefit, which violates the
requirement that the employer file such application for the employee, a requirement
which precludes the employee, King, from filing it for himself under the guise of
doing so for his employer. Probably the most important fact of all here is that the
SBNs Clerk of Court (as both she and Asst. Bar Counsel King have referred to
her and held her out to Coughlin and the public as) had added Coughlin's email
address to her blocked senders list by the time of the alleged emailing b y
Coughlin of 12/12/12. Therefore, Peters did not received such email from
Coughlin, and Coughlin was well aware at that time (Peters had notified him and he
was receiving failure messages for emails he sent to Peters) that she could and
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would no longer receive any emails from him (this became a point of criticism by
Coughlin as it underscores the SBN's failure to investigate, and Peters and the SBN
also hold her out as an Investigator). Regardless, even if it is proven that such an
email was sent by Coughlin, there is simply no credible basis for finding that such
is a threat to the SBN, Peters, or King (the SBN's TPO/EPO application in 607 fails
to identify just which employee it seeks to protect, as such, the failure to meet such
jurisdicitonal prerequisite renders it void), and further, such purported
correspondence must be seen as constitutionally protected excercise of free
speech.
Coughlin has already been subject to severe consequences of the OBC's
abuse of process here, including being subject to $5,000 bondable bail upon his
custodial arrest of 2/8/13 (and concomitant damage to his ability to defend his 14th
Amendment protected property right, his law license, in the appeal of the NNDB
Panel's recommendation that he be permanently disbarred (now on appeal in
62337). Further, King really applied for the TPO/EPO for himself, and is merely
masquerading as the agent of the SBN sufficient to attempt to get around his lack
of standing to so file for himself (to make his job easier, to intimidate or obstruct
Coughlin out of exposing King's fraudulent approach as a bar counsel, etc.). The
application can only be filed by the employer or its agent, pursuant to NRS 33.250.
An employee has no standing to file this type of protection order. This application
will contain the facts the applicant wants the court to consider in determining
whether a protection order against harassment in the workplace shall be issued.
King's application contains nothing Pursuant to NRS 33.240, in order for the court
to grant an application against harassment in the workplace, some or all of the
following acts or threats to commit the Further, its troubling the RPD Detective
Ytrubide was referred this matter in his role in the misdemeanor investigations
department, yet manage to incorrectly and maliciously overcharge Coughlin with
both a gross misdemeanor and a felony, especially where the SBN failed to even
put up the $100 security bond required for its application in 607, another
jurisdictional prerequisite. The fax header on the SBN's 12/20/12 application in 607
reveal that the RJC itself faxed the SBN the application form for the TPO.
That is inappropriate, much like the 4/11/12 email from RJC Judicial
Secretary Lori Townsend to the SBN's King (especially where the RJC has
steadfastly refused to even comply with the requirement that it respond, by
affidavit, witihin 5 days to the various motions to disqualify various RJC Judges
incident to the four retaliatory prosecutions undertaken against Coughlin in the RJC
since August 2011. The employer may not seek a workplace harassment TPO/EPO
primarily to accomplish a purpose for which it was not designed such as prohibiting
free speech or other activities that are constitutionally protected or otherwise
protected by law. The TPO and EPO obtained by the OBC from the RJC is a big an
abuse of process as can be. Simply put, the OBCs Clerk of Court, Laura Peters,
and Asst. Bar Counsel Patrick King grew tired of Coughlin discovering and
pointing out the numerous egregious instances of misconduct and fraud on their
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part, and leveraged that protection order against workplace harassment at the first
moment they (under their completely unreasonable viewpoint) felt there was even a
scintilla of something to hang their hat on, nevermind that such consisted of a
protected written grievance to the SBN about Coughlin's WCPD's patent, per se
professional misconduct, or that the alleged implied threat in no way related to
the SBN (the SBN is not and never was Coughlin's public defender, and even if it
was, nothing in the email Coughlin is alleged to have sent the WCPD on 12/12/12
(copied to complaints@nvbar.org as a written grievance against Leslie) could
reasonably be interpreted to be a threat, much less something worthy of a yearlong
protection order. Further, the OBC and Clerk of Court Laura Peters wished to
avoid being placed on notice of the wrongdoing of Richard G. Hill, Esq., and others
by Coughlin's faxes and emails (many of which contained audio and video files
demonstrating that Hill has lied continuously in an attempt to have Coughlin
disbarred), in addition to shortening the time Coughlin would have to prepare and
file post-hearing Motions, and motiosn to alter, amend, vacate, or otherwise
challenge the 12/14/12 Findings of Fact; Conclusions of Law of the NNDB Panel
in the formal disciplinary matter held on 11/14/12, which the OBC and NNDB
allege was comprised of the dictate to decide Coughlin's nature and extent of
Coughlin's punishment for his conviction of petty larceny in RMC 11 CR 22176
(see 60838), along with three grievances (NG12-0204 by Richard G. Hill, Esq.;
NG12-0434 by RMC Judges (according to Judge Holmes, see Judge Dilworth's
disputing Judge Holmes' assertions in her 3/14/12 written grievance to the OBC as
to her acting on behalf of all of the RMC, including her fellow judges; and NG120435, the grievance, apparently, consisting of the 4/13/09 Order After Trial by
RMC Administrative Judge William Gardner's sister, 2JDC Judge Linda Gardner,
which sanctioned Coughlin $934 under NRS 7.085 incident to a motion for
sanctions made during closing argument by Springgate in a divorce case (ie, no
compliance by Springgate with NRCP's procedural requirement that a filing ready
sanctions motion be served on Coughlin 21 days prior to making such a motion for
an attorney's fee sanction...which was largely premised on the assertion that
Coughlin failed to follow procedural rules, even where it was Springgate whose
Trial Statement was filed late and Springgate whom failed to comply with the PreTrial Order in failing to have, where he sought the introduction of more than ten
exhibits, those exhibits indexed, bound, and tabbed, and failed to provide a copy of
such to opposing counsel at the time of trial, as required by Judge L. Gardner's
2/25/09 Pre-Trial Order.
The same failure to comply with the 21 day safe harbor jurisdicitonal
prerequisite by Richard G. Hill, Esq.'s associate, Baker, would render Judge
Flanagan's $42,065.00 sanction award of 6/25/12 (formal hearing exhibit 2 at the
11/14/12 disciplinary hearing) void as well, except for the fact that NRAP 38
actually applies, rather than NRS 7.085 (which invokes NRCP 11, ie, not applicable
to appeals, and NRAP 38 must be made on a court's own motion, and the
application of DCR 13(3) that Judge Flanagan admits to in his 6/25/12 Order in
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03628 (Judge Flanagan wrote: After reviewing Merliss's moving papers-including

the detailed and thorough summary of fees and his counsels' accompanying
Declarations-and after considering all of the parties' arguments, this Court
concludes Merliss's attorney's fees request is authorized by Nevada law. This Court
also has considered the factors set forth in Brunzell, supra. After analyzing those
factors, and given the unique features of this case, this Court concludes Merliss's
fee request is reasonable. P3:13.. Where Judge Flanagan specifically mentions
only the landlord's moving papers and where he previously notes (incorrectly) in
the order that Coughlin failed to file any opposition (In the absence of any
opposition from Appellant ZACHARY BARKER COUGHLIN ("Coughlin"),
Merliss submitted this matter for decision on May 9, 2012. However, on June 9,
2012, Coughlin filed a Supplement to Opposition to Motion for Attorney's Fees. In
response, Merliss filed a Reply to Supplement to Opposition to Motion for
Attorney's Fees on June 14, 2012, and submitted the matter-again-that same day.
Merliss requests this Court to award attorney's fees in the amount of $42,065.50
against Coughlin in the underlying summary eviction matter pursuant to NRS
69.050 and NRS 7.085 P1:5-16; but note, Coughlin's law license was suspended in
60838 pursuant to his conviction of petty larceny in the RMC of a candy bar and
some cough drops , a suspension now lasting nearly one year (11/30/11 conviction
by Judge Howard in 11 CR 22176, where a three day incarceration was also
ordered incident to an Order Punishing Summary Contempt incident to Coughlin's
being forced to self represent where denied his Sixth Amendment right to counsel
by the RMC), (compare to Stephen R. Harris, Esq's misappropriating $755,000
from clients, admitting to using it on prostitutes and designer good receiving only a
three months actual suspension, no temporary suspension, etc., etc., and no criminal
prosecution incident thereto)
( Further, in his 8/28/12 Order in 03628, Judge Flanagan further drove home
the point that his 6/25/12 Order was not an attorney fees sanction, wherein Judge
Flanagan wrote: Again, as was the case in Coughlin's attempt to set aside Merliss's
award of costs Coughlin's Motions here attempt to re-litigate substantive issues this
Court has already decided, or frivolous claims this Court has previously ignored.
P2:6-10; further the OBC's King email Coughlin a copy of that 8/28/12 Order by
Judge Flanagan, providing conclusive proof that King was aware of it, and yet
persisted in his violating of RPC 3.1, and 3.3 in seeking to have Coughlin disbarred
incident to the fraudulent assertion he and Hill maintained at the 11/14/12 Hearing
that Judge Flanagan's attorney fee award of 6/25/12 was a sanction. Peters and
King are basically afraid of a few things they did wrong, and which are perhaps
fraudulent, causing consequences to their careers...and, accordingly, the began to
threaten to abuse the protection order process in early November 2012 (shortly after
Coughlin pointed out that the SBN put insufficient
Coughlin has a right to confront his accuser's an nothing in King's TPO application
specifies just which employees of the SBN such protection orders were designed to
protect, and further, King showed up as counsel so as to King, and as to the
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failure to appear of those the SBN failed to list as the parties to be protected, the
EPO is void. King's 12/20/12 TPO Application in 607 is less than truthful. One, at
page 4 of 6, it fails to identify a TPO Applciation by Richard G. Hill, Esq., against
Coughlin where King, Peters, and the SBN were made well aware of such by
Coughlin, and even provided both the Order in RCP 2012-000018 and Hill's lied
filled 1/12/12 TPO Application therein, where such information is required to be
included pursuant to question 1(b). The complicity between NNDB Member Hill
and King runs throughout Coughlin's formal disciplinary matter, and King's failure
to divulge this information, especially as it relates to Hill, is troubling. Additionally
(and this is ironic considering King has attempted to have Coughlin permanently
disbarred incident to his own fraudulent allegation that Coughlin filed IFP's in the
RMC without identifying himself as an attorney), at page 5 of 6 King fails to
truthfully and completely answer question 8 therein, which reads: 8. Have there
been any other Court actions or any other relationships between the employer and
the Adverse Party? King check the 'yes box. In the blank following If yes,
please describe: King wrote Discipline Hearing held 11/14/2012.
King completely fails to indicate that there is another action between the
parties in that the appeal of the 12/14/12 FOFCOL is now before the Nevada
Supreme Court in 62337 (which would necessarily, and obviously involve
communications between these two parties and their respective counsel, making
RJC Judge Pearson's TPO a distrubingly overbroad order that has very troubling
lack of regard for Coughlin's rights as a litigant in two different cases wherein the
SBN is the opposing party, both of which implicate an extremely valuable and
primary property right to Coughlin, his law license. Further, King's simply nating
Discipline hearing held 11/14/2012 competely fails to inform the court as to the
fact that there was an ongoing trial court case between these two parties, with the
SBN operating in at least a dual role as both the prosecutor and the situs of the
court, and the Clerk of Court's location. This goes to the heart of the problem
currently in Nevada where the SBN cannot be trusted to wear so many hats, where
King and Peters have blatantly abused the public's trust in that regard and sought to
take advantage of the current structure at every possible opportunity, something the
NNDB and Panel here have been entirely too permissive with regard to, which is
troubling
5/28/13 Order:
"This is an appeal from district court orders denying an emergency motion for a
temporary restraining order or injunction and awarding attorney fees in a landlordtenant matter. Second Judicial District Court, Washoe County; Patrick Flanagan,
Judge.
Appellant moved the district court for a temporary restraining order or injunction in
an appeal from a justice court order in a landlord tenant dispute. Following the
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denial of that motion, appellant appealed to this court. Subsequently, the district
court entered an order awarding attorney fees to respondent and appellant also
appealed from that order.
The district court has final appellate jurisdiction in all cases arising in justice
courts. Nev. Const. art. 6, 6; see also Waugh v. Casazza, 85 Nev. 520, 521, 458
P.2d 359, 360 (1969). Although NRAP 3A(b)(3) authorizes an appeal from an order
refusing to grant an injunction, and NRAP 3A(b)(8) authorizes an appeal from a
post-judgment order awarding attorney fees, see Winston Prods. Co., Inc. v.
DeBoer, 122 Nev. 517, 525, 134 P.3d 726, 731 (2006) (recognizing that an order
awarding attorney fees and costs is substantively appealable as a special order after
final judgment), because the orders challenged in this case arose from the district
court's exercise of appellate jurisdiction over an appeal from a justice court
decision, the district court's orders were ostensibly rendered final and are not
appealable to this court.For the same reasons, to the extent that appellant seeks to
appeal from any other order or determination arising from the district court's
appellate review of the justice court matter, this court likewise lacks jurisdiction to
consider any such appeals. Accordingly, as we lack jurisdiction over this appeal, we
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ORDER this appeal DISMISSED.l /s/ Gibbons, Douglas, Saitta (fn1 lRespondent's
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April 26, 2013, motion seeking to dismiss this appeal for lack of jurisdiction on
other grounds and his April 26, 2013, motion to strike are denied as moot. To the
extent that respondent seeks attorney fees based on the motion to dismiss this
appeal, that request is denied. We further deny as moot any other requests for relief
pending in this matter.)"
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Footnote 1 in that 5/28/13 Order in 61383 reveals the extent to which Hill's Motion
to Dismiss failed to argue that the Court lacked jurisdiction to hear the appeal of
Coughlin's 12/30/11 Motion for TRO per NRCP 62/Motion for Stay pursuant to
NRS 40.385 (and the District Court and N. S. Ct. both seem to be overlooking the
extent to which that motion was premised upon, and cited to specifically, NRS
40.385, which at least according to 8JDC Judge Herndon's analysis in Venetian v
Two Roads (the transcript from the 8JDC motion to stay hearing is attached as an
exhibit to a filing in that NSCT case).
It seems there is a reason that Hill/Baker continually sought to characterize
Coughlin's 12/30/11 filing of a Motion for TRO/Motion for Stay Pursuant to NRS
40.385 as simply a Motion for TRO...something both Judge Flanagan and the
NSCT Panel have seemingly accepted as a proper and complete characterization
thereof. This incorrect view becomes important when considering the extent to
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which NRS 40.385 vests original jurisdiction in the District Court, not the Justice
Court, for hearing such Motions for Stay. This means that Nev. Const. Article 6
Sec. 6. does not vest "final appellate jurisdiction" in the District Court in such
instances, as the version of NRS 40.385 in effect during all relevant times herein
was that which became effective 10/1/11, which implicates NRAP 8 (as does NRS
40.400):
NRS40.385Stay of execution upon appeal; duty of tenant who retains
possession of premises to pay rent during stay.Upon an appeal from an order
entered pursuant to NRS 40.253:
1.Except as otherwise provided in this subsection, a stay of execution may be
obtained by filing with the trial court a bond in the amount of $250 to cover the
expected costs on appeal. A surety upon the bond submits to the jurisdiction of the
appellate court and irrevocably appoints the clerk of that court as the suretys agent
upon whom papers affecting the suretys liability upon the bond may be served.
Liability of a surety may be enforced, or the bond may be released, on motion in
the appellate court without independent action. A tenant of commercial property
may obtain a stay of execution only upon the issuance of a stay pursuant to
Rule 8 of the Nevada Rules of Appellate Procedure and the posting of a
supersedeas bond in the amount of 100 percent of the unpaid rent claim of the
landlord.
2.A tenant who retains possession of the premises that are the subject of the
appeal during the pendency of the appeal shall pay to the landlord rent in the
amount provided in the underlying contract between the tenant and the landlord as
it becomes due. If the tenant fails to pay such rent, the landlord may initiate new
proceedings for a summary eviction by serving the tenant with a new notice
pursuant to NRS 40.253.
(Added to NRS by 1997, 3510; A 2011, 1492)
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The funny thing about NRS 40.385 is that is provides further support for the
argument that the summary evictions procedures found in NRS 40.253 may not be
utilized against a commerical tenant such as Coughlin in a no cause eviction per
NRS 40.254. Coughlin did, in fact "raise in the trial court" such argument (despite
Hill and Baker repeatedly lying that Coughlin had not raised it, both in Baker's
2/24/12 Brief in the appeal to the District Court in CV11-03628, and in their
testimony at the 6/18/12 criminal trespass trial against Coughlin stemming from the
11/13/11 arrest at his former home law office.
Besides a multitude of instances where Coughlin identified the property in his
pleadings and the transcripts of the 10/13/11 and 10/25/11 hearings as his "office"
(Judge Sferrazza even said "I'm not going to let you use the office without paying
rent" during the 10/25/11 hearing/"Trial"), in Coughlin's 10/17/11 filign of an
"Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order" as to the
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10/13/11 "Eviction Decision and Order" by Judge Sferrazza "setting the matter for
Trial on 10/25/11" should Coughlin deposit some $2,275 in "rent escrow" based
upon a ruling that Coughlin's NRS 118A.510 retaliation defense to the summary
eviction contained enough of a tertiary connection to alleged habitability claims to
justify invoking NRS 118A.355(5), despite the fact that Coughlin, one, wasn't
defending a non-pay summary eviction by alleging habitability as a defense, but,
rather, was defending against a no-cause summary eviction by alleging, in part,
retaliation. Further, Coughlin clearly disclaimed any application of NRS
118A.355(5), and rather, specifically indicated that any rent alleged owed to
Merliss (and Merliss never did allege Coughlin owed him any rent, Judge Sferrazza
seemingly alleged that for Merliss, or let Merliss's counsel make such unverified,
unattested allegations based upon hearing, even where counsel Baker lacked a
single witness, Merliss included, for the 10/13/11 summary eviction proceeding,
and where neither Merliss, nor Baker, ever filed and affidavit or Declaration
alleging Coughlin owed any rent, and where
"In most cases, the landlord can choose whether to file a summary or formal
eviction action. However, there are circumstances under which summary eviction
cannot be used. For instance, summary eviction is not available for: 2) Eviction
of commercial tenants for other than nonpayment of rent (See NRS 40.254)
Using location for a "commercial" law practice, you filed a no cause, ie, "for
other than nonpayment of rent, not based in law or fact, Rule 11, plus this escrow
thing gets put asunder. NRS 40.254 Unlawful detainer: Supplemental remedy of
summary eviction and exclusion of tenant from certain types of property. Lease
allows for use for commercial purposes. Void, void, void! NJCRCP 59, 60..."
NRS 40.310 Issue of fact to be tried by jury if proper demand made. Whenever an
issue of fact is presented by the pleadings, it shall be tried by a jury, if proper
demand is made pursuant to the Nevada Rules of Civil Procedure or the Justice
Court Rules of Civil Procedure. Coughlin demands a jury trial.
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(see Coughlin's 10/17/11 Motion for Stay

As to the summary eviction from Coughlin's from home law office at 121
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River Rock on 11/1/11 and the appeal thereof (see 61383, and the SCR 111(4)
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Petition by the SBN incident to the criminal trespass convictino Coughlin sustained
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as a collateral consequence to Richard Hill, Esq., Casey D. Baker, Esq., and Dr.
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phrase therein "test the truthfullness and sufficiency of the affidavits" and "no legal
defense". Previously I thought such language meant the NRCP 56(c) prong of
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"genuine issue of material fact" was NOT included in any analysis of whether there
is "no legal defense"...but upon reviewing Anvui some more, and some other
materials, is seems the "genuine issue of material fact" prong is included under an
analysis of whether there is "no legal defense" (which seems unfair to me in a
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summary eviction setting considering there is essentially zero opportunity for

discovery, and especially where Judge Sferrazza essentially allowed the landlord to
file the "unlawful detainer affidavit" required by NRS 40.254(2) and or NRS
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40.253(5), in open court, at the time of the "trial"/continuation of the summary

eviction proceeding from last week..
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Such approach prejudiced Coughlin's defense (beyond Coughlin essentially

being required to litigate the no cause summary eviction as a non-payment
summary eviction, replete with an extended review of my alleged "habitability
defense" (ie, my retaliation defense tangentially involved issues of habitability)) in
that the holdover proceeding/no cause basis/issue of whether the lease had been
terminated versus "expired" (Hill's associate and the landlord essentially committed
fraud by declaring the lease was "expired" when, in actuality, the language of the
lease indicated it was for "not less than 12 months", not a finite period of 12
months (sure, the landlord can argue such contradictions between his and his
counsel's testimony/statements in unlawful detainer affidavit by the landlord were
patent or obvious from a review of the 10/19/11 Declaration of Lanldord's Counsel
(which contains nothing more than a conclusory statement that the landlord's claim
is "authorized by law"), but given the three days for constructive service thereof
and the Proof of Service therein, Coughlin did not, and can only be viewed as
constructively served such 10/19/11 Declaration of Landlord's Attorney (which
sought to satisfy NRS 40.254(2)'s requirements) a mere one judicial day before the
10/25/11 proceeding. Such scant notice of the basis and specific factual
allegations underlying the landlord's action for possession severely prejudiced
Coughlin's defense. Despite that, Coughlin did manage to preserve in the record
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his contention that the lease was not "expired" sufficient to argue the the 8/22/11
Notice of Termination was insufficient.
The main purpose of pleadings in a summary proceeding is to apprise the
other party, by allegations of ultimate facts, what will be established at the trial.
[4] A tenant is entitled to a concise statement of the ultimate facts on which a
nonpayment summary proceeding is predicated so that the issues are properly
raised and can be met.[5] Thus, a complaint filed in a forcible entry and detainer
proceeding must sufficiently apprise the tenant of the nature of the action brought
against him or her.[6]...The complainant must set out the facts on which he or she
bases a right to recover,[10] and a statement of legal conclusions only is
insufficient.[11] Since the remedy is purely statutory, a plaintiff must allege such
facts as bring the case within the provisions of the particular statute relied on.[12] It
is essential that the complaint or affidavit show that the plaintiff has a right of
possession.[13] As to requirements for pleading a cause of action, generally, see
C.J.S., Pleading 115 to 157. . [FN4] N.Y.Smith v. Scott, 190 Misc. 600, 76
N.Y.S.2d 91 (City Ct. 1948). . [FN5] N.Y.Sapphire Hotel Corp. v. Netzick, 82
Misc. 2d 95, 368 N.Y.S.2d 113 (N.Y. City Civ. Ct. . 1975). . [FN6] Me.Rubin v.
Josephson, 478 A.2d 665 (Me. 1984). Adequate notice of transaction and material
elements N.Y.Olean Urban Renewal Agency v. Herman, 50 A.D.2d 1081, 376
N.Y.S.2d 328 (4th Dep't 1975). Effect of inaccurate description of leased property
AlaskaLeisnoi, Inc. v. Stratman, 960 P.2d 14 (Alaska 1998). [FN10] N.J.
Weller v. Kelly, 136 N.J.L. 281, 55 A.2d 55 (N.J. Sup. Ct. 1947). . N.Y.Stier v.
President Hotel, Inc., 28 A.D.2d 795, 281 N.Y.S.2d 140 (3d Dep't 1967). . [FN11]
N.J.Weller v. Kelly, 136 N.J.L. 281, 55 A.2d 55 (N.J. Sup. Ct. 1947). . N.Y.
Stier v. President Hotel, Inc., 28 A.D.2d 795, 281 N.Y.S.2d 140 (3d Dep't 1967). .
[FN12] Ky.Jobe v. Witten, 305 Ky. 457, 204 S.W.2d 575 (1947). . N.Y.
Midville Estates v. Cobey, 187 Misc. 350, 64 N.Y.S.2d 177 (App. Term 1946). .
Jurisdictional nature of such allegations N.J.Community Realty Management,
Inc. for Wrightstown Arms Apartments v. Harris, 155 N.J. 212, 714 A.2d 282
(1998). N.Y.Stier v. President Hotel, Inc., 28 A.D.2d 795, 281 N.Y.S.2d 140 (3d
Dep't 1967). . Wis.Rupp v. Board of Directors of Assembly No. 58 of Equitable
Reserve Ass'n, 244 Wis. 244, 12 . N.W.2d 26 (1943). . [FN13] Conn.Macha v.
Eastern Conn. Training School for Firemen, Inc., 1 Conn. Cir. Ct. 469, 24 Conn. .
Supp. 151, 187 A.2d 638 (App. Div. 1962). . N.M.Kuykendall v. Ulibarri, 56
N.M. 43, 239 P.2d 731 (1952). . [FN14] Mo.Bess v. Griffin, 234 S.W.2d 978
(Mo. Ct. App. 1950). . N.Y.Granet Const. Corp. v. Longo, 42 Misc. 2d 798, 249
N.Y.S.2d 231 (Sup 1964).
Certainly, Coughlin's 10/6/11 Tenant's Answer and numerous filings thereafter
assisted the landlord greatly by noticing him as to the law and specific factual basis
for Coughlin's various defenses and counterclaims. An answer or other pleading of
the defendant is sufficient where it sets up in proper form any defense that, if
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established, will prevent a recovery of judgment by the plaintiff. Ill.Beach v.

Boettcher, 323 Ill. App. 79, 55 N.E.2d 104 (1st Dist. 1944). Prima facie defense
N.Y.Core Management Corp. v. Loeb, 118 N.Y.S.2d 657 (App. Term 1952).
Setoff or counterclaim. A setoff or counterclaim, when permitted to be interposed,
must be specially pleaded. Ala.Myles v. Strange, 226 Ala. 49, 145 So. 313
(1932). Right to file answer and counterclaim Ga.Leonard v. Donald, 134 Ga.
App. 482, 214 S.E.2d 731 (1975). . As to setoffs and counterclaims, generally, see
1549. . Such a pleading must allege facts sufficient to constitute a cause of action
on the part of the defendant against the plaintiff. N.Y.8008 Realty Corp. v.
Rubin, 85 N.Y.S.2d 163 (App. Term 1948). . Allegations sufficient Mont.
Hutchinson v. Burton, 126 Mont. 279, 247 P.2d 987 (1952).
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The 10/19/11 Declaration of Counsel by Hill's associate, which fails to satisfy

the verification requirement in NRS 40.300 (though that may only apply to plenary
trials) or the RPC 3.7 prohibition against an attorney acting as a witness or making
a declaration based upon what his client told him, allegedly, then claiming attorney
client privilege somehow protects against any cross examination of such, etc. (Hill's
associate, prior to the landlord's "unlawful detainer affidavit" being filed in open
court as an exhibit during the 10/25/11 "continuation of a summary eviction
proceeding" (which is how Sferrazza reclassified his earlier written order following
the initial 10/13/11 summary eviction proceeding (at which the landlord failed to
appear, Hill's associate appearing with no witness to authenticate or "substantiate"
the "unlawful detainer affidavit" (much less allow Coughlin to "test the truthfulness
and sufficiency of the ("unlawful detainer") affidavit (a la NRS 40.254(2))" by the
landlord per NRS 40.253(6)) that Hill's associate Baker failed to have marked or
admitted on 10/13/11.
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It does not appear Coughlin was even provided a copy of such "unlawful
detainer affidavit" by the landlord until halfway through the 10/25/11 "continuation
of the summary eviction proceeding" of 10/13/11), only to have such admitted as an
exhibit at the subsequent 10/25/11 ""Trial", wait, er, no, it's not a "Trial" like I ruled
last week, if you're going to be a stickler about the NJCRCP 109 "20 days to file an
answer once served with a Complaint" procedural rule for "trials"...", essentially,
said Judge Sferrazza, whereupon he recharacterized such 10/25/11 date as a
"continuation of the summary eviction proceeding" meant to provide Coughlin an
opportunity to "substantiate" the "legal defense" he asserted in his Tenant's
Affidavit and during the sua sponte cross examination by Sferrazza on 10/13/11
(not much else to do when the California landlord fails to show up for the
hearing...and despite the RJC's allowing property managers and Nevada Court
Services to commit the unauthorized practice of law in landlord tenant matters,
there is nothing in NRS 40.253 et seq that allows for a "landlord's agent" to do
anything beyond that allowed by NRS 40.253(1)'s "the landlord or the landlords
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agent, unless otherwise agreed in writing, may serve or have served a notice in
writing, requiring in the alternative the payment of the rent or the surrender of the
premises:" ... and NRS 40.253(5)'s: " 5. Upon noncompliance with the notice: (a)
The landlord or the landlords agent may apply by affidavit of complaint for
eviction to the justice court of the township in which the dwelling, apartment,
mobile home or commercial premises are located or to the district court of the
county in which the dwelling, apartment, mobile home or commercial premises are
located, whichever has jurisdiction over the matter. The court may thereupon
issue an order directing the sheriff or constable of the county to remove the
tenant within 24 hours after receipt of the order. The affidavit must state or
contain: (it would seem that NRS 40.254's incorporation of the procedure's in NRS
40.253 would replace the requirements for what such affidavit should contain in a
non-payment setting with those laid out in NRS 40.254(2) for an "unlawful detainer
affidavit" in a no-cause setting (they differ somewhat markedly)..."
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The landlord is a neurologist from Chico, and the property is actually titled
in the "Matthew Merliss Living Trust", as such, it's not entirely clear that Merliss
himself has standing, or that the District Court does not actually have exclusive
jurisdiction (NRS 40.253(5)'s "whichever has jurisdiction") to the extent issues of
title are involved.
Am Jur
843. Application to holdover tenant
848. Requisites; sufficiency of Notice of Termination and Unlawful Detainer
852. Form of petition or complaint
(4) Defenses, Setoff, and Counterclaims:
(a) In General: 865
(6) Appeal: 885. Mootness 886. Procedural issues 887. Standards of review
888.
Bond; continuing payment of rent
Coughlin's possession of the premises was based on his mixed used tenancy
(the lease expressly allowed for using the premises for residential, commercial, and
"any other purposes", and Gasser v. Jet Craft makes clear that the landlord's
argument that some alleged failure to have a current or paid up or active business
license as to the mattress business (or to have the address in question for that sole
proprietorship listed with the State of Nevada's Department of Taxation (though,
there is conflicting evidence in that regard, and regardless, Merliss failed to raise
such issue in the trial court) or home law office/law practice or other technical
deficiencies does not operate to make such commercial use of the premises "illegal"
or violative of any restricdtion against using the premises for any "unlawful
purpose".
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Jurisdictional determination: Possession not based

on residential tenancy, eviction not proper remedy and summary procedure not
available. Grimm v. Huckabee, 891 So. 2d 608 (Fla. 1st DCA 2005).
The 10/27/11 FOFCOLOSE fails to specify whether Coughlin's tenancy was
residential, commercial, or both. Judicial estoppel does not operate to preclude
Coughlin from pleading and arguing that his was both a commercial and residential
tenancy ("home law office" is a phrase repeated continuously, particularly in the
introductory pleadings and transcripts of the proceedings). At best Merliss might
argue that as to the portion of Coughlin's tenancy that was residential, he is
permitted to utilize the procedures in NRS 40.253, however, such approach would
not entitle Merliss to utilize such procedures against to portion of Coughlin's
tenancy that was of a commercial, law office, nature. Perhaps judicial estoppel
applies to prevent Merliss from originally claiming to be evicting Coughlin for nonpayment of rent in 1492, then changing course and bringing the no-cause summary
eviction in 1708. Certainly, collateral estoppel from 1492, as such issue was
actually litigated therein (Merliss turning tale and "dismissing" his own nonpayment summary eviction hardly operates as a get out of jail pass as to the
application of collateral estoppel in 1708 vis a vis the application of NRS
118A.355(5) by Judge Sferrazza, especially where Merliss's attorney repeatedly
insisted he was not seeking rent and that possession of the property was all that was
sought, and where Coughlin never once admitted to owing or withholding any rent
from Merliss. Rather, Coughlin invoked NRS 118A.360, agreements between
landlord and tenant operating as rent deductions, and the payment of rent to Merliss
in asserting that most decidedly did not owe Merliss any rent, and was in no way
asserting a posture under NRS 118A.355(5) vis a vis "withholding" any rent.
The order requiring Coughlin to deposit into the RJC a "rent escrow" of
$2,275 (which Couglin filed an interlocutory appeal to on 10/17/11, and any
purported justification by the RJC that it's failure to transmit such appeal to the
District Court premised upon some notion that Coughlin had failed to "perfect" his
appeal (especially where such is based on any notion that Coughlin, whom was
granted in forma pauperis status by the RJC's 10/6/11 Order, needed to pay the
filing fee of either the RJC or 2JDC, or some "appeal bond" (especially where
NJCRCP 73-76 are clearly not applicable to summary evictions. See NRS 40.385
and the RJC's own "Appeal Information" handouts) "Although a landlord generally
is entitled to require a tenant in possession to deposit rents into the court registry
during the course of any landlord tenant dispute where the tenant interposes any
defense other than payment, the rule yields where title is in issue. This exception is
well illustrated by the recent Fourth District Court of Appeal case, Frey v. Livecchi,
852 So.2d 896 (Fla. 4th DCA 2003). In Frey, Pamela Livecchi, the owner of a
Broward County home, entered into a one-year residential lease agreement with the
Freys. Id. at 897. The Freys alleged that at the end of the lease agreement they had
entered into an option to purchase the property. Id. Livecchi, on the other hand,
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denied the existence of any such option and asserted that at the end of the lease, the
Freys became month-to-month tenants. Id. At the end of the period, Livecchi sent
the Freys a notice to vacate the premises. Id. The Freys responded with a complaint
for specific performance based upon the purported option. Id. Without conducting
an evidentiary hearing on this dispute, the trial court ordered the Freys to put the
disputed past due rent in the registry of the court or face an order of eviction. Id.
The court of appeal reversed stating: Section 83.60(2), Florida Statutes, requires
payment of rent into the registry of the court in residential landlord tenant disputes
under Part II of Chapter 83. 83.60, Fla. Stat. (1999). However, section 83.60 does
not apply when the occupancy is under a contract for sale of a dwelling unit or the
property of which it is a part. 83.42(2), Fla. Stat. (1999). The Freys claim that this
provision is inapplicable because they were not tenants under the statute. Rather,
their claim is based on their rights under a contract for sale. The resolution of this
factual dispute would determine whether section 83.60 is applicable. Because such
a determination would be dispositive, we hold that the trial court was required to
conduct an evidentiary hearing before determining whether the Freys were required
to pay money into the court registry. Because the trial court failed to conduct such a
hearing, we find that the trial court erred in imposing such a requirement, erred in
entering the default judgment, and reverse the entry of the final default judgment.
Id. at 897-98; ?see also Grimm v. Huckabee, 891 So.2d 608 (Fla. 1st DCA 2005).
Cf. Blanco v. Novoa, 854 So.2d 672, 673 (Fla. 3d DCA 2003)(reversing a motion
to pay accrued rent into the registry of the court where the trial court construed
the agreement between Blanco and Novoa to be a [true] lease rather than a
mortgage); ?First Hanover v. Vazquez, 848 So.2d 1188 (Fla. 3d DCA 2003)
(affirming the grant of a motion for default and non-payment of rent where tenant
ratified the conveyance of property by bringing action for damages for fraudulent
inducement apparently without placing title in issue). As in Frey, there is a factual
dispute in this case concerning who is the true owner of the property. Because the
trial court's order requiring payments by Minalla of monies into the registry was
made without conducting an evidentiary hearing concerning the nature of the
transaction and who is the true owner of the residence, the court erred in imposing
the payment requirement upon her." Minalla v. Equinamics Corp., 954. So. 2d
645 (Fla. 3d DCA 2007).
Tennessee Bar Ass'n v. Berke, 48 Tenn. App. 140, 344 S.W.2d 567 (1960).
Evidence bearing the earmarks of
private spite should be accepted with extreme caution and scrutinized most carefully.
Cal.Sampson v.
State Bar, 12 Cal. 3d 70, 115 Cal. Rptr. 43, 524 P.2d 139 (1974).
W.Va.Committee on Legal Ethics of West Virginia State Bar v. Pietranton, 143 W. Va. 11, 99 S.E.2d
15 (1957).
Determinations in prior proceedings. (See SCR 114 for analogy as to not

recognizing convictions where due process was so obviously lacking in the trial
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court) In some jurisdictions, a prior conviction of a criminal offense may

conclusively establish guilt of the offense charged in attorney disciplinary
proceedings.[17] Likewise, a foreign jurisdiction's adjudication of guilt may be
deemed conclusive proof of guilt of the attorney misconduct charged.[18] The
burden then falls upon the attorney to demonstrate why the foreign judgment is not
valid or why the state should not accept it and impose sanctions based thereon.[19]
While a judgment in a civil proceeding to which the respondent was a party
may be conclusive that he or she performed particular acts having particular
civil consequences,[20] the result in the civil action is not conclusive in a
disciplinary proceeding in establishing that the respondent's conduct was such,
under the circumstances, as justifies disciplinary action.[21] Moreover, the
issue of what discipline is appropriate is not concluded by a determination in a
prior proceeding, even when it is conclusive of misconduct on the part of the
attorney.[ 22].
[FN17] N.J.In re Boylan, 162 N.J. 289, 744 A.2d 158 (2000). Mass.
Matter of Concemi, 422 Mass. 326, 662 N.E.2d 1030 (1996). Consideration of
underlying conduct not precluded A conviction does not preclude consideration of
the actual conduct itself for the purpose of determining the appropriate discipline to
be accorded an attorney. Ill.In re Ciardelli, 118 Ill. 2d 233, 113 Ill. Dec. 94, 514
N.E.2d 1006 (1987). [FN18] Fla.The Florida Bar v. Mogil, 763 So. 2d 303 (Fla.
2000). Unsupported finding disregarded A finding by a board, in an out-of-state
disciplinary proceeding, that the respondent had charged an excessive fee would be
disregarded in a disciplinary proceeding within the state, where no basis for
supporting the finding could be found. Mo.In re Weiner, 530 S.W.2d 222, 81
A.L.R.3d 1272 (Mo. 1975), supplemented, 547 S.W.2d 459 (Mo. 1977). Burden of
showing infirmity of foreign proceeding The burden of showing that the respondent
was denied due process and that there was an infirmity of proof in the foreign
disbarment proceeding is on the accused attorney. Neb.State ex rel. Nebraska
State Bar Ass'n v. Dineen, 235 Neb. 363, 455 N.W.2d 178 (1990). [FN19] 100.
[FN20] Tenn.Berke v. Chattanooga Bar Ass'n, 58 Tenn. App. 636, 436 S.W.2d
296 (1968). [FN21] IowaCommittee on Professional Ethics v. Wright, 178
N.W.2d 749 (Iowa 1970). Tenn.Tennessee Bar Ass'n v. Berke, 48 Tenn. App.
140, 344 S.W.2d 567 (1960). [FN22] Tenn.Berke v. Chattanooga Bar Ass'n, 58
Tenn. App. 636, 436 S.W.2d 296 (1968).
Further, the 2/28/12 and 3/13/12 Orders by Judge Holmes (Formal Hearing
Exhibits 4 and 5) were in RCM 11 TR 26800, with the "TR" signfiying the fact that
the matter was a "traffic citation", ie, not a criminal matter. The alleged infraction
consisted of a 'boulevard stop', more commonly referred to as a "California Roll".
As such
It is particularly obvious from a review of the transcript of the criminal
trespass conviction as rendered that there was "no basis for supporting the finding"
therein and as such (even though the SCR 111(4) Petition admits such "conviction"
was not a "serious offense" (making all the more incongrous Pat King's
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recommending permanent disbarment (although, curiously, King seemed rather

eager to see Hill's client, Merliss, in particular, and to the exclusion of, say, CIS in
60302 or 60317 getting their attorney fee awards paid (even where Hill and King
know full well that Judge Flanagan's 8/28/12 Order in 03628 (see 61383) makes
even more clear than his 3/27/12, 3/30/12, and 6/25/12 Orders that Coughlin did
not commit any sanctionable conduct in that case (which was not even notice-pled
as being at issue in King's 8/23/12 Complaint, violating SCR 105(2)(c), and, of
course, King attempted to make Formal Hearing Exhibit 2 that 6/25/12 attorney's
fee award by Judge Flanagan...only problem is that such award was premised upon
(see adjudicatory boundaries being limited to that put before the court by the
parties) Hill's associate Baker's 4/19/12 post-"judgment" Motion for Atty Fee
Award sanctions...premised upon NRS 7.085 and NRS 69.050....only problem is
(you think the $60K they allege there client paid them to "win" the summary
eviction of attorney Coughlin from his former home law office located in a
dwelling not worth $90k in today's market) that NRS 40.400 makes real clear that
NRAP applies to that appeal from the justice to the district court, and NRAP 38
makes clear that costs (killing the 5/22/12 Order awarding some $2,500 in "costs"
under NRS 18.005(17) for "work" done by the contractor that had absolutely
nothing to do with the issues on appeal in 03628 (where Coughlin was precluded
from brining counterclaims in this "summary eviction proceeding", then certainly
Merliss should not be able to win some "judgment" for "costs", which are really
mere "damages" he alleges were incurred incident to a burglary of the property that
occurred on 12/12/11 during the six weeks when Hill in his 11/21/11 email, at the
very least, implied he was able to prevent Coughlin from obtaining a timely hearing
on his NRS 40.253(8) 11/16/12 Motion to Contest Personal Property Lien until
12/20/11. HIll succeeded in that, but Coughlin's personalty was subject to a
burglary of 12/11/11...how Merliss's is able to receive a "costs" award premised
upon NRS 18.005 (where such does not apply to appeals given the import of NRS
40.400 and NRAP 38, see Berosini, is really not clear, but a theme develops when
reviewing each of the orders by Judge Flanagan in that appeal of a summary
eviction....awards of fees, costs, and possession all premised upon statutes and rules
that only apply to plenary matters and appeals thereof (NRS 69.050 (Merliss's
counsel's citation to such it particularly troubling given the extent to which it was
forced to recognize in the trial court that NRS 69.030 does not apply to summary
eviction proceedings (indeed, the whole of NRS 69 applies to judgments only, not
orders), as such Merliss was forced to "join in vacating the attorney's fee award" in
the justice court of $1,500, which is ridiculously disproportionate to the $42,065
awarded by Judge Flanagan in his 6/25/12 DCR 13(3) application/attorney fee
award, ie not a sanction (8/28/12 Order speaks to "previously ignored" "frivolous"
something or other...one's either pregnant or they aren't...ridiculous to attempt to
assert a collateral bar for that which the district court judge admits he never found,
but that's Hill and King in a nutshell...Hill is on the NNDB Board, along with
Echeverria....no comment....), NJCRCP 72, 76 "must not be tried anew" fails to
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recognize Anvui's "de novo review", and while some authority might allow for
using the ROA from below to conduct such "de novo review" (its not a trial de
novo, after all), the application of Gibellini, and some "clearly erroneous" standard
and level of deference to the summary eviction order (ie, not a judgment) of the
justice court
While a judgment in a civil proceeding to which the respondent was a
party may be conclusive that he or she performed particular acts having
particular civil consequences,[20] the result in the civil action is not conclusive
in a disciplinary proceeding in establishing that the respondent's conduct was
such, under the circumstances, as justifies disciplinary action.[21] [FN20]
Tenn.Berke v. Chattanooga Bar Ass'n, 58 Tenn. App. 636, 436 S.W.2d 296
(1968). [FN21] IowaCommittee on Professional Ethics v. Wright, 178 N.W.2d
749 (Iowa 1970). Tenn.Tennessee Bar Ass'n v. Berke, 48 Tenn. App. 140, 344
S.W.2d 567 (1960). So FHE 4 and 5 from 26800 should have been excluded
(particularly where King won his own Motion to Quash Coughlin's subpoenas
insisting one could not question judges about their though processes, only to the
have King do that in question Judges Holmes and Beesley about there (the panel
denied Coughlin the right to call for direct examination Hill, Holmes, and Beesley,
and perhaps Elcano, in addition to failing to (well, SCR 110(3)(4) makes such the
provenance of the chairman of the board, not the panel chair) pursue contempt
proceedings (or report the need for such to a district court judge per SCR 110) upon
a mulittude of individuals and entities failing to comply with Coughlin's SCR 110
subpoenas (reno justice court, RMC defender Keith Loomis, Judges Elliott and
Flanagan and the Clerks and REcord sCustodians of the 2JDC, City of Reno
Marshals....apparently the law doesn't apply to those whom work for the courts in
Washoe County and Reno...and City of Reno Chief Criminal Deputy Dan Wong is
happy to cosign SBN "Clerk of Court" Laura Peters and Pat King's willfull
direlection of duties, including those to maintain filings and transport such along
with the ROA and Supplementals thereto in 62337. par for the reno city attorney's
office, either side of it:
http://www.rgj.com/article/20130701/NEWS/307010033/Reno-happily-defendpolice-sued-custody-death
this is the functional equialent of a motion for mistrial.
So, a traffic citation case is as much akin to the civil proceeding in Berke as
it is to a criminal matter.
Duty of attorney to present favorable evidence
An attorney was under a duty, in disciplinary proceedings, to present any evidence
he deemed favorable
to himself.
Cal.Coviello v. State Bar, 45 Cal. 2d 57, 286 P.2d 357 (1955). Hard to do with
NNDB Panel Chair Echeverria rules everything the respondent seeks to introduce
as evidence (for any variety of purposes, mitigation, impeachment, Claiborne style
demonstrations that the convictions (and "convictions", as NRS 22.030 and NRS
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22.100 "convictions" involve "civil" contempt statutes, and where NRS 199.360
speaks to "criminal contempt" and NRS 22 resides in the "Civil Practice" Title of
NRS, the implication is that such is not criminal in nature, and therefore SCR
111(5) "conviction is conclusive proof of guilt" should not apply (and certainly
should not apply to result in some finding of guilt as to any number of alleged
violatiosn of Rules of Professional Conduct (ie, th 11/30/11 or 2/27/12 summary
contempt orders do not allow for the Panel to abdicate its responsibilities as the
trier of fact, content to skip straight to the "determinin the nature and severity of the
punishment" phases, because, gosh, they are only following the 6/7/12 Order in
60838 and SCR 111(8), ever so closely, right?
Support by admissible evidence (1) That some evidence in a disciplinary
proceeding tried before a judge may have been improperly received would not
require reversal, where the remaining evidence supported a suspension. Ala.In re
McKay, 280 Ala. 174, 191 So. 2d 1 (1966). (2) Any evidence improperly admitted
by the trial court in a disbarment proceeding will be excluded from consideration
by the court of appeals on a trial de novo, and, therefore, any error by the trial court
in admitting and considering incompetent evidence is harmless if there is adequate,
competent evidence in the record upon which to base the trial judge's conclusions
and the concurrence of the court of appeals. Tenn.Berke v. Chattanooga Bar
Ass'n, 58 Tenn. App. 636, 436 S.W.2d 296 (1968).
Problem here is, formal hearing exhibit (FHE) 2 gets tossed because (also,
Exhibit 3, the 4/13/09 divorce case order after trial, which was subsumed by th
6/19/09 Final Decree therein anyways, which not only failed to find misconduct on
Coughlin's part, but the lack of any NCJC Rule 2.15 reporting by family court
judge gardner operates as a collateral bar to the OBC's contentions, however vague
an insufficiently pled, that such laches ridden order supports some finding that this
or that RPC was violated...., one, it was never notice-pled, and two, it fails to
contain a finding, even, of any misconduct on Coughlin's part (reciting the parties
arguments is hardly a "finding", duh, its, actually, beyond duh, its just flat out fraud
by Hill and King to come to the hearing and not only attempt to ambush Coughlin
in the inequity attendant to failing to notice pled the issue (King possess Flanagan's
3/27/12 ORder denyign the landlord (Hill and Baker's ) Second Motion for ORder
to Show cause, so anything in the complaitn vaguely alluding to some "interfering
with the contractor" in some unspecified, vaguely alluded to eviction (which one?
Coughlin was evicted nearly 10 times since August 2011 by a Reno Justice Court
that RPD Sargent Paul Sifre alluded to some level of complicity, apparently,
between the RJC and the RPD with respect to such mass wrongfull evictions of
Coughlin, somethign WCDA DDA Zachary Norman Young, Esq. committed Brady
violations with respect to in RCR12-065630 in failing to turn such over undtil just
day before the start of the 12/11/11 trial therein, to bookend his brady and RPC 3.8
violation sin rCR11-063341 where he made argument and put on testimony that
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was demonstrated to be lies respecting RPD OFficer Nicholas Duralde's

contentions as to what his wife and the other ECOMM dispatchers told him
sufficient to justify his terry stop analysis in rCR2011-063341 (only problems it he
was out of his car, on the scene, unable to read the only message sent by ECOMM
that mentioned any "possible fight" sufficient to buttress Duralde's specious terry
analysis....). Now DDA Amos Stege insists on carrying on a prosecution in
RCR2012-072675 incident to RJC Bailiff Reyes (whose wife file a TPO against
him alleging he is "off his medications" and controlling and violent throwing
Coughlin around in the courthouse on 5/23/13 shortly after Coughlin submitted
written requests for sensitive documents necessary to his work in 61383 and
62337) well outside the suspect "administrative order 2012-01" that the RJC has
now recharacterized as a "criminal complaint" case, which Stege and the WCDA's
Office have no problem, according to Stege, with such usurpation of their executive
functions by their former coworkers at the WCDA''s Office turned judges, incident
to Judge Sferrazza's original 12/20/12 "Administrative Order 2012-01" In Re
Coughlin that mischaracterized the jurisdictional mandate provided by NEv Const 6
Art 6 by remixing "District courts" therein to read "Nevada courts' to get around
that whole distinction between limited and general jurisdiction and justice and
district courts, with such limited jurisdiction justice courts possessing well less
inherent authority, though such Administrative Order did not speak to any such
inherent authority upon which it purported to be premised. WCDA DDA Stege
admitted to Coughlin that he had every intention of continuing to sanction such
actions by the RJC (see NCJC Rule 2.15), even where Bruce Lindsay keeps getting
quick checks (and Lindsay threatened to "rip each of (Coughlin's) limbs)
off....where the justice court admits to directdly appointing Lindsay, despite Canon
2 and those 2006 LA Times receiverships "administrative appointments"
appearances issues dicating that such directing appointing of appointed counsel
may well be per se prohibited...Further, STege admits to not viewing reading
Coughlin's filings as part of his RPC 3.8 duty, and immediately requests the justice
court to begin setting picks for him upon Lindsay showing up just long enough to
collect a check before being granted his withdrawal ("your honor, please limit Mr.
Coughlin's ability to even contact us at the WCDA's Office", no problem
continuing their scattershot style of prosecuting Coughlin, just a little hestitant to
have to deal with all those tireseom attempts at defending himself).
Support by admissible evidence (1) That some evidence in a disciplinary
proceeding tried before a judge may have been improperly received would not
require reversal, where the remaining evidence supported a suspension. Ala.In re
McKay, 280 Ala. 174, 191 So. 2d 1 (1966). (2) Any evidence improperly admitted
by the trial court in a disbarment proceeding will be excluded from consideration
by the court of appeals on a trial de novo, and, therefore, any error by the trial court
in admitting and considering incompetent evidence is harmless if there is adequate,
competent evidence in the record upon which to base the trial judge's conclusions
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and the concurrence of the court of appeals. Tenn.Berke v. Chattanooga Bar

Ass'n, 58 Tenn. App. 636, 436 S.W.2d 296 (1968).
Laches as to FHE 3 the 4/13/09 Order after trial (which resulted in the
WCDA's Office's partner in teh ECR program, WLS Paul Elcano firing Coughlin
(Elcano's daughter has recently been hired by the WCDA's Office as an attorney,
while the district court order in 60302, which found ever more creative ways of
dismissing Coughlin's lawsuit against Elcano (not to mention the fact that the sister
case in 60317 saw Judge Elliott preside over the matter, and fail to recuse himself
or even disclose the fact of his Presidency of CAAW's Executive Board where
CAAW was WLS's co-defendant in the matter...not to be outdone, his successor,
former WCDA's Office Judge Sattler failed to disclose or recuse himself from that
same matter upon taking it over, despite his sitting on WLS's Board...huh?)..
and the FHE 3 2jdc Judge Gardner Order after Trial is laches barred: The
defense of laches may not be available in a disciplinary proceeding,[3] particularly
where the attorney in question contributes to the delay.[4] While staleness in a
charge against an attorney may prevent its being considered,[5] a court will not
refuse to hear charges of unprofessional conduct against an attorney even if a long
period of time has elapsed since the conduct at issue occurred, unless prejudice is
shown.[6] The defense of laches may not be available in a disciplinary proceeding,
[3] particularly where the attorney in question contributes to the delay.[4] While
staleness in a charge against an attorney may prevent its being considered,[5] a
court will not refuse to hear charges of unprofessional conduct against an attorney
even if a long period of time has elapsed since the conduct at issue occurred, unless
prejudice is shown.[6] [FN5] Kan.In re Ratner, 194 Kan. 362, 399 P.2d 865
(1965). Tenn.Tennessee Bar Ass'n v. Berke, 48 Tenn. App. 140, 344 S.W.2d 567
(1960). [FN6] Cal.Yokozeki v. State Bar, 11 Cal. 3d 436, 113 Cal. Rptr. 602,
521 P.2d 858 (1974). Ill.In re Bossov, 60 Ill. 2d 439, 328 N.E.2d 309 (1975).
N.J.In re Sarbone, 63 N.J. 94, 304 A.2d 734 (1973). Pa.Office of Disciplinary
Counsel v. Davis, 532 Pa. 22, 614 A.2d 1116 (1992), reinstatement granted, 543
Pa. 318, 671 A.2d 222 (1996). Vt.In re Wright, 131 Vt. 473, 310 A.2d 1, 92
A.L.R.3d 639 (1973).
22
23
The assertions herein are made, pursuant to NRS 53.045 under penalty of perjry
24
25
and based upon my first hand knowledge of these matters, except to perhaps a very,
26
very few aspects of a a very few assertions which are made upon information and
27
belief.\
28
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Also, under Sexton in Nevada, the SBN's Complaint had to be "verified" by

a person, not an entity, like the SBN, and Asst. Bar Counsel King is unable to
provide such verification lackign first hand knowledge, and his failure to offer
anything into evidence to in any way indicate just what Hill's alleged written
grievance entailed must operate to completely fail to establish any sort of notice
pleading of anything relative to hill or the summary eviction or appeal thereof in
8
9
10
11
03628 (see 61383), particularly where at the time of craftin his 8/23/12 Complaint,
King had obviously come to the decision that he needed to disenfect his prosecution
of Richard G. Hill, Esq's reputation and ways, only problem is, Coughlin had beat
12
13
down every last insipid accustation against him by the various peopel involved here
14
(and you they know who they are) that King was going to have to go to the dance
15
alone, so at the last minute he slummed it over to Hill's office, and lucked out in
16
17
getting NVB Judge Beesley and WLS's Elcano to come down to the formal hearing
18
(well, Beesley phoned it in, which made it hard to cross examine him or
19
authenticate any documents, in addition to the fact that his testimony was only
20
constructively noticed the day prior to the hearing, somethign King pulled in the In
21
22
Re Boles case too, but at least Elcano's testimony completely contradicted his
23
statement in his various suspension/termination letters to Coughlin vis a vis
24
Coughlin's tenure with WLS, as a domestic violence attorney in 2007-2009. so
25
26
there's that, which is nice, but Elcano and WLS obstructionist tactics clearly
27
develop the prejudice in support of the laches defense, particularly with respect to
28
their preventing Coughlin from accessing excuplatory materials vis a vis his work
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with then client Joshi and the effect her own level of organization and approach to
the alimony/community property issues involved (see 53833 and 54844) had as to
3
4
the 3/12/09 and 3/17/09 trial in that matter (though WLS"s Breckenridges' ordering
the JAVS cd recording of Coughlin's 3/10/09 TPO hearing adovcacy on behalf of a
male victim of domestic violence and the aghast horror displayed by some the
2JDC CAAW run TPO Office advocate (whom was , apparently, advocating on
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behalf of the alleged abuser? well, perhaps dueling TPOs) whee Breckenridge had
such copy of the record, as revealed in the docket, picked up on 4/10/09...and the
$1,000 attorney fee NRS 7.085 award was entered 4/13/09, though, strangely, WLS
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just rode the prestige train of that short lived "sanction" (it appears the 6/19/09
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Final Decree admits Coughlin was right in ultimately awarding Coughlin's client
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some alimony, so...which is it, Coughlin was vexatious in arguing for alimony
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(even citing to an alr supporting his contention that a duty is accord greater
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protection than a debt, especially third party unsecured credit card debt to which the
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opposing spouse was sole signatory (its hardly fraud for Coughlin to recognize the
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realites of securitization and "fail" to demand his client to assist John Springgate in
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resucing his client from the decision to maintain all that "power and control" over
his stash of credit cards during the marriage, no?).
The criminal trespass conviction the subject of 61901's SCR 111(4) Petition
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is so facially invalid as to provide absolutely no proof of guilt, even. Really, it
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provides a basis for any judge reading this to report RMC Judge Gardner under a
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variety of basis pursuant to NCJC Rule 2.15, in addition to Reno City Attorney
Hazlett-Stevens for the many instances of misconduct he engaged in as well.
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THE COURT (RMC Judge William Gardner, the brother of 2JDC Judge
Linda Gardner, co-grievants against Coughlin in NG12-0435, see also
Coughlin's Petition for Writ of Mandamus against 2JDC Judge L. Gardner
in 53833 and 54844, noting Judge W. Garnder's failure to divulge the
familial relation until Coughlin brought it up, even where Judge W.
Gardner subsequently admitted to having been passed by his sister, Judge
L. Garnder, her 4/13/09 Order After Trial (FHE 3), which he then passed
around to all the fellow RMC Judges, with Judge Nash Holmes including
such in her 3/14/12 "box of materials" that she had deliever to the SBN,
stamped received "3/14/12", but for which Pat King and Laura Peters
made a concious, willful decision to attempt to mislead in this process by
then affixing a date received stamping on the 4/13/09 Order of "3/15/09",
manipulating on several occasions with interlineations the "5" in the "15"
of "3/15/12", then attempting to cover up the multiple improprieties and
conflicts of interest that arisen incident thereto subsequently): No, we're
done. That's it. You know how it works. The prosecutor goes first, you go
second, they finish up. They have the burden of proof. That's it. No more
argument. That's very clear. Alright, let me just make a couple comments
here. Both parties have identified - there's numerous issues here. The big
issue is the warning. Under our statute, both 207.200, and RMC 810.0lD,
the party - it doesn't even talk about the vex or annoy, the party who goes
or remains, either one, Mr. Hazlett-Stevens pointed that out, into any
building after being warned by the owner or the occupant, and the owners
and occupants can be agents with ostensible, actual or implied authority,
and certainly Mr. Hill and Mr. Baker had that authority. That's clearly
established by the evidence. I f you go back onto that property after having
been warned, you are guilty of a trespass, and I guess the question is what
is a warning? And unlike many areas in the law, it's not defined under the
trespassing ordinance, or the trespassing statute. It's a notice requirement.
And the real issue in this case - there's a number of issues, but I do there's no question, Mr. Coughlin, that you were on property that belonged
to another at 1 2 1 River Rock on November 1 3th, and that's in the City of
Reno, and there's no question about that. The question is, what type of
warning did you have? You had so many types of warnings, it's hard to
figure out which one is the best. Page - 148- First of all, the first warning and by the way, when we talk about warning here, when you look at the
statute under state law or the Municipal Code, both the Legislature and the
City Council have given some guidance that indicate for some occupants
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they've got sufficient warning if the property is posted in a conspicuous

manner in intervals of not less than 700 feet. So, something as broad as
that is sufficient warning under our trespass statute. And the statute goes
on to say it's prima facia evidence of a trespass if the property is posted or
fenced on a property. That's prima facia. So, the question is did you have
notice? Did you have some sort of warning not to be on that property, and
here's what the Court has determined. You received some kind of mild
notice, and a warning when you were given a 5-day notice and a 30-day
notice. Probably in and of itself, probably not enough to support a
trespassing finding. But at two separate hearings in October of 20 1 1 , on
the 1 3th and the 25th, where you were present in Court, there can be no
question that the issue is whether or not the owner of that property wanted
you on that property more, or should you be on that property. Then, right
in open Court, Judge Sferrazza evicted you from the property. He
followed that up with a written Eviction Decision and Order clearly
indicating that you were evicted, and that the stay was denied. So, I don't
know what - that would be what I call super notice, or super warning,
coming from the Judge himself. Page -149- It's often the situation we
never get that kind of warning. So not only did you get a warning, you got
an Order fr om the Judge that you were evicted from the property. That
was then posted on the front door of a property that you had been in and
returned to on November pt, 2012 (sic) the day it was posted. There was a
copy left on a coffee table later at some point in time after Mr. Hill had
entered the property and realized that there had been someone in the
property. You were emailed. Whether or not you received that email, I
don't know, but there was at least another attempt to email you at an
address to which you had responded, and to an address, an email address,
to which you had responded that you would not accept emails on your - as
notice. Finally, you were mailed a Notice of Entry o f Judgment to 1 2 1
River Rock. I'm sure - I would guess you didn't get that, but the parties
here did everything possible to provide you notice, to provide you
warning, and you had actual notice, you had constructive notice, that you
shouldn't be on that property. The State of Nevada and the Supreme Court
decision which Mr. Hazlett-Stevens quoted this morning and I have in
front of me, State v. McNichols, \ 06 Nev. 6 5 1 , clearly, clearly, says that
after someone has been evicted, a subsequent reentry in the property is a
trespass. A trespass reentry is what the Supreme Court called it, did not
create an objective of that expectation of privacy. So, that's just the first
section. That's been proved beyond any doubt. There's no question that
portion of the statute has been proved. Page -1 50- And I would also
submit that Mr. Hazlett-Stevens is correct. And after going back on that
property numerous occasions, setting up a residence with your pet in the
basement, constitutes a separate basis independent from the notice
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requirement that you went on to that property with the intent to vex or
annoy the owner. So, under any theory set fo rth by the City, I find you
guilty of the charge of Trespassing. We can proceed to sentencing. Mr.
Hazlett-Stevens?..."
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Its instructive to compare the summary eviction order as rendered in that summary
eviction proceeding (see 61383) from which the above criminal trespass conviction
stemmed, in the Reno Justice Court such NRS 40.253 proceeding was, involving
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Richard G. Hill, Esq.'s law firm, with his then associate Casey D. Baker, Esq.
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appearing for the landlord Merliss for the 121 River Rock former home law office
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at which Coughlin was arrested for criminal trespass:
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Judge: me I the defendant has the rights to make an argument you have a right
to the argument stance tell you what I'm going to do until I hear the arguments
Plaintiff: well I think customarily it's the defendant gets to go plaintiff gets no
less
Judge: one actually is you are burdened so sure burdened so it's his burden on
the retaliatory part of it but it sure burdened on the eviction itself
Plaintiff: okay thank you Your Honor with respect to plaintiff's burden the
plaintiffs plaintiff has introduced evidence that the lease terminated by its terms
at the end of February 2011 thereafter Mr. Coughlin was a month-to-month
tenant pursuant to NRS 40.251 or Coughlin was properly served with a no
cause termination notice to vacate on August 22 as exhibit B exhibit C is the
five day notice of unlawful detainer based on Mr. Coughlin's failure to vacate
the premises after his tenancy was terminated the affidavits and testimony
presented here today and form conforms with the statute conformed with the
form promulgated by the Nevada Supreme Court and with the form provided
by this court plaintiff has met its burden to show that Mr. Coughlin was a
month to month tenant in August 2011 when the termination notice was
properly served the eviction notice was properly served Mr. Coughlin now
bears the burden Your Honor it shifts to him to present and substantiate a legal
defense now the legal standard for summary judgment in Nevada which is what
were doing dealing with here is that Mr. Coughlin must again transcend his
allegations of his pleadings and show by admissible evidence that there is a
disputed issue of fact that he has a legal defense as a matter of law he has not
done that Your Honor he has identified only a couple of things and despite
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great latitude by the courts to to present evidence and establishes legal defense
he has failed to do so NRS 118A.510 that is the retaliatory eviction statutes
now Mr. Coughlin chose to focus on subsection 1B a complaint that he
complained in good faith to the landlord or law enforcement agency for a
violation of this chapter or of a specific statute that imposes a criminal penalty
we talked about this at length today Mr. Coughlin identified one e-mail which
he admitted on a cross examination does not identify a specific statute that
imposes a criminal penalty and I think we need to be extremely clear. With this
statute the statute requires the tenant has complaint in good faith to the landlord
of a specific statute that imposes a criminal liability he did not do that he did
not identify a statute he alleged something about some landscapers damaged
the carpet he's read on the lawn that does not satisfy the statute Your Honor
moving down the statute to sub EEE the tenant has instituted or defended
against judicial or administrative proceeding or arbitration in which the tenant
raised an issue of compliance with the requirements of this chapter respecting
habitability of dwelling its. That cannot be. He notices the first no cause
termination notice to vacate exhibit B was served on August 22, 2011 Mr.
Coughlin did not institute or defendant any proceeding on any habitability
issues until after those notices were provided Dr. Merliss can't retaliate for
something that is going to happen in the future that has not happened yet Mr.
Coughlin cannot proceed under that statute to the extent Mr. Coughlin is
complaining about this small business first of all the may e-mail in Exhibit 8
does not qualify in or satisfied the statutes regarding notice to a landlord about
a habitability issues and Dr. Merliss drove this point home when he testified
that he didn't understand what Mr. Coughlin was asking for I mean if you look
through these e-mails what Mr. Coughlin does is he identifies something he
claims is some sort of problem and then he tries to bargain some money off of
the rent for he has not produced to mean he does not say in then they e-mail
this is my notice to you under NRS 118 A .355 I am going to withhold this rent
unless you fix this he just says we've got this issue he is later come for the court
and he has told it that he fixed it to the tune of $500 well he is not produced in
receipt is not produced a bit or invoice from contractor he hasn't produced
anything furthermore Your Honor under NRS 118 A355 so to the tenant may
not proceed under this section if the landlord's inability to adequately remedy
the failure or use his best efforts to remedy the failure within 14 days is due to
the tenant's refusal to allow lawful access to dwelling unit as required by the
rental agreement or this chapter Dr. Merliss testified that he tried to send Zach
Nash out there he tried to send Randy Fisher the handyman out there they
weren't allowed in nine Your Honor if the court is I have this gentleman ready
to testify sooner to that effect nevertheless Mr. Coughlin he cannot proceed
under the statute he has no defense if he doesn't let them in to fix. What is more
Your Honor Mr. Coughlin wants to focus on this 48 hour notice under the lease
if Mr. Coughlin is the one making a complaint the complaints about these
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alleged it dishes came all being one of them which we have no proof of that
there is more than the house but let's just say for arguments sake he makes the
complaint then he is waived the right to hide behind the notice provision of the
lease or at the very least should be a stop from asserting it it's his request that's
what were running into and that's what we see here on exhibits a through I
Your Honor here. He here he is Mr. Coughlin makes a complaint about mold
and insulation and here is Dr. Merliss immediately saying hey I'll get
somebody out there will get this fixed note lookup statutory notice NRS
inspection landlord tenant. Mr. Coughlin should be a stop from the from hiding
behind the notice provision in the lease with respect to Randy Fisher Your
Honor I was not able to put him on the stand today but Mr. Coughlin was
provided with substantial notice more than 48 hours for Mr. Fisher to go
inspect the window issue there was an electrical lied that's Mr. Coughlin
identified. Mr. Coughlin cannot proceed under the retaliatory under the habit to
excuse me under the habitability statutes if he doesn't allow lawful access to the
property in any event Your Honor nothing that Mr. Coughlin as not even made
an attempt much less a showing to to have any of the issues that he identified as
habitability type issues the Windows the stairs the weeds the mold he is not
made any attempt to have those fit under the habitability statute
Judge: well I tend to agree that under subsection see or EM sorry of 118A.510
one he he has to have instituted or defended against a judicial or administrative
proceeding based on habitability which that is different than complaining about
habitability which he can interests through a separate lawsuit
Plaintiff: yes
Judge: so I simply Simply complaining about habitability issues does not
satisfy the retaliatory conduct provision
Plaintiff: that is exactly right Your Honor and in any event Mr. Coughlin has
not shown as is his burden to do that any of his complaints were in good faith
under that statute or that Dr. Merliss acted in a retaliatory fashion Dr. Merliss
said I didn't evict you because of these things you didn't pay your rent we tried
to help you you would let us that's not retaliation Your Honor he's Mr.
Coughlin is attempting to make logical leaps between him threatening to sue
for retaliation and Dr. Merle is hiring our office that that is you know per se
retaliatory well what are you supposed to do when you're tenant threatens to
sue you you gotta get a lawyer it's just simply not relevant in the logical leave
is not their Sir. Your Honor the only issue before the court today his possession
of the property in the court notice this and we've gone over this Mr. Coughlin
has gone on and on and on about potential claims
Coughlin Your Honor it's been 5 min.
Judge: they have 5 min. are up so go ahead Mr. Coughlin
Coughlin thank you Your Honor just sit at the outset that I know I've been
critical of Mr. Plaintiff: at some point throughout this but I do think Dr. Merle
us is gotten his money's worth is gotten some pretty solid litigating in most
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respects Your Honor I feel pretty strongly about this case but I could see where
possibly some other people would see other people feels different ways I think
it has a lot to do with maybe what you want this date in the CD to be if you
wanted to be a one where the people who aren't that powerful don't have much
money but who demands that the law be followed or if you want to be a
scarcity like that I guess you would rule one way but if you're going to ruled
the other way it seems to me that you would have to make some torturous
twists and turning her to find that Dr. Merliss all the sudden doesn't get his rent
on August 11 he wakes up inspect the country August 11, 2011 notices his
mortgage check hasn't been coming in every day on August 11, 2011 an e-mail
saying hey what's up with this I want my money I don't want to hear about your
complaints I want my money you're not gonna give me your money will guess
what I'm sending to people down there right now one today and one tomorrow
oh you want your notice guess what single further communications to my
attorney see how you like that kick you out on your ass in a big you and that's
how it comes across to me and that's exactly what the legislature intended to
prevent with 118 A.510. It has been educational to me an interesting certainly
to try to present some of these arguments justice court ruled Las Vegas 44
certainly have good refer to your vast breadth of your experience and its
approach in your courtroom there are considering your longest tenured mayor
Reno's history
Judge: surgeon-escrow any points with so
Defendant: on about try to score points Your Honor am trying to validate to
myself that someone is bringing to bear to his decision on this ability to see the
whole field. What I'm worried about is what this does to we want to be Las
Vegas do we want to be rule 44 Las Vegas where is such a transient community
people are handing out prostitution pamphlets got all this super Las Vegas type
stuff going on and so they had to enact rule 44 to allow them to do certain
things to deal with the craziness Reno's not Las Vegas Reno is months the most
well read cities in the country I went to law school Las Vegas unfamiliar with
Las Vegas I'm from Reno unfamiliar with Reno investing in tenants rights and I
have a background legal services I work for Washoe legal services they have a
landlord tenant section there I didn't work and I worked as a domestic violence
attorney for a while but investing in tenants rights is an investment in the
community and that something that this community needs at this but thank you
Your Honor;
Judge: alright I am prepared to rule and I do first of all I do want to say I
acknowledge the defendant's argument with respect to rule 44 And Justice
Court in Las Vegas and I have been unable to find a similar rule with
respect to Reno justice court so my decision with respect to the escrow
money will be separate from this but I do find number one that the landlord
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met its burden of proof with respect to unlawful detainer that the exhibits and
the testimony submitted to the court specifically exhibit B the tenant was
notified of the no cause termination in a timely manner and with proper service
exhibit C the tenant was notified five day notice of unlawful detainer and
compliance with the statute and with proper service and therefore the defendant
was an unlawful detainer effective as of the date of the beginning of these
proceedings which was on artists I'm sorry well certainly by October 10
when the landlord's affidavit was filed but certainly today without question
further I have considered the tenant's arguments with respect to it retaliation
specifically under 118A.510 with respect to subsection "a" although the
tenant has complained about violations of building housing or health code
I do not find there is any evidence that he made said complaint to a
government agency charged with responsibility for enforcement of that
code.
Second, with respect to the subsection "b", although defendant did present
evidence today of destruction of carpet and alleged that it was a crime under
NRS 206.330 205.270 206.040 there is no evidence that said complaint cited a
specific statute to the landlord but rather a general complaint about the
structure of this carpet and therefore I find it that subsection of the statute
was not satisfied as will him and I further find that even if it was even if the
landlord knew what you're trying to say the landlord did not retaliate
against you for that the landlord eviction was based on nonpayment of
rent not your complaining of your destruction of carpet and I also at the
prior court proceeding I made findings with respect to the damages and
those damages in total were $2725 and that was the outside number and so I
found that you owed at least $2275 even giving you the benefit of all the
doubts and today there was evidence presented that the stairs were only $75 I
gave you $1250 for the stairs credit there was an e-mail presented today that
indicated that it's all you are asking for was $75.
Defendant: may I preserve my objection for settlement offers being admitted
Judge: will you can reserve your objection preservative I am making my
findings are not of
Judge: and then with respect to the noxious weeds first of all I find that that
is not a habitability issue second of all I find that under the lease you were
required to maintain the lawn and third this is under subsection "a", you didn't
make a complaint the governmental agency and there is no evidence that you
did with respect to the noxious weeds, as to the moldy insulation I do find that
that could be a habitability issue clearly could be. However, again under
118A.510 subsection to make it retaliatory it has to be have been presented
either in action suit. By you or defendant against you against by you and the
judicial administrative proceeding or arbitration in which the tenant raised
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the issue of compliance with the requirements of habitability and since you
didn't raise this issue until after the landlord had in fact filed the complaint I
find that that it did not violate the habitability statute did not violate the
retaliatory eviction statute for all those reasons I find that the defense of
retaliation does not meet the requirements of chapter 40 specifically one second
here specifically 40.253 subsections 6 The Court determines that there is not a
legal defense to the alleged unlawful detainer and therefore the court to this
grant the eviction with respect to the money in escrow the court finds that that
money is to the landlord however I am not going to order that today since the
defendant is made argument that the court does not have enough fact a proper
rule with respect to escrow as similar to Las Vegas justice court rule 44 and
therefore since the tenant still has the ability to appeal in this matter I will give
him 10 days to file a proper appeal which is the statutory time friend and if
he does so that money will be used to satisfy his appeal bond in this matter
if he does not do so then at that time a proper motion can be made by
plaintiff's counsel on this matter the eviction will be effective October 31 at 5
PM.
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Defendant: Your Honor is the IFP status bearing on the appeal or is that a
whole new IFP bond?
Judge: I denied your IFP on the appeal but I am not sure if I actually did it in
writing Sir
Defendant: but you granted to the instant case
Judge: I believe I don't recall
Plaintiff: but you denied it for the appeal?
Judge: well the thing is there is enough money deposited that you don't need
an IFP Sir
Plaintiff: it's all the money I have my name
Judge: while it may be but I am not releasing it to you but I am allowing you
to use it to satisfy the appeal bond in this case which would normally be three
months rent are I
Defendant: not double?
Judge: okay I will grant your IFP for this appeal if you go forward but the
appeal you filed was not a proper appeal Sir
Defendant: okay at that point I get the rent escrow back?
Judge: no you don't get rent that what happens is it's gonna satisfy the appeal
bond pending your appeal to the District Court
Defendant: so the the appeal bond toward the IFP doesn't apply to it
Judge: no. The of appeal bond a separate the IFP's for the filing fee that's all
it's good for
Defendant: sometimes it covers depositions and
Judge: well it's not been a cover in this case are of Artie told you
Defendant: and that's your ruling orders that
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Judge: dying embers because it would be in District Court?

Judge: well you can argue District Court but it will be my ruling that you
have to post appeal bond post an appeal bond and I will since there's some
question about the money and the escrow I am going to order that it satisfied
the appeal bond in this case
Defendant: on believe I filed an interlocutory appeal about the escrow
Judge: yeah I know you did but so far as I'm concerned that was not a valid
appeal
Defendant: okay
Judge: but you can go forward with that appeal that's up to you are not going
to advise you
Defendant: do we adress the motion to stay here today Your Honor?
Judge: the motion to what question mark
Defendant: the motion to stay Your Honor
Judge: the motion to dismiss is denied writing get a stay from the District
Court if you want
Defendant: okay maybe I don't want to address the motion the state today if
that's all the inquiry that's going to be too voted to it devoted to it
Judge: I have read during the recess your briefs and stuff but I'm denying a
motion to stay Richard Brisson stuff I'm denying a motion to stay so it's clear
Plaintiff: Your Honor I have two quick points with respect to an appeal bond
Dr. Merliss is entitled to an award of fees under NRS 40.254 sub three under
NRS 40.254 sub three
Judge: what you can prepare proper memorandum of costs and fees
Plaintiff: yes or we will
Defendant: a prevailing party or in some egregious circumstances you get
these?
Plaintiff: it's in the statute
Judge: it's in the statute under chapter 40 in fact they can get three times
the rent too
Defendant: for when the nerve because somebody just
Judge: they could you need to read the statute
Plaintiff: my point in bringing that up Your Honor is that we will be asking for
that those fees be considered part of the appeal bond in addition to the money
already with the court I mean Mr. you seen the briefs Dr. Merliss has incurred
substantial amount of fees
Judge: well I understand but I don't even have your memorandum of costs and
fees
Plaintiff: we will make the motion
Judge: you make the proper motion and I will decide it
Plaintiff: thank you Your Honor
Judge: it doesn't have to be decided today
Plaintiff: that's true Your Honor
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Judge: and in the meantime the money's not going anywhere nor do I believe
this defendant is going to come up with more money
Plaintiff: Your Honor we would like to ask the court for permission to inspect
the property prior to October 31 we've attempted to inspect in the past but we
are very concerned about the property being damaged between now and then
Judge: I have already told you that I would allow in order to inspect the
property allowing order to inspect the property and what is your position on
that as to a time when it could be accommodated Sir newly cough and you said
my position on the time to accommodate that and let
Judge: yeah
Defendant: this emergency need to inspect it because it's good to be emptied in
six days my position is that it shocks the conscience
Judge: will okay I will grant the order 48 hours from today
Plaintiff: 48 hours from today we can and specs are
Judge: yes
Defendant: and I just like to preserve for the appeal all the egregious conduct
by the process server and all these others other matters
Judge: what you can preserve everything you want Sir what you can preserve
everything you want Sir
Plaintiff: shall I present prepare an order court
Judge: you can prepare the order
Plaintiff: I mean for the entire thing
Judge: you can prepare findings of fact and conclusions of law and a
judgment if you wish
Defendant: can I Your Honor?
Judge: yes you get if you want to do it and he can look at it but I would
suggest that the plaintiff prepared and submitted to you for comments
Defendant: well he is the one who got one years rent to litigate this case so
Judge: one years rent?
Bait Coughlin
Plaintiff: and understand either Surrey
Defendant: yeah 900x12 months
Plaintiff: all prepare the order and submit it Coughlin for his review
Judge: okay what you need to get it done you can both prepare orders and all
picked the one I want to sign
Plaintiff: you'll have by tomorrow answer
Judge: when will years be in Mr. Coughlin when will yours be in Mr. Coughlin
Defendant: well I will have to look at what records on the Your Honor records
on that Your Honor
Judge: well if it's I'm going to give you today is Wednesday it will have to be
done by Thursday because I will be signing an order on Thursday no later
than noon on Thursday
Plaintiff: noon on Thursday yes or
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Judge: alright y'all have a good day

Plaintiff: thank you
Defendant: thank you sir."
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Its quite clear that the summary eviction order as rendered from the bench by
justice court Judge Sferrazza on 10/27/11 departs markedly from the prosed
Order that Hill's associate Baker was able to get Judge Sferrazza to sign, but
regardless, Judge Sferrazza's orders/rulings from rendered from the bench at the
conclusion of the 11/7/11 hearing in the justice court amended such 10/27/11
FOFCOLOSE, as well.
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Judge Sferrazza's Findings of Fact, Conclusions of Law, and Order for Summary
Eviction of 10/27/11, reads: "FINDINGS OF FACT, CONCLUSIONS OF LAW,
AND ORDER FOR SUMMARY EVICTION
This matter having come on regularly for an evidentiary hearing
pursuant to NRS 40.254 and NRS 40.253(6) on October 13, 2011, and
continued on October 25, 2011, before the Honorable Peter J. Sferrazza, sitting
without a jury; the plaintiff/landlord, Matt Merliss; ("Merliss"), having been
present, and represented by counsel, Richard G. Hill, Chartered and Casey D.
Baker, Esq., and defendant/tenant, Zachary Barker Coughlin, Esq. ("Coughlin"),
having been present and having proceeded in proper person; the parties having
offered evidence, called witnesses and having offered argument; the matter having
been submitted to the Court for a decision; the Court being fully informed in the
premises and good cause appearing therefor; the Court herewith enters its findings
of fact, conclusions of law and order for summary eviction:
FINDINGS OF FACT
The Court finds the following facts:
1. Merliss is the owner of the real property located at 121 River Rock, Reno,
Nevada (the "Property").
2. The tenancy at issue commenced on March 1, 2010, and was for a term of 12
months.
3. The rental agreement terminated by its terms on February 28, 2011. Thereafter,
Coughlin became a month to month tenant pursuant to NRS 118A.470 and
paragraph 3 of the parties' rental agreement.
4. Coughlin became subject to the provisions of NRS 40.251 to 40.2516,
inclusive, at the end of the stated term of the rental agreement, whereupon he
became a monthto-month tenant, as noted above.
5. On August 22, 2011, Merliss properly and lawfully terminated Coughlin's
month-to-month tenancy pursuant to NRS 40.251, by serving the statutory NoCause Termination Notice to Vacate NRS 40.251(1) upon him, which notice was
admitted into evidence at the hearing. The court specifically finds that service of
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that notice was proper pursuant to, and for all purposes contemplated under, NRS
40.280.
6. Coughlin failed to vacate the Property within 30 calendar days of being served
with the notice to vacate, and was therefore in unlawful detainer of the Property as
of September 27, 2011, at the latest.
7. On September 27, 2011, Merliss properly served Coughlin with a Five-Day
Notice of Unlawful Detainer For Failure to Vacate Rental Unit -NRS 40.251
(No-Cause Termination) and Notice of Summary Eviction -NRS 40.254, which
notice was admitted into evidence at the hearing. The court specifically finds
that service of that notice was proper pursuant to, and for all purposes
contemplated under, NRS 40.280.
8. Merliss' claim for relief of possession of the premises was authorized by law.
9. Coughlin alleged, as a legal defense to the summary eviction, retaliatory conduct
by Merliss under various subsections of NRS 118A.510. Coughlin's alleged defense
was further based, in part, on what he identified as "habitability" issues, and his
alleged complaints regarding same. Coughlin further alleged that Merliss acted in a
discriminatory manner toward him based on Coughlin's race, national origin, and
sex.
10. The court finds that Coughlin failed to present any evidence that Merliss acted
in any prohibited, discriminatory, or retaliatory fashion as alleged by Coughlin, or
otherwise. Specifically, the court finds:
10.1. Coughlin failed to present any evidence that he "complained in good
faith of a violation of a building, housing or health code applicable to the premises
and affecting health or safety to a governmental agency charged with the
responsibility for the enforcement of that code" as required by NRS 118A.510(1)
(a).
10.2. Coughlin failed to present any evidence that he "complained in good faith
to the landlord or a law enforcement agency of a violation of [NRS Chapter
118A] or of a specific statute that imposes a criminal penalty" as required by
NRS 118A.510(1)(b)
10.3 Coughlin failed to present any evidence that prior to being served with
the referenced termination and eviction notices, Coughlin had "instituted or
defended against a judicial or administrative proceeding or arbitration in which [he]
raised an issue of compliance with the requirements of [NRS Chapter 118A]
respecting the habitability of dwelling units" as required by NRS 118A.510(1)(e).
10.4 Coughlin failed to present any evidence that he had "complained in
good faith to the landlord, a government agency, an attorney, a fair housing agency
or any other appropriate body of a violation of NRS 118.010 to 118.120, inclusive,
or the Fair Housing Act of 1968, 42 U.S.C. 3601 et seq., or ha[d] otherwise
exercised rights which are guaranteed or protected under those laws" as required by
NRS 118A.510(1)(g).
11. Coughlin failed to present any evidence that the Property was at any time not
habitable, as that term is defined in NRS 118A.290, or otherwise, with respect to
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any of the alleged deficiencies identified by him. Those alleged, but unproven,
deficiencies included, but were not limited to, the front and back steps, any broken
window, any alleged mold, any falling insulation, the garbage disposal, and any
weeds on the Property.
11.1. With respect to any weeds on the Property, the court further
specifically finds that the maintenance of the surrounding grounds, including weed
control, was the sole responsibility of Coughlin under paragraph 22 of the parties'
rental agreement.
12. Coughlin failed to present any evidence that he complied, or that Merliss failed
to comply, with any requirement set forth in NRS 118A.355 and NRS 118A.360,
which statutes address the withholding of rent for alleged "habitability" issues.
12.1. As such, the court finds that Coughlin was not entitled to withhold
any rent based on any alleged "habitability" issue, or otherwise, and that all
sums heretofore deposited by Coughlin pursuant to the Court's order dated
October 13, 2011, rightfully belong to Merliss as and for past due rent.
13. If any finding of fact above is, in fact, a conclusion of law, it should be regarded
as such, and its validity should not be affected by where in this decision it is
located.
CONCLUSIONS OF LAW
The Court concludes the following as the controlling law in this case:
1. The Court has jurisdiction over the parties and subject matter of this
case. Venue is appropriate in this court.
2. The ultimate issue before the court at the referenced hearing was the right
of the landlord, Merliss, to immediate possession of the Property. NRS 40.254.
NRS 40.253(6).
3. The purpose of the hearing was to "determine the truthfulness and
sufficiency of the tenant's and the landlord's affidavits," to determine whether
there is any "legal defense as to the alleged unlawful detainer," and whether
"the tenant is guilty of an unlawful detainer". NRS 40.253(6).
5. "[A]n order granting summary eviction under NRS 40.253(6) should be
reviewed on appeal based upon the standard for review of an order granting
summary judgment under NRCP 56 because these proceedings are analogous."
Anvui, LLC v. C.L. Dragon, LLC, 123 Nev. 212, 215, 163 P.3d 405 (2007).
6. "To successfully defend against a summary judgment motion, the
nonmoving party must transcend the pleadings and, by affidavit or other
admissible evidence, introduce specific facts that show a genuine issue of material
fact." Torrealba v. Kesmilis, 124 Nev. 95, 178 P.3d 716 (2008).
7. Coughlin failed to show that any genuine issue of material fact remains
for trial. As such, Coughlin failed to meet his burden of proof to establish any legal
defense to the summary eviction. Anvui. Torrealba.
8. As no issues of fact had yet been presented to the court to warrant a
trial, Coughlin was not entitled to have the summary eviction hearing heard by
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ajury. NJCRCP 38. NJCRCP 39. NRS 40.310. Any demand by Coughlin for a jury
was untimely, in any event. NJCRCP 38.
9. Pursuant to NRS 40.253(6), Merliss is entitled to immediate possession of
the property.
ORDER FOR SUMMARY EVICTION
Landlord, MATT MERLISS, having applied by Affidavit for an Order
seeking summary eviction of the above-named Tenant and it appearing from the
record on file herein that the statutory requirements have been met and that the
Tenant, after notice, unlawfully detains and withholds the rental unit, and the Court
being fully advised and finding good cause, therefore,
IT IS HEREBY ORDERED, ADJUDGED AND DECREED AS
FOLLOWS:
That the sheriff/constable of Reno Township, or one of their duly authorized
agents be, and hereby is, directed to remove each and every person found upon
the rental unit at 121 River Rock, Reno, Washoe County, Nevada, by no earlier
than October 31, 2011 at 5 pm. Landlord is hereby awarded the right of possession
of the premises.
IT IS HEREBY FURTHER ORDERED, ADJUDGED AND DECREED
AS FOLLOWS:
The sums currently on deposit with the Court, in the amount of $2,275.00,
are the property of the landlord, Matt Merliss, but shall not be immediately
released to him. Instead, those sums shall serve as Coughlin's security for costs on
appeal, pursuant to NJCRCP 73, in the event Coughlin timely and properly appeals
this order. In the event Coughlin fails to timely and properly appeal this order,
those sums shall be immediately released to Merliss or his counsel of record.
These sums shall not, in any event, operate to stay enforcement of this order and
the surrender of the right of Coughlin to possess the Property. Nothing in this
order shall prevent this court or an appellate court from releasing the deposited
funds to Merliss or his counsel prior to or after any appeal is perfected, or from
increasing the amount of any security to be posted by Coughlin for any reason, or
both, either upon its own motion or upon motion by Merliss.
IT IS SO ORDERED."
he landlord may not, in retaliation, terminate a tenancy, refuse to renew a
tenancy, increase rent or decrease essential items or services required by the
rental agreement or this chapter, or bring or threaten to bring an action for
possession if:
Dated this 7 2 13
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electronically
Zach Coughlin, Esq.
Appellant
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Proof of Service:
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foregoing document to all registered efilers, and to those whom are not I placed a
true and correct copy of the foregoing document in the usps mail on this date:
David Clark via Eflex
mailed to Pat King at Bar's Northern Office, EPO permitting
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DATED THIS: Dated thi 7 2 13
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/s/ Zach Coughlin

Zach Coughlin
Appellant
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INDEX TO EXHIBITS:
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request for Lindsay's fax to RJC Clifton of 3/5/13

RE: Notice of Appearances filed in which cases?
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 7/17/13 2:53 PM
To: Robert Lindsay (rbrucelindsaylaw@yahoo.com)
21 attachments
7 8 13 6 19 13 stamped first pt ex 1 in 61383 0204 65630 71437
63341 67980 72675 Notice Motion Request global resolution
handwritten on dockets.pdf (2.1 MB) , 1 11 13 correct formatting 0204
067980 1048 12420 email to Lindsay RBL.pdf (292.1 KB) , 1 17 13
0204 email to Lindsay 067980.pdf (744.0 KB) , 1 17 13 email that
was also faxed to fbl@robertbrucelindsay.com Lindsay 0204
067980.pdf (159.6 KB) , 1 18 13 to 3 15 13 emails between Coughlin
and Lindsay 0204 AO12-01 063341 067980 065630 71437 printed
just from coughlin to lindsay.pdf (3.0 MB) , 2 21 13 0204 063341
067980 email to WCDA DDA Young and Lindsay update on
NNAHMS request for continuance of 2 25 12 Hearing in 063341.pdf
(164.9 KB) , 2 25 13 email from Lindsay's re update on NNAHMS
indicating DDA Young informed her hearing on 2 25 13 was
cancelled.pdf (190.0 KB) , 3 5 13 0204 0204 AO12-01 065630
067980 063341 Lindsay fax cover sheet for letter to Clifton seeking
continuance of 3 5 13 Show Cause Hearing in AO12-01, Pear.pdf
(404.4 KB) , 3 11 13 0204 071437 063341 Motion to Remove
Lindsay as Co-Counsel 2 25 13 OSC 2 1 13 DAS arrest.pdf (924.1
KB) , 3 12 13 0204 063341 071437 067980 AO12-01 Fax cover sheet
from RJC Lori Townsend to Lindsay's Office Minutes from OSC
addressed getting mental eval and Administrative Order, silent on
Bailiffs manufacture DAS missed check in.pdf (637.5 KB) , 5 23 13
0204 063341 ao1201 071437 Motion to Remove Bruce Lindsay, Esq.
as atty of record and notice of appeal of any orders purporting to
continue Admin Order RJC.pdf (710.8 KB) , 7 2 12 0204 RJC
eviction 1048 RCR12-067980 Case Summary Docket Lindsay
numerous continuances 6 14 12 5 Day UD Notice fraudulent and listed
Sparks JC NRS 40.253.pdf (378.5 KB) , 12 28 12 R Bruce Lindsay
$700 bill for representation in 067980 failed to move for competency
eval prior to 1 22 13 trial date in 065630.pdf (381.4 KB) , 5 16 13

0204 067980 Docket as of update since 4 1 13.pdf (361.1 KB) , 5 16
13 0204 063341 Docket as of OCR.pdf (1783.5 KB) , 5 16 13 0204
065630 complete as of.pdf (1501.0 KB) , 2 25 13 to 3 14 13 0204
071437 65630 63341 67980 all emails from Lindsay's
rbrucelindsaylaw@yahoo.com address.pdf (2.1 MB) , 5 16 13 0204
71437 Docket as of OCR.pdf (303.5 KB) , 5 16 13 0204 067980
Docket as of update since 4 1 13.pdf (361.1 KB) , 5 16 13 0204
063341 Docket as of OCR.pdf (1783.5 KB) , 5 16 13 0204 065630
complete as of.pdf (1501.0 KB)
Dear Law Office of R. Bruce Lindsay,

I am writing to request a copy of the fax that was read to me over the phone
that your office sent RJC Judge Clifton on 3/5/13. Please note that on the
attached docket for that matter, therein is listed a 3/5/13 Order to Show Cause
Hearing.
Whether Mr. Lindsay was directly made appointed counsel pursuant to some
NCJC Canon 2 Rule 2.13 "Administrative Appointment" or not, he appeared
in the matter, and, therefore, was required to obtain an Order, in writing,
allowing his withdrawal, before his non-appearance at the 3/19/13 Trial in
RCR2012-065630 would be acceptable.
Further, as to being "reinstated" into DAS in RCR2013-071437, that would
imply Coughlin was ever instated into DAS in that matter to begin with, and,
given that such matter was only given a case number on 3/14/13, and the
alleged "reinstatement" was ordered on 3/11/13, such is not possible. Further,
for a criminal case matter such as RCR2013-071437 there needs to be a
charging document, and the associated probable cause sheet and arrest report,
or citation. Please provide that. Without that, there really is no "case" for Mr.
Linsday to be quadruple billing on. That is, getting paid four times to do
nothing once. A real 401K (4 times to do nothing ("0") once ("1"), 'kay?
Whether Mr. Lindsay agreed to appear on RCR2012-065630 in consideration
for some acquiescence on Coughlin's part to Lindsay partaking in such a 401K
approach to Administrative Appointments, on the condition that the global
resolution (resolving all criminal matters (ie, Lindsay has never been given
permission to appear in the matter of the 12/20/12 "Administrative Order

2012-01 In the Matter of Zachary Coughlin", no matter which case the RJC
shoehorns such into, then move it out of, then gives a new criminal case
number on 3/14/13, etc.) in which Coughlin has ever been a party in the RJC
in a manner which would result in Coughlin having no SCR 111(6) "serious"
offense convictions, and in accord with the 8/27/12 plea bargain deal
Coughlin accepted.
ON 3/14/13 Lindsay's Office wrote "I need to clarify with you that Mr. Lindsay was
appointed to the following cases in Court to wit;
RCR2013-71437 the contempt charges that you were reinstated into DAS and CCP
RCR2011-063341 petty larceny matter that you were already convicted on but again for the contempt of
court matters."
The thing is both Lindsay and the RJC/WCDA need to be clear as to what "contempt of court matters" fit into
which case, and in which "case" (as RCR2013-071437 is an example of the judiciary attempting to usurp the
executive branch's prosecutorial charging function) is any "reinstating" to DAS even possible (not to mention
that "reinstating" Coughlin into CCP when he was never placed in CCP in the first place is a logical fallacy).
RCR 12-067980 obstructing justice and resisting case that has been set for a pretrial on April 16, 2013.
Apparently the case that is going to trial on Tuesday 03-19-13, is Case No. RCR2012-065630 and as you
indicated the Judge specifically stated that no additional counsel would be appointed on this case,"
Hopefully, Mr. Lindsay is aware that there are other circumstances wherein he could appear as attorney of
record, beyond just being appointed by "Dave" (as Mr. Linsday referred to Judge Clifton in suddenly
explaining the welching on the "global resolution" that Mr. Lindsay and his assistant Diana Simms explained
to Coughlin that both RJC Judges Pearson and Clifton and the WCDA's Office DDA Young had agreed to,
when Coughlin queried Lindsay as to why, if there was a global resolution done, there was still going to be a
trial held on 3/19/13 in RCR2012-065630).
Further the 2006 LA Times article on Administrative Appointments and the problems associated therewith
in the judiciary in Nevada and the changes in Nevada law that such glaring consternation begat has become
exceedingly relevant in the context of Mr. Lindsay's appearance as attorney of record in these matters (the
excuse that Lindsay was only "appointed" in RCR2012-065630 for the 2/13/13 hearing on some alleged
Order to Show Cause (please provide a complete copy of the discovery, charging document, and rest of
the file in that matter) does not fly where Sims admits that Lindsay appeared as attorney of record in that
matter, and sent a 3/5/13 fax to the RJC addressed to Judge Clifton, baring the case number RCR2012065630 seeking a continuance of the 3/5/13 hearing on the Order to Show Cause (again, the entry in the
docket of RCR2012-065630 of a 3/5/13 Order to Show Cause hearing is extremely problematic for both
the RJC and Mr. Linsday, and is integral to the misconduct issues arising in the appeal of that matter in
CR13-0614).
Simply put, being court appointed is not the only manner in which Lindsay may appear in a matter, and once
he appears (as he did in RCR2012-065630, at least as early as the 3/5/13 fax to the RJC seeking a
continuance of the 3/5/13 Order to Show Cause Hearing listed in the docket therein (see NRS 4.240
docket entries in justice courts are prima facie evidence of fact) he is bound by the Rules of Professional
Conduct, which would apply to his failure to appear at the 3/19/13 trial in that matter, not to mention his
completely welching on the "global resolution", his failing to appear at any of the CCP hearings (despite his
express indication that he would), and his indicating to Coughlin both before, during, and after, the 3/11/13
Order to Show Cause hearing(s) that nothing more than a two week continuance as to any of the matters
being addressed was being ordered, and that a global resolution had been agreed to by the WCDA, which
Lindsay also indicated had been approved by both RJC Judges Pearson and Clifton (and the welshing on
that deal no makes extraordinarily suspect the RJC's contention that it need not proved the alleged
"contempt" or "probation violation" in RCR2011-063341 (which is an entirely specious charge, and the
RJC's now seeking to characterize such 2/1/13 arrest as one premised upon a warrant, when, clearly, the
Arrest Report and Declaration of Probable Cause by DAS Officer Wickman and Ramos reveals a listing of
NRS 211A.125, the warrantless arrest of a probationer statue (and where the "warrant #" box is crossed
out, and considering the docket in RCR2011-063341 clearly reveals the warrant issued on 1/9/13 was
clearly withdrawn on 1/10/13...meaning there was no "warrant arraignment" on 2/4/13, and the fact that
such DAS arrest occurred at 7:02 pm, as listed on the Arrest Report, makes such a wrongful arrest in
violation of NRS 171.136's restriction against warrantless misdemeanor arrests between the hours of 7 am
and 7 pm, not to mention that the alleged "probable cause" for such arrest is entirely suspect given the
multitude of issues respecting the specious allegations that Coughlin "failed to check in" with DAS on either
1/2/13 or 1/23/13...)
NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court;
affidavit or statement to be filed when contempt committed outside immediate view and presence of
court; disqualification of judge.
2. If a contempt is not committed in the immediate view and presence of the court or judge at
chambers, an affidavit must be presented to the court or judge of the facts constituting the contempt, or
a statement of the facts by the masters or arbitrator
Further, the extent to which then Chief Judge Sferrazza's 12/20/12 Administrative Order (now, allegedly, a
criminal case in RCR2013-071437) blatantly misstates Art. 6 Sec. 6 of the Constitution of the State of
Nevada (such authority is accorded to "District courts", not "Nevada courts", and further, as to the
11/28/12 Order by then Chief Judge Sferrazza in "ALL CASES ALL DEPARTMENTS" barring Coughlin
from fax filing with the RJC, citing to JCRRT 10 when JCRRT 2 clearly reveals that such local rules do not
apply to either landlord tenant matters or criminal cases, makes that Administrative Order, the 2/25/13
Order to Show Cause stemming from it, and Bruce Lindsay, Esq.'s 401K approach to "representation" all
the more dubious and deserving of consternation, particularly given that extremely blase attitude of all
involved with respect to ameliorating the damages done by such apparent misconduct, made worse by the
RJC's failure to provide Coughlin the 2/4/13 and 2/5/13 JAVS recordings he has request (law of the case
incident to the IFP Order on file therein makes the unattributed refusal by some RJC Clerk (likely Robbin
Baker) to process and provide such JAVS recording, extremely suspect, especially considering the import
of the CR13-0552 Petition for Writ of Mandamus that Coughlin filed to address the NRS 178.405
violations in RCR2012-065630, and concomitant, potential SCR 111(6) "serious" offense conviction
stemming therefrom).
Further the unattributed and dubious allegations in the 2/25/13 Order to Show Cause require someone put
such assertions in an affidavit under NRS 22.030(2)
03/05/2013: CANCELED Order 10 Show Cause (2:00 PM) (Judicial Officer: Pearson, Scott) Vacated (that is
the actual docket entry in RCR2012-065630)
Further, the extent to which the WCDA and RJC gave Lindsay continuance after continuance in RCR2012067980 where Coughlin was routinely denied any continuances he requested (and, especially where on
2/5/13, the WCDA and both Judges Pearson and Clifton violated NRS 178.405's mandatory stay pending
the outcome of a competency evaluation dictate...which is made all the more dubious given the RJC's
repeated failure to turn over the JAVS recording of those 2/5/13 hearings before Judge Pearson (the first
one at 8:30 am, where Judge Pearson entered an Order for Competency Evaluation requiring Judge Clifton
stay the trial in RCR2013-065630, and the second hearing, where WCDA Z. Young was somehow able to
summon Judge Pearson for an Emergency Hearing to Set Aside such Order, despite NRS 178.405 making
such Motion forbidden (and the State wants to whine about such order being garnered "ex parte" at the
2/5/13 8:30 am hearing, well...show up, State, don't rely on DAS Officers to commit the unauthorized
practice of law on your behalf (they are witnesses, they belong were witnesses belong, not at the
prosecutors table making argument).
Further, the email from Lindsay's office of 3/14/13 fails to acknowledge the appointment of Lindsay in
RCR2012-065630 (whether limited to the 2/13/13 Order to Show Cause hearing or not).
Further, the email Lindsay's Motion to Withdraw in RCR2012-067980 was not granted, making even more
problematic the fact that Lindsay threatened to murder Coughlin on 3/16/13 by asserting that he would "rip
each of your limbs off your body" to Coughlin over the telephone.
Luckily, there is still an argument that the RJC has jurisdiction over some of these matters given the tolling
motions Coughlin filed in these various cases prevented the RJC from being divested of jurisdiction to undo
all this damages done by it and R. Bruce Lindsay, Esq.
Please provide a complete copy of all of Coughlin's case files.

Of course, all of Coughlin's assertions are fully supported by Lindsay's own written correspondence to
Coughlin:
"Re: Notice of Appearances filed in which cases?? From: Robert Lindsay (rbrucelindsaylaw@yahoo.com)
This sender is in your safe list. Sent: Wed 3/13/13 8:57 AM To: Zach Coughlin (zachcoughlin@hotmail.com)
Dear Zach: Thank you for the email. Please note that I am working on putting together three separate files
with case numbers and discovery . I will contact the court this morning and talk with them regarding the
upcoming court dates (especially tuesday) and then I will call you this morning."
"Re: proposal that might be your office some more money and resolve this whole thing.? From: Robert
Lindsay (rbrucelindsaylaw@yahoo.com) This sender is in your safe list. Sent:
Tue 3/05/13 11:03 AM To:
Zach Coughlin (zachcoughlin@hotmail.com) Zack I did not receive the email with the five page
attachment. I will be faxing the letter I read to you before lunch so I was hoping to get that attachments. From:
Zach Coughlin <zachcoughlin@hotmail.com> To: Robert Lindsay <rbrucelindsaylaw@yahoo.com>;
"zyoung@da.washoecounty.us" <zyoung@da.washoecounty.us>; "mkandaras@da.washoecounty.us"
<mkandaras@da.washoecounty.us>; "dwatts@da.washoecounty.us" <dwatts@da.washoecounty.us>;
"mcovington@da.washoecounty.us" <mcovington@da.washoecounty.us>; "plippar@da.washoecounty.us"
<plippar@da.washoecounty.us>; "plipparelli@da.washoecounty.us" <plipparelli@da.washoecounty.us>;
"jhelzer@da.washoecounty.us" <jhelzer@da.washoecounty.us> Sent: Wednesday, February 27, 2013 9:14 PM
Subject: proposal that might be your office some more money and resolve this whole thing. Dear Mr. Lindsay
and WCDA's Office, I respectfully submit this in the hopes that a global deal..."
"Re: proposal that might be your office some more money and resolve this whole thing.? From: Robert
Lindsay (rbrucelindsaylaw@yahoo.com) This sender is in your safe list. Sent:
Thu 2/28/13 10:40 AM To:
Zach Coughlin (zachcoughlin@hotmail.com) Zach I don't even know where to begin. You have the right
idea here and then you just keep going on and on. Can you please contact our office so that we can make an
appointment to have you come in and go over all of the facts and documents. 324-3333 or 230-4697. The
sooner the better. From: Zach Coughlin <zachcoughlin@hotmail.com> To: Robert Lindsay
<rbrucelindsaylaw@yahoo.com>; "zyoung@da.washoecounty.us" <zyoung@da.washoecounty.us>;
"mkandaras@da.washoecounty.us" <mkandaras@da.washoecounty.us>; "dwatts@da.washoecounty.us"
<dwatts@da.washoecounty.us>; "mcovington@da.washoecounty.us" <mcovington@da.washoecounty.us>;
"plippar@da.washoecounty.us" <plippar@da.washoecounty.us>; "plipparelli@da.washoecounty.us"
<plipparelli@da.washoecounty.us>; "jhelzer@da.washoecounty.us" <jhelzer@da.washoecounty.us> Sent:
Wednesday, February 27, 2013 9:14 PM Subject: proposal that might be your office some more money and
resolve this whole thing. Dear Mr. Lindsay and WCDA's Office, I respectfully submit this in the hopes that a
global deal..."
"
Re: update on NNAHMS, request for continuance

of 2/25/13 Hearing in 067980
From: Robert Lindsay (rbrucelindsaylaw@yahoo.com) This sender is in
your safe list.
Sent: Mon 2/25/13 1:57 PM
To: Zach Coughlin (zachcoughlin@hotmail.com)
Zach: Please do not second guess me when I tell you I have things handled. There is no need for you to
cause more confusion. It does not help. You wanted the continuance I told you I would take care of it and I
did. You going into the court after the fact does not look good. Your next court date is for March 11,
2013 for the Order to show cause hearing and the Pretrial on the resisting arrest. In addition the other two
tpo violations are scheduled for March 6, 2013 at 9:00 a.m. I will be in touch with the Court to verify if the
DA actually filed charges. So relax and lets work together like we said we would.
From: Zach Coughlin <zachcoughlin@hotmail.com>

To: Robert Lindsay <rbrucelindsaylaw@yahoo.com>
Sent: Sunday, February 24, 2013 4:50 PM
Subject: RE: update on NNAHMS, request for continuance of 2/25/13 Hearing in
067980..."
"Re: update on NNAHMS, request for continuance of 2/25/13 Hearing in 067980?
From:
Robert Lindsay (rbrucelindsaylaw@yahoo.com) This sender is in your
safe list. Sent: Sun 2/24/13 2:53 PM To:
Zach Coughlin
(zachcoughlin@hotmail.com) Yes both of the cases have been continued. I will
call Robin in the morning and reset them for a couple weeks out. I explained to
Zach that you are doing everything possible to get on your feet and that you are
working with NAHMS as well as counseling etc. If you do everything required by
DAS over the next few weeks maybe when you go to court on the probation
violation it will work out so that the violation is dismissed or time served. Hang in
there your doing well, try to breathe and stay out of trouble ok!!! ...
From: Zach Coughlin <zachcoughlin@hotmail.com> To: Robert Lindsay
<rbrucelindsaylaw@yahoo.com> Sent: Saturday, February 23, 2013 10:10 PM
Subject: RE: update on NNAHMS, request for continuance of 2/25/13 Hearing in
067980 Hi Diana, I am not sure I ever had your phone number beyond the one for
your office listed at http://www.nvbar.org/. When you wrote, below, "Zach I got a
call from Zach and your hearing has been continued. Please call me" Does that
mean my hearing in 11-063341 on the DAS Probation Violation (arrest of 2/2/13
alleging that I failed to check in on 1/3/13/ and 1/23/13, $500 cash bail posted)
Show Cause to show why my probation on a 180 suspended sentence should not
be revoked has been continued AS WELL? That's the hearing I really wanted
continued because, as specifically mentioned by Judge Pearson at a 2/3/13
Show Cause hearing on the morning of 2/3/13 (I was bailed out at 1 am and
found out about the hearing when I called the RJC to inquired about the start time
of my continued trial in a different case in 12-065630...that DAS hearing in
063341 was incorrectly noticed on my Jail Release papers for 2/5/13 or
something...At that 2/3/13 Hearing I got an Order for Competency Evaluation from
Pearson, then went and provided that to Judge Clifton at the resumption of the
065630 trial immediately thereafter, which, under NRS 178.405, required Clifton
to suspend the trial in 065630. Of course, he did not. He has demonstrated a
willingness to fail to apply the law as written in certain instances, invariably to the
benefit of the State. Somehow, Judge Clifton then allowed DDA a recess to go to
the counter and request and Emergency Hearing before Judge Pearson to have
that Order for Competency Evaluation entered an hour before in 063341 vacated.
DDA Young was successful in getting a hearing and having that Order vacated.
Judge Pearson was evasive during that hearing when questioned as to whether
he had extra-judicial discussions with Clifton (whom had just exited the Bench in
Courtroom D long enough for Judge Pearson to hold the Emergency Hearing to
Vacate his just entered Order for Competency Evaluation, which he claimed to
have been reviewing, unprompted, following his entry of that Order, in his
chambers, unprompted...)...."
"Date: Fri, 22 Feb 2013 16:37:16 -0800From:
rbrucelindsaylaw@yahoo.comSubject: Re: update on NNAHMS, request for
continuance of 2/25/13 Hearing in 067980To: zachcoughlin@hotmail.com Zach I
got a call from Zach and your hearing has been continued. Please call me From:
Zach Coughlin <zachcoughlin@hotmail.com> To: "rbrucelindsaylaw@yahoo.com"
<rbrucelindsaylaw@yahoo.com>; "rbl@robertbrucelindsay.com"
<rbl@robertbrucelindsay.com>; "zyoung@da.washoecounty.us"
<zyoung@da.washoecounty.us> Sent: Thursday, February 21, 2013 4:08 PM
Subject: update on NNAHMS, request for continuance of 2/25/13 Hearing in
067980 Dear Mr. Lindsay and DDA Young, I am writing to request from DDA
Young a stipulation to a continuance of the 2/25/3 Show Cause Hearing in
063341, which I understand may have been combined with 067980, so I am
copying Mr. Lindsay...."
"Re: sorry for the delay

From:
Robert Lindsay (rbrucelindsaylaw@yahoo.com)
Sent:
Wed 2/20/13 12:06 PM
To: Zach Coughlin (zachcoughlin@hotmail.com); rbl@robertbrucelindsay.com
(rbl@robertbrucelindsay.com)...
To: "rbrucelindsaylaw@yahoo.com" <rbrucelindsaylaw@yahoo.com>;
"rbl@robertbrucelindsay.com" <rbl@robertbrucelindsay.com>
Sent: Friday, February 8, 2013 2:21 AM
Subject: FW: sorry for the delay
I need to see something out of your office soon. So far I got Bruce failing to file a
Motion for Order for Competency Evaluation and stipping to everything to make
DDA Young's routine easier...and generally seeming out of it, and he has
provided absolutely zero legal advice so far...zip...nothing. Please respond to my
written requests below. I need to know what your office is willing to do

immediately, otherwise its time to refund the $700.00Zachary Barker Coughlin
1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.comTo: rbl@robertbrucelindsay.comSubject: sorry
for the delayDate: Fri, 11 Jan 2013 14:45:21 -0800
Dear Mr. Lindsay,
https://skydrive.live.com/redir?resid=43084638F32F5F28%21118
Please find very relevant materials to the defense of this case attached and at the
above link. I have scanned everything therein for viruses and it is 100% safe and
virus free.
Sorry for the delay, I am not flaking on you, its just been hectic, i'll get to getting it
scanned and returned, very busy addressing a recent Order of the NNDB seeking
to disbar me, but I will get to it.
I don't want much, okay. Just a few simple things.If you get me this stuff, as far as
I am concerned, we are straight (assuming you don't pull a Jim Leslie and insist
on remaing on my case as long as possible to purposefully torpedo it....) There
was talk of Cape Fear with Leslie well before he moved to withdraw and got a
TPO, and now an EPO (though courthouse sanctuary doctrine makes the
"service" thereof rather suspect. Leslie was not all "terrified" back then...What
changed? Oh, that's right, he was finished puttin' in work for the County (ie,
makign sure I got convicted on both counts in 063341, thanks to his making the
NRS 171.136 (or trying to, at least, ...he failed) citizen's arrest arguments that
went completely over DDA Young head (or, more likely DDA Young just couldn't
stomach anymore of the farce and chose not to make such arguments to the
tirbunal). Can you serve the WCDA with request for discovery and subpoena the
RJC and WCSO for the following (assuming the won't just copy the stuff an
provide it all nice'n'easy like):
certified audio transcripts of the following hearings in the RJC:
1. 7/5/12 in RJC Rev2012-001048 hearing granting a default victory incident to a
6/28/12 motion to set aside the fraudulently procurred 6/27/12 Lockotu Order at
the rental where the 067980 arrest occurred.
2. 7/31/12 hearing in rjc rev2012-001048 before Judge Pearson (this was a
hearing noticed on 7/23/12 to address my Motion to Set Aside the 6/27/12
eviction Order signed by Judge Schroeder despite my 6/26/12 email and fax to
the RJC, SJC, WCSO, and City of Reno regarding my filign the Tenant's Answer
in the SJC, and the deficiencies in the 5 day notice. (please see the attached
police report by the RPD incident to the pretextual (and Soldal v. Cook Co
violating, not that it matters, this is nevada after all) arrest shortly upon my bailing
out on the 067980 charge in RMC 12 CR 12420(wherein the "approach" by the
RPD (to which RPD Sargent Sifre incidates some level of complicity between the
RPD and RJC in a recording only recently propound by the WCDA just 2 judicial
days before the 12/11/12 Trial stemming from the 1/14/12 misuse of 911 arrest in
rcr2012-065630 (a witness just sadly passed away unexpectedly 2 days after the
DA complete his direct examination of her, EComm's Kariann Beechler).
2.1 the audio transcript of the one hearing in REV 2012-075658 Zach Coughlin
vs Jeff Nichols. This is relevant to 067980 because its another eviction scenario
and establishes a pattern and practice by the RPD, WCSO and RJC to refuse to
uphold my rights while aggressively applying an overly rigid and formulaic
application of rules to me as a pro se tenant, and even going beyond that, some
might say, at times. Please, this one is important, I need it. A former WCSO
Deputy pu
3. I would like you to serve on the WCDA a request for discovery and also a
subpoena/FOIA (I know, NRS Open Records REquest) on ECOMM for any 911
calls, RPD Dispatch calls from civilians, or recordings between the RPD or wcso
or Reno sparks Indian colony Police or dispatch/ECOMM in any way connected
to me, Zach Coughlin, or suspected to be connected to me. I am not going to ask
for much more, if you get me all that, I'll be good, if not...I'll be tedious.
4. any and all recordings made by anyone (RPD, WCSO, Northwinds Staff,
bystanders, and especially Jeff Chandler or Ryan WRay or anyone else
associate with Nevada Court Services) of ANY interactions with me in any way
connected to Northwinds Apartments and my tenancies there (i had three rentals,
units 29, 45, and 71). Please have served a subpoena duces tecum on Nevada
Court Services directed to anythign (documentation, recordings, etc) related to
Zach Coughlin and serve a witness subpoena on NCS's Ryan Wray (might have
stopped working there, but still subpoena him please) as well as Jeff Chandler.
5. The RMC audio transcript of the (it woudl cost my $35 i don't have, and they
probably have to waive the fee for you, the RJC does when Leslie and the WCPD
request recordings) 7/5/12 unnoticed bail hearing in RMC 12 CR 12420 wherein
my bail was impermissibly raise from a bondable $1,415 to a cash only $3,000 for
charges that were plainly manufacture anyways.

6. the 12/3/12 Trial audio transcript in RMC 12 CR 12420.
7. the 12/18/12 audio transcript of the hearing in 067980 (the case you are on)
wherein Jim Leslie (without DDA Young there) was able to get some things
done...you likely are required to, or at least, might want to, have this anyways.... I
dont' necessarily need the hard copies (you can sign up for a free hotmail
account at www.outlook.com and skydrive them to me, its totally easy, or I can
pick them up, copy them, and deliver them to you...i just dont' have the money
and the court's nickel and dime me like crazy).
8. The 12/6/12 filing in the appeal of an associated RJC prosecution in rcr2012063341 (it is the Record on Appeal, basically, but I think they titled it "Notice of
Appeal" on the docket...and the RJC has failed to provide me a copy of it...not
even the brand new filings listing the index of documents included in that 12/6/12
filing (which is basically a Notice of Appeal). YES, IT is relevant to this case...it
goes to conflicts analysis to both the RJC (even across departments, especially
given some admission by Clifton as to looking over "submission on subpoenas"
from that 063341 case before Sferrazza, on the record in 065630...DDA Young is
an efiler and could easily email you that 20 mb or so 12/6/12 Notice of Appeal
(804 page) filign in CR12-2025 (the appeal of rcr2011-063341, the first of 10
arrest/incarcerations of me since 8/20/11).
Please subpoena Nevada Court Services Ryan Wray (he may not work there
anymore, but he was present at the scene of the arrest and, obviously, along with
Northwinds Manager Duane Jakobs (who testified on that 7/31/12 audio
transcript I am requesting you obtain and copy me on in rev2012-001048 about
the events in question in 067980) participated in attempted break in an fraudulent
Declaration of Service of the 6/14/12 5 Day UD Notice.
9. Lastly, please serve the RJC Custodian of Records a Subpoena duces tecum
for all records/fax logs/information/documentation related to any faxing of Orders
by RJC Judges to the WCSO between October 24th, 2011 and November 2nd
2011 (each fax has a job number, etc. I want a sequential printout or log of those
faxes as it goes to whether the RJC, in accord with its admitted policy, faxed to
the WCSO the two different ORders by Judge SFerrazza related to the Eviction (a
10/25/11 "Eviction ORder and Decision" and a 10/27/11 "Findings of Fact,
Conclusions of Law, and ORder for Summary Eviction". I need to know if and
when such items were faxed or transmitted to the WCSO...it is very relevant given
the same WCSO Deputy Machen conducted the lockout on 11/1/11 from my
former home law office, according to the locksmith, REno Carson Messenger
receipts, the transcript of th 6/18/12 criminal trespass trial in RMC 11 Cr 26405
(sworn testimony of Casey Baker, eSq. and Richard G. HIll, eSq.) demonstrates
that the WCSO's Office is being obstructive, as is the RJC (whom failed to comply
with my SCR 105(4)/SCR 119 properly issued and served supboena and
subpoena decus tecums of 10/30/12 in the formal disciplinary matter (espeically
consiering the 4/11/12 volunteering of information and documents by RJC judges
secretary Lori Townsend), and further specify the subpoena duces tecum is for
the "file stamped cover page" of any filign by Couglin in RJC rev2012-000374.
10. the audio transcript of the 8/7/12 TPO Hearing in RJC RCP2012-000287)
for Milan Krebs v. Zach Coughlin (Krebs was NOrthwinds Apts maintenance man
(the one doing the sawzalling to the metal door of unit 29 incident to the arrest in
067980...He testified under oath the matters of material direct relevane to the
defense of this case. This is a no brainer, and the fact that Leslie continuously
refused to obtain a copy of this hearing (again, the RJC waives the $35 fee for th
wCPD...so what was Leslie's excuse? That Northwind's Apartments sent him
some photgraphs of a microwave? Please. Jim Leslie is a joke. That might be
relevant to an evictio hearing, but not to a NRS 199.280 defense. What Krebs
testified to at that TPO extension hearing on cross examination is obviously
extremely relevant, particularly where there was extensive questioning directed to
the circumstances of the arrest in 067980.
11. Lastly, a subpoena duces tecum on the Custodian of Records for the Reno
muni Court and the Custodian of Records for the City of REno Marshals for any
an all documentation, marshal's reports, or recordings (Thompsons admitted to
makign at least on on or about 3/22/12) in any way related to Coguhlin (obviously,
there shoudl be an arrest report from the 2/27/12 direct contempt arrest wherein
Marshal Harley, as testified to by Judge Nash Holmes at my disciplinary hearing
on 11/14/12 via her hearsay of what Harley told her, has apparently alleged some
"disassemblign of a recording device and hiding a component of it in the restroom
during arestroom break that was begrudingly granted immediately after Holmes
began interrogating Coughlin about hwether he was "recording the proceedings"
and or whether he "had a recording device", upon which, alleged Holmes,
Coughlin immediately got "all squirmy and begged to use the restroom"....Okay,
lets see the documentation, marshal's report etc. for anything, but especially
including that. IF they move to QUash I want be copied on it (please copy me on
anything anyone sends you ever in any way related to me) as I have some
authority and opposition work I woudl like for you to at least consider incident to
any reply you may wish to file....this is relevant. RJC Clifton signed an ORder for
Competency eval on 2/27/12 at 1:31 pm...JUDge Nash holmes could nto be found
by her staff at that time, despite the traffic citaiton trial connected to Richard G.
Hill, Esq.'s office and the trespass arrest being schedule to occur then...both
HOlmes and Clifton were mysteriously transferred criminal cases involving
Coughlin on 2/27/12...both are lifelong prosecutors, formerly Holmes was Clifton's

boss from about 91 to 94 ish (not to mention Linda Gardner was a coworker (see
54844 and 60302), and Nash Holmes 3/14/12 grievance against Coughli nto the
SBN admits to communications with the WCPD about Coughlin.
12. please subpoena duces tecum the WCPD as to anything in any way related
to HOlmes admission regarding the WCPD in her 3/14/12 grievance...
13. Lastly, please serve a subpoena duces tecum on the custodian of REcords
for Richard G. HIll, ESq. and his former associates new firm in Kentucky, Casey
D. Baker, Esq's Baker and Baker or whatever tey call themsleves narrowly
tailored to any documentation, recordings, or information baring on when and if
their office provided the two different eviction ORders to the wcso office (Baker's
testimony at the 6/18/12 crimnal trespass trial (there is an oficial transcript at te
link) sheds some light on this vis a vis October 28th, 2011...and familiarzie
yourslef with the void/stale order concept incident to NRS 40.253's requirement
that the lockout be done "within 24 hours" of "receipt of the order"....by the
WCSO...the same deputy makign the arrest in 067980 conducted that lockout
and filed a fraudulent affidavit of service on 11/7/11 alleging to have "personally
served" me...which his supervisor was ofrced to admit, in writing, he did not, but
rather merely posted the order on the door (hill lied at the 6/18/12 trespass trial in
testying "they posted it to the door because you ran away" despite that being
completely false, and where HIll admits he was not even present that day, and his
associate completely failes to back up hill's baseless, defamatory accusation (one
of many by Hill).
And that's it. You do all that and provide a reasonable return and attempt to
counter all the bs MOtions to Quash sure to ensue, and we are straight. You can
move to withdraw and I will give you glowing review, I promise. Hell, I will even
draft all these subpoenas for your approval and the oppositions to the motions to
quash if you like, and provide the authority in support of them. But I need you to
issue the subpoenas and have them served, and get the recordings, etc....even if
they make you pay for them, none of this adds up to more than $200 (perhaps
you can file a notice of appearance, if an efiler on the cr12-2025 under some
justification that is is necessary to the defense herein or I would allow you to
appear as co-counsel provided you dont' insist on hijacking things..., but
obviously paying $1 page for all 804 pages hard copy from aint goign to work....
I really appreciate any help you can provide.
Sifre's admissions as to said complicity may provide a basis for your filing a
Motion to conflict out the rjc and the wcda's office (in addition to DDA Kandaras'
involvement in the turning over of my smartphone and data card to the City of
Reno Marshals and the RMC in 11 TR 26800, as admitted to by WCSO Hodge to
me, in front of local attorney Pam Willmore (I was arrested incidnet to a contempt
finding at the 2/27/12 trial before judge Nash Holmes, and it was not until after my
property was booked into my personal secured property and well after any time
for a "search incident to arrest" that the WC Jail released to the RMC and its
Marshals on 2/28/12 my property, which was returned 37 days later wiped of all
data incident to an Order of 3/30/12 that seems to have clearly be responsive to a
filing by me in NVB 10-05104 before Judge Nash Holmes and Washoe Legal
Services Exec. Director Elcano 1977 McGeorge SOL classmate, NVB Judge B.
Beesley....all three of whom testified at my 11/14/12 formal disciplinary hearing at
the SBN, despite SCR 105(2)(c) being desecrated in every way imaginable,
another Mirching to besmirch the judicial system in Nevada. DDA Kandaras is on
the NNDB and refuses to deny that she or David Hamilton, Esq. (Richard G. Hill,
Esq.'s best friend) were on my screening Panel. This IS revelvant to what you
are getting seven bones for, under a conflict or disqualification analysis (I would
like a reason why this case was transferred on 2/27/12 from Judge Lynch, same
day another case in the RMC was transferred to jUdge Holmes (the 1/12/12
custodial arrest for jaywalkign cuz richard g. hill said to cas in rmc 12 CR 12420.
7/5/12 in RJC Rev2012-001048 (this is the summary eviction from the very unit
#29 rental at Northwinds Apartment, 1680 Sky Mountain Drive that I was arrested
at on 6/28/12 in the matter you were assigned and contracted to handle for
$700.00). I did not attend the hearing because I was rearrested on 7/3/12 by the
Reno Police Department just blocks from Northwinds Apartments in RMC 12 CR
12420 (a custodial arrest involving three charges, one, a simple traffic citation for
failure to secure a load on one's vehicle (they allege an empty plastic storage tub
fell off my vehicle), two, no proof of vehicle insurance (despite RPD Officer Alan
Weaver admitting that I showed him a high resolution pdf of my then current
USAA auto insurance on a 4.7 inch smart phone screen...he said it had to be a
paper printout), and three, "disturbing the peace" based upon the criminal
complaint signed by Northwind's Apartments maintenance man, 23 year old Milan
Krebs (whom obtained a TPO against me from the RJC in RCP2012-000287 on
7/5/12 after the RPD fraudulently urged Krebs to apply for one incident to the
7/3/12 arrest, as further confirmed by the commentary by the same RPD Sargent
Sifre (only finally propounded to me following a 12/5/12 email from the WCDA
informing me of the availability of such discovery
please let me know, in writing, and with specifics, whether or not you will move, in
writing, to obtain the above indicated materials, and provide an indication of how
soon you will do so, with proof thereof. Sorry to have to ask for that, but time is of
the essence and I need to know if this is going to work out with you or not. If it
does, I will absolutely credit you for being a faithful defender of the Sixth
Amendment, and maybe more.
Sincerely,
Zach Coughlin1471 E. 9th St.Reno, NV 89512Tel and Fax: 949 667
7402ZachCoughlin@hotmail.com"
Sincerely,
Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
7402 ZachCoughlin@hotmail.com
PS:
"
Re: Notice of Appearances filed in which cases?

your safe list.
Sent: Wed 3/13/13 8:57 AM
with case numbers and discovery .
I will contact the court this morning and talk with them regarding the upcoming court dates (especially
tuesday) and then I will call you this morning...."
"
Re: Notice of Appearances filed in which cases?

your safe list.
Sent: Wed 3/13/13 8:57 AM
with case numbers and discovery .
I will contact the court this morning and talk with them regarding the upcoming court dates (especially
tuesday) and then I will call you this morning.

Sent: Tuesday, March 12, 2013 4:29 PM
Subject: Notice of Appearances filed in which cases
Dear Mr Lindsay,
Would you please communicate with me a bit more with regard to what the
overall plan is, the contigencies, worst case, best case, etc. For instance, what
if no global resolution is worked out by 3/19/13, the trial date for 12-065630
before Judge Clifton...."
Date: Thu, 14 Mar 2013 09:33:53 -0700

From: rbrucelindsaylaw@yahoo.com
Subject: Re: Notice of Appearances filed in which cases?
To: zachcoughlin@hotmail.com
Dear Mr. Coughlin:

I need to clarify with you that Mr. Lindsay was appointed to the following cases in Court to wit;
RCR2013-71437 the contempt charges that you were reinstated into DAS and CCP
RCR2011-063341 petty larceny matter that you were already convicted on but again for the contempt of
court matters.
RCR 12-067980 obstructing justice and resisting case that has been set for a pretrial on April 16, 2013.
Apparently the case that is going to trial on Tuesday 03-19-13, is Case No. RCR2012-065630 and as you
indicated the Judge specifically stated that no additional counsel would be appointed on this case, as you
had one appointed and they withdrew, you then requested to represent yourself. I believe this accurate.
Mr. Lindsay would like to schedule an appointment with you for Friday March 15, 2013 to go over these
matters. However, you need to make sure to take your medication and be in a rational state of mind when
you meet with him.
Also, Mr. Lindsay informed you that you were to provide a list of the medications that you are currently
taking as well as the name of the psychologist that will be performing the evaluation with and that you are
suppose to meeting with regularly.
Furthermore Zach: Please do not send me a large email I simply need you to pleas just follow the
instructions as outlined above and make an appointment with our office. I apologize for any confusion, but
as I specifically informed you a couple of days ago I needed to review our files and consult with Mr.
Lindsay before offering any information and have now done so.
Thank you in advance for your anticipated cooperation.
Diana Sims
Legal Assistant to
ROBERT BRUCE LINDSAY

Sent: Tuesday, March 12, 2013 4:29 PM
Subject: Notice of Appearances filed in which cases?
Dear Mr. Lindsay,

Would you please communicate with me a bit more with regard to what the
overall plan is, the contigencies, worst case, best case, etc. For instance,
what if no global resolution is worked out by 3/19/13, the trial date for 12065630 before Judge Clifton.
I like you personally, Bruce, and Diana too, but I am frustrated. Everytime I
go into court I don't know if I will be allowed to go home that day. I have
offered the County, the WCDA, etc., etc. everything I could think they want,
but no deals get done...the WCDA is shielding DDA Young from any emails,
faxes, voice mails from me (See the letter ADA Helzer recently resent), which
I think impermissibly attempts to absolve him of his obligations under the
RPC. I am very unhappy about what happened on 2/13/13 (not a huge deal,
but I am working on a brief to save my law license, and five days in jail
doesn't help). Its not clear to me what happened yesterday before Judge
Pearson. I can chill out, but how about seeking clarification as to what
occurred, and if, in fact, I am now subject to some 3 year probation requiring
me to check in with CCP, in addition, to checking in with DAS, every
week...how is that a good deal for me? Keep me out of jail? From what?
What was I in danger of going to jail over? An allegation of calling the
wrong number at the RJC to check the time for a hearing? Hardly colorable
for the RJC to assert a justification for 6 months in jail? What else? A DAS
probation violation? Well, did I have an email from DAS Officer Brown
excusing such violation? Was the arrest after 7pm in violation of NRS
171.136? I dont' like going to court, checking in with probation, giving
people my medical records. These are positives. Having limites on my ability
to travel, to move...Giving the RJC leverage to put me back in jail should I
point out how their various egregiously incorrect under the law eviction order
contributed mightily to a tremendously painful and unhappy 18 months of my
life. And you, so far, have always assumed I was wrong, and that they only
way is to give up any leverage I have, for....what? 5 days in jail for being late
to court (no consultation with you prior to appearing before Judge Clifton is
hardly "representation"...If some binding order issued yesterday from Judge
Pearson, its not as though I received any analysis from you before hand. That
is why I didn't agree to anything beyond a two week continuance, which I was
you confirmed in my initial phone call to you afterwards, then, later, you
changed your position and asserted something else...I think we need to work
together here, and that, if you really think about it, neither you nor I "agreed"
to any such consent Order that Judge Pearson for the WCDA may alleged
occurred. Further, any such Order was issued in AO12-01...which is not even
a "case", nor was it issued upon "a properly made motion"....as such, and CCP
Order is void...somehow I think we could influence Judge Pearson to adopt
that viewpoint to whatever extent he does not yet...But I am not even sure he
entered an order, or "rendered", etc...I need something in writing telling me
what, if anything, I am required to do to comply with any such "Order" should
it be the case that there is one. If there is, I want to file a motion to stay
probation, correct illegal sentence, notice of appeal thereto, etc., and the time
frame is extremely limited. Maybe Judge Pearson would rather "clarify"
things than have a Notice of Appeal filed divesting him of the ability to do so.
It seems you feel that going in to CCP would be a good thing, that it likely
wouldn't be three years in duration, would provide me an opportunity to sell
myself to Judge Pearson more, etc...But that's assumign stupid things don't
happen, like me being late to a check-in, continued issues with a Bailiff or
two, ADA Helzer telling DAS Officer Ramos to arrest me when he needs
leverage on something (if that is what happened), etc., etc. It just doesn't
seem that thought out to go, in two weeks, and enter some CCP Consent
Order to dispose of two rather dubious Show Cause Orders or Probation
Violations...Were were the witnesses yesterday? No witnesses, no
contempt...so that adds credence to the view that yesterday was more of a
status conference in which no orders issued, an certainly not a CCP obligation
for 3 years where the only discernible benefit to the client is getting an Order
paying for a Dr. Yasar evaluation when such an Order was already rendered
on 2/2/13 (Pearson has just failed to have a check cut...). I dont' need my
meds paid for by CCP, NNAHMS is doing that, and my future psychiatrist
visits are paid for too. So any consenting to an Order that anyone alleges you
did yesterday on behalf of your client would not be supportable much under a
theory that your client obtained much benefit from it...beyond a dubious
assertion that jail time was likely. At some point the RJC Judges have to
consider the PR on the horizon attendant to any jailing me for 6 months
incident to a RJC Bailiff detaining me just long enough for DAS to close its
doors on 1/23/13, upon which some suspect revocation of probation would
be based...
Will you please email me or fax me something in writing indicating, by case
number, which cases you are attorney of record for me on, and to what
extent? I have been told by your office and the RJC, and the WCDA's Office
that you are my attorney of record in 12-065630, for which the Trial is set to
occur on 3/19/13 at 8:30 am. If that is the case, I would like to meet with
you and prepare for trial, and your being listed as attorney of record therein
has now limited my ability to have subpoenas issued, to make filings, etc.
My understanding of the hearing yesterday before Judge Pearson is that it was
a combination hearing involving three separate and distinct matters:
12-067980, the case in which you are listed as attorney of record by the RJC,
though the Motion I filed on 12/3/12 therein has never been addressed by the
RJC
AO12-01, the "case" wherein the "Caption" reads "In the Administrative
Matter of Zachary Coughlin...Administrative Order 12-01" from which the
12/20/12 "Administrative Order 12-01" by then Chief Judge Sferrazza issued,
though service thereof I believe should be quashed, as, should be, the 2/25/13
Order to Show Cause that shares the same "caption", and
11-063341, the iPhone petty larceny conviction case currently on appeal in
CR12-2025 (where I was granted In Forma Pauperis status on 1/9/13 and
have an Order (see attached) requiring the preparation of some 15 hours of
trial transcripts).
I believe the AO12-01 of 2/25/13 is void for lack of jurisidiction and for the
other reasons set out in my various attached filings. Please note t
Please indicate whether you were compensated by anyone in any way for your
appearing in 12-065630 on 2/13/13 and how you came to appear at such
hearing, whether such hearing involved criminal or civil contempt, and
whether you are attorney of record on the appeal thereof (please see the
Notice of Appeal I filed in that matter on 2/25/13, within the 10 days under
NRS 189.010, as to the 5 day summary incarceration Order for some type of
contempt...I gather. Given you were late to court yesterday, I noted that you
were not taken into custody following the hearing and yourself subject to
such a Contempt Hearing). Please indicate when, and in exactly what matters,
and to what extent, you have complied with the local rules with respect to
filing a notice of appearance in any of my cases. I am sorry to come across as
so formal and technical, but there are significant consequences to me possible
in these various matters.
Given the proximity of the 3/19/13 Trial date in 12-065630 and your
statement to me on the phone today, that you could not speak with me about
any of the matters for which you are listed as my attorney of record, including
the case wherein there is a trial date on calendar of 3/19/13 at 8:30 am, I
believe it is necessary for a stipulation to a continuance be sought from DDA
Young and and Order granting such continuance from the RJC.
Additionally, I have my medication and pyschiatrist viists paid for by
NNAMHS. I have no interest in joining a CCP with the RJC, much less for 3
years. You indicated to me that nothing occurred in court at the combination
hearing yesterday (which,. from my understanding combined the Show Cause
Order of 2/25/13 incident to the 12/20/12 Administrative Order 1201...which I have called "case number AO12-01...and I object to such Order
be recharacterized at this point as being incident to 11-063341 (There was a
Show Cause Hearing, continued from 2/25/13 in 11-063341 that was to take
place yesterday 3/11/13, though it did not take place as far as I know, and any
Order that was entered (I did not agree to any Order being entered, and you
represented to me that no Orders were going to be entered in any matter or
case being addressed in court yesterday 3/11/13 incident to the 9 am
combination hearing of that date beyond a 2 week continuance being entered,
sufficient to allow you and I and DDA Young to work together towards a
global resolution, involving both the matters in which you are attorney of
record, and to which I have so consented to you being attorney of record, and
those where you and I are co-counsel, and those where I am self representing,
whichever the case may be (and at this point, that seems to be up for debate
and in the eye of the beholder).
Please indicate whether you will be seeking a continuance as to the 3/19/12
Trial date at 8:30 am in 12-065630 before Judge Clifton, and, if not, when
you and I can meet to address matters related thereto.
NNAHMS is paying for my medication and future psychiatrist visits, and I am
starting counseling there with a psychologist. As such, I don't know why it
would be necessary to provide my prescription records. I would like the RJC
to fulfill the Order rendered on 2/2/13 that it would pay for a mental health
evaluation with my private psychiatrist (Dr. Suat Yasar) whom I have gone to
for years, and who, thus, I feel would be able to provide a more in depth and
better mental health evaluation.
To the extent that during the hearing yesterday (I was only able to speak with
you very, very briefly yesterday prior to the 9:00 am hearing, given your
arriving at 9:20 am for yesterday's hearing, which was set for 9:00 am). I
would like to consult with you further regarding the possibilities of entering
the RJC's CCP program, though at this point, I don't see how doing such
provides much benefit to me beyond being subject to more Orders To Show
Cause should I fail to appear to a check in or arrive late. I have no interest in
being subject to such a program for 36 months. I do not believe I consented
to any Order being entered which would place me in such a CCP program for
36 months or require me to check in at the RJC a second time per week in
addition to my usual Wednesday DAS check ins. You mentioned some

possibile benefit of being enrolled in the CCP program or, in the future, after
more consulation and informed consent being garned from me, upon any such
Consent Order being entered requiring me to participate in the CCP program,
as involving having my medications and psychiatrist visits paid for. However,
NNAHMS is currently providing such a service, and NNAHMS does not
subject me to Order to Show Cause if I am late to an appointment, and given
my ADHD/ADD and Major Depressive Disorder diagnosis, being late from
time to time is a distinct possibility.
If your understanding of what occurred in court yesteday before Judge
Pearson is different than mine, please let me know in writing. I know I was
crying in court and very distraught and indicated to you that I had not had my
medication in two days, and I feel that likely augured towards your moving
for a Competency Evaluation or otherwise seeking a stay of the
proceedings...further, you were provided the 2/2/13 Order for Competency
Evaluation by Judge Pearson, and even where Judge Pearson may have
purported to set aside such Order only an hour after entering it, I don't believe
he has the jurisdiction to do that, but rather, that I must be examined by a a
mental health care professional with the requisite certifcation to perform such
evaluations prior to any matter, in any department of the RJC proceeding.
While I granted you a limited right to pursue a global resolution in a civil
context of the various matters involved here, in a co-counsel arrangement in
which I retain final say on everything, including your continue participation in
any such matters (and, in the proper order, and prior to giving up any leverage
I may have, I am in favor of you being compensated by the State as much and
in as many cases as possible, just not before a deal is worked out in a civil
context disposing of these various matters and where, any subsequent filing
by you of a notice of appearance in a criminal matter is as my co-counsel).
Sincerely,
Zach Coughlin
Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
7402 ZachCoughlin@hotmail.com
Zach has 11 files to share with you on SkyDrive. To view them, click the links below.
2 25 12 0204 Order to Show Cause Order 2012-01 RJC Sferrazza Pearson.pdf
2 25 13 Notice of Appeal of Order of 2 13 12 5 Day Incarceration for Contempt 065630 0204.pdf
2 25 13 Request to RJC Chief Judge Pearson for Order for Yasar Evaluation.pdf
2 28 13 0204 063341 WCDA DDA Hezler 2 25 13 letter with new handwritten note remailed threatening
TRO TPO.pdf
2 28 13 0204 AO12-01 Motion for Extension of Time to File Responsive Document to 2 25 13 Order in
AO12-01 for 3 5 13 Hearing by 4pm on 2 28 13.pdf
2 28 13 0204 RJC AO12-01 Motion for Extension of Time to Filed Responsive Document to 2 25 13 Order
in AO12-01 re Right to Counsel.pdf
3 1 13 0204 063341 Coughlin's Motion to for Check for Dr. Yaser Pursuant to Order Rendered on 2 13
13 , Subm of Proposed Order for Mental Eval.pdf
3 1 13 0204 AO12-01 Coughlin's Motion to Dismiss Show Cause Order Lack Specificity Insuff Service, Mtn
for Continuance of 3 5 13 Hearing, Set Aside AO12-01 Void Lack Juris 067980 063341 065630.pdf
3 11 13 0204 063341 067980 AO12-01 filign in relation to what occurred before Judge Pearson
today.pdf
12 3 12 067980 Motion to Substitute Out Leslie and Conflict out wcda wcpd motion for mistrial notice of
leslie and young's failure to hold msc on 11 20 12.pdf
12 20 12 438pm RJC Chief Judge Sferrazza 12-01 Administrative Order 0204 063341 065630 067980
1048 607 599 074328 ocrd tagged.pdf
Download all
11:59:52a,m,
7753256715
1 120
10-08-2012
REV 2012-001082 Northwind Apts. Vs Zach Coughlin

REV 2012-001083
Northwind Apts. Vs Zach Coughlin
REV 2012-075658
Zach Coughlin vs Jeff Nichols
RJC 2012-076746
Zach Coughlin vs Northwind Apts.
REV 2012-00374
Park Terrace Townhomes vs Zach Coughlin
REV 2012-074408
Zach Coughlin vs Park Terrace Townhomes
REV 2012-001048
Northwind Apts vs Zach Coughlin
REV 2012-001167
REV 2012-001168
REV 2011-001492
Matt Merliss vs Zach Coughlin
REV 2011-001708
Matthew Merliss vs Zachary Coughlin
RJC 2012-078432
Zachary Barker Coughlin vs Superior Mini

Storage
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FILED
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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
Attorney for Appellant
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
IN AND FOR THE COUNTY OF WASHOE
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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.
)
)
) CASE NO: CV11-03628
) DEPT: D7
)
)
)
)
) Opposition to Motion for Attorney's Fees
)
)
)
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Opposition to Motion for Attorney's Fees

PLEASE NOTE: ALL I DID HERE IS ADD A DECLARATION BECAUSE I AIM TO LISTEN
AND LEARN WHEN JUDGE FLANAGAN POINTS OUT SOMETHING THAT MY MOTIONS
LACK AND I AM TRYING TO GET BETTER AS AN ATTORNEY
This undersigned hereby files this Opposition to Motion for Attorney's Fees, as Attorney of Record
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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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SOMEWHAT SLAPDASH NATURE OF THIS FILING, HOWEVER, IT MUST BE EXCUSED
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TO SOME EXTENT CONSIDERING THE UNDERSIGNED JUST SPENT 12 HOURS IN JAIL
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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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ARRESTED THE UNDERSIGNED FOR "JAYWALKING" OR "FAILURE TO USE A
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SIDEWALK WHERE PRESENT" OR SOME OTHER SUCH CHARGE WHILE THE
20
UNDERSIGNED WAS IN THE COURSE OF FILMING THE DESTRUCTION OF ITEMS OF
21
PERSONAL PROPERTY (LIKE THE LAST THING THE UNDERSIGNED'S GRANDMOTHER
22
GAVE HIM BEFORE SHE DIED, LIKE THE CARICTURE DRAWING OF THE
23
24
UNDERSIGNEDS GIRLFRIEND AND DOMESTIC PARTNER FOR FIVE YEARS WHOSE 22
25
YEAR OLD COUSIN JUST DIED IN A CAR ACCIDENT DAYS AGO) PEACEABLY AND ON
26
PUBLIC PROPERTY AND AFTER A RENO PD OFFICER WHO ACTUALLY HAS SOME
27
CLASS INFORMED RICHARD HILL THAT THE UNDERSIGNED WAS NOT DOING
28
- 2

000027
ANYTHING ILLEGAL. BUT THEN IN COMES OFFICER DEL VECHIO WHO ACTUALLY
"DREW DOWN" AFTER SCREACHING TO A HALT AND VEERING ACROSS THE LANE OF
3
4
5
6
ONCOMING TRAFFIC ON THE UNDERSIGNED THIS SUMMER IN FRONT OF THE SAME

LAW OFFICE AT NIGHT DUE TO THE UNDERSIGNED'S MOUNTAIN BIKE, ALLEGEDLY
LACKING A PROPER LIGHT, AND NOTHING ELSE. TODAY, WHILE BEING ARRESTED
FOR JAYWALKING (DESPITE THE FACT THAT RICHARD HILL'S CREW OF MOVERS
HAD THEIR TRUCK PARKED IN THE MIDDLE OF THE SIDEWALK THE UNDERSIGNED
9
10
11
12
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
13
WITH FLAMING SKULLS ON IT IN A REPEATING ED HARDY INSPIRED DESIGN. THE
14
UNDERSIGNED WAS DENIED ANY PHONE CALLS AT THE WASHOE COUNTY JAIL FOR
15
AT LEAST 6 HOURS, IMMEDIATELY PLACED IN A SOLITARY CONFINEMENT STYLE
16
ICE LOCKER DESPITE HAVING MADE NO DEMONSTRATION OR RESISTENCE OR
17
18
DEMONSTRATING ANY INAPPROPRIATE CONDUCT TO THE JAIL STAFF, WHEREUPON
19
SEVERAL JAIL NURSE REFUSED TO PROVIDE MEDICAL CARE (EXCESSIVE FORCE
20
WAS USED DURING THE ARREST, WHICH APPARENTLY, WAS CONDUCTED BY AN
21
OFFICER LEEDY THAT OFFICER DEL VECHIO WAS "TRAINING", THEN MONEY WAS
22
STOLEN FROM THE UNDERSIGNED BY THE JAIL STAFF, A DEPUTY ADAMS, IN FRONT
23
24
OF DEPUTY DOCIO INFORMED THE UNDERSIGNED THAT HE "DIDN'T GIVE A SHIT IF A
25
DIPSHIT LIKE YOU HAS LIFE THREATENING MEDICAL ISSUES" AND REFUSED TO
26
SUMMON A NURSE. THE WASHOE COUNTY JAIL FOUND IT APPROPRIATE TO
27
FINALLY RELEASE THE UNDERSIGNED FROM JAIL AFTER MAKING HIM PAY SOME OF
28
- 3

000028
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
3
4
5
6
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
9
10
11
12
DRESS ONLY IN A THIN SHIRT AND JEANS, THE TEMPERATURE A FREEZING 25

DEGREES, AND THE UNDERSIGNED HAVING $2 IN HIS POCKET, WHEREUPON THE
UNDERSIGNED CALLED 911 AND WAS HUNG UP ON BY SUPERVISOR "KARI" WHO
13
INFORMED THE UNDERSIGNED THAT SHE KNEW EVERYTHING THE RENO PD COULD
14
OR WOULD DO AND THAT THEY WOULDN'T DO ANYTHING WRONG, AND THEN KARI
15
REFUSED TO DIVULGE THE IDENTITY OF THE 911 OPERATORS WHO INFORMED THE
16
UNDERSIGNED THAT HYPTHERMIA OR EXPOSURE TO COLD WEATHER DID NOT
17
18
CONSITUTE AN EMERGENCY, NEITHER WOULD A SITUATION WHERE POLICE OR
19
SHERIFF PERSONNEL WERE CONSPIRING TO MURDER SOMEONE RISE TO THE LEVEL
20
OF EMERGENCY. FINALLY THE UNDERSIGNED GOT TO HIS VEHICLE, NEAR THE
21
SIENNA HOTEL, ONLY TO PROMPTLY BE PULLED OVER BY 5-6 ARMED RENO PD
22
OFFICERS WHOM CITED THE FACT THAT THE UNDERSIGNED LICENSE PLATE WAS
23
24
GONE (IT HAD, APPARENTLY, MYSTERIOUSLY DISAPPEARED WHILE THE
25
UNDERSIGNED WAS IN JAIL FOR A CUSTODIAL ARREST FOR "JAYWALKING",
26
SOMETHING RICHARD HILL, ESQ. DID IN FRONT OF THESE VERY SAME OFFICERS
27
SEVERAL TIMES WHILE THE UNDERSIGNED WAS IN THE PATROL CAR), INCLUDING
28
- 4

000029
ONE WHOM THE UNDERSIGNED HAS SUBMITTED A COMPLAINT REGARDING TO THE
RENO PD JUST DAYS BEFORE, OFFICER NICHOLAS DURALDE, WHOM WAS PRESENT
3
4
5
6
WHEN OFFICER RON ROSA ATTEMPTED TO EXTORT A CONFESSION OR CONSENT TO

SEARCH FROM THE UNDERSIGNED DURING AN INCIDENT IN AUGUST BY, IN ROSA'S
WORDS "CALLING THE STATE BAR" AND DEFAMING THE UNDERSIGNED,
WHEREUPON OFFICER DURALDE COMMITTED EGREGIOUS POLICE MISCONDUCT. IT
IS IMPORTANT TO NOTE THAT RENO PD OFFICER CARTER PREVIOUSLY INFORMED
9
10
11
12
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
13
THE UNDERSIGNED FOR FAILURE TO STOP COMPLETELY BEFORE THE WHITE LINE
14
AT A STOP SIGN, IN A RETALIATORY FASHION, AFTER THE UNDERSIGNED LEFT
15
RICHARD HILL, ESQ.S OFFICE, WHERE RICHARD HILL HAD BEEN REFUSING TO TURN
16
OVER THE UNDERSIGNED STATE OF NEVADA DRIVER'S LICENSE FOR OVER ONE
17
18
WEEK. FURTHER, RICHARD HILL'S LICENSED CONTRACTOR (WHOM HAD
19
PREVIOUSLY SUBMITTED WHAT APPEARS TO BE A FRAUDULENT BILL FOR $1060 TO
20
BOARD UP AND "FIX A LEAK IN THE BASEMENT" (THE LEAK, HE INFORMED THE
21
UNDERSIGNED, HE ACTUALLY JUST FIXED OUT OF THE "GOODNESS OF HIS HEART")
22
AS, SOMEHOW, QUALIFYING AS "REASONABLE STORAGE, MOVING, AND
23
24
INVENTORYING EXPENSES" LANDLORD LIEN UNDER NRS 118A.490, DESPITE THE
25
FACT THAT THE CONTRACTOR USED THE UNDERSIGNED'S OWN WOOD AND
26
PLYWOOD TO BOARD UP THE PROPERTY DESPITE CHARGING $1060 FOR DOING SO
27
AND WHOM TODAY WAS THROWING AWAY THE CALIFORNIA NUEROSURGEON,
28
- 5

000030
MATTHEW JOEL MERLISS, MD.'S CARPET, WHILE RICHARD HILL WAS APPARENTLY
READYING HIMSELF TO SUE THE UNDERSIGNED BOTH FOR THE COST OF DISPOSING
3
4
5
6
IT AND FOR COST OF IT AS PROPERTY, AND BOTH OF THESE DISCOVERIES SEEMED

TO VEX THE CONTRACTOR SO COMPLETELY THAT HE FELT IS NECESSARY TO CALL
UP RICHARD HILL RIGHT AWAY AND HAVE RICHARD DO HIS THING WITH THE RENO
PD (LIKE WHEN OFFICER CARTER AND OFFICER LOPEZ ARRESTED THE
UNDERSIGNED FOR TRESPASSING DESPITE NOT ONCE IDENTYING THEMSELVES
9
10
11
12
PRIOR TO ARREST AS OFFICER AND NO ONE HAVING ASKED THE UNDERSIGNED TO

LEAVE THE PREMISES, AND WHERE THESE OFFICERS, AGAIN, STRANGELY, FOUND
THE UNDERSIGNED NOT "CANDIDATE FOR A CITATION". THE ARREST TODAY WAS
13
PARTICULARLY CONVENIENT FOR RICHARD HILL CONSIDERING IT PREVENTED ANY
14
FILMING OF THE DESTRUCTION OF PROPERTY HE WAS ENGAGING IN. RICHARD HILL
15
PREVIOUSLY GAVE THE UNDERSIGNED A BAG OF TRASH IN RESPONSE TO THE
16
UNDERSIGNED'S DEMAND THAT HILL CEASE APPLYING AN UNLAWFUL RENT
17
18
DISTRAINT TO THE UNDERSIGNED'S CLIENT'S FILES. FURTHER, WHEN THE
19
UNDERSIGNED REFERENCE THE DAMAGE RICHARD HILL WAS DOING TO CLIENT'S
20
INTERESTS IN CASES JUST LIKE THE CARPENTIER'S, RICHARD HILL, IN JUDGE
21
SFERRAZZAS COURT ROOM WATCHING THE PROCEEDINGS AND PERIODICALLY
22
CROSSING THE BAR TO PASS POST IT NOTES TO CASEY BAKER (DESPITE JUDGE
23
24
SFERRAZZA DIRECTING HILL AND OTHER WITNESSES TO LEAVE THE COURTROOM
25
UNTIL CALLED TO TESTIFY) MADE A MASTURBATORY JESTURE AND EXTREMELY
26
DISMISSIVE AND CRUDE FACIAL EXPRESSION AS IF TO SIGNAL HOW LITTLE HE
27
28
- 6

000031
CARED ABOUT THE FORECLOSURE DEFENSE OF MIDDLE CLASS AMERICANS AND
CITIZENS OF WASHOE COUNTY LIKE the undersigned's foreclosure defense clients.
3
4
5
Dated this January 13th, 2012
6
7
8
9
10
11
12
/s/ Zach Coughlin_________________

Zach Coughlin, Esq.
NV Bar No. 9473
1422 E. 9th St. #2
Reno, NV 89512
Tele: 775-338-8118
Fax: 949-667-7402
Attorney for Appellant
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 7

000032
DECLARATION OF ZACH COUGHLIN, ESQ. IN SUPPORT OF

OPPOSITION TO ATTORNEY'S FEE MOTION
1. This Declaration is made pursuant to the provisions of NRS 53.045, we are presently
in the State of Nevada and I declare under penalty of perjury that the foregoing is true
and correct.
2. Declarant is a party in this case.
3. Declarant avers that the factual statements set for above in the foregoing document
are accurate to the best of his knowledge.
4. I, Zach Coughlin, am available to testify, if necessary, as to these matters. I declare
under penalty of perjury that the foregoing is true and correct.
Executed on January 13, 2011
/S/ ZACH COUGHLIN_
ZACH COUGHLIN, ESQ.
COUNSEL OF RECORD FOR SELF
000033
AFFIRMATION Pursuant to NRS 239B.030

Also, this document does not contain any social security number or other
inappropriate material pursuant to NRS 239B.030.
DATED this January 13th, 2012
_/s/ Zach Coughlin

Zach Coughlin
Appellant
000034
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
000035
tf(,377
ORIINAl
:->.
...r:::.
COCDlTo. _
RPD1200020C
[2- f7t/
c.ua.
R\(2S0d;d- L(
.
-..aro- ===( '010
- Set PAG
RELSTO
OISSEMINAOOH IS RESTRICTED TO CA.ew. JUS1lCE AGENCIES
f\,4:"
Y?
C:H..
z..
of
REVIEWED FOR PROBAel.E CAUSe (PC)
PC FOUND 0
PC NOT FOUNO
OEFEM>AHT ORDeRED RElEASED. DATE

S-308
(REVISED 3t'06)
DATE
prababIe cause exIIta 10 hold said per.an for pAIIImInIIy hearing (II c:hIrge Is
DEClARANT
____
(5 I
d- 8Y...-_
DATE (
SECONDARY DlSSEMNATlOH TO NON-CAIMIIW. AGENCIES IS PAOHBTED.
,'IHEREFORE, DtcIatant I8QU11Sla that ftndIng be made by magIIIraIe ...

; Of misdMleanOf) 0( for till' (f c:tI8I'ge Is misdemeanof).
Page
TuJO-
qg;
SUI"""!,
TIME ______
_______
1.0.'
/Q21f
-----_a.---- . MAGISTRATE
----------
-tl ....-p::::I'
.
-. MAGISTRATE
000036
Page: _2
___
DECLARATION SUPPLEMENT
_
__
CASEt# _t=2 74
9_
-
On 1114112 at approx 2115 hn, Officers were dispatched to
report of a domestic
COUGHLIN, had been
a
ng party,
disturbance. While enroute, Officers were notified the
responsible for chronically abusing 911 over the past few days. RPD Dispatch further advised that
COUGHLIN stated he thought RPD was trying to kill him for complaining about Officers and also
thought RPD Officers st o l e his license plates. Sgt Sifre responded along with Officers due to the history
with COUGHLIN.
Upon arrival, C OUG HLIN met Officers out in front ofhis house. He video taped the interaction with his
video camera. He said he called 911 to claim his dog was missing and his two female roommates were
responsible. While Officers were speaking with the two female roommates insi de the apartment about
what happened tonight, COU GHLIN was standing outside in the parking lot near his vehicle looking
through 8 personal bag.
Officers were standing outside near COUGHLIN when he made a calIon his cell phone. He asked the
person on the other end of the phone to speak with a Reno Police Sergeant. A couple of minutes later,
Officers on scene were advised by RPD Dispatch that the reporting party from our call, COUGHLIN, was
currently on the pho ne with 911 and had called claiming an Officer was shining a flashlight in his face.
Officers and a Sergeant were on-scene at the same time he called 911 and requested to speak with another
RPD Sergeant while no emergency existed. At that point, COUGHLIN was arrested fo r misuse of91 I.
He was booked at WCSO Jail.
WHEREFORE. Declarant requests that a finding be made by a magistrate that probable cause exists 10 hold said penon ror
preliminary hearing (if charge is a felony or gross misdemeanor) or ror a trial (if charge is a misdemeanor).
REVIEWED FOR PROBABLE CAUSE (PC).
PC FOUND PC NOT FOUND --t=L
DATE:
-..,...
=-
___...,...
DECLARANT
=
"'----
ore: Schaur
=-=
-===--=
==-____ ,MAGISTRATE
DEFENDANT ORDERED RELEASED, DATE:
PAGE
____
___
_
1.0./#
10993
OP
_-_-.MAGIS=TRA::-:-:TE=;...
_-
000037
EMERGENCY COMMUNICATIONS DMSION

Incident Recording Request
Today's Date: 14 January 2012
R0006 case # 12-843 and R1110 case # 12-974
case or Inddent Number:

Date & llme(s) of Incident:
Purpose of Request:
Date:
WCSO:
RFD:
Time:
1/14/2012
2111
-------
Misuse of 911 from 01/13/12 and 01/14/12
Talk Group(.}
RENO:
Please note: recording requests require a minimum

of ten (10) calendar days to complete.
Requested:
181 RP YLW
0
we GRN1 0 we WHT1 0
RF RED
0 TMFIRE
0
RP GRN
0 PS lE2 0 Other (specify):

we GRN2 0 PS LE2
0 Other (specify):
RF ORNG 0 RF GOLD 0 Other (specify):
SHARE
-For radio trafftc: It9ln recording at

hours and end recording at
-If more than one talk gro up requested, give begin and end times for each.
hours.
Initial Phone call?

Yes
[gI No 0
What are you looking for
callers dalrns of crimes, harassing statements and his phone number
and any special
listed In the call history.
Instructions? (to make sure we
get you the right Information)
Retording Medium:
.avi file (e-mail attachment)
rzI cd 0 Call printouts
_
___ _________
___
_
Your Approving Supervisor:
...; ..;;;; .;..; II r

Sgt O.;.' M .;.;.; e ;...
i
Name and Phone Number of person to be contacted when request Is completed: J Schaur #10993
Reno Pollee Department, 334-2200
Requestor's name, agency name (if applicable) phone #
Send to: ecommops@d.reno.ny.u5 (Internet) or ecommops (Intranet)

For Emergency Communications use only:
Request Received:
Date:
TIme:
Request Received By:

Request Assigned To:
Recording Made By:
Delivered /Sent Out:
Date:
Time:
DPF1116
Rev: 07/08
000038
12974
.........
OIUO
RENO POLICE DEPARTMENT

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01/U/2012
BOX 1900
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12974
(UD/un. OJILY)
PRA
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LAW ENFORCEMENT PERSONNEL 3: ;HEGLAR -RPO-
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2l7'7 '
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fOf a report of a domestk:

On 1/14112 at approx 2115 hrs, Officers were dispatched to
disturbance. While enrouta, OffIcers were notified the reporting party, Zachary COUGHLIN, had been responsible
for chronically abusing 911 over the past few days. RPD Dispatch further advised that COUGHLIN stated he
thought RPD was trying to kill him for complaining about OffIcers and also thought RPD OffIcers stole his license
plates. Sgt Sitr. responded along with Officers due to the history with COUGHLIN.
Upon arrival, COUGHLIN met Officers out In front of his house. He video taped the interaction with his video
camera. He said he called 911 to claim his dog was missing and his two female roommates
responsible.
This call to 911 was not an emergency. Whi le Offlcers were spea ldng with the two female roommates inside the
apartment about what happened tonight. COUGHLIN
standing outside in the parking lot near his vehide
Iooldng through a personal bag.
were
was
Officer Heglar and I were standing outside near COUGHUN when he made a call on his cell phone. He asked the
person on the other end of the cell phone to speak with 8 Reno Police Sergeant A couple of minutes later,
OffIcers on scene were advised tha t the reporting party from our call was currently on the phone with 911 and had
called claiming an
Officer was shining a f1ashUght In his face.
Officers and a Sergeant were on-scene at the same time he called 911 and requested to speak with another RPO
Sergeant while no emergency existed. At that point. COUGHLIN was arrested for misuse of 911.
A records check revealed COUGHLIN has misused 911 several times over the past several days. On 1/13112 at
approx 0118 hrs, COUGHLIN called from the same cell phone number that he called from tonight In front of
Officers and claimed at tha t time that RPD
after him and stole his license plates. He also wanted to lodge
complaints about the Dispatch Supervisor and RPO Officers. He refused to leave his name a t that time.
was
Also on 1/13112, COUGHUN called 911 again from the 7-11 store at 900 Parr BI at about 0558 hrs. He called 911
and harassed the call-taker because he believed he was mistreated
ile he was in jail. He
allo upset he
was not given a ride home by jail staff. He was warned several times to stop calling 911 and was warned about
the misuse of ..
.
- 911.
wh
RlO93/SCHAOR,
JASOH
._. __ . ..
. .- .
was
-- ..._.. . .
01/24/2012 10:17
.. _
l'
].'&9. .t .!
000041
12974
Narrative
COUGHUN continued to cal 911 and did not have an emergency. He claimed he was denied S8fVica fO(
hypothermia but refused medical treatment. He then claimed he was going to sue everyone and that RPO was
going to kUI him for flUng complaints against OffIcers. He also requested RPO give him a ride. He was again
warned about the misuse of 911.
Several of the caUs made or 1/13112 were made from the same cell phone number as COUGHUN called 911
from tonight In the presence of O1ftcers while not having any type of emergency. This estabUshes repeat pattern
of behaviol of catllng 91 1 while not having an emergency. The total number of times COUGHLIN called and
abused 911 over the past few days was not available from RPO Dispatch at this time.
I requested a copy of the 911 tape recordings from RPO Olspatch for the 911 call made by COUGHUN tonight I
also included a copy of the call log from 1/13112 which details the misuse of 911 by COUGHLIN on that date and
numerous subsequent warnings about the misuse of 911.
COUGHLIN was booked at WCSO JaU.

NFO .
. R.,iotiCiiibet"
'1U0993/S,
'
JASON
....... Ai-
. 01/24/o. .10: _?
_
000042
Law incident #20130006
11'"
INCIDENT HISTORY DE:
Initiate: 00:04:32
/R120130006
01/13/12
call/Cue
Paac 1 of4
tiY .
i;
Nbr:
R0006/RP1200000843
--E&:
OO+Os.:-o8-----c:.eR4\la_:S ZD---
Pr:imaJ:Y Unit:
Jul:isdictJ.on:
Location: 900
RP)
Lec
PARR BL
0N1t
RNO (BENNIE
LN ,
39SN SB ON
Comments:
DAREA:
Beat/Stn:
1m
Em:
CUrrent:
Map Page: 1'2 fiNE
J7J:3
c15j.
U
Dispoaition:
Dispatch: 00:10:19
On.cane:
00: 14 : 27
Close:
00: 34:18
44
'r!Pe : DISTR
!'n.l :
Priority:
Page:
DIS'l'URBANCB
Page:
rDetail
00:05:58
BNTRY
:711
- pp
- CK FOR SUBJ
ABUSING 911 - AND HARRASSING .SO' S
- SUBJ BELIEVES HE lIAS MISTUATBD

IN JAIL - UPSET THAT WHBN D WAS
RELEASED THEY DIDN'T GIVI: BIH A
IUDE - PER SG'l' MADRID - SEND 2
UNITS -
00:05:58
PRIOR
00:06:34
UPDATE
00 : 06 : 34
SOPP
00:06:51
UPDATE
00:06:51
StIPP
RP BUSCK.01/08/12 @ 13:35:44 (34

MORE)
COMP:-->711 SOURCE:-->PP PBONE:-SUBJ HAS BEEN ADVD UPZAftDLY'
TO STOP CALLING 9 1 1 - BUT
CONTINUES TO DO SO - EXTREMELY
UNCOOPERATIVE - NFl \NAME:711
\PH:
\SOURCE: PP
PRI:1-->2
NO FURTHER INFOIUO.TION
'rEXT:
filc://C:\Tiburon\Rms7S 1_LlVE\Cad\Message\McssagcDisplay02.htm
000043
Law Incident #20J30006
00:07:36
MISCX
IJr '7'1'
. F.ige
2 of"
SUBJ NOW CLAIKING SBRVICJ:S AU

BZ ING DBlfIBD HOWBWR RP RU'USKD
MEDICAL FOR. CLAnam
BDHIA.
RP STAING HZ' S
--------GO-Ntr-SOZ IVIRYdRi:rs------
CLADttNG UD IS GOING '!O Ja BIM
FOR FILING C(MPLAIN'lS NaINS'.r

OFCRS; HOWEVER BE WOULD LID RPD
TO GIVB HIM A RIDB
WARNED AGAl:N
FOR 9-1-1 ABUSE - NFl

00:09:06
mscx
00:10:19
JUt REFUSES TO GIVZ HIS HAMJ: STATES BE I S AN AftORNZY

NJ'I
Cl11 ClS3
00:10:19
DISP-ENR
ID
ID
00:10!38
BACK-BR
elll H123
10
N123 (RS471)HARZZ,
00:10:19
00:10:38
00: 1 0 : 51
Clll
(Rl2301) BONN, THBW
C1S3
(Rl09S') MCCAULEY,
00:14:21
ID
CISO
00:14:27
ONSCBNB
CIS3
00:15:04
MISe
CIS!,
00:15:22
ONSCENB
00:15:52
MIse
N123
C1S3, CLERK
SCOTT A
INSRVICB Cll1
BACK-BR ciS3 e1S0
00:14:21
PA'llUCK
00:16:13
00:16:13
0 0 : 1 7: 23
BACK-OS
10
MIse
00:17:32
MISC
00:17:58
MIse
00:18:52
BACK-OS
OO:1 8: 2
ID
(RI0164)BRONBTT, MXCHABL
NO ONE AT THE p/p's
A TAXI
ADVING HE POSS LEft
H123 N145
;
H145
(R9100)BLAS,
IN
PATRICK
N123,
ZACHARY CAVANAR
ONE OJ' OUR

PERSONS OF INTEREST !'OR SIOO
6I 4
180
- REAL SHO HAIR

N123, WE DO HAVE PC FOR 911 MISUSE
Nl23, PER PRIOR CALL # 845 GLASSBS
COUGHLIN,
ZACHARY
OLN/
N123 JS38
J538
DOBI
(TM0043) GRUBER, RICK
file:I!C;\Tiburon\Rsns7SI_L1VE\Cad\Message\MessagcDisplay02.htm
111412012
000044
tPIl" ,,.-,''
Law Incident #20130006
Page 3 of 4
00:19:03
CHGLOCOS
ClUNG AREA IN
CAS. HZ' S ON I'OOT
00:19:39
MIse
N123, C395 : SBRVBD W/TPO - CANHO't
J538 ON DANDINI,
BE
W/IH
100 rt OF mJ; 1 RIVD
ROCK ADDR
00:21:36
MIse
C1S], RENO SPARKS CAN AND SBB ' Ii'
P/O
I'IlOM 711 AND WDRB Tar UB

GOING
00:22:32
MISCX
SOBJ WAS
ASlUNG FOR A
RIDE
"DOW'l'OWN NEAR THE SIENA"
00:22:34
MISC
N145, GOO! nrro DNO SPARKS CAB
00:'22:42
CHGLOC
N145
00:23:03
INSRV1:CB J538
CHGLOCOS elSO
MIse
elSO,
00:23:16
00:24:13
HE RBSIDES HiS VEH DESC:SILV/BLU HONDA COOP

838NBR/NV - DlREC'fi,Y BAST or 'l'HB
RIVER WALK ADDR WAS 1IBERE BIS VBB

WAS PARDO PER C395 - PEa el50 BIS
VBH IS STILL TBZU - RIVER ROCK
ADDR ext S OK so FAR
00:24:30
CHGLOC
00:24:36
CHGLOC
00:25:13
BACK-OS
ClS3
Ni23
e1S0 ClSS
00:25:13
IO
C1SS
00:25:16
CHGLOC
C1 5 5
00:25:18
MIse
ClS3, ltENO SPAlUCS CAB P/U AND
(Rl0474) GARLOCK,
ROBERT
DROPPED J 01'1' AT THE BANK 01'

AMERICA AT CENTER/7TH, 0020 HRS 00:26:04
CHGLOCOS
00:26:13
CHGLOC
N14S
N123
00:26:44
MISC
C1S3, PER H130 NO PC ON 911 - : BE

NEVER IDEN'rli'IBD HIMSELF VIOLM'ED THE TPO THAT WOULD
lri
HE
BB
ALL
WE HAVE RIGHT NOW
file://C:\Tiburon\Rms7S1_LlVE\Cad\Message\MessageOisplay02.htm
1I14l1012
000045
Law lDcidcnt 120130006
00:26:52
CASE
00:27:48
INSCE
00:28:39
MIse
C1S3 RP1200000843 Aasigned

C155
C153 , PBR-THE CAB DRIYBR/ JACK
30'S 600/1Q _R SK'BLK
"
"
BUt
JACD'l AND A WHIB SHIRT ,

PANTS -
00:28: 48
MISCX
C1S3, PER TO CAB DRIVER/

WMA 30'S 600/150 BLO HAIR
JACKET AND A WHID SHIRT ,
fI
JACK
"
LSW/BLK
BL1t
Pr!S 00:30:45
INSRV2CE -N145,
00:30: 47
mSRVICE 912-3
00:31:20
INSRVICI C1S0
00: 34: 19
CT.TU
OTL
00:34 : 1 8
01:55:05
C1S3 UNK
CLOSE
C153 tJNlIt
MIse
.06,
SAMB
SUBJECT
CAIT.1!!D 9-1-1
FROM HIS PERSONAL CBLL (

AT 011 8 BOORS - CALLING TO SnD
RPD IS AFDR HIM - STOLEN HIS LIC
PLT - AND LODGB I'ORImL cOHPI.AIfts
BOOT DISP StJPV AND OFCRS REFUSED HIS NAMBD AND BUNG m' ON
CISP SUPV - INFO GrvzN TO SQr
WHO AOVD WE WOULD LB!' THIS

CALL SLIDS AS SUBJ WILL LIKELY NO'!'
ANSWER HIS DOOR ANY'IIAY - IF SUBJ
CONTINUES TO CALL , PER. MAITLAND
BRONET'l'
ENTER ANOTHER CD'S

OPERATOR ASSIGNNEHTS:
RC'f2
SUPl
RR.U
RRA3
H03D
N.I'I
1U1992 PDlROD , MIRANIlA

11.4393 AVANSDO I DKRA D
11.6191 CI.NUt, JDJ!:Kf
P.91'8 aoona, BLAIHA
1U09n NCCADIoEX, PA'l'JaClt
61e:JIC:\Tiburon\Rms7S1_LIVE\Cad\Messagc\MessagcDisplay02.htm
1/1412012
000046
EMERGENCY COMMUNICATIONS DMSION

Incident Recording equest
Please note: recording reQuests teqlMe mIMn
otten (10) r days to ampletiL .
. Todcr(s Date 11January 2012
Date &. l1me(s) of
Inddent:
Date:
Talk Group(_) Raq..-ted:

RENO:
RP
r&1
RFO:
WCGRNl
RF RED
nme:
2111
----- ----
Misuse 01911 from 01/13/12 and 01/11/12
Purpose of Request:
WCSO:
l/14/29U
RP YlW
o
0 WCWHTl o
0 lMfJRE
o
SHARE
0 PS lf2 0 Other (specify):

0 PS LE2 0 Other (specify):
RF ORNG 0 RF GOlD 0 Other (specify):
we GRN2
Initial Phone call? Yes IZI No 0

What are you looking for
callers claims of atmes,
listed In the call history.
and any special
Instructions? (to mike 5ure we
get you the rfgl'tt Information)
RecOrding Medium:
.vi
harassing statements and his phone number
file (e-mai attachment)
181 cd 0 Call printouts
Supervisor: ...;: ;:.;. :..:. Ie ::... ----:

SgtO MH:.:.= r _
--
Name and Phone Number of person to be contacted when request Is completed: J Schaur 110993
Reno Police Department, 33+2200
Requestor's name, agency name (If applicable) phone #
Your Approving
ecommoQSid,reno.ny.us(Iotenlet) or ecommops(lntranetJ
For Emergency Communications use only:
Send to:
Request ReceIved;
Date:
---
Time:
---
Request Received By:

Request Assigned To:
Recordll'l9 M&de By:
OeUvered ISent Out:
Date:
Tlme:
------
DPF-I 1 16
Rev: 07/08
000047
,J/?"/I(Ip(/ r5 "y(;/ :::tl,/

"C illoPlI(',;jJ al ,'::fUll'
NJ)I, /flU
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"
H/(II
( {\fl' J) IHAFR
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f 1 IH_II. ,",
J-I\ ,"JI J.J\Ii.\H
_' f'"rnl \rr../
N,-""
,m',
\,-\,,,1,/
1\1;11'1
"II" ru h"re/h.II"" om
/,,,,, (JIf;, t' H". -' ; II

\\I_IUI
H,',,.,_ \,'\,,,/,/
'illl) Ii {;111Hilf'R /,,,,,11,,,./,,,,,

'1,','//"1.:/0.., ,I'" ;',11,/1"/0'",, ",,,..
'>"FRRI f. If/IJ. L...,'/ {"/lI,1'1I
,lull ,I n, hd"III1fi.,,,
,,,m
A IHf\ I \IF/Sf\ {.I,'"/I",,"ur'

k,".'I",, ,III, h,mll!!I1"" ,om
,January 14, :!i)I:.!

\' I. \ E:\ tAl L ON l.Y pOI (rick"Co !l\ha Lor!;,
Palri(;k King, Esq .

. \ssbt llIt Bar COllIISl'!
Stat..: Bar of :\'1:'\,1(1<1

9<-\56 Dou hle R. Bhd.
Rello. :"Jl'v;lda H95:.! I
Rc:
Zal'h;lI'Y B. CouJ.;hlin. E (l.

Nevada Hal' No. ')47:1
\Ir. f.\ing:
You and I h;1\ t' p n." ' iously discllssed "Ir, Coughl ill,
Ir. Coughlin, due tu
h is mental in!'>lahilit , la<:k of integrity, :lIld cOlllpletc inColllpctCIH.:e, con!'>titutl's a danger

to the public if ll c i!'> allo \\'\:d 10 l'Ontinu t! 10 praL'lice law, This letter is written to
di..,<:h:lrgc m
and Illy a.., ()t'iatc's rcporlin,l!, obligation s under RPC R,3, l'lea!lc wl1 idl'r
t hl' follo\\ ing :
I, U iss(m(' L', (,('.-;sill, ('\' I 0-0 1 :!4 I, .\Ith ough not ;!lllong I r. Cough ! i n's
llIo!'>1 ..,ignificdnI t.-'Ih it.:.d \ 'iola l ions. i I pl'l' '>l'lI b a good III il.:roctl 1ll of his dercl id iOI1!l, I r.
C".':->!'>in \\'iI!'! a dit.'nt of our oH'i('e, Ill' ddrauded the plallllifr. as i!'> his /IIUe/IIS opel'ulJ(/i in
'
.
dl'aling with \\ omen, Approximatl'ly ont \ car .1 flel' judgllll'nt \\ as 1..'1l1crcu a ud the GI'>e
coni..'lutlt.' d, :,\11', Co u ghli n intcl'j t'l' lt.'d hilll'>df in the <:;!se 011 hl'half of Gl'ssin. trying In
<:ollcrt 011 a sanction award ;I)!,aill.'>t oppOSlllg coullsei. II lurns out Ihat ht.'C'IUSl' he had
,
'
filed hankrupll'Y, (;/,',>,>11l nn longl ]" o\\'ns this dallll. If -{)\I look o tt the fik', you \\ill St'. t.'
Ih,lt Coughlin ,tPPt'il]'t'd ,!nd Iltl'nlilt'd;t hlltIIT\: "pal'li;,1 \, it h drawal" dOl'IIIllt.'llt 011
.
Dt'l'l'mlwr H. :.!Oll.
000048
Ll'tter to Patrit'k King, E. q.

...
. Ianuary q, :::!()1;!
Page :.!
Sub cqllcnt to that timf.' . Coughlin has heen ghost\\ riting documents that
purport to be frolll Gessin. individually. and e liling thclll for Gc'!'sin. lie is lIsing the
"Is/" for Gessin's ... ignatul'I.!. Thcse arc dearly lIot doculllcnts that arc
pn.:pared by
iglll;:d or
Ir. (;essin, and the fal'! that o lllchody (Coughlin) t! fil('s thl'm confirms he
is gho')t\\ riting \\it 1I0ut !he required discloslll'l. In addition. it appears that Coughlin
..
has fat :ilitatc d Ihc liling of \\ hat Illay hl' a fr:llldlllcnt hankruptcy Oil behalf of Gessin.
Coughlin\ lack of cOlllpelelU.:e is til'lIIollstrated ill till' Ces i!l else hy the fact that he
.
does not understand Ihe dfed on the 0\\ !ler hip of Gc!' in\ IXltelltial d ail1 l<; from
eLl'. . the claims now bL'long to the hankruptcy trustee,
Gcssin hav ing filed a hankruptcy,

not Gcssin.)
As with all uf the m;ltters refef('nccd helm". 1 strollbly SUAAcst that you
l'on!al'l the Second Judicial Oislrit;t Court and get e filiJlg access to the tases mentioned
so you tan look at the docllments yourself. (;1:1(\(' 'Iall. Esq. . is opposing counsel in that
ca (' and lIIay be of help to you.
:.!.
':U1I informed and Iwlicvc that ;\1r. Coughlin was re cently convicted of a
theft crime in 1{l.'IlO ).Iunieip;t i Court. I am further infurmed that Ihe malleI' arises Ollt of
shoplifting al Walmar!. ThaI case is presently Oil appeal to the district court in case
number CR11 :.!()64.
I r. Coughlin is n..:pre cnting himself.
3. ;\1r. Coughlin is prl....lntly fadng criminal ehaq.!,cs I't'garding the theft of

.
an iPod. Thill is pt..nding in Reno .Ju ticc Co urt as l'ase numher RCR:.!OIIo63341. I
h,I\e reviewed the file.
'
Ir. Coughlin got into ome sort ()f;lr lIment with his public
deft..'IHkr. :-\ a ['eslllt, he was rcfCITl.'d Oilt for a com pdlllt:)' eva IliaIiOIt.
.
I{'rliss, a ph ... il.'ian from Chi/o. C;llifornia.
Dr. :'\Icrliss O\\'JlS the propel'l) al I:.!I Ri\ 'er Rock SIred. Reno, ;.Je\ada. Beginning in
Ia n.:h :.!OIO, Ihl' property was leased to I['. Coughlin and his thcngirlfriend. The lcase
4 \\'t' I'l.'prl. '...ent Dr.
Iatlhc\\'
expired in Fehruar) mII. The girlfriend left the eommunity in appro\illl:tlt.:I)

:.
Iay:.w II.
Dr. ;\Ierlio;... cunl.lded us in appro:\illlatdy :\\lgu 1 2011 10 assi 1 in e \ it..: t ing Ir.
Coughlin. Coughli n had not paid rcnl or utilitics ...int..c ;\1:1)'. lie tOlltcnded that there
were habitability iS llt: s wilh the property that justified his with holding ren!. All of his
daims \\'l'I't.' t!etidt..d ad \l' 1''';l.'I) to Iii... po-;ition at the evil'tion hcari11).;. ,Jlistin' of the
Peace Pl'll'r Sfl'rM"I ortiel't.'d CO I I ).\ h I in l.'\ il'ted from Ihe pn'lH ise-; effecti\'c :-Jo\ 'cmbel' I.
:.!Oll. 011 thdt datl', the Wa!ihoc COllllt) Shcrifrs Department performed their llol'ln,iI
c\ictioll procedllrl': locks wcre chall ed and the e\ idion notice \\a... po:-.ted Oil thl! front
d oor. \\'t' \ idl. otapl'd the hOllle <lnd it..; l'Illltl.nts .It thilt Inlle. Upon IIIspeltion over the
'
lIe:\1 ft'\\' days, It IWc:lIHe apparent Ih<ll "solllebody" \\as hn'aking into the home Oil a
.
fl',t!,ul.lr h;l is.
On Sunday,
f)\l'ml1t'r IJ, :'!OII. Ik
krliss came to lo \\ n . and I met him
.11 the hUIIll.' tin Rl\er Rock Stred . .h \\l.' \\;llked through thl' homt:. it \1;Is OhVUlUS that
000049
Ll'Itt.'r to Patrid" King, E::.q.

,January q, :..!Ol:..!
Pagc
SOIlH'Ollt' had bel'n in thl.'rc ::.illt'\! [ had last bccll in scvcral da s befort'. Dr.
lcrli'is
discO\l'[wl that thc baselllcnt door \\'a barrit"adt'u (nol lol'kcd) from the inside. The
RCIIO Polil'e Dcpartlllcnt was SUIIIlllo[H.:d. Thcy tried to l'O:!X whoc\cr \\a in the
'
ha::.t.'nH..'llt out, \\ithIHlt succesS. Aftcr Dr.
Ierliss had tl) kick the door down, it was
di l'O\'l'rcd that ;\11', Coughlin had hroken ill and was 1i\illg in the hasement. lie \\3S
arrc::.ted and is presently facing criminal trespass l'harge in Reno
ll1nicipal Com\. See
case no. [I CR 2(q()S :!I. lie is also fad II.):; a t"ontclIlpt lIlotioll ill frollt of,Judge Sfer:tna
ill the c\'ktion ca:-.c..Judge Sferal.la has sta)ed that mattcr pending the resolution of the
tTiminal trial. That lrial wa sc.:heduled for January 10. :!Ol:l, hut W:IS continued at the
re(llIc t of Ir. Cuughlill' ncw attorney.
s. The eviction order is now Oil ;tppeal to the Second ,Judicial District
Court. Sec c.:ase ('\'11(J: 6:!8. pending in I)clxlrtlllent 7. A, part \ If t he eviction pro('css,
;, licll \\a asscrkd again t the per onal property that Coughlin left bchind at the home.
011 :'\!ovclllber 16,
OI1. Coughlin filed a motion to contesl thc landlord's licll ill the Reno
,Ju"tit'c Court. The l;ourt tried to promptly set a hearing, hut Coughlin refused to
cooperate in :,ctting the matter, ilild the court took it uff calendar. Coughlin then rl'
illitiatl'd that prol'l!SS and a hearing was Ill 'lll in Ikn:JIlber. <1( which time tilt.! court heard
l'\ idclH'c of Coughl in 's lack of l'oopt.'ration in ::'t.,tling the :-.Jo \'elllher hearing. You ma
also \\ant lo t'Ont;u:t RCllo ./ustil'l' Court staff. alit! ill particular, c.:hidderk Karcn St;\Ilcil.
Ir. Coughlin's ahu i\l trealmcnt of hcr and her staff. Aftt.'r the hl 'aring, thc court
iS lIed all Order granting Coughlin a two-day time window to rCIllO\'C his personal
ahout
propcrty. The first day was ThurSliay, Dcccmber :!:!, 20 I I . Aftcr Coughlin was allowed
into the home that first day, hc sCllt Otlt an ('-mail to the dfect that becau c he had
appealed .Judge Sferal..L.a's order, he Has entitled to a stay of proc.:ccdings and wasgoing
to reSUJlle livingin the hllllle, :\s a result, he did very little to remuve any of his persoJlal
properly that day, 011 Friday. Dec.:c/Ilber ::!3, :.WII, after he learncd, again, that his stay
had heell denied. Coughlin a...scmbled a small c.:rcw and tllt.,\, were able to I'l'!lIO\'e a
'
LJb t;tntial.I111()llnt of hi pcrsonal propcrly. (YOII Ill'eu to understand that Ir.
Coughlin is a hoarder. \Ve have the photo!' anu \idl'oS if you wOlild like \0 sec thCIlI,)
'
Ilowe\l'r. :,\11'. Coughlill did lIot get all nf his propcrty out. For c:\amplc, I c.:ollllied [3l';!r
seats th;tt he had 'iomehow managed (0 get <10\\n into the hasemcilt.
11;[\ing failed to remo\'e all of his bdoll),\ings, i\lr. C(Hlghlin thell tllovt'd
hdort. ' .J IIdge Fla naga n for ;1 telll porary re tra iIIin!; order to prC\'l'JIt Ihe d i p(lo;a I of hi
"baIlllc)[It:.'J PI'OI)L' rt\ in accordillll'C \\ itII ,I udge SfCr:lU;l'S order. . \tt:lc.:llcd i :\ Ir.
Coughllll' s mot ion, Illy officl'" opposi (ion, and Ir. CoughIiII's rl'pl). The l' lIncu \llellts
demonstrate i\lr. Coughlin's i.:olllpll,tl' ,IIU!lIl1l'[' ilH.:ompetellce as:ln attorney.
OIl .J.ll1l1ar II, :!Ol:.!, Judge I'lanagan dt'nil 'd Ir. Coughlin's l'l'qUi..':-.1 for ,I
tl'llIpOr,tn rl' t['ailll\lg onll'l'. On,l.tllll,try I :! , :!Oll, the contrat"tor hirl'd to c.:!L'.IJl tht:.'
hOll l' l'OIllIlll'llcl'd \\()["k, :'\.11'. Coughlin !lagged the contral.'lor dowlI in traffic \\hen hl'
(tIll' cOJltractor) \\,\'> 011 hb \\;t) to tht.' dump \\ilh the abandoned propt.'rt) from the
hOIllt'. ( olighlill l':tl i ed tIlt.' polin.', who drri\l'd at tht:.' tran:-.fer statioll. Coughlin \\'a,
LilSt'l\ aS i..'rting th.1I till' contral'tor had tried to run him Inl'\'. lie also told the polict'
.
'
000050
I.etter to Patrick King, Esq .

.January 14. 201:!
Page 4
that the conlrador had "tolen his possessions. Aftel' [ presented the court orders to the
police. the contra(tol' was :lIlo\\'e(\ to proceed. At their instrlldion, I h:l\ e now had a '['PO
i,,:-;uf..d :l)!,ainst Cou)!,hlin b) Rello Ju!:>ti...:e Court.

[Iowe\ l'r, bdore the lontra...:tor L'OlIld )!,et balk to the River Ro...:k house,
Coughlin was there. J Ie had his \ ideo camera and \\as walking, up and down the street
sl.:rcalllin)!, and ) elling at the polil:e, at the ('ontrador. and at mc. when I arrived. ).1r.
Coughlin ended up being :lrre:,ted and taken to jail. The police informed me that
hl.'L'ause of the number and types of contad thc)' h:1\ e had ",ith him, he is 110 longer
d igiblc for L'itaIions in t he ('veilI of infrad ions.

Enclo l'd ()II \\ill find a copy of a supplemental document filed by ).11'.
Coughlin 011 .Janll:ll 1:3. :.:012, and sent to my staff and I hy em:'!il frolll Coughlin Ihal
tIIorniug. Please note that the atturney designation Oil the first page indicates that it is
being t1led by Coughlin as 'lppellant. You will note that the captioll is from a differellt
casc, It is IIlldcilr ill which L'a:-,c ).11'. COll)!,hlin intended 10 file this document. although,
bel:<llIse of the else tllllnbl'r and the caption, it appcar to ha\'e ultimately heen routed 10
the Carpentier ...:use
(C\'u
OI709)
and not the eviction appeal case
(CVII o: 628).
I am
told that ('(lulls....1 in thc captioned casc llIay also be in the prOl:CSS of filing a har
complaint "WI in", Coughlin.
n. \\'hl'll the hOllse was sel:ured after Coughlin 's arrest. \\'C found a crack
pipe alill a hag of what apPl.'ared to he marijuana. The l:Olltral'lor also reported findill)!, a
hox of pills and a \ ial uf some sort. We understand Coughlin has un lIcccssflllly tried
till' I.;nn l. r::; Concerned for I.a\\ yel'''' progl'mn. und th:lt he has a hbtorv of suhstance
.
prohk'n;:-;,
.
), 11'. Coughlin has filed t\\O la\\'suits again!:>t his fOl'lller el11plo) er,
\\'a:-.hol' IA.'gal Ser\'ice . Ill' has ::illed all of the hoard of diret:lol's and t he management of
IIIt'l.'Olllpany. Both cases h:l\'e nuw heen disll1isst'd. Both cases demonstrate his lack of
l'ompt.'It.'IIL'C. I suggest
oIlC()tllacl.J()scph Garin. E,"'q., itl Las \'eg:ls, :IS he was cOlIll el
for thl' defendant:-; in thatC<lSt.'. You may want to cunlad Paul Elcano. Esq., Ihe direclor
of \Va" hOl' I.l'g'!I St.'I'\'iL"l' .
K. ).Ir. COIl hlin has a hahit of iniliating ca es and a:-;king to pmcceti ill
-'orllll/ })(I1II)('l'i:>. Ill.' has dOlll':-;O in cases against I11l. m)' office, m)' dien!, and WaslH>l'
I.lgal Sl'rvi...cs. You will find thCl1l if you run a search for Coughlin Z 011 the Second
.Juciil.'ial Dj.,trict Court \\('h:-.itc. The courts that howe rcvicwcd the documents ha\'e
gl'lIl'l'ally lh.'nied his n. qlll... IS. What is of note is th.lt his reprcselltatiolls in the
p plicat io tiS to pron'('d i/I );"'/I/a 1)(1II11C't'is a t'i i ll"':ollsi:-;tl'lI t \\ itIt and cunlra I'V to 11lL'
..
'
npl'l....clliation'i th:11 lit' lIa... made to .Judgl. FbnaJ!,an III the nHllt:\t of sl'l.'kin .1
tlmpoJ'ar.' rl...tr<linin onkr. Un 11lL' OIh,' hand. he tells lile (:Olll't he i ... hl'Oke and has lIll
propel'ty lIId on tIll' other hand, he IS tdlill)!, the ('ollrt that he has a gl'l':lt deal of
\ ,tllIOlhle propcrty :11 Ihe home that tleeds to hl.' protccll'd. This delllonstratcs a gro ...
tHk of cilndor \\ith till' lrihun:ds with \\ hidl he <.leak
a
000051
l.ettl'r tt) Patl irk King. :I "-'q.

. January 14. :..!Ol:..!
Page .')
9. COll h1in has also tried to file a casc against me. my as ol'iate. my dient.
.lIld others, including the Reno .]u!'!licc Court. It is I1lso to he found Oil tht! \\'L'bsite.
.JudgL' Stclnheimcr has ruled that he did not comply with
10.
RCP 8.
Coughlin's hch:1\ior was unusual to !)tart, and has become more and
more hi 1.:1l"J"e during thL' lime we havL' hL'en dealing with him. lie scl'\cs p:'pcrs hc dOl'!'t
not filt'. ;lnd lites papers he ducs nol SCI"\"C. Ill' I.:onsistenlly SigiiS l'l.'rtifiealcs of service
that he has mailed tu u!). but we have
received all\lhing from him by mail. Ill.' has
posted videos of Ihe evil:! ion service attempts and parts of the trial on YouTuhe.
including some rel.:onlings he secrdly made ill court with his ccllphnne.
II.
Another example of his incompetence is that he does nol understand
whal orders arc. :l.Ild arc 1101. apPf'alahle. ! Ie does not understand I h:lt filing a notice of
appeal di\e!)ts the 10\\'e!" court of jurbdil:!iotl.
I am confident Ihat once you look into this matter, )OU \\ill ':lgn.:c that ,\11'.
Coughlin !)hould nOI he pral'licing Ia\\. Ill' is a danger to the comlllllllity.
Sillcel"ely.
lSI
Richard G. Iii!!
RGII:kn
Enclosures:
-Coughlin .\lIlcllllcd Emergency .\Iolion for Restraining Order
-:\lcrliss Oppositiull to .\Iolion forTRO
-Coughlin Reply ttl Opposition to .\lotioll fOl" TRO
Supplemental Reply tu Opposition dated l/q/12
000052
Laura Peters
David Clark
Monday, January 23,
Fro m :
Sent:
To:
Subject:
2012 6:02 PM
laura Peters
FW: Attorney
I guess this is s
reporting under SCR 111
a self-report_
David A Clark
Bar Counsel
State Bar of Nevada
600 East Charleston Blvd_
Las Vegas, NV 89104
(7 02) 317-1444-direct
1800) 254-2797
(702) 382-8747- fax
--
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_-_ ...
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From: Zach Coughlin [mailto:zachcoughlln@hotmaitcom]
Sent:
Monday, January 23, 2012 3:18 PM
To: David aark
Subject: Attorney reporting under SCR
111
Dear Bar Counsel Oark,
It has recently come to my attention that Nevada Supreme Court Rule 111 may apply to a crfmlnal conviction I
received (and for whIch an appeal is currently pending) in Reno Municipal Court in case RMC 11 CR
22176 for the
offense of petit larceny of a chocolate bar and some cough drops_

Supreme Court has obligation in dlscfpllnary proceeding to look beyond label given to attorney's
conviction to true nature
of facts, in order to detennine whether underlying circumstances of conviction warrant discipline_
Sup.ct_Rules, Rule 111,
subd_ 3_ State Bar of NevadaV. Qajboroe. 1988, 756 P,2d 464, 104 Ney. 115.
Sincerely,
Zach Coughlin, ESQ.

1422 E. 9th St. #2
RENO, NV 89512
tel: 775 33B BlIB
fax: 949 667 7402
nail,
ZachCoughlin@hotrCQOl
Nevada Bar No: 9473
000053
02979
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Document Code:
Zach Coughlin,Esq.
NV Bar No: 9473 (currently suspended)
PO BOX 3961
Reno, NV 89505
Tel and Fax: 949 667 7402
Plaintiff/Sub-Tenant
IN THE JUSTICE COURT OF RENO TOWNSHIP

IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA
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ACG-APMI, INC. DBA NORTHWINDS

)
APARTMENTS; DWAYNE JAKOB,
)
Individually and in his capacity as property
)
manager for NORTHWINDS APARTMENTS; ) CASE NO: RJC Rev2012-001048
NEVADA COURTS SERVICES, LLC (NCS); )
JEFF CHANDLER, Individually and in his
) DEPT. NO: 4
capacity as owner and CEO of NCS;R. WRAY, )
Individually and in his capacity as licensed
)
process server for NCS;NORTHWIND
)
APARTMENT ASSOC LLC 1031 XPRESS )
NORTHWIND LLC 110 110TH AVE NE
STE 550 BELLEVUE, WA 98004 Description
Summary
Fictitious Firm Name Counter 74040 04/01/1997 12:00:00 AM
Expiration Date: 04/01/2002 Business Name:
NORTHWIND APARTMENTS Owners:
NORTHWIND APARTMENT ASSOCIATES,
LLC
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Landlord,
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vs.
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ZACHARY BARKER COUGHLIN;
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Tenant
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REQUEST FOR SUBMISSION OF COUGHLIN'S MOTION TO SET ASIDE ORDER OF

SUMMARY EVICTION OF JUNE 27TH, 2012; or, plead in the alternative, Supplement to
- 1/34 REQUEST FOR SUBMISSION OF COUGHLIN'S MOTION TO SET ASIDE ORDER OF SUMMARY EVICTION OF JUNE
27TH, 2012; or, plead in the alternative, Supplement to Coughlin's Motion to Set Aside Summary Eviction Order and ORder follwing
Hearing on July 31st, 2011
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Coughlin's Motion to Set Aside Summary Eviction Order and ORder follwing Hearing on July
31st, 2011
COMES NOW, ZACH COUGHLIN, ESQ., and files the above titled document and request
that the Motion to Set Aside the June 28th, 2012 Lockout Order by submitted to the Judge for a
decision. he and him and him and him and Jeff Chandler Nevada court services are making of the
court wait a second that's lovely to this they put the word court in the name and their business then
they bang on people's doors and leave out the Nevada bed and just say court services in and allowed
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angry tone while dressed up looking like Sheriffs,,, you really have to hand it to this guy Jeff
Chandler he is a master of manipulation and intimidation upon hapless tenants he has his crew and
himself dress up looking like they're the got damn Sheriff then they'd put the word court in there after
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name who would possibly not do everything they say and even if you do failed to do it they say they
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will try and break into your rental and all were rental as they have on Coughlin on numerous
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occasions will Coughlin got arrested for trespassing various made up charges that the law local law
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enforcement have brought Coughlin whether to afraid to charge in the trespass Nevada court services
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his escape prosecution despite that date and can this captured on tape when behind of a closed
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backyard gate Coughlin's law office and banged on Windows for 30 and 40 min. at a time three times
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a day while they have another guy ringing the doorbell over and over and over and issued taunts to
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anyone inside Coughlin's former law office. Ahen R. WrayJuly 31st, 2012 Hearing was not noticed
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for the purposes of disposing of any such Motion, and further, the Order following that hearing
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purported to rule on matters not connected to Unit 29 (mentioning unit 45 in the Order), which,
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would necessarily make the Order, under NRS 40.400 and NRCP 60(b)(4), void for lack jurisdiction.
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Being that a tolling Motion has not been disposed of in this matter, there may still be an appeal, as
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the deadline to file one has not run. Legislatures make the law. NRCP 11 provides corporations,
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such as the ones that own and run Northwinds Apartments (doing business in 10 states, not some
Mom 'n Pop operation) cannot appear pro se...and nothing in NRS 118A, NRS 118, or NRS 40
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changes that. There might be something allowing a "landlord's agent" to post a notice (maybe,
maybe not), but there is nothing allowing one to practice law. But...if Coughlin's law license is
suspended...does that mean he can open up shop and start representing clients in landlord tenants
matter before the RJC for a fee? Just like Northwinds? Northwind's Web site contains the following
text: " Nevada Court Services...An Eviction, Process Service & Consulting Company,,,Northern
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Nevada Eviction Service Northern Nevada's only Professionally Licensed, Fully Insured and
Uniformed Eviction Agency...Reno / Sparks Eviction Services Professionally Licensed and Fully
Insured Private Agency We provide your property with Workers Comp. Insurance and State of
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Nevada Licensing NON- PAYMENT OF RENT NOTICES Prepare & Service Package We will
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Prepare Serve / Post your notice. We will fax your notice to your office and hold the original or mail
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the original with the affidavit to you upon request. NOTE: You must calendar your Lock Out date
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and call our office should you need the Lock Out. $40.00 per notice + mileage if applicable Full
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Service Package We will prepare your notices. (Including all Types of Notices to meet your needs)
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We will Serve / Post your notice. Prepare the return of service for the court should your Notice go to
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Lock Out. Track by computer the number of days prior to the first available Lock Out date. We will
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prepare your Lock Out Affidavit, pick up your checks if necessary and file with the court . We will
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make the arrangements with the Sheriff's Office and appear on your behalf at the Lock Out.". There
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is nothing wrong with Coughlin. And mincing explanations that these Orders are not "personally...I
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am sorry you are in this situation, its nothing personal...." do not change the fact that Judges apply
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the law, while legislatures enact the law, and that the law must be so applied faithfully and without
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prejudice or conflict, even where Coughlin is currently at odds with some in the Washoe County
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District Attorney's Office and some individual's spent most of their career so far there. Further, it
was impermissible to base Coughlin's bail in the arrest incident to this matter RCR2012-067980 on
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pending criminal charges under some totality of the circumstances theory. Bench Book Courts of
Limited Jurisdiction 2008 and 2010 Supplement. Bail may be for one thing and one thing only, to
ensure the defendant's appearance at trial.
incident to the NOtice served on my rental at Northwind Apartments 1680

Sky Mountin Drive unit 29 on June 28th, 2012. I believe the tenant's
affidavit I filed in response to that 5 day notice should be given a brand new
case number, though the designation by ncs that it was an "Amended
NOtice" pursuant to is is is is is is is isis it is as if the isthe 6/14/12 one (the
one R. Wray lied about effecting "personal service" on me of, which got me
arrested just before I was to fax to the RJC, by noon, a Tenant's Answer or
MOtion to Dismiss for failure to state a cause of action or deficieny of
service of process or something (I arguably needn't have even filed
anything in the RJC where the 6/14/12 notice listed Sparks Justice Court.
Oh, it gets better...Nevada Courts services filed a Landlord's Affidavit
attesting to have rented Coughlin a "dwelling" which is defined as a
"sleeping place or residence" in NRS 118A...and pursued an eviction under
NRS 118A...citing a breach by Coughlin for allegedly using the unit 29 for
a residence or sleeping place, instead of pursuing NRS 40.760 or NRS
118.475 eviction remedies (which, by the way, may result in the Sheriff
evicting Coughlin or forcing him to quit any alleged use of Unit 29 as a
"dwelling place or residence", but YOU WILL NOT THAT UNDER
THOSE STATUTES COUGHLIN WOULD BE ALLOWED, UNDER
THE LAW TO CONINUTE STORING AND ACCESSING HIS
PROPERTY THERE!!!!CAN'T HAVE IT BOTH WAYS ALL THE
TIME, GUYS. Oh, also, who in the hell signed the Landlord's affidavit?
There is no textual indication of whom the solitary letter of a "signature"
belongs to....maybe because it would be a NRCP 11 violation for a
corporation to appear "pro se", especially where represented by someone
committing the unauthoried practice of law?
000057
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R. Wray made some interesting statements on the video of the 6/28/12

arrest filmed by Coughlin, especially concerning Coughlin's contention that
Wray and NOrthwind's Dwane Jakob's attempts to break and enter and
trespass into Unit 29 constituted "personally serving" Coughlin a 5 day
Unlawful Detainer Notice on 6/14/12. If NCS did not "personally serve"
Coughlin, then Coughlin would have had until June 28th, 2012 at noon at
the earliest (and arguably until the close of business at 5pm on 6/28/12 to
file a response (ie Tenant's Answer or MOtion to Dismiss, etc), in Sparks
Justice Court OR EVEN in REno Justice Court. Coughlin was arrested at
10:30 am on 6/28/12, thereby, under color of law, the WCSO, NCS and
NOrthwind and Jakob fraudulently prevented Coughlin from filing (if he
did not already previously, espeically in the 6/13/12 faxes that are
mysteriously unaccounted for in rJC files) a Tenan'ts Response (tEnan'ts
answer, or Tenant's AFfidavit or Motion to Dismiss, etc.).
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So, R. Wray and NCS, its kind of a big deal that you lied about effecting
personal service on 6/14/12 of the 5 day notice.
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Coughlin has three different version of that notice or "Declaration of

Srevice by License PRocess SErver" R. Wray. in one, a time of 9:23
(presumably am, but that is not circled, nor is pm) on 6/14/12 is listed, and
a rubber stamp indicating "r. wray", is there, along with a hadnwritten "reg
#r-043948" is there. that Declaration indicates that R. WRay "personally
served" the partey named, Coughlin. Oddly, this first version (and all three
of these are in the RJC file in rev2012-001048) instead of "jennifer
Chandler" being in , I guess, the signature line for the "agent" of the
landlrod (and she always just places a "rubber stamp" of her name
anyways..", instead of Jennifer Chandler, on the one 6/14/12 5 day NOtice
(and all version sof this notice have checks on box 3 and 6, which read "3.
Recieved a 5 day notice of possible unlawful detiner for failure to comply
with the rental agreement....6. Remained in possesion of the premises
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000058
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subject to the provision of Chpater 118A of the NRS after having failed to
perform the basic or contractual obligations imposed upon you by that
Chapter, namey (SEE ATTAChed)" though the "attached just seems to
include a copy of the "Rental Agreement" with no real indication of how
Coughlin was in violation of it, and no indication of why NOrthwinds feels
Coughlin remained in violation thereof despite Coughlin's written
communications indicating that he was not in breach. Anyways, rather tha
a rubber stamp indicating "jennifer Chandler" on that one 5 day notice, the
one where WRay actually affixes his actual signature, follow by a handwritt
r-043948 (his licensed process sever number), the spot usually baring the
"Jennifer Chandler" rubber stamp is instead taken up by a signature by
Nevada Court Services resient notary public HB Cedomio....AGain, there is
no time listed on that first version of the NOtice or which includeds at the
bottom the "Declaration of Service...."
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In the second version of the "notice of Unlawful detainer..." served on June 14th, 2012, in his
"Declaration of Service by Licnese process Server" (which, arguably inovkes the "penalty of
perjury dicate of NRS 53.045...) Wray against declares he personally served Coughlin, with a
time of 9:23 indicated, and a rubber stamp of "R. Wray" on the signature line, with a
handwritten "REg #R-043948" (and that version was faxed by the Sparks Justice Court to the
Reno Justice Court on June 28th, 2012 at 11:05 am, (in a 13 page fax, many pages of which are
not in the RJC file, though that fax does included the header from the fax from Coughlin to the
"Sparks Justice Court on 6 26 12 at 12:00pm, which was a 10 page fax, and the versio of the
6/14/12 5 day notice with Declartion of Service by r. Wray indicating a time of 9:23 is page 6 of
10 of Coguhlin's fax to the Sparks Justice Couer (according to the fax hearders) while also being
page 12 of teh June 28th, 2012 fax from the Sparks Justice court to the Reno Justice Court. right
about the moment Coughlin was being placed in WCSO Deputy Machen squad or patrol vehicle
for transprot to the jail, where Coughlin would be forced to fork over some more bail, etc., etc.
IN the Third version of the "Declaration of Service" on the same June 14th, 2012 "NOTICE OF
UNLAWFUL DETAINER FOR FAILURE TO VACATE PREMISES ..This third version of
his 6/14/12 Declaration of Service by Licensed PRocess Serve R. Wray has the typical "jennifer
chandler" rubber stamp for the NOtice half of the page, and has a rubber stamp for "?R.wray",
along with a clearly differt handwrirtn note of "reg# r043" (obviously, aside from the
handwriting "analysis" the handwrittn numberical indication of the process servicer number is
truncated on this third version by 3 numbers). Additionaly this third version indicates it was
"personally served" at 12:54 pm.
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Why all the different versions? why, if personally service was effect at 9:23 am, woud R. Wray
need to return and do it again, all for Unit 29, nmin you only (all the other Declartions of
Service from that date of 6/14/12 , ie for units 45 and 71, indicate that Wray merely posted teh
notice to the rented property (and therefore would entail 3 more days fro mailing to get
"construtive notice" under NRCP 6(e) and NRCP 5(b)(2), which landlord's like Northwinds just
hate.
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Then there is the fact that NCS snuck into the file later a whole nother type
of notice, one under NRS 40.760...which, of course, changes everything..
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OF course, Wray did not "personally serve" Coughlin. Wray attempts to

make some half-baked argument about how he slid (after failing in his
attempts to break and enter and trespass in to Unit 29 on 6/14/29) the 5 day
UD Notice into a crack in the door of the rental, and perceived it to "move"
after he let go of it, thereby, apparently, entitling him to assert that he
effected "personal service" upon tenant Zach Coughlin, or, apparently,
otherwise complied with NRCP 5, and therefore cut short the time for
Coughlin to respond as a tenant and secure a hearing (rather than be
incarcerated after having unknown violent sounding figures (flashbacks to
other interactions with Nevada Court Services) banging on his doors,
refusing to indentify themselves, then ultimately taking a chainsaw (or
sawz-all) to a metal door to a confined windowless rental.
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NRS 40.400 makes NRCP the applicable rules here, not JCRCP, nor
JCRRT:
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RULE 5. SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS
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Rule
Drafters Note
Commentary
(a) Service: When Required. Except as otherwise provided in these rules, every order required
by its terms to be served, every pleading subsequent to the original complaint unless the court
otherwise orders because of numerous defendants, every paper relating to discovery required to
be served upon a party unless the court otherwise orders, every written motion other than one
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which may be heard ex parte, and every written notice, appearance, demand, offer of judgment,
designation of record on appeal, and similar paper shall be served upon each of the parties. No
service need be made on parties in default for failure to appear except that pleadings asserting
new or additional claims for relief against them shall be served upon them in the manner
provided for service of summons in Rule 4.
[As amended; effective September 27, 1971.]
(b) Same: How Made.
(1) Whenever under these rules service is required or permitted to be made upon a party
represented by an attorney, the service shall be made upon the attorney unless the court orders
that service be made upon the party.
(2) Service under this rule is made by:
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(A) Delivering a copy to the attorney or the party by:
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(i) handing it to the attorney or to the party;

(ii) leaving it at the attorneys or partys office with a clerk or other person in charge, or if there
is no one in charge, leaving it in a conspicuous place in the office; or
(iii) if the office is closed or the person to be served has no office, leaving it at the persons
dwelling house or usual place of abode with some person of suitable age and discretion residing
there.
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(B) Mailing a copy to the attorney or the party at his or her last known address. Service by mail
is complete on mailing; provided, however, a motion, answer or other document constituting the
initial appearance of a party must also, if served by mail, be filed within the time allowed for
service; and provided further, that after such initial appearance, service by mail be made only by
mailing from a point within the State of Nevada.
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(C) If the attorney or the party has no known address, leaving a copy with the clerk of the court.
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(D) Delivering a copy by electronic means if the attorney or the party served has consented to
service by electronic means. Service by electronic means is complete on transmission provided,
however, a motion, answer or other document constituting the initial appearance of a party must
also, if served by electronic means, be filed within the time allowed for service. The served
attorneys or partys consent to service by electronic means shall be expressly stated and filed in
writing with the clerk of the court and served on the other parties to the action. The written
consent shall identify:
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(i) the persons upon whom service must be made;
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(ii) the appropriate address or location for such service, such as the electronic-mail address or
facsimile number;
(iii) the format to be used for attachments; and
(iv) any other limits on the scope or duration of the consent.
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An attorneys or partys consent shall remain effective until expressly revoked or until the
representation of a party changes through entry, withdrawal, or substitution of counsel. An
attorney or party who has consented to service by electronic means shall, within 10 days after
any change of electronic-mail address or facsimile number, serve and file notice of the new
electronic-mail address or facsimile number.
(3) Service by electronic means under Rule 5(b)(2)(D) is not effective if the party making
service learns that the attempted service did not reach the person to be served.
(4) Proof of service may be made by certificate of an attorney or of the attorneys employee, or
by written admission, or by affidavit, or other proof satisfactory to the court. Failure to make
proof of service shall not affect the validity of service"
In the legal work drafted and filed by a non-attorney, a criminal violation in NCS's and Jeff
Chandler's committing the authorized practice of law (what happens to people doing plastic
surgery without a license? jail time, lots of it...because something could go badly, badly wrong
and people could get hurt...like Coughlin got hurt, damaged, arrested, financially destroyed, etc.,
etc. here. thin skull plaintiff, consequential damages Winchell v Schiff 2008 case seafood,
storage place lost business and lost profits $300K damages, etc.. while in jail Coughlin was
prevented from filing in matters that ultimately wound up with a $40,050 judgment against
Coughlin, and there's more, for which NOrthwind, and NCS, Chandler and WRay, and perhaps,
some others, will be liable.). In the "Affidavit of Landlord for Breach" filed on June 27th, 2012
by ,well, who knows, given it just says "Lanldord" and has what appear s to be a handwritten
"S" in the signature line...but, lets say it was filed by Jeff Chandler, whom crossed the bar and
argued before Judge Pearson on July 31st, 2011 in REv2012-001048 on behalf of his "client'
Northwind Apartments, Associates LLC (see acg-ampi.com, doing business in 10 states, kinda
seems like they could afford and attorney rather than destroy our community with hack pretend
lawyers who play dress as a Sheriff and bully peopel while attempting to break and enter and
trespass...and then RPD Alan Weaver and SArgent Oliver Miller, and WCSO Deputy John
Machen and Deputy Gomez chip in some Soldal v. Cook County violating 1983 violations as
well....puke, puke. puke... IN the "Affidavit of Landlord for Breach" that Chandler drafted and
filed, he wrote, at paragraph 4. "him and nation surrender of the premises was to have taken
place on or before June 13, 2012. That legal notice has been served on the tenant's in accordance
with the provisions of NRS chapter 40.280 as amended on 6/14/12."
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Chandler's Affidavit of Landlord for Breach demonstrates a lack of candor to the tribunal, which
would be professional misconduct to report to the SBN, but, Chadler aint a lawyer, so,and what
are ya goin' ta do? DDA Yound? DDA Kandaras, isn't that your jurisdiction? That is a
criminal law violation, right, unauthorized practice of law...and in that June 27th, 2012 Affidavit
of Landlord Chandler sneakily lists "N/a" in the blank for the "original period of is (blank)
terminating on o forr transferring to a periodic tenancy on that date. A copy of the written
rental agreement, if any , is attached hereto."....Upon information and belief, chandler failed to
inlcude a copy of the Rental Agreement in at least one of these NOrthwind files (not sure if it
was in the one for unit 29, rev2012-001048, but it woudl make sense, as Northwind's eggs were
all in that basket in a sense.) Anyways, the Rental AGreement makes clear the period is not
"n/a"...why would Chandler do that? Coudl it be that NRS 40.253 has differ atent laws for
tenancies where the rent is reserved by a period of 1 week or less? Coughlin paid for one
month's rent up front at the time the Renal Agreement was signed. Also, see isthe craigslist ad
Coughlin responded to placed by Northwind, and incorporated into an "Rental Agreement",
along with verbal indications, arguably, under NRS 118A.160 (which only applies to "dwelling
places", but the Landlord's Affidavit inidcates this rental was, in paragraph 2 such, as it states
"2. That yor affiant isrented a certain dwelling or apartment to Zach Coughlin, located at 1680
sky mountain dr...#29, Reno, NV on 5/4/12 for an original period of N/a terminating on or
transferrinto a periodic tenancy on that date. a copy of the written rental agreemet if any, is
attached hereto.".. Chandler seems to want to take advanteg of NRS 40.253(2)'s quickie service
approach for week to week rentals, which unit 29, by virtue of the terms of the Rental
Agreement, clearly was not. as him and him and him this but the new the signatures is written
in the amount of $75 is due no later than the first of late after the for every month late is asked
Bob Loblaw clearly this was a periodic tenancy of month to month for variety further one
provision and this one is rental agreements has written 30 days notice to vacate is required or
rental will be responsible the next months rent covered Chandler tends to one characterize this
as a week to week or less type tenancy to take advantage of the lessons service requirements
there and found in NRS 40.253(1)-(2):
Further, the Rental Agreement is not necessarily limited to the document that NOrthwind
Apartments purports to be the "GARAGE / CARPORT RENTAL AGREEMENT" as their
exists no limitation in that document that affirmatively disclaims any incorporation of
statements by then Manage Deede Call (whom mysteriously disappeared upon current Manager
Dwayne Jakob showing up) or incorporated into the Rental Agreement or Lease by virtue of the
advertisements that Northwinds held out to the public on Craigslist, which is how Coughlin
learned of their offer, upon which Coughlin called then Manager Deede Call and met with her in
person. Attached in Exhibit 1 is the Craigslist ad that Northwinds was running at the time, and
it read:
"$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below
Welcome to Northwind Apartments. We offer storage units to non-Northwind Residents! If you
need more storage, we offer garages to rent for $75 per month. They are a full size single car
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garage. Most public storages would charge over $150 dollars for the same size! Our community
is located in northwest Reno, right
off of McCarran. Please call us at (775) 747-9200 or come by. We are located at 1680 Sky
Mountain Drive in Northwest Reno."
AND IT GETS BETTER: The thing about NRS 40.760 is that it specifically indicates that
it does not apply to "garages". And Judges don't legislate from the bench, they just apply the
law as written, so people can depend on notice provided by precedent and published laws. To do
otherwise is judicial misconduct arguably requiring a Complaint with the Judicial Discipline
Commission.
Further Coughlin asked and then Manager Deede Call (she is listed as the manager on the
"RENTAL AGREEMENT" of May 4th, 2012, and it bears hers and Coguhlin's signature,
numerous questions vis a vis the use of the rental, and clearly, Deede Call gave Coughlin
permission (and actually, Call did not indicate any "special permission" to use the rentals for
something other than parking a car was necessary to obtain anyways, and no one has established
that Coughlin did not use the rentals for parking anyways, and any Fourth Amendment violating
trespass and videoing of Coughlin's rentals is not admissible anyways. Soldal v. Cook Co.
CHAPTER 40 - ACTIONS AND PROCEEDINGS IN PARTICULAR CASES CONCERNING
PROPERTY SUMMARY PROCEEDINGS FOR OBTAINING POSSESSION OF REAL
PROPERTY, RECREATIONAL VEHICLE OR MOBILE HOME
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of
tenant for default in payment of rent.
NRS 40.280 Service of notices to quit; proof required before issuance of order to remove.
NRS 40.400 Rules of practice.
CHAPTER 108 - STATUTORY LIENS
LIENS OF OWNERS OF FACILITIES FOR STORAGE
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NRS 108.475
Use of storage space for residence prohibited; eviction; nature of facility;
effect of issuance of document of title for property.
CHAPTER 118A - LANDLORD AND TENANT: DWELLINGS
CHAPTER 197 - CRIMES BY AND AGAINST THE EXECUTIVE POWER OF

THIS STATE
NRS 197.090
Interfering with public officer.
NRS 197.100
Influencing public officer.
NRS 197.110
Misconduct of public officer.
NRS 197.120
False impersonation of public officer; intrusion into and
refusal to surrender public office.
NRS 197.130
False report by public officer.
NRS 197.140
Public officer making false certificate.
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NRS 197.160
NRS 197.180
NRS 197.190
Fraudulently presenting claim to public officer.

Wrongful exercise of official power.
Obstructing public officer.
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The arrest of Coughlin at Northwinds Apartments on June 28th, 2012 by the same WCSO
Deputy Machen who filed a false affidavit attesting to have "personally served" Coughlin the
Summary Eviction ORder from Coughlin's former home law office on November 1st, 2011,
when in reality, Machen just posted the Order to the door when nobody was home (and
therefore committed trespass under color of law, as he failed to comply with NRCP 5(b)(2)
(made applicable to landlord tenant matters by NRS 40.400) and NRCP 6(e).
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So, WCSO Machen arrested Coughlin for a violation of NRS 197.190:
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NRS 197.190 Obstructing public officer. Every person who, after due notice, shall
refuse or neglect to make or furnish any statement, report or information lawfully
required of the person by any public officer, or who, in such statement, report or
information shall make any willfully untrue, misleading or exaggerated statement, or
who shall willfully hinder, delay or obstruct any public officer in the discharge of
official powers or duties, shall, where no other provision of law applies, be guilty of a
misdemeanor.
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Yet DDA charged Coughlin in the Criminal Complaint in RJC RCR2012-067980 with
a different crime, NRS 199.280:
"NRS: CHAPTER 199 - CRIMES AGAINST PUBLIC JUSTICE
OTHER OFFENSES
NRS 199.280
Resisting public officer.
A person who, in any case or under any circumstances not otherwise specially
provided for, willfully resists, delays or obstructs a public officer in discharging or
attempting to discharge any legal duty of his or her office shall be punished:
1. Where a firearm is used in the course of such resistance, obstruction or delay, or
the person intentionally removes, takes or attempts to remove or take a firearm from
the person of, or the immediate presence of, the public officer in the course of such
resistance, obstruction or delay, for a category C felony as provided in NRS 193.130.
2. Where a dangerous weapon, other than a firearm, is used in the course of such
resistance, obstruction or delay, or the person intentionally removes, takes or attempts
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to remove or take a weapon, other than a firearm, from the person of, or the immediate
presence of, the public officer in the course of such resistance, obstruction or delay, for
a category D felony as provided in NRS 193.130.
3. Where no dangerous weapon is used in the course of such resistance, obstruction
or delay, for a misdemeanor."
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Why the change from DDA Young? It couldn't be becuase NRS 199.280 is more
damaging to Coughlin's law license, in light of SCR 111(6), than would be a simple
little NRS 197.190 charge, could it? Is that permissible where the WCDA and WCSO
have a vested interest in discrediting and demolishing Coughlin in light of allegation
of misconduct by both of those offices with respect to its treatment of Coughlin, in
addition to misconduct against Coughlin by the WCDC?
Nevada Supreme Court Rule 111(6): "6. Definition of serious crime. The term
serious crime means (1) a felony and (2) any crime less than a felony a necessary
element of which is, as determined by the statutory or common-law definition of the
crime, improper conduct as an attorney, interference with the administration of
justice, false swearing, misrepresentation, fraud, willful failure to file an income tax
return, deceit, bribery, extortion, misappropriation,". Convictions of a "serious crime"
require Bar Counsel to file a SCR 111 Petition against the attorney.
Could there be any clear demonstration of the retaliatory animus against Coughlin by
the Washoe County District Attorney's Office? Are prosecutors paid to play out
grudges and sanction misconduct by local law enforcement? Rather than just a
"resisting" charge, DDA Young and the WCDA want to try to glom on a "false
swearing" and "inteferring with the administration of justice" claim, even where the
know of the 6/26/12 written correspondence by Coughlin to both the Sparks and Reno
Justice Courts and the Civil Division of the Washoe County Sheriff's Office. Enough
is Enough. This prosecutorial misconduct must not stand.
But, really Coughlin is hereby complaining to the landlord, pursuant to NS 118A.510
of a violation of the criminal law by one who is arguably an "agent" of the landlord
(not making a bribery allegation here, to be clear, though):
NRS 197.200 Oppression under color of office.
1. An officer, or a person pretending to be an officer, who unlawfully and
maliciously, under pretense or color of official authority:
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(a) Arrests or detains a person against the persons will;
(b) Seizes or levies upon anothers property;
(c) Dispossesses another of any lands or tenements; or
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(d) Does any act whereby the person, property or rights of another person are
injured,
commits oppression.
2. An officer or person committing oppression shall be punished:
(a) Where physical force or the immediate threat of physical force is used, for a
category D felony as provided in NRS 193.130.
(b) Where no physical force or immediate threat of physical force is used, for a
gross misdemeanor.
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Further, this is an officil written complaint against WCSO Deputy Machen and
Gomez, please place a copy of this Complaint in their employment and personnel files,
and please do the same with respect to RPD Officer Alan Weaver, Sargent Dye,
Sargent Oliver Miller, and Officer Welch for their gross misdemeanor, consisting of
doing that which is the domain of the Sheriff under NRS 40.760 in conection with the
matter at Superior Mini Storage on or around September 21st, 2012 under the
following law, in light of teh language in NRS 40.760 and NRS 108.475, which I
made the RPD aware of at the time, and Soldal v. Cook Co. Couldn't be too much of a
budget crunch when local law enforcement acts the way they do, veritably goading
civil rights tenant's right attorney's into suing them through their reckless and tacky
behavior: NRS 197.180 Wrongful exercise of official power. Any person who
willfully takes upon himself or herself to exercise or officiate in any office or place of
another, without being lawfully authorized thereto, is guilty of a gross misdemeanor.
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Also, uner NRS 118A.510, I am complaining of the following violations of criminal

law on Northwind's behalf:
NRS 197.120 False impersonation of public officer; intrusion into and refusal to
surrender public office. Every person who shall falsely personate or represent any
public officer, or who shall willfully intrude into a public office to which the person
has not been duly elected or appointed, or who shall willfully exercise any of the
functions or perform any of the duties of such officer, without having duly qualified
therefor, as required by law, or who, having been an executive or administrative
officer, shall willfully exercise any of the functions of office after his or her right to do
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so has ceased, or wrongfully refuse to surrender the official seal or any books or
papers appertaining to such office, upon the demand of his or her lawful successor,
shall be guilty of a gross misdemeanor.
[1911 C&P 67; RL 6332; NCL 10016]
NRS 197.130 False report by public officer. Every public officer who shall
knowingly make any false or misleading statement in any official report or statement,
under circumstances not otherwise prohibited by law, shall be guilty of a gross
misdemeanor.
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NEvada Court Services regularly attempts to mislead tenant's into thinking the act with color of law. From Joel Durden
barking at me in his Sheriff look-a-like getup that he is an "officer of the court" and from "Court Services" to having the
word "Court" in their name,etc., etc. NEvad Court Services impersonates public officers. Additionally, Machen's police
report is false to the extent that it fails to indicate that, at least at some point, Machen and or Deputy Gomez refused to
idnetify themslevs. They don't know what someone is doing inside when they purport to "knock and announce" and the
must reasonably be expected to assume one could have not heard their initial announcing their idnetify (whether because
they had headphones or, were in the bathroom, whatever...and Machen and his cowboy partner Gomez refused to identify
themselves in response to a request that they do so by Coughlin, and similarly refused to slide through the door any
paperwork or warrant describing the purpose of their visit.
WCSO is that Machem's Affidavit of Service indicates that he "personally

served" me, which kind of reminds me of all that robo-signing and MERS
fraud I come across in my day job (and do you wonder how many attorneys
in the foreclosure defense game I am in constant contact with who are
watching and witness the potential RICO violations this writing mentions?),
which includes being a foreclosure defense attorney. So which is it? Did
Machem "personally serve" me the Summary Eviction Order? Richard G.
Hill, Esq. likes to argue that I was "served" in compliance with all time
related rules because it was done in the "usual custom and practice of the
WCSO. What, exactly, is the "usual custom and practice of the WCSO? I
hear a lot about this "within 24 hours" stuff. So, I go hunting for some
black letter law to support what those at the RJC and in the clueless
community at large (which often includes Nevada Legal Services and
Washoe Legal Services, the people you guys had such trouble actually
serving in the lawsuits I filed, which may have actually helped improved
legal services in this community, if they were not dismissed due to
insufficiency of service of process, even where the IFP required the WCSO
to served the defendants....). Anyway, back to the "within 24 hours"
phraseology: "
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This whole business about The court may thereupon issue an order
directing the sheriff or constable of the county to remove the tenant within
24 hours after receipt of the order... is inapplicable to this situation, where
an Order Granting Summary Eviction was signed by October 27th, 2011.
That language is only found in situations inapplicable to the current one.
NRS 40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of NRS
40 where this within 24 hours language occurs, and those situations only
apply where, in:
40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...
(b) Advise the tenant: . (2) That if the court determines that the tenant is
guilty of an unlawful detainer, the court may issue a summary order for
removal of the tenant or an order providing for the nonadmittance of the
tenant, directing the sheriff or constable of the county to remove the tenant
within 24 hours after receipt of the order
and,
40.253(5)(a): 5. Upon noncompliance with the notice:
(a) The landlord
or the landlords agent may apply by affidavit of complaint for eviction to
the justice court of the township in which the dwelling, apartment, mobile
home or commercial premises are located or to the district court of the
county in which the dwelling, apartment, mobile home or commercial
premises are located, whichever has jurisdiction over the matter. The court
may thereupon issue an order directing the sheriff or constable of the
county to remove the tenant within 24 hours after receipt of the order. The
way these summary eviction proceedings are being carried out in Reno
Justice Court presently shocks the conscience and violates Nevada law.
There is not basis for effectuating a lockout the way WCSO's Deputy
Machem did in this case. The above two sections containing the within 24
hours of receipt language are inapplicable, as those situations do not
invoke the present circumstances, where the Tenant did file an Affidavit
and did contest this matter to a degree not often seen. To require Nevada's
tenants to get up and get out within 24 hours of receipt of the order
(what does that even mean? The use of terms like rendition, rendered,
notice of entry, pronounced, is absent here, and this receipt of the
order language is something rarely found elsewhere in Nevada law-see
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attached DMV statutory citations, and in employment law litigations where

one must file a Complaint within 90 days of receipt of a Right To Sue
Letter, a situation which follows NRCP 5(b), and NRCP 6(e) in imputing
receipt of such a letter, when actual receipt is not shown, by applying a
constructive notice standard that relies upon the days for mailing
extension of time for items served in the mailing, etc.). In Abraham v.
Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009), the
record did not reflect when the plaintiff received his right-to-sue letter. The
letter was issued on November 24, 2006. The court calculated that the 90day period commenced on November 30, 2006, based on three days for
mailing after excluding Saturdays and Sundays. In order to bring a claim
under either Title VII or the ADA, a plaintiff must exhaust administrative
remedies and sue within 90 days of receipt of a right to sue letter. See 42
U.S.C. 2000e-5(f)(1). See Baldwin County Welcome Center v. Brown,
466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)(granting
plaintiff an additional three days for mailing pursuant to Rule 6).
Further, despite what the inaccurate handouts of Nevada Legal Services
may say about this 24 hours and the applicability of the JCRCP to cases
like these, NRS 40.400 Rules of practice, holds that :The provisions of
NRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate
Procedure relative to civil actions, appeals and new trials, so far as they are
not inconsistent with the provisions of NRS 40.220 to 40.420, inclusive,
apply to the proceedings mentioned in those sections. As such NRCP 6(a),
(e) applies to the Order of Summary Eviction that WCSO Deputy Machem
alleged, under penalty of perjury, that he "personally served" upon me on
November 1, 2011. That is a lie by Mr. Machem, unless "personally
served" is defined in a rather impersonal way and or Machem and I have
totally different understanding of the definition of "personally served",
which may be the case. Or, perhaps the Sheriff's Office is busy and doesn't
want to wait around to "personally serve" every tenant it wishes to evict.
Fine, then just use the "mail it and allow three days" rule in NRCP 6(e)...the
landlord's might not like it, but they can use that frustration as an incentive
not to jump to litigating every disagreement about habitability that a tenant
brings to them. You may not realize how ridiculous some landlord's get.
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In my case, I offered to fix basic things that clearly implicated the

habitability rules in NRS 118A.290 and the Californian neurosurgeon,
Beverly Hill High School graduate landlord balked and complained then
hired and attorney four days into a dispute.....at which point the rules
against contacting represented parties prevented much in the way of real
settlement discussion, particularly where opposing counsel has
continuously demonstrated a complete indifference to pursuing settlement
(why would he at the rates he bills hours at?). I just don't think the
Sheriff's Office needs to sully its image or damage the citizen tenants of
Washoe County in the name of pleasing people like Dr. Matt Merliss or
Richard G. Hill, Esq.
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I am hereby complaining to Northwind Apartments of a violation of the criminal law by one of

its agents R. Wray and other process servers with NCS (Oh, and RPD Officer Weaver also
threatened to use "hydraulic explosives" to gain entry to one of my three rentals at Northwind,
though no exigent circumstance existed and though he lacked a warrant. I have previously
complained of Lou Cadia, Milan Krebs, both Northwind Maintenance Personnel, and Northwind
Property Manager or Apartment Manager Dwayne Jakob attempt to break and enter into my
rentals (why is it when Richard G. Hill, Esq. calls the RPD and alleges I am trespassing, I get
subject to a custodial arrest and Hill gets the State Bar of Nevada to try to prosecute me for
"breaking an entering", even though WCSO Machen lied in his Affidavit of Service in RJC
rev2011-0010708, and the Court had failed to return to me at the time of arrest the $2,275 it
wasn't permitted to require I deposit in a "rent escrow" account in the first place, and where Hill
and his contractor are caught on video admitting to having remove my ladder from the former
law office (in a video of December 23rd, 2011...why doesn't the RPD arrest Hill and Phil
Stewart for larceny of my ladder? Do I have to be Wal-Mart or Richard G. Hill or Northwinds
Apartments (ie, rich, connected) to get the RPD to enforce the law when I complain of a
violation?
1. Except as otherwise provided in NRS 40.253, the notices required by NRS 40.251 to 40.260, inclusive, may be served:
(a) By delivering a copy to the tenant personally, in the presence of a witness;
(b) If the tenant is absent from the tenants place of residence or from the tenants usual place of business, by leaving
a copy with a person of suitable age and discretion at either place and mailing a copy to the tenant at the tenants
place of residence or place of business; or
(c) If the place of residence or business cannot be ascertained, or a person of suitable age or discretion cannot be
found there, by posting a copy in a conspicuous place on the leased property, delivering a copy to a person there
residing, if the person can be found, and mailing a copy to the tenant at the place where the leased property is situated.
2. Service upon a subtenant may be made in the same manner as provided in subsection 1.
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3. Before an order to remove a tenant is issued pursuant to subsection 5 of NRS 40.253, a landlord shall file with the
court a proof of service of any notice required by that section. Before a person may be removed as prescribed in NRS
40.290 to 40.420, inclusive, a landlord shall file with the court proof of service of any notice required pursuant to
NRS 40.255. Except as otherwise provided in subsection 4, this proof must consist of:
(a) A statement, signed by the tenant and a witness, acknowledging that the tenant received the notice on a specified date;
(b) A certificate of mailing issued by the United States Postal Service; or
(c) The endorsement of a sheriff, constable or other process server stating the time and manner of service.
4. If service of the notice was not delivered in person to a tenant whose rent is reserved by a period of 1 week or less and
the tenancy has not continued for more than 45 days, proof of service must include:
(a) A certificate of mailing issued by the United States Postal Service or by a private postal service to the landlord or the
landlords agent; or
(b) The endorsement of a sheriff or constable stating the:
(1) Time and date the request for service was made by the landlord or the landlords agent;
(2) Time, date and manner of the service; and
(3) Fees paid for the service."
[
NRS 118A.430 Failure of tenant to comply with rental agreement or perform basic obligations:
Termination of rental agreement.
1. Except as otherwise provided in this chapter, if the tenant fails to comply with the rental
agreement or fails to perform his or her basic obligations under this chapter, the landlord may
deliver a written notice to the tenant specifying the acts and omissions constituting the breach
and that the rental agreement will terminate as provided in this section. If the breach is
remediable and the tenant does not adequately remedy the breach or use his or her best efforts to
remedy the breach within 5 days after receipt of the notice, or if the breach cannot be remedied,
the landlord may terminate the rental agreement.
2. If the tenant is not reasonably able to remedy the breach, the tenant may avoid termination
of the rental agreement by authorizing the landlord to enter and remedy the breach and by
paying any reasonable expenses or damages resulting from the breach or the remedy thereof.
Northwinds and NCS failed to comply with NRS 118A.430(1) (to the extent it even applies her)
in that in no way did it "deliver a written notice to the tenant specifying the acts and omissions
constituting the breach". Northwinds simply wrote "see attached", after paragraph 6 of teh
6/14/12 Notice, which reads "6. Remained in posssession of the premises subject to the
provisions of Chapter 118A of the NRS after having failed ot perfrom the basic or contractual
obligations imposed upon you by that Chapter, namely: (SEE ATTACHED)" and then NCS, at
most, include a copy of the "Rental Agreement" with its filing of this Notice to the RJC, which
in no way specifies what aspect of that Rental Agreement Coughlin is purportedly in breach of,
or what facts supports such an allegation.
Any Order he is void or subject oa NRCP 60b set aside based upon the fraud of NCS and Wray
in lying where he declares (under penalty of perjury) to have "personally served" Coughlin the 5
day notie on 6/14/12, and under NRCP 60b4 void for lack of jurisdiction where NCS failed to
specify in the Lanldord's Affidavit all that required under NRS 40.253. and for so many other
reasons, such at 118A does not apply if the rental is deemed to be not e "dwelling", and that an
illegal lockout is not available even if Coughlin is ruled to have been "using as a residence" the
rental, should the rental be a "storage facility" which City of Reno Code Enforcement does not
view it to be...and Further, by Northwinds very own descriptives, it is a garage, one they held
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out to the public for more than mere "parking a car", and as such, under NRS 40.760 and
108.4733, 108.475 and NRS 40.760 are not even available to Northwind. They. Are. Stuck.
Deal With It.
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NRS 108.4733
Facility defined.
storage area in a private residence.
Facility means real property divided into individual storage spaces. The term does not include a garage or
NRS 108.4746
Storage space defined.
occupant who has access to the space.
Storage space means a space used for storing personal property, which is rented or leased to an individual
NRS 108.475 Use of storage space for residence prohibited; eviction; nature of facility; effect of issuance of
document of title for property.
1. A person shall not use a storage space at a facility for a residence. The owner of such a facility shall evict any
person who uses a storage space at the facility as a residence in the manner provided for in NRS 40.760.
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NRS 108.4755 Contents of rental agreement.

1. Each rental agreement must be in writing and must contain:
(a) A provision printed in a size equal to at least 10-point type that states, IT IS UNLAWFUL TO USE A STORAGE
SPACE IN THIS FACILITY AS A RESIDENCE.
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MISCELLANEOUS PROVISIONS
NRS 40.760 Summary eviction of person using facility for storage as residence.
1. When a person is using a storage space at a facility as a residence, the owner or the owners agent shall serve or have
served a notice in writing which directs the person to cease using the storage space as a residence no later than 24 hours
after receiving the notice. The notice must advise the person that:
(a) NRS 108.475 requires the owner to ask the court to have the person evicted if the person has not ceased using the
storage space as a residence within 24 hours; and
(b) The person may continue to use the storage space to store the persons personal property in accordance with the
rental agreement.
2. If the person does not cease using the storage space as a residence within 24 hours after receiving the notice to do
so, the owner of the facility or the owners agent shall apply by affidavit for summary eviction to the justice of the peace
of the township wherein the facility is located. The affidavit must contain:
(a) The date the rental agreement became effective.
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(b) A statement that the person is using the storage space as a residence.
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(c) The date and time the person was served with written notice to cease using the storage space as a residence.
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(d) A statement that the person has not ceased using the facility as a residence within 24 hours after receiving the
notice.
3. Upon receipt of such an affidavit the justice of the peace shall issue an order directing the sheriff or constable of
the county to remove the person within 24 hours after receipt of the order. The sheriff or constable shall not remove the
persons personal property from the facility.
4. For the purposes of this section:
(a) Facility means real property divided into individual storage spaces. The term does not include a garage or
storage area in a private residence.
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(b) Storage space means a space used for storing personal property, which is rented or leased to an individual
occupant who has access to the space.
(Added to NRS by 1989, 213; A 2011, 1830)
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Nevada Process Server Licensing Requirements

It is required that all process servers are licensed and 21, or over, two-years experience as a process server and insurance against
liability to third persons with limits of no less then $200,000. No bonding is required. However, applicants must deposit $750 upon
submitting their application to pay for a background investigation, the maximum an applicant can be charged for a background check
is $1500. Applicants must also pass a written application and may be required to pass an oral exam as well. Licenses are issued by
the Nevada Private Investigators Licensing Board. Nevada is the most expensive state in the nation to get licensed. [Nevada Revised
Statutes 648.110 and 648.135]
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tenant for default in payment of rent.
"
1. Except as otherwise provided in subsection 10, in addition to the remedy provided in NRS
40.2512 and 40.290 to 40.420, inclusive, when the tenant of any dwelling, apartment, mobile
home, recreational vehicle or commercial premises with periodic rent reserved by the month or
any shorter period is in default in payment of the rent, the landlord or the landlords agent,
unless otherwise agreed in writing, may serve or have served a notice in writing, requiring in the
alternative the payment of the rent or the surrender of the premises:
(a) At or before noon of the fifth full day following the day of service; or
(b) If the landlord chooses not to proceed in the manner set forth in paragraph (a) and the rent is
reserved by a period of 1 week or less and the tenancy has not continued for more than 45 days,
at or before noon of the fourth full day following the day of service.
As used in this subsection, day of service means the day the landlord or the landlords agent
personally delivers the notice to the tenant. If personal service was not so delivered, the day of
service means the day the notice is delivered, after posting and mailing pursuant to subsection
2, to the sheriff or constable for service if the request for service is made before noon. If the
request for service by the sheriff or constable is made after noon, the day of service shall be
deemed to be the day next following the day that the request is made for service by the sheriff or
constable.
2. A landlord or the landlords agent who serves a notice to a tenant pursuant to paragraph (b) of
subsection 1 shall attempt to deliver the notice in person in the manner set forth in paragraph (a)
of subsection 1 of NRS 40.280. If the notice cannot be delivered in person, the landlord or the
landlords agent:
(a) Shall post a copy of the notice in a conspicuous place on the premises and mail the notice by
overnight mail; and
(b) After the notice has been posted and mailed, may deliver the notice to the sheriff or
constable for service in the manner set forth in subsection 1 of NRS 40.280. The sheriff or
constable shall not accept the notice for service unless it is accompanied by written evidence,
signed by the tenant when the tenant took possession of the premises, that the landlord or the
landlords agent informed the tenant of the provisions of this section which set forth the lawful
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procedures for eviction from a short-term tenancy. Upon acceptance, the sheriff or constable
shall serve the notice within 48 hours after the request for service was made by the landlord or
the landlords agent.
3. A notice served pursuant to subsection 1 or 2 must:
(a) Identify the court that has jurisdiction over the matter; and
(b) Advise the tenant:
(1) Of the tenants right to contest the matter by filing, within the time specified in subsection 1
for the payment of the rent or surrender of the premises, an affidavit with the court that has
jurisdiction over the matter stating that the tenant has tendered payment or is not in default in
the payment of the rent;
(2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may
issue a summary order for removal of the tenant or an order providing for the nonadmittance of
the tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours
after receipt of the order; and
(3) That, pursuant to NRS 118A.390, a tenant may seek relief if a landlord unlawfully removes
the tenant from the premises or excludes the tenant by blocking or attempting to block the
tenants entry upon the premises or willfully interrupts or causes or permits the interruption of
an essential service required by the rental agreement or chapter 118A of NRS.
4. If the tenant files such an affidavit at or before the time stated in the notice, the landlord or the
landlords agent, after receipt of a file-stamped copy of the affidavit which was filed, shall not
provide for the nonadmittance of the tenant to the premises by locking or otherwise.
5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the
justice court of the township in which the dwelling, apartment, mobile home or commercial
premises are located or to the district court of the county in which the dwelling, apartment,
mobile home or commercial premises are located, whichever has jurisdiction over the matter.
The court may thereupon issue an order directing the sheriff or constable of the county to
remove the tenant within 24 hours after receipt of the order. The affidavit must state or contain:
(1) The date the tenancy commenced.
(2) The amount of periodic rent reserved.
(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the first
months rent, by the tenant.
(4) The date the rental payments became delinquent.
(5) The length of time the tenant has remained in possession without paying rent.
(6) The amount of rent claimed due and delinquent.
(7) A statement that the written notice was served on the tenant in accordance with NRS 40.280.
(8) A copy of the written notice served on the tenant.
(9) A copy of the signed written rental agreement, if any.
(b) Except when the tenant has timely filed the affidavit described in subsection 3 and a filestamped copy of it has been received by the landlord or the landlords agent, and except when
the landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may,
in a peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
otherwise.
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6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the
information contained in the affidavit, and the filing by the landlord of the affidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, after service of notice of
the hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or
notice provided for in this section. If the court determines that there is no legal defense as to the
alleged unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a
summary order for removal of the tenant or an order providing for the nonadmittance of the
tenant. If the court determines that there is a legal defense as to the alleged unlawful detainer,
the court shall refuse to grant either party any relief, and, except as otherwise provided in this
subsection, shall require that any further proceedings be conducted pursuant to NRS 40.290 to
40.420, inclusive. The issuance of a summary order for removal of the tenant does not preclude
an action by the tenant for any damages or other relief to which the tenant may be entitled. If the
alleged unlawful detainer was based upon subsection 5 of NRS 40.2514, the refusal by the court
to grant relief does not preclude the landlord thereafter from pursuing an action for unlawful
detainer in accordance with NRS 40.251.
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a
motion, file a motion with the court, on a form provided by the clerk of the court, to dispute the
amount of the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 for
the inventory, moving and storage of personal property left on the premises. The motion must be
filed within 20 days after the summary order for removal of the tenant or the abandonment of
the premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed from the premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the
motion. The hearing must be held within 10 days after the filing of the motion. The court shall
affix the date of the hearing to the motion and order a copy served upon the landlord by the
sheriff, constable or other process server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230
and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges determined to be
due or if no charges are determined to be due.
9. A landlord shall not refuse to accept rent from a tenant that is submitted after the landlord or
the landlords agent has served or had served a notice pursuant to subsection 1 if the refusal is
based on the fact that the tenant has not paid collection fees, attorneys fees or other costs other
than rent, a reasonable charge for late payments of rent or dishonored checks, or a security. As
used in this subsection, security has the meaning ascribed to it in NRS 118A.240.
10. This section does not apply to the tenant of a mobile home lot in a mobile home park or to
the tenant of a recreational vehicle lot in an area of a mobile home park in this State other than
an area designated as a recreational vehicle lot pursuant to the provisions of subsection 6 of
NRS 40.215.
(Added to NRS by 1967, 195; A 1969, 263, 575; 1973, 1085; 1975, 1202; 1977, 418, 1346;
1979, 1398, 1879; 1985, 229; 1987, 1239; 1989, 1082, 1232; 1991, 113; 1995, 1851; 1997,
3511; 1999, 981; 2009, 1966; 2011, 235, 1489)
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tenant from certain types of property. Except as otherwise provided by specific statute, in
addition to the remedy provided in NRS 40.251 and in NRS 40.290 to 40.420, inclusive, when
the tenant of a dwelling unit which is subject to the provisions of chapter 118A of NRS, part of a
low-rent housing program operated by a public housing authority, a mobile home or a
recreational vehicle is guilty of an unlawful detainer, the landlord is entitled to the summary
procedures provided in NRS 40.253 except that:
1. Written notice to surrender the premises must:
(a) Be given to the tenant in accordance with the provisions of NRS 40.280;
(b) Advise the tenant of the court that has jurisdiction over the matter; and
(c) Advise the tenant of the tenants right to contest the notice by filing within 5 days an
affidavit with the court that has jurisdiction over the matter that the tenant is not guilty of an
unlawful detainer.
2. The affidavit of the landlord or the landlords agent submitted to the justice court or the
district court must contain:
(a) The date when the tenancy commenced, the term of the tenancy, and, if any, a copy of the
rental agreement.
(b) The date when the tenancy or rental agreement allegedly terminated.
(c) The date when the tenant became subject to the provisions of NRS 40.251 to 40.2516,
inclusive, together with any supporting facts.
(d) The date when the written notice was given, a copy of the notice and a statement that notice
was served in accordance with NRS 40.280.
(e) A statement that the claim for relief was authorized by law.
3. If the tenant is found guilty of unlawful detainer as a result of the tenants violation of any of
the provisions of NRS 453.011 to 453.552, inclusive, except NRS 453.336, the landlord is
entitled to be awarded any reasonable attorneys fees incurred by the landlord or the landlords
agent as a result of a hearing, if any, held pursuant to subsection 6 of NRS 40.253 wherein the
tenant contested the eviction.
(Added to NRS by 1985, 227; A 1989, 1084, 1234; 1991, 115; 1995, 1853; 2001, 1065; 2003,
561)"
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I WOULD LIKE TO KNOW WHY THE FILE IN RJC REV2012-001048

HAS MY 6 PAGE FAX OF JUNE 30TH, 2012 (AND PLEASE NOTE
THE LIMITED OR SPECIAL APPEARANCE NATURE OF THAT
FILING IN THE NOTE AT THE BOTTOM OF THE FIRST PAGE....YET
IT IS NOT FILE STAMPED, AND I WAS NEVER CALLED, OR
FAXED, OR NOTIFIED IN ANY WAY CONCERNING THE
SCHEDULING OF MY CONSTITUTIONALLY GUARANTEED
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HEARING BEFORE A SUMMARY EVICTION OR STATUS OF MY

IFP REQUEST.
MY POSITION IS THAT I AM ENTITLED TO A SUMMARY
EVICTION HEARING ON UNIT 29 AND THAT IT IS LONG
OVERDUE. PLEASE LET ME KNOW WHEN THAT HEARING CAN
TAKE PLACE. I DO NOT BELIEVE ANY JUDGE CURRENTLY HAS
JURISDICTION ON IT, AND THAT THE NEW CASE, WITH A NEW
CASE NUMBER SHOULD BE "RANDOMLY ASSIGNED"
Further in the Reno justice court file for rjc rev2012-001048 is a tenant affidavit and declaration from Coughlin faxed to
the court on June 30, 2012 contain six pages it is unclear why Coughlin was not granted a summary eviction hearing as
required by law and Coughlin is hereby demanding one and a jury trial which he is entitled to one pursuant the 19
Seventies the Court decision and FRCP rule 30 a.m. that Coughlin is requesting one prior to the time set for hearing that's
right folks were going to a jury trial when Nevada court services served an amended eviction notice on June 28 Coughlin
there and had five days to file for an eviction summary eviction hearing and he did so on June 30 just for the Reno PD
managed commit another wrongful arrest of Coughlin further there was County jail failed to transfer Coughlin for the
July 5 hearing on Coughlin's motion to set aside the original June 27 order however the June 27 order in this case was
extinguished by that posting of an amended lockout notice therefore and eight it's not file stamp but it should be by the
Reno justice court the six page fax by Coughlin on June 30, 2012, though Karen Stancil appears to have handwritten in
the case number RJC rev2012-001048
PLEASE NOTE I AM USING AUDIO DICTATION TRANSCRIPTION SOFTWARE FOR THIS
CORRESPONDENCE AND IT MIGHT HAVE SOME ERRORS, WHICH COULD GREATLY ALTER THE
MEANING, AS I DON'T HAVE TIME TO CORRECT THEM RIGHT NOW.
additionaly THERE WAS SEVERAL FAXES TO THE RJC CIVIL DIVISION BY COUGHLIN ON OR ABOUT
JUNE 13TH, 2012, AND COUGHLIN REQUESTS A COPY OF THOSE OR SOME INDICATION OF WHY THEY
WERE NOT FILED AND COUGHLIN WILL CHECK HIS OWN RECORDS IN THAT REGARD WHEN HE HAS
TIME...HOWEVER, TO THE EXTENT ONE OF THOSE FILINGS WAS A TENANT'S AFFIDAVIT DIRECTED
TOWARDS UNIT 29, LOTS OF PROCEDURAL IMPLICATIONS WILL STEM.
NORTHWIND APARTMENT
ASSOC LLC
1031 XPRESS
NORTHWIND LLC
110 110TH AVE NE STE
550
BELLEVUE, WA 98004
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Description Summary
Fictitious Firm Name - Counter
74040
04/01/1997 12:00:00 AM Expiration Date: 04/01/2002
Business Name: NORTHWIND APARTMENTS Owners: NORTHWIND APARTMENT ASSOCIATES, LLC
s Firm Name - Counter - 109351
Filing Information
Filing Number
109351
000078
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Filing Date
03/16/2006 12:00:00 AM
Expiration Date
03/16/2011
Business Information
Business Name
RENO RED BOOK
Owner Information
Owner/Corporate Name
JEFFREY G CHANDLER u
104085
Business Name: BOTTS CANDY COMPANY Owners: JENNIFER V CHANDLER, CINDY R VANDERZIEL
Him and him and him and him motion a set of society eviction order of the number of bases one it went unopposed and
hundred Polk case Coughlin wins in that regard to the notice of hearing by the Reno justice court is dated July 31,
2012 are not as of the hearing on July 21, 2012 stated July 24, 2012 and him notices on what the hearing is limited
to quote you may appear on the data show cause why the court should or should not grant motion to stay the eviction
order in the motion for expedited relief following legal lot coverage utility shut off. If you the. Must be prepared
to provide testimonial documentary evidence the court which torture position if he failed to appear karmic
renovation would form a dismiss case. With what the notice does not say is that the hearing will address the motion
to set aside eviction order Coughlin filed on July 24, 2012 and that which and for which now he request the court to
rule in his favor or at least provide hearing or at the very and for or at the very least require Northwind and/or
their qualified attorneys or whoever to file an opposition something under of explaining why their are three
separate notices for her three separate process affidavits of service for the June 14, 2012 personal service of a
five-day unlawful detainer affidavit by Robert Ray of Nevada court services that's right there's three separate ones
and Coughlin's possession now and they bear different things as well isn't that interesting half add to that the
fact that Nevada court services agreed with Coughlin's assessment that its original on June 14 notice of unlawful
detainer failure to vacate premises was ineffective and that it listed the wrong forum is or court for the tenant to
file a tenant at search engines affidavit as required by law under 40.253 that's not something the judge piercing
can excised from the law or legislate from the bench out of existence that is a law. The Reno justice court does not
have jurisdiction with the notice last Sparks justice court the fugitive document for the landlord to file it
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landlord's affidavit and then to manage to get Coughlin arrested based upon a void order that should never issued
judge Shrader particularly where supervisor of the syllable division Karen Stancil was alerted and well in advance
by Coughlin through phone calls and mid-June in that June 26 of written correspondence to the court that included in
the file on the left side of the correspondence and where the Sparks justice court itself fax the Reno justice court
that a fax alerting it to the problematic aspects of the June 14 notice Coughlin was arrested he went to jail he
paid bail he did time incurred massive damages it's appalling for judge piercing to ignore all this while also
sanctioning the unauthorized practice of law by Jeff Chandler Nevada court services who dress up like they are
Sheriff's and managed to the word court into their name and bang on people store and leave off the Nevada part so
much so that it and it seems as though they are actually acting with color of law in the screening you to come out
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of your house and bang on the door parted sounds like they are cost of the Sheriff and have to do exactly what you
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said. Those few who don't Nevada court services has something up their sleeve in the form of attempting to break and
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enter and one's residence or sex service of process by as Nevada court services has done to Coughlin on numerous
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occasions sometimes captured on videotape further Nevada court services is trespassed on numerous occasions like
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office property Coughlin however is the only one who's arrested and convicted trespassing and had reported rehashes
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patent trademark office and had impact his ability to practice his chosen profession for which he has to does have a
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law license and actually did that a lot four. Further there's initial conflict in the judge piercing work to the
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district attorneys office first 12 years of his career and the Washoe County Sheriff and potentially Washoe County
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District Attorney's Office may have it engages the misconduct in connection with the approximately 10 different
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incarcerations Coughlin space this year most all connected one where another To the Way, Reno justice court handles
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landlord-tenant matters or fails to apply the law as written and created by the assembly the Senate i.e. the
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legislature Nevada and Carson City to be clear Nevada court services recognize the validity of Coughlin's argument
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that when he announced to them on June 28 at approximately 10 AM to 10:45 AM is where Coughlin pointed out that
the
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the June 14 notice listed Sparks justice court that Nevada court services responded by serving in the amended
declaration of service by license process server on June 28 thereby vitiate in any order lockout order rescinding
and waving it etc. etc. June 28, 2012 fax from the Sparks justice court to the Reno justice court contains a fax
Coughlin sent the Sparks justice court on June 26 that at 12 PM noon of that date that faction Coughlin was 10 pages
the facts from the Sparks justice court the Reno justice court was apparently 13 pages no number of those pages are
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not included in the file of this matter and the Reno justice court back to the three different notices of unlawful
detainer either stamped by w which doesn't count by the way one needs to sign something attorneys don't get a stamp
things and file them and then later on claim they didn't commit commit misconduct or her perjury or rule 11
violation merely because it is sign something Nevada court services continues to just put stamps instead of actual
signatures and that's an appropriate and under the Aiken case is in Nevada and summary of proceedings the technical
aspects of notice and due process requirements must be strictly adhered to not run out with the bathwater by judge
Pearson because he either doesn't like off-line or thinks Coughlin doesn't deserve due process of the law article
protection because Coughlin's an attorney you know Coughlin's not a license attorney currently needs not able to
make attorney money or do attorney things or even commit the unauthorized practice of law with impunity like Nevada
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court services because know Coughlin you know of Coughlin was to do so the State Bar would find it to be a contempt.
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Further judge Pearson's order for summary eviction of July 31 is void in several respects one it purports rule one
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units 2971 when unit 71 is not properly before the court unit 71 has its own case numbers of rev2012-0067 and
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rev2012-001082 (the multiplicty is due to, as here, THE RJC shortcutting due process aspects of the process,
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whererin "Orders" by Judges paid quite a bit of money are nothing more than handwritten notes on Coughlin's own
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filings...Some of those such "note ORders" by Judge Schroeder resulte in confusing vis a vis whether Coguhlin's
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IFP's were granted, and necessitated the filing of companion cases for units 45 and 71 in rev2012-0067 and rev201-
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0068 in rev2012-001082 and rev2012-00183. To simply make Coughlin scapegoated all medicine blame him for taking
of
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regardless the July 31 order by judge Pearson in rev 2012 00 1048 purports rule on matters not noticed in the July
24 notice specifically in that order which reads the court finds eviction was appropriate motion to stay eviction
order denied motion to set aside eviction order denies motion to contest personal property lien denied motion on
illegal lockout denied tenant have always property removed is 2971 by 5 PM on August 5, 2012 only about half of that
order was properly before the court notice litigants that I'm what was notice to the litigants in the July 24 notice
was that the hearing would be limited to the motion to stay eviction order in a motion for expedited relief
following illegal lockout utility shutoff however the order went on to rule on matters non-there and noticed
including the motion to set aside the eviction order the motion to contest personal property lien and that matters
related to the property of a unit not even involved in a case number unit 71 further there required Coughlin a hub
Allis property removed even earlier than the law requires given that after the 30 day plan under NRS 118 A.460 the
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landlord may not dispose of the property until 14 days of pass from mailing to the tenant last known address a
certified letter. So there and again judge Pearson is violating the law in failing to apply evenly to Coughlin in
fact he's attempting to exCise protections accorded and Coughlin under Nevada's landlord tenant law which is the
most pro-landlord law set of laws in the country but that's not good enough for judge piercing he wants to cut even
more protections out of it when it comes to Coughlin and the reasoning behind that is not clear though Coughlin has
had some issues with Washoe County District Attorney's Office this year in judge Pearson did spend the first 12
years of his career there.
Attached in exhibit a are the three different June 14 declarations of service by license process server Robert (or Ryan?)
Wray ..That's right, Coughlin has in his possession three different NOtice of UD dated 6/14/12 and either "stamped" with
"R. Way" or actually containing a handwritten signature by R. Wray (though the one actually signed lacks a time
indication, and they all lack a "manner of service" or any other particular beyond falsely attesting to have been
"personally served". WRay and NORthwinds manager attempted to break and enter into unit 29 in hopes of effecting
"personal service" upon Coughlin in a unit that had not windows and that had the door closed and locked and or barred.
That is a criminal act and Coughlin is now again hereby complaining about it to the landlrod, so have fun reading NRS
118A.510's and NRS 118A.390 and I'll see you in Court, and WRay, you should probably self report to the process server
licensing body and hope for the best. Check out the video fo the 6/28/12 arrest wherein the WCSO's Gomez and Machen
tell Chandler to "let us do the talking, Jeff", then Chandler, dressed up in an outfit and with a company name intended to
connote color of law type authority, purports to trespass Coughlin from the whole place, ie, the entire premises at 1680
Sky Mountain Dr., depsit Coughlin still having, at the time, one, and perhaps two valid leases, to units 45 and 71.
Further, the Washoe County Detention Center or jail took a tenan'ts affidavit from Coughlin on or aoround July 15th,
2012 for units 45 and another for unit 71 and due to Coughlin's indigency, the jail library indicate it would be filed with
the rjc....WAs it?
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he Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe where they
have a valid reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.
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Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
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predecessor statute to NRS 40.2516 to mean that the alternative five (5) day notice must be given
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before the tenants can be dispossed and a lease can be validly terminated. The court stated that this
five (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
ttp://www.constitution.org/ussc/506-056a.htm
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U.S. Supreme Court

SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
SEVENTH CIRCUIT
No. 91-6516
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CONCLUSION
The undersigned hereby request this Court consider these materials presented herein in
deciding upon this matter.
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AFFIRMATION AND DECLARATION

I declare, pursuant to NRS 53.045, under penalty of perjury under the laws of the State
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of Nevada that the foregoing is true and correct and that this document does not contain any
social security numbers, pursuant to NRS 239B.030, an affirmation to that effect this hereby is.
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DATED this 9th of October, 2012:
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_/s/ Zach Coughlin

Zach Coughlin,
pro se tenant
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PROOF OF SERVICE
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On this date, I caused a copy of the foregoing document s to be served upon the following by
faxing and emailing to those who have consented to such service and or by hand delivery to dropslot
or front desk, and by placing a true and correct copy of the foregoing document in the U.S. mail
addressed to:
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NORTHWIND APARTMENT
ASSOC LLC
1031 XPRESS
NORTHWIND LLC
550
BELLEVUE, WA 98004
Description Summary
74040
Business Name: NORTHWIND APARTMENTS Owners: NORTHWIND APARTMENT
ASSOCIATES, LLC
Nevada Court Services
Lew Taitel, Esq., Staff Attorney
Jeff Chandler, Owner and CEO
Robert Wray, Licensed Process Server
475 S. Arlington Avenue, Suite 1A
Reno, NV 89501
(775) 348-7560
Lewis S. Taitel, Esq.
Attorney at Law
475 S. Arlington Suite 1A
Reno, Nevada 89501
(775) 322-2272
Fax: (775) 348-7977
Nevada State Bar No. 4397
Not sure who Mr. Taitel represents in this matter, if anyone...
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Lew Taitel, Esq., Staff Attorney
Jeff Chandler, Owner and CEO
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Robert Wray, Licensed Process Server

475 So. Arlington Suite 1A
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
Email: nevcs@nevcs.com
? unauthorized practitioner of law for Northwinds Apartments?
ACG-AMPI, IN
Northwinds Apartments
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DATED this 9th of October, 2012:
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/s/ Zach Coughlin

Zach Coughlin, pro se tenant
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index to exhibits:
exhibit 1 55 pages
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000087
One Size Car Garage For Rent
reno craigslist > housing > parking & storage
email this posting to a friend
Stating a discriminatory preference in a housing post is illegal - please flag discriminatory posts as prohibited
please flag with care: [?]
Avoid scams and fraud by dealing locally! Beware any arrangement involving Western Union, Moneygram, wire
transfer, or a landlord/owner who is out of the country or cannot meet you in person. More info
miscategorized
prohibited
$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below [Errors when replying to ads?]
spam/overpost
best of craigslist
Welcome to Northwind Apartments. We offer storage units to non-Northwind Residents!

If you need more storage, we offer garages to rent for $75 per month. They are a full size single car garage. Most
public storages would charge over $150 dollars for the same size! Our community is located in northwest Reno, right
off of McCarran.
Please call us at (775) 747-9200 or come by. We are located at 1680 Sky Mountain Drive in Northwest Reno.
1680 Sky Mountain Dr. (google map) (yahoo map)

000088
file:///R|/jackieboy/Documents/$75%20garage%20747-9200%201600%20sky%20mountain%20dr..html[10/10/2012 2:50:35 AM]
One Size Car Garage For Rent
Location: Northwest Reno, NV

it's NOT ok to contact this poster with services or other commercial interests
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file:///R|/jackieboy/Documents/$75%20garage%20747-9200%201600%20sky%20mountain%20dr..html[10/10/2012 2:50:35 AM]
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Hotmail Print Message
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I demand my summary eviction hearing, before a jury based

upon 6 28 12 notice and my faxed Tenants Answer of 6 30 12
i
Sent: Wed 10/10/12 5:38 AM
To: stuttle@washoecounty.us; kstancil@washoecounty.us; rjcweb@wasoecounty.us;
037nor2@acg.com; 037nor4@acg.com; nevcs@nevcs.com; chansen@washoecounty.us;
renodirect@reno.gov; rjcweb@washoecounty.us; cwood@washoecounty.us;
william@hornelawfirm.com; pilbinfo@ag.nv.gov; tsegerblom@asm.state.nv.us
Dear Mr. Tuttle and Supervisor, Civil Division Stancil and Supervisor of the Civil
Division at Sparks Justice Court Hansen,
Mr. Hansen, I believe I am entitled to a hearing in your court. I would like one. May I
have a date. Mr. Tuttle and Ms. Stancil, I believe I am entitled to several hearings in
your court, may I have such and a date and time for them?
I am writing to demand respectfully my hearing incident to the NOtice served on my
rental at Northwind Apartments 1680 Sky Mountin Drive unit 29 on June 28th, 2012.
I believe the tenant's affidavit I filed in response to that 5 day notice should be given
a brand new case number, though the designation by ncs that it was an "Amended
NOtice" pursuant to is is is is is is is isis it is as if the isthe 6/14/12 one (the one R.
Wray lied about effecting "personal service" on me of, which got me arrested just
before I was to fax to the RJC, by noon, a Tenant's Answer or MOtion to Dismiss for
failure to state a cause of action or deficieny of service of process or something (I
arguably needn't have even filed anything in the RJC where the 6/14/12 notice listed
Sparks Justice Court.
Oh, it gets better...Nevada Courts services filed a Landlord's Affidavit attesting to
have rented Coughlin a "dwelling" which is defined as a "sleeping place or residence"
in NRS 118A...and pursued an eviction under NRS 118A...citing a breach by Coughlin
for allegedly using the unit 29 for a residence or sleeping place, instead of pursuing
NRS 40.760 or NRS 118.475 eviction remedies (which, by the way, may result in the
Sheriff evicting Coughlin or forcing him to quit any alleged use of Unit 29 as a
"dwelling place or residence", but YOU WILL NOT THAT UNDER THOSE
000108
file:///C|/...012%20email%20to%20stuttle@washoecounty.us%20regarding%20ncs%20rev2012-001048%20etc%20ncs.htm[10/10/2012 6:23:17 AM]
STATUTES COUGHLIN WOULD BE ALLOWED, UNDER THE LAW TO

CONINUTE STORING AND ACCESSING HIS PROPERTY THERE!!!!CAN'T
HAVE IT BOTH WAYS ALL THE TIME, GUYS. Oh, also, who in the hell signed
the Landlord's affidavit? There is no textual indication of whom the solitary letter of a
"signature" belongs to....maybe because it would be a NRCP 11 violation for a
corporation to appear "pro se", especially where represented by someone committing
the unauthoried practice of law?
R. Wray made some interesting statements on the video of the 6/28/12 arrest filmed by
Coughlin, especially concerning Coughlin's contention that Wray and NOrthwind's
Dwane Jakob's attempts to break and enter and trespass into Unit 29 constituted
"personally serving" Coughlin a 5 day Unlawful Detainer Notice on 6/14/12. If NCS
did not "personally serve" Coughlin, then Coughlin would have had until June 28th,
2012 at noon at the earliest (and arguably until the close of business at 5pm on
6/28/12 to file a response (ie Tenant's Answer or MOtion to Dismiss, etc), in Sparks
Justice Court OR EVEN in REno Justice Court. Coughlin was arrested at 10:30 am
on 6/28/12, thereby, under color of law, the WCSO, NCS and NOrthwind and Jakob
fraudulently prevented Coughlin from filing (if he did not already previously,
espeically in the 6/13/12 faxes that are mysteriously unaccounted for in rJC files) a
Tenan'ts Response (tEnan'ts answer, or Tenant's AFfidavit or Motion to Dismiss, etc.).
So, R. Wray and NCS, its kind of a big deal that you lied about effecting personal
service on 6/14/12 of the 5 day notice.
Coughlin has three different version of that notice or "Declaration of Srevice by

License PRocess SErver" R. Wray. in one, a time of 9:23 (presumably am, but that is
not circled, nor is pm) on 6/14/12 is listed, and a rubber stamp indicating "r. wray", is
there, along with a hadnwritten "reg #r-043948" is there. that Declaration indicates
that R. WRay "personally served" the partey named, Coughlin. Oddly, this first
version (and all three of these are in the RJC file in rev2012-001048) instead of
"jennifer Chandler" being in , I guess, the signature line for the "agent" of the landlrod
(and she always just places a "rubber stamp" of her name anyways..", instead of
Jennifer Chandler, on the one 6/14/12 5 day NOtice (and all version sof this notice
have checks on box 3 and 6, which read "3. Recieved a 5 day notice of possible
unlawful detiner for failure to comply with the rental agreement....6. Remained in
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possesion of the premises subject to the provision of Chpater 118A of the NRS after
having failed to perform the basic or contractual obligations imposed upon you by that
Chapter, namey (SEE ATTAChed)" though the "attached just seems to include a
copy of the "Rental Agreement" with no real indication of how Coughlin was in
violation of it, and no indication of why NOrthwinds feels Coughlin remained in
violation thereof despite Coughlin's written communications indicating that he was not
in breach. Anyways, rather tha a rubber stamp indicating "jennifer Chandler" on that
one 5 day notice, the one where WRay actually affixes his actual signature, follow by
a handwritt r-043948 (his licensed process sever number), the spot usually baring the
"Jennifer Chandler" rubber stamp is instead taken up by a signature by Nevada Court
Services resient notary public HB Cedomio....AGain, there is no time listed on that
first version of the NOtice or which includeds at the bottom the "Declaration of
Service...."
In the second version of the "notice of Unlawful detainer..." served on June 14th,
2012, in his "Declaration of Service by Licnese process Server" (which, arguably
inovkes the "penalty of perjury dicate of NRS 53.045...) Wray against declares he
personally served Coughlin, with a time of 9:23 indicated, and a rubber stamp of "R.
Wray" on the signature line, with a handwritten "REg #R-043948" (and that version
was faxed by the Sparks Justice Court to the Reno Justice Court on June 28th, 2012 at
11:05 am, (in a 13 page fax, many pages of which are not in the RJC file, though that
fax does included the header from the fax from Coughlin to the "Sparks Justice Court
on 6 26 12 at 12:00pm, which was a 10 page fax, and the versio of the 6/14/12 5 day
notice with Declartion of Service by r. Wray indicating a time of 9:23 is page 6 of 10
of Coguhlin's fax to the Sparks Justice Couer (according to the fax hearders) while
also being page 12 of teh June 28th, 2012 fax from the Sparks Justice court to the
Reno Justice Court. right about the moment Coughlin was being placed in WCSO
Deputy Machen squad or patrol vehicle for transprot to the jail, where Coughlin would
be forced to fork over some more bail, etc., etc.
IN the Third version of the "Declaration of Service" on the same June 14th, 2012
"NOTICE OF UNLAWFUL DETAINER FOR FAILURE TO VACATE PREMISES
..This third version of his 6/14/12 Declaration of Service by Licensed PRocess Serve
R. Wray has the typical "jennifer chandler" rubber stamp for the NOtice half of the
page, and has a rubber stamp for "?R.wray", along with a clearly differt handwrirtn
note of "reg# r043" (obviously, aside from the handwriting "analysis" the handwrittn
000110
numberical indication of the process servicer number is truncated on this third version
by 3 numbers). Additionaly this third version indicates it was "personally served" at
12:54 pm.
Why all the different versions? why, if personally service was effect at 9:23 am, woud
R. Wray need to return and do it again, all for Unit 29, nmin you only (all the other
Declartions of Service from that date of 6/14/12 , ie for units 45 and 71, indicate that
Wray merely posted teh notice to the rented property (and therefore would entail 3
more days fro mailing to get "construtive notice" under NRCP 6(e) and NRCP 5(b)(2),
which landlord's like Northwinds just hate.
Then there is the fact that NCS snuck into the file later a whole nother type of notice,
one under NRS 40.760...which, of course, changes everything..
OF course, Wray did not "personally serve" Coughlin. Wray attempts to make some
half-baked argument about how he slid (after failing in his attempts to break and enter
and trespass in to Unit 29 on 6/14/29) the 5 day UD Notice into a crack in the door of
the rental, and perceived it to "move" after he let go of it, thereby, apparently, entitling
him to assert that he effected "personal service" upon tenant Zach Coughlin, or,
apparently, otherwise complied with NRCP 5, and therefore cut short the time for
Coughlin to respond as a tenant and secure a hearing (rather than be incarcerated after
having unknown violent sounding figures (flashbacks to other interactions with
Nevada Court Services) banging on his doors, refusing to indentify themselves, then
ultimately taking a chainsaw (or sawz-all) to a metal door to a confined windowless
rental.
NRS 40.400 makes NRCP the applicable rules here, not JCRCP, nor JCRRT:
RULE 5. SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS
Rule
Drafters Note
Commentary
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(a) Service: When Required. Except as otherwise provided in these rules, every order
required by its terms to be served, every pleading subsequent to the original complaint
unless the court otherwise orders because of numerous defendants, every paper
relating to discovery required to be served upon a party unless the court otherwise
orders, every written motion other than one which may be heard ex parte, and every
written notice, appearance, demand, offer of judgment, designation of record on
appeal, and similar paper shall be served upon each of the parties. No service need be
made on parties in default for failure to appear except that pleadings asserting new or
additional claims for relief against them shall be served upon them in the manner
provided for service of summons in Rule 4.
(b) Same: How Made.
(1) Whenever under these rules service is required or permitted to be made upon a
party represented by an attorney, the service shall be made upon the attorney unless
the court orders that service be made upon the party.
(2) Service under this rule is made by:
(A) Delivering a copy to the attorney or the party by:
(i) handing it to the attorney or to the party;
(ii) leaving it at the attorneys or partys office with a clerk or other person in charge,
or if there is no one in charge, leaving it in a conspicuous place in the office; or
(iii) if the office is closed or the person to be served has no office, leaving it at the
persons dwelling house or usual place of abode with some person of suitable age and
discretion residing there.
(B) Mailing a copy to the attorney or the party at his or her last known address.
Service by mail is complete on mailing; provided, however, a motion, answer or other
document constituting the initial appearance of a party must also, if served by mail, be
filed within the time allowed for service; and provided further, that after such initial
appearance, service by mail be made only by mailing from a point within the State of
Nevada.
000112
(C) If the attorney or the party has no known address, leaving a copy with the clerk of
the court.
(D) Delivering a copy by electronic means if the attorney or the party served has
consented to service by electronic means. Service by electronic means is complete on
transmission provided, however, a motion, answer or other document constituting the
initial appearance of a party must also, if served by electronic means, be filed within
the time allowed for service. The served attorneys or partys consent to service by
electronic means shall be expressly stated and filed in writing with the clerk of the
court and served on the other parties to the action. The written consent shall identify:
(i) the persons upon whom service must be made;
(ii) the appropriate address or location for such service, such as the electronic-mail
address or facsimile number;
(iii) the format to be used for attachments; and
(iv) any other limits on the scope or duration of the consent.
An attorneys or partys consent shall remain effective until expressly revoked or until
the representation of a party changes through entry, withdrawal, or substitution of
counsel. An attorney or party who has consented to service by electronic means shall,
within 10 days after any change of electronic-mail address or facsimile number, serve
and file notice of the new electronic-mail address or facsimile number.
(3) Service by electronic means under Rule 5(b)(2)(D) is not effective if the party
making service learns that the attempted service did not reach the person to be served.
(4) Proof of service may be made by certificate of an attorney or of the attorneys
employee, or by written admission, or by affidavit, or other proof satisfactory to the
court. Failure to make proof of service shall not affect the validity of service"
In the legal work drafted and filed by a non-attorney, a criminal violation in NCS's
and Jeff Chandler's committing the authorized practice of law (what happens to people
doing plastic surgery without a license? jail time, lots of it...because something could
000113
go badly, badly wrong and people could get hurt...like Coughlin got hurt, damaged,
arrested, financially destroyed, etc., etc. here. thin skull plaintiff, consequential
damages Winchell v Schiff 2008 case seafood, storage place lost business and lost
profits $300K damages, etc.. while in jail Coughlin was prevented from filing in
matters that ultimately wound up with a $40,050 judgment against Coughlin, and
there's more, for which NOrthwind, and NCS, Chandler and WRay, and perhaps, some
others, will be liable.). In the "Affidavit of Landlord for Breach" filed on June 27th,
2012 by ,well, who knows, given it just says "Lanldord" and has what appear s to be a
handwritten "S" in the signature line...but, lets say it was filed by Jeff Chandler, whom
crossed the bar and argued before Judge Pearson on July 31st, 2011 in REv2012001048 on behalf of his "client' Northwind Apartments, Associates LLC (see acgampi.com, doing business in 10 states, kinda seems like they could afford and attorney
rather than destroy our community with hack pretend lawyers who play dress as a
Sheriff and bully peopel while attempting to break and enter and trespass...and then
RPD Alan Weaver and SArgent Oliver Miller, and WCSO Deputy John Machen and
Deputy Gomez chip in some Soldal v. Cook County violating 1983 violations as
well....puke, puke. puke... IN the "Affidavit of Landlord for Breach" that Chandler
drafted and filed, he wrote, at paragraph 4. "him and nation surrender of the premises
was to have taken place on or before June 13, 2012. That legal notice has been served
on the tenant's in accordance with the provisions of NRS chapter 40.280 as amended
on 6/14/12."
Chandler's Affidavit of Landlord for Breach demonstrates a lack of candor to the

tribunal, which would be professional misconduct to report to the SBN, but, Chadler
aint a lawyer, so,and what are ya goin' ta do? DDA Yound? DDA Kandaras, isn't that
your jurisdiction? That is a criminal law violation, right, unauthorized practice of
law...and in that June 27th, 2012 Affidavit of Landlord Chandler sneakily lists "N/a" in
the blank for the "original period of is (blank) terminating on o forr transferring to a
periodic tenancy on that date. A copy of the written rental agreement, if any , is
attached hereto."....Upon information and belief, chandler failed to inlcude a copy of
the Rental Agreement in at least one of these NOrthwind files (not sure if it was in the
one for unit 29, rev2012-001048, but it woudl make sense, as Northwind's eggs were
all in that basket in a sense.) Anyways, the Rental AGreement makes clear the period
is not "n/a"...why would Chandler do that? Coudl it be that NRS 40.253 has differ
atent laws for tenancies where the rent is reserved by a period of 1 week or less?
Coughlin paid for one month's rent up front at the time the Renal Agreement was
000114
signed. Also, see isthe craigslist ad Coughlin responded to placed by Northwind, and
incorporated into an "Rental Agreement", along with verbal indications, arguably,
under NRS 118A.160 (which only applies to "dwelling places", but the Landlord's
Affidavit inidcates this rental was, in paragraph 2 such, as it states "2. That yor
affiant isrented a certain dwelling or apartment to Zach Coughlin, located at 1680 sky
mountain dr...#29, Reno, NV on 5/4/12 for an original period of N/a terminating on or
transferrinto a periodic tenancy on that date. a copy of the written rental agreemet if
any, is attached hereto.".. Chandler seems to want to take advanteg of NRS
40.253(2)'s quickie service approach for week to week rentals, which unit 29, by
virtue of the terms of the Rental Agreement, clearly was not. as him and him and him
this but the new the signatures is written in the amount of $75 is due no later than the
first of late after the for every month late is asked Bob Loblaw clearly this was a
periodic tenancy of month to month for variety further one provision and this one is
rental agreements has written 30 days notice to vacate is required or rental will be
responsible the next months rent covered Chandler tends to one characterize this as a
week to week or less type tenancy to take advantage of the lessons service
requirements there and found in NRS 40.253(1)-(2):
Further, the Rental Agreement is not necessarily limited to the document that
NOrthwind Apartments purports to be the "GARAGE / CARPORT RENTAL
AGREEMENT" as their exists no limitation in that document that affirmatively
disclaims any incorporation of statements by then Manage Deede Call (whom
mysteriously disappeared upon current Manager Dwayne Jakob showing up) or
incorporated into the Rental Agreement or Lease by virtue of the advertisements that
Northwinds held out to the public on Craigslist, which is how Coughlin learned of
their offer, upon which Coughlin called then Manager Deede Call and met with her in
person. Attached in Exhibit 1 is the Craigslist ad that Northwinds was running at the
time, and it read:
"$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below
Welcome to Northwind Apartments. We offer storage units to non-Northwind
Residents!If you need more storage, we offer garages to rent for $75 per month.
They are a full size single car garage. Mostpublic storages would charge over $150
dollars for the same size! Our community is located in northwest Reno, right
off of McCarran.Please call us at (775) 747-9200 or come by. We are located at 1680
000115
Sky Mountain Drive in Northwest Reno."

AND IT GETS BETTER: The thing about NRS 40.760 is that it specifically
indicates that it does not apply to "garages". And Judges don't legislate from the
bench, they just apply the law as written, so people can depend on notice provided by
precedent and published laws. To do otherwise is judicial misconduct arguably
requiring a Complaint with the Judicial Discipline Commission.
Further Coughlin asked and then Manager Deede Call (she is listed as the manager on
the "RENTAL AGREEMENT" of May 4th, 2012, and it bears hers and Coguhlin's
signature, numerous questions vis a vis the use of the rental, and clearly, Deede Call
gave Coughlin permission (and actually, Call did not indicate any "special permission"
to use the rentals for something other than parking a car was necessary to obtain
anyways, and no one has established that Coughlin did not use the rentals for parking
anyways, and any Fourth Amendment violating trespass and videoing of Coughlin's
rentals is not admissible anyways. Soldal v. Cook Co.
CHAPTER 40 - ACTIONS AND PROCEEDINGS IN PARTICULAR CASES

CONCERNING PROPERTY SUMMARY PROCEEDINGS FOR OBTAINING
POSSESSION OF REAL PROPERTY, RECREATIONAL VEHICLE OR MOBILE
HOME
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and
exclusion of tenant for default in payment of rent.
NRS 40.280 Service of notices to quit; proof required before issuance of order to
remove.
NRS 40.400 Rules of practice.
CHAPTER 108 - STATUTORY LIENS
LIENS OF OWNERS OF FACILITIES FOR STORAGE
NRS 108.475 Use of storage space for residence prohibited; eviction; nature of
facility; effect of issuance of document of title for property.
000116
CHAPTER 118A - LANDLORD AND TENANT: DWELLINGS
CHAPTER 197 - CRIMES BY AND AGAINST THE EXECUTIVE POWER OF THIS

STATE
NRS 197.090 Interfering with public officer.
NRS 197.100 Influencing public officer.
NRS 197.110 Misconduct of public officer.
NRS 197.120 False impersonation of public officer; intrusion into and refusal to
surrender public office.
NRS 197.130 False report by public officer.
NRS 197.140 Public officer making false certificate.
NRS 197.160 Fraudulently presenting claim to public officer.
NRS 197.180 Wrongful exercise of official power.
NRS 197.190 Obstructing public officer.
The arrest of Coughlin at Northwinds Apartments on June 28th, 2012 by the same
WCSO Deputy Machen who filed a false affidavit attesting to have "personally
served" Coughlin the Summary Eviction ORder from Coughlin's former home law
office on November 1st, 2011, when in reality, Machen just posted the Order to the
door when nobody was home (and therefore committed trespass under color of law, as
he failed to comply with NRCP 5(b)(2) (made applicable to landlord tenant matters by
NRS 40.400) and NRCP 6(e).
So, WCSO Machen arrested Coughlin for a violation of NRS 197.190:
NRS 197.190 Obstructing public officer. Every person who, after due notice, shall refuse or
neglect to make or furnish any statement, report or information lawfully required of the person by
any public officer, or who, in such statement, report or information shall make any willfully untrue,
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misleading or exaggerated statement, or who shall willfully hinder, delay or obstruct any public
officer in the discharge of official powers or duties, shall, where no other provision of law applies,
be guilty of a misdemeanor.
Yet DDA charged Coughlin in the Criminal Complaint in RJC RCR2012-067980 with a different
crime, NRS 199.280:
"NRS: CHAPTER 199 - CRIMES AGAINST PUBLIC JUSTICE
OTHER OFFENSES
NRS 199.280 Resisting public officer.

A person who, in any case or under any circumstances not otherwise specially provided for,
willfully resists, delays or obstructs a public officer in discharging or attempting to discharge any
legal duty of his or her office shall be punished:
1. Where a firearm is used in the course of such resistance, obstruction or delay, or the person
intentionally removes, takes or attempts to remove or take a firearm from the person of, or the
immediate presence of, the public officer in the course of such resistance, obstruction or delay, for a
category C felony as provided in NRS 193.130.
2. Where a dangerous weapon, other than a firearm, is used in the course of such resistance,
obstruction or delay, or the person intentionally removes, takes or attempts to remove or take a
weapon, other than a firearm, from the person of, or the immediate presence of, the public officer in
the course of such resistance, obstruction or delay, for a category D felony as provided in NRS
193.130.
3. Where no dangerous weapon is used in the course of such resistance, obstruction or delay,
for a misdemeanor."
Why the change from DDA Young? It couldn't be becuase NRS 199.280 is more damaging to
Coughlin's law license, in light of SCR 111(6), than would be a simple little NRS 197.190 charge,
could it? Is that permissible where the WCDA and WCSO have a vested interest in discrediting
and demolishing Coughlin in light of allegation of misconduct by both of those offices with respect
to its treatment of Coughlin, in addition to misconduct against Coughlin by the WCDC?
000118
Nevada Supreme Court Rule 111(6): "6. Definition of serious crime. The term serious crime
means (1) a felony and (2) any crime less than a felony a necessary element of which is, as
determined by the statutory or common-law definition of the crime, improper conduct as an
attorney, interference with the administration of justice, false swearing, misrepresentation,
fraud, willful failure to file an income tax return, deceit, bribery, extortion, misappropriation,".
Convictions of a "serious crime" require Bar Counsel to file a SCR 111 Petition against the
attorney.
Could there be any clear demonstration of the retaliatory animus against Coughlin by the Washoe
County District Attorney's Office? Are prosecutors paid to play out grudges and sanction
misconduct by local law enforcement? Rather than just a "resisting" charge, DDA Young and the
WCDA want to try to glom on a "false swearing" and "inteferring with the administration of
justice" claim, even where the know of the 6/26/12 written correspondence by Coughlin to both the
Sparks and Reno Justice Courts and the Civil Division of the Washoe County Sheriff's Office.
Enough is Enough. This prosecutorial misconduct must not stand.
But, really Coughlin is hereby complaining to the landlord, pursuant to NS 118A.510 of a violation
of the criminal law by one who is arguably an "agent" of the landlord (not making a bribery
allegation here, to be clear, though):
NRS197.200Oppression under color of office.
1. An officer, or a person pretending to be an officer, who unlawfully and maliciously, under
pretense or color of official authority:
(a) Arrests or detains a person against the persons will;
(b) Seizes or levies upon anothers property;
(c) Dispossesses another of any lands or tenements; or
(d) Does any act whereby the person, property or rights of another person are injured,
commits oppression.
2. An officer or person committing oppression shall be punished:
(a) Where physical force or the immediate threat of physical force is used, for a category D
felony as provided inNRS 193.130.
(b) Where no physical force or immediate threat of physical force is used, for a gross
misdemeanor.
Further, this is an officil written complaint against WCSO Deputy Machen and Gomez, please place
a copy of this Complaint in their employment and personnel files, and please do the same with
respect to RPD Officer Alan Weaver, Sargent Dye, Sargent Oliver Miller, and Officer Welch for
their gross misdemeanor, consisting of doing that which is the domain of the Sheriff under NRS
40.760 in conection with the matter at Superior Mini Storage on or around September 21st, 2012
under the following law, in light of teh language in NRS 40.760 and NRS 108.475, which I made
the RPD aware of at the time, and Soldal v. Cook Co. Couldn't be too much of a budget crunch
000119
when local law enforcement acts the way they do, veritably goading civil rights tenant's right
attorney's into suing them through their reckless and tacky behavior: NRS197.180Wrongful
exercise of official power.Any person who willfully takes upon himself or herself to exercise or
officiate in any office or place of another, without being lawfully authorized thereto, is guilty of a
gross misdemeanor.
Also, uner NRS 118A.510, I am complaining of the following violations of criminal law on
Northwind's behalf:
NRS197.120False impersonation of public officer; intrusion into and refusal to surrender
public office.Every person who shall falsely personate or represent any public officer, or who
shall willfully intrude into a public office to which the person has not been duly elected or
appointed, or who shall willfully exercise any of the functions or perform any of the duties of such
officer, without having duly qualified therefor, as required by law, or who, having been an
executive or administrative officer, shall willfully exercise any of the functions of office after his or
her right to do so has ceased, or wrongfully refuse to surrender the official seal or any books or
papers appertaining to such office, upon the demand of his or her lawful successor, shall be guilty
of a gross misdemeanor.
[1911 C&P 67; RL 6332; NCL 10016]
NRS197.130False report by public officer.Every public officer who shall knowingly make
any false or misleading statement in any official report or statement, under circumstances not
otherwise prohibited by law, shall be guilty of a gross misdemeanor.
NEvada Court Services regularly attempts to mislead tenant's into thinking the act with color of law. From Joel
Durden barking at me in his Sheriff look-a-like getup that he is an "officer of the court" and from "Court
Services" to having the word "Court" in their name,etc., etc. NEvad Court Services impersonates public officers.
Additionally, Machen's police report is false to the extent that it fails to indicate that, at least at some point,
Machen and or Deputy Gomez refused to idnetify themslevs. They don't know what someone is doing inside
when they purport to "knock and announce" and the must reasonably be expected to assume one could have not
heard their initial announcing their idnetify (whether because they had headphones or, were in the bathroom,
whatever...and Machen and his cowboy partner Gomez refused to identify themselves in response to a request
that they do so by Coughlin, and similarly refused to slide through the door any paperwork or warrant describing
the purpose of their visit.
WCSO is that Machem's Affidavit of Service indicates that he "personally served" me,
which kind of reminds me of all that robo-signing and MERS fraud I come across in
my day job (and do you wonder how many attorneys in the foreclosure defense game I
am in constant contact with who are watching and witness the potential RICO
violations this writing mentions?), which includes being a foreclosure defense
attorney. So which is it? Did Machem "personally serve" me the Summary Eviction
Order? Richard G. Hill, Esq. likes to argue that I was "served" in compliance with all
time related rules because it was done in the "usual custom and practice of the
WCSO. What, exactly, is the "usual custom and practice of the WCSO? I hear a lot
about this "within 24 hours" stuff. So, I go hunting for some black letter law to
support what those at the RJC and in the clueless community at large (which often
includes Nevada Legal Services and Washoe Legal Services, the people you guys had
such trouble actually serving in the lawsuits I filed, which may have actually helped
000120
improved legal services in this community, if they were not dismissed due to
insufficiency of service of process, even where the IFP required the WCSO to served
the defendants....). Anyway, back to the "within 24 hours" phraseology: "
This whole business about The court may thereupon issue an order directing the
sheriff or constable of the county to remove the tenant within 24 hours after receipt of
the order... is inapplicable to this situation, where an Order Granting Summary
Eviction was signed by October 27th, 2011. That language is only found in situations
inapplicable to the current one. NRS 40.253(3)(b)(2), and NRS 40.253(5)(a) are the
only sections of NRS 40 where this within 24 hours language occurs, and those
situations only apply where, in:
40.253(3)(b)(2): 3. A notice served pursuant to subsection 1 or 2 must: ...(b) Advise
the tenant: . (2) That if the court determines that the tenant is guilty of an unlawful
detainer, the court may issue a summary order for removal of the tenant or an order
providing for the nonadmittance of the tenant, directing the sheriff or constable of the
county to remove the tenant within 24 hours after receipt of the order
and,
40.253(5)(a): 5. Upon noncompliance with the notice: (a) The landlord or the
landlords agent may apply by affidavit of complaint for eviction to the justice court
of the township in which the dwelling, apartment, mobile home or commercial
premises are located or to the district court of the county in which the dwelling,
apartment, mobile home or commercial premises are located, whichever has
jurisdiction over the matter. The court may thereupon issue an order directing the
sheriff or constable of the county to remove the tenant within 24 hours after receipt of
the order. The way these summary eviction proceedings are being carried out in Reno
Justice Court presently shocks the conscience and violates Nevada law. There is not
basis for effectuating a lockout the way WCSO's Deputy Machem did in this case. The
above two sections containing the within 24 hours of receipt language are
inapplicable, as those situations do not invoke the present circumstances, where the
Tenant did file an Affidavit and did contest this matter to a degree not often seen. To
require Nevada's tenants to get up and get out within 24 hours of receipt of the
order (what does that even mean? The use of terms like rendition, rendered,
notice of entry, pronounced, is absent here, and this receipt of the order
language is something rarely found elsewhere in Nevada law-see attached DMV
000121
statutory citations, and in employment law litigations where one must file a Complaint
within 90 days of receipt of a Right To Sue Letter, a situation which follows NRCP
5(b), and NRCP 6(e) in imputing receipt of such a letter, when actual receipt is not
shown, by applying a constructive notice standard that relies upon the days for
mailing extension of time for items served in the mailing, etc.). In Abraham v. Woods
Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009), the record did not reflect
when the plaintiff received his right-to-sue letter. The letter was issued on November
24, 2006. The court calculated that the 90-day period commenced on November 30,
2006, based on three days for mailing after excluding Saturdays and Sundays. In order
to bring a claim under either Title VII or the ADA, a plaintiff must exhaust
administrative remedies and sue within 90 days of receipt of a right to sue letter. See
42 U.S.C. 2000e-5(f)(1). See Baldwin County Welcome Center v. Brown, 466 U.S.
147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984)(granting plaintiff an additional
three days for mailing pursuant to Rule 6).
Further, despite what the inaccurate handouts of Nevada Legal Services may say about
this 24 hours and the applicability of the JCRCP to cases like these, NRS 40.400
Rules of practice, holds that :The provisions of NRS, Nevada Rules of Civil
Procedure and Nevada Rules of Appellate Procedure relative to civil actions, appeals
and new trials, so far as they are not inconsistent with the provisions of NRS 40.220 to
40.420, inclusive, apply to the proceedings mentioned in those sections. As such
NRCP 6(a),(e) applies to the Order of Summary Eviction that WCSO Deputy Machem
alleged, under penalty of perjury, that he "personally served" upon me on November 1,
2011. That is a lie by Mr. Machem, unless "personally served" is defined in a rather
impersonal way and or Machem and I have totally different understanding of the
definition of "personally served", which may be the case. Or, perhaps the Sheriff's
Office is busy and doesn't want to wait around to "personally serve" every tenant it
wishes to evict. Fine, then just use the "mail it and allow three days" rule in NRCP
6(e)...the landlord's might not like it, but they can use that frustration as an incentive
not to jump to litigating every disagreement about habitability that a tenant brings to
them. You may not realize how ridiculous some landlord's get. In my case, I offered
to fix basic things that clearly implicated the habitability rules in NRS 118A.290 and
the Californian neurosurgeon, Beverly Hill High School graduate landlord balked and
complained then hired and attorney four days into a dispute.....at which point the rules
against contacting represented parties prevented much in the way of real settlement
discussion, particularly where opposing counsel has continuously demonstrated a
000122
complete indifference to pursuing settlement (why would he at the rates he bills hours
at?). I just don't think the Sheriff's Office needs to sully its image or damage the
citizen tenants of Washoe County in the name of pleasing people like Dr. Matt Merliss
or Richard G. Hill, Esq.
I am hereby complaining to Northwind Apartments of a violation of the criminal law

by one of its agents R. Wray and other process servers with NCS (Oh, and RPD
Officer Weaver also threatened to use "hydraulic explosives" to gain entry to one of
my three rentals at Northwind, though no exigent circumstance existed and though he
lacked a warrant. I have previously complained of Lou Cadia, Milan Krebs, both
Northwind Maintenance Personnel, and Northwind Property Manager or Apartment
Manager Dwayne Jakob attempt to break and enter into my rentals (why is it when
Richard G. Hill, Esq. calls the RPD and alleges I am trespassing, I get subject to a
custodial arrest and Hill gets the State Bar of Nevada to try to prosecute me for
"breaking an entering", even though WCSO Machen lied in his Affidavit of Service in
RJC rev2011-0010708, and the Court had failed to return to me at the time of arrest
the $2,275 it wasn't permitted to require I deposit in a "rent escrow" account in the
first place, and where Hill and his contractor are caught on video admitting to having
remove my ladder from the former law office (in a video of December 23rd,
2011...why doesn't the RPD arrest Hill and Phil Stewart for larceny of my ladder? Do
I have to be Wal-Mart or Richard G. Hill or Northwinds Apartments (ie, rich,
connected) to get the RPD to enforce the law when I complain of a violation?
1. Except as otherwise provided in NRS 40.253, the notices required by NRS 40.251 to 40.260, inclusive, may
be served:
(a) By delivering a copy to the tenant personally, in the presence of a witness;
(b) If the tenant is absent from the tenants place of residence or from the tenants usual place of business, by
leaving a copy with a person of suitable age and discretion at either place and mailing a copy to the tenant
at the tenants place of residence or place of business; or
000123
(c) If the place of residence or business cannot be ascertained, or a person of suitable age or discretion cannot
be found there, by posting a copy in a conspicuous place on the leased property, delivering a copy to a person
there residing, if the person can be found, and mailing a copy to the tenant at the place where the leased
property is situated.
2. Service upon a subtenant may be made in the same manner as provided in subsection 1.
3. Before an order to remove a tenant is issued pursuant to subsection 5 of NRS 40.253, a landlord shall file
with the court a proof of service of any notice required by that section. Before a person may be removed as
prescribed in NRS 40.290 to 40.420, inclusive, a landlord shall file with the court proof of service of any
notice required pursuant to NRS 40.255. Except as otherwise provided in subsection 4, this proof must
consist of:
(a) A statement, signed by the tenant and a witness, acknowledging that the tenant received the notice on a
specified date;
(b) A certificate of mailing issued by the United States Postal Service; or
(c) The endorsement of a sheriff, constable or other process server stating the time and manner of service.
4. If service of the notice was not delivered in person to a tenant whose rent is reserved by a period of 1 week or
less and the tenancy has not continued for more than 45 days, proof of service must include:
(a) A certificate of mailing issued by the United States Postal Service or by a private postal service to the
landlord or the landlords agent; or
(b) The endorsement of a sheriff or constable stating the:
(1) Time and date the request for service was made by the landlord or the landlords agent;
(2) Time, date and manner of the service; and
(3) Fees paid for the service."
[
NRS 118A.430 Failure of tenant to comply with rental agreement or perform basic
obligations: Termination of rental agreement.
1. Except as otherwise provided in this chapter, if the tenant fails to comply with
the rental agreement or fails to perform his or her basic obligations under this chapter,
the landlord may deliver a written notice to the tenant specifying the acts and
omissions constituting the breach and that the rental agreement will terminate as
provided in this section. If the breach is remediable and the tenant does not adequately
remedy the breach or use his or her best efforts to remedy the breach within 5 days
after receipt of the notice, or if the breach cannot be remedied, the landlord may
terminate the rental agreement.
2. If the tenant is not reasonably able to remedy the breach, the tenant may avoid
000124
termination of the rental agreement by authorizing the landlord to enter and remedy
the breach and by paying any reasonable expenses or damages resulting from the
breach or the remedy thereof.
Northwinds and NCS failed to comply with NRS 118A.430(1) (to the extent it even
applies her) in that in no way did it "deliver a written notice to the tenant specifying
the acts and omissions constituting the breach". Northwinds simply wrote "see
attached", after paragraph 6 of teh 6/14/12 Notice, which reads "6. Remained in
posssession of the premises subject to the provisions of Chapter 118A of the NRS
after having failed ot perfrom the basic or contractual obligations imposed upon you
by that Chapter, namely: (SEE ATTACHED)" and then NCS, at most, include a copy
of the "Rental Agreement" with its filing of this Notice to the RJC, which in no way
specifies what aspect of that Rental Agreement Coughlin is purportedly in breach of,
or what facts supports such an allegation.
Any Order he is void or subject oa NRCP 60b set aside based upon the fraud of NCS
and Wray in lying where he declares (under penalty of perjury) to have "personally
served" Coughlin the 5 day notie on 6/14/12, and under NRCP 60b4 void for lack of
jurisdiction where NCS failed to specify in the Lanldord's Affidavit all that required
under NRS 40.253. and for so many other reasons, such at 118A does not apply if the
rental is deemed to be not e "dwelling", and that an illegal lockout is not available
even if Coughlin is ruled to have been "using as a residence" the rental, should the
rental be a "storage facility" which City of Reno Code Enforcement does not view it
to be...and Further, by Northwinds very own descriptives, it is a garage, one they held
out to the public for more than mere "parking a car", and as such, under NRS 40.760
and 108.4733, 108.475 and NRS 40.760 are not even available to Northwind. They.
Are. Stuck. Deal With It.
NRS108.4733Facility defined.Facility means real property divided into individual storage spaces. The term does not include a
garage or storage area in a private residence.
000125
NRS108.4746Storage space defined.Storage space means a space used for storing personal property, which is rented or leased to
an individual occupant who has access to the space.
NRS108.475Use of storage space for residence prohibited; eviction; nature of facility; effect of issuance of document of title for
property.
1. A person shall not use a storage space at a facility for a residence. The owner of such a facility shall evict any person who uses a
storage space at the facility as a residence in the manner provided for inNRS 40.760.
NRS108.4755Contents of rental agreement.

1. Each rental agreement must be in writing and must contain:
(a) A provision printed in a size equal to at least 10-point type that states, IT IS UNLAWFUL TO USE A STORAGE SPACE IN THIS
FACILITY AS A RESIDENCE.
MISCELLANEOUS PROVISIONS
NRS 40.760 Summary eviction of person using facility for storage as residence.
1. When a person is using a storage space at a facility as a residence, the owner or the owners agent shall serve or have served a notice in
writing which directs the person to cease using the storage space as a residence no later than 24 hours after receiving the notice. The notice
must advise the person that:
(a)NRS 108.475requires the owner to ask the court to have the person evicted if the person has not ceased using the storage space as a
residence within 24 hours; and
(b) The person may continue to use the storage space to store the persons personal property in accordance with the rental agreement.
2. If the person does not cease using the storage space as a residence within 24 hours after receiving the notice to do so, the owner of the
facility or the owners agent shall apply by affidavit for summary eviction to the justice of the peace of the township wherein the facility is
located. The affidavit must contain:
(a) The date the rental agreement became effective.
(b) A statement that the person is using the storage space as a residence.
(c) The date and time the person was served with written notice to cease using the storage space as a residence.
(d) A statement that the person has not ceased using the facility as a residence within 24 hours after receiving the notice.
3. Upon receipt of such an affidavit the justice of the peace shall issue an order directing the sheriff or constable of the county to remove
the person within 24 hours after receipt of the order. The sheriff or constable shall not remove the persons personal property from the
facility.
4. For the purposes of this section:
(a) Facility means real property divided into individual storage spaces. The term does not include a garage or storage area in a private
residence.
(b) Storage space means a space used for storing personal property, which is rented or leased to an individual occupant who has
access to the space.
(Added to NRS by 1989, 213; A2011, 1830)
Nevada Process Server Licensing Requirements

It is required that all process servers are licensed and 21, or over, two-years experience as a process server and
000126

insurance against liability to third persons with limits of no less then $200,000. No bonding is required. However,
applicants must deposit $750 upon submitting their application to pay for a background investigation, the maximum an
applicant can be charged for a background check is $1500. Applicants must also pass a written application and may be
required to pass an oral exam as well. Licenses are issued by the Nevada Private Investigators Licensing Board.
Nevada is the most expensive state in the nation to get licensed. [Nevada Revised Statutes 648.110 and 648.135]

exclusion of tenant for default in payment of rent.
"
1. Except as otherwise provided in subsection 10, in addition to the remedy provided

in NRS 40.2512 and 40.290 to 40.420, inclusive, when the tenant of any dwelling,
apartment, mobile home, recreational vehicle or commercial premises with periodic
rent reserved by the month or any shorter period is in default in payment of the rent,
the landlord or the landlords agent, unless otherwise agreed in writing, may serve or
have served a notice in writing, requiring in the alternative the payment of the rent or
the surrender of the premises:
(a) At or before noon of the fifth full day following the day of service; or
(b) If the landlord chooses not to proceed in the manner set forth in paragraph (a) and
the rent is reserved by a period of 1 week or less and the tenancy has not continued for
more than 45 days, at or before noon of the fourth full day following the day of
service.
As used in this subsection, day of service means the day the landlord or the
landlords agent personally delivers the notice to the tenant. If personal service was
not so delivered, the day of service means the day the notice is delivered, after
posting and mailing pursuant to subsection 2, to the sheriff or constable for service if
the request for service is made before noon. If the request for service by the sheriff or
constable is made after noon, the day of service shall be deemed to be the day next
following the day that the request is made for service by the sheriff or constable.
2. A landlord or the landlords agent who serves a notice to a tenant pursuant to
paragraph (b) of subsection 1 shall attempt to deliver the notice in person in the
manner set forth in paragraph (a) of subsection 1 of NRS 40.280. If the notice cannot
be delivered in person, the landlord or the landlords agent:
(a) Shall post a copy of the notice in a conspicuous place on the premises and mail the
000127
notice by overnight mail; and

(b) After the notice has been posted and mailed, may deliver the notice to the sheriff
or constable for service in the manner set forth in subsection 1 of NRS 40.280. The
sheriff or constable shall not accept the notice for service unless it is accompanied by
written evidence, signed by the tenant when the tenant took possession of the
premises, that the landlord or the landlords agent informed the tenant of the
provisions of this section which set forth the lawful procedures for eviction from a
short-term tenancy. Upon acceptance, the sheriff or constable shall serve the notice
within 48 hours after the request for service was made by the landlord or the
landlords agent.
3. A notice served pursuant to subsection 1 or 2 must:
(1) Of the tenants right to contest the matter by filing, within the time specified in
subsection 1 for the payment of the rent or surrender of the premises, an affidavit with
the court that has jurisdiction over the matter stating that the tenant has tendered
payment or is not in default in the payment of the rent;
(2) That if the court determines that the tenant is guilty of an unlawful detainer, the
court may issue a summary order for removal of the tenant or an order providing for
the nonadmittance of the tenant, directing the sheriff or constable of the county to
remove the tenant within 24 hours after receipt of the order; and
(3) That, pursuant to NRS 118A.390, a tenant may seek relief if a landlord unlawfully
removes the tenant from the premises or excludes the tenant by blocking or attempting
to block the tenants entry upon the premises or willfully interrupts or causes or
permits the interruption of an essential service required by the rental agreement or
chapter 118A of NRS.
4. If the tenant files such an affidavit at or before the time stated in the notice, the
landlord or the landlords agent, after receipt of a file-stamped copy of the affidavit
which was filed, shall not provide for the nonadmittance of the tenant to the premises
by locking or otherwise.
000128

(a) The landlord or the landlords agent may apply by affidavit of complaint for
eviction to the justice court of the township in which the dwelling, apartment, mobile
home or commercial premises are located or to the district court of the county in
which the dwelling, apartment, mobile home or commercial premises are located,
whichever has jurisdiction over the matter. The court may thereupon issue an order
directing the sheriff or constable of the county to remove the tenant within 24 hours
after receipt of the order. The affidavit must state or contain:
(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess
of the first months rent, by the tenant.
(7) A statement that the written notice was served on the tenant in accordance with
NRS 40.280.
(b) Except when the tenant has timely filed the affidavit described in subsection 3 and
a file-stamped copy of it has been received by the landlord or the landlords agent, and
except when the landlord is prohibited pursuant to NRS 118A.480, the landlord or the
landlords agent may, in a peaceable manner, provide for the nonadmittance of the
tenant to the premises by locking or otherwise.
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of
the information contained in the affidavit, and the filing by the landlord of the
affidavit permitted by subsection 5, the justice court or the district court shall hold a
000129
hearing, after service of notice of the hearing upon the parties, to determine the
truthfulness and sufficiency of any affidavit or notice provided for in this section. If
the court determines that there is no legal defense as to the alleged unlawful detainer
and the tenant is guilty of an unlawful detainer, the court may issue a summary order
for removal of the tenant or an order providing for the nonadmittance of the tenant. If
the court determines that there is a legal defense as to the alleged unlawful detainer,
the court shall refuse to grant either party any relief, and, except as otherwise provided
in this subsection, shall require that any further proceedings be conducted pursuant to
NRS 40.290 to 40.420, inclusive. The issuance of a summary order for removal of the
tenant does not preclude an action by the tenant for any damages or other relief to
which the tenant may be entitled. If the alleged unlawful detainer was based upon
subsection 5 of NRS 40.2514, the refusal by the court to grant relief does not preclude
the landlord thereafter from pursuing an action for unlawful detainer in accordance
with NRS 40.251.
7. The tenant may, upon payment of the appropriate fees relating to the filing and
service of a motion, file a motion with the court, on a form provided by the clerk of
the court, to dispute the amount of the costs, if any, claimed by the landlord pursuant
to NRS 118A.460 or 118C.230 for the inventory, moving and storage of personal
property left on the premises. The motion must be filed within 20 days after the
summary order for removal of the tenant or the abandonment of the premises by the
tenant, or within 20 days after:
whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a
hearing on the motion. The hearing must be held within 10 days after the filing of the
motion. The court shall affix the date of the hearing to the motion and order a copy
served upon the landlord by the sheriff, constable or other process server. At the
hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or
118C.230 and any accumulating daily costs; and
000130
(b) Order the release of the tenants property upon the payment of the charges
determined to be due or if no charges are determined to be due.
9. A landlord shall not refuse to accept rent from a tenant that is submitted after the
landlord or the landlords agent has served or had served a notice pursuant to
subsection 1 if the refusal is based on the fact that the tenant has not paid collection
fees, attorneys fees or other costs other than rent, a reasonable charge for late
payments of rent or dishonored checks, or a security. As used in this subsection,
security has the meaning ascribed to it in NRS 118A.240.
10. This section does not apply to the tenant of a mobile home lot in a mobile home
park or to the tenant of a recreational vehicle lot in an area of a mobile home park in
this State other than an area designated as a recreational vehicle lot pursuant to the
provisions of subsection 6 of NRS 40.215.
(Added to NRS by 1967, 195; A 1969, 263, 575; 1973, 1085; 1975, 1202; 1977, 418,
1346; 1979, 1398, 1879; 1985, 229; 1987, 1239; 1989, 1082, 1232; 1991, 113; 1995,
1851; 1997, 3511; 1999, 981; 2009, 1966; 2011, 235, 1489)

exclusion of tenant from certain types of property. Except as otherwise provided by
specific statute, in addition to the remedy provided in NRS 40.251 and in NRS 40.290
to 40.420, inclusive, when the tenant of a dwelling unit which is subject to the
provisions of chapter 118A of NRS, part of a low-rent housing program operated by a
public housing authority, a mobile home or a recreational vehicle is guilty of an
unlawful detainer, the landlord is entitled to the summary procedures provided in NRS
40.253 except that:
1. Written notice to surrender the premises must:
(a) Be given to the tenant in accordance with the provisions of NRS 40.280;
(b) Advise the tenant of the court that has jurisdiction over the matter; and
(c) Advise the tenant of the tenants right to contest the notice by filing within 5 days
an affidavit with the court that has jurisdiction over the matter that the tenant is not
guilty of an unlawful detainer.
000131
2. The affidavit of the landlord or the landlords agent submitted to the justice court or
the district court must contain:
(a) The date when the tenancy commenced, the term of the tenancy, and, if any, a copy
of the rental agreement.
(b) The date when the tenancy or rental agreement allegedly terminated.
(c) The date when the tenant became subject to the provisions of NRS 40.251 to
40.2516, inclusive, together with any supporting facts.
(d) The date when the written notice was given, a copy of the notice and a statement
that notice was served in accordance with NRS 40.280.
(e) A statement that the claim for relief was authorized by law.
3. If the tenant is found guilty of unlawful detainer as a result of the tenants violation
of any of the provisions of NRS 453.011 to 453.552, inclusive, except NRS 453.336,
the landlord is entitled to be awarded any reasonable attorneys fees incurred by the
landlord or the landlords agent as a result of a hearing, if any, held pursuant to
subsection 6 of NRS 40.253 wherein the tenant contested the eviction.
(Added to NRS by 1985, 227; A 1989, 1084, 1234; 1991, 115; 1995, 1853; 2001,
1065; 2003, 561)"
I WOULD LIKE TO KNOW WHY THE FILE IN RJC REV2012-001048 HAS MY 6

PAGE FAX OF JUNE 30TH, 2012 (AND PLEASE NOTE THE LIMITED OR
SPECIAL APPEARANCE NATURE OF THAT FILING IN THE NOTE AT THE
BOTTOM OF THE FIRST PAGE....YET IT IS NOT FILE STAMPED, AND I WAS
NEVER CALLED, OR FAXED, OR NOTIFIED IN ANY WAY CONCERNING
THE SCHEDULING OF MY CONSTITUTIONALLY GUARANTEED HEARING
BEFORE A SUMMARY EVICTION OR STATUS OF MY IFP REQUEST.
000132
MY POSITION IS THAT I AM ENTITLED TO A SUMMARY EVICTION

HEARING ON UNIT 29 AND THAT IT IS LONG OVERDUE. PLEASE LET ME
KNOW WHEN THAT HEARING CAN TAKE PLACE. I DO NOT BELIEVE ANY
JUDGE CURRENTLY HAS JURISDICTION ON IT, AND THAT THE NEW
CASE, WITH A NEW CASE NUMBER SHOULD BE "RANDOMLY ASSIGNED"
Further in the Reno justice court file for rjc rev2012-001048 is a tenant affidavit and declaration from
Coughlin faxed to the court on June 30, 2012 contain six pages it is unclear why Coughlin was not
granted a summary eviction hearing as required by law and Coughlin is hereby demanding one and a
jury trial which he is entitled to one pursuant the 19 Seventies the Court decision and FRCP rule 30
a.m. that Coughlin is requesting one prior to the time set for hearing that's right folks were going to a
jury trial when Nevada court services served an amended eviction notice on June 28 Coughlin there
and had five days to file for an eviction summary eviction hearing and he did so on June 30 just for
the Reno PD managed commit another wrongful arrest of Coughlin further there was County jail failed
to transfer Coughlin for the July 5 hearing on Coughlin's motion to set aside the original June 27 order
however the June 27 order in this case was extinguished by that posting of an amended lockout
notice therefore and eight it's not file stamp but it should be by the Reno justice court the six page
fax by Coughlin on June 30, 2012, though Karen Stancil appears to have handwritten in the case
number RJC rev2012-001048
PLEASE NOTE I AM USING AUDIO DICTATION TRANSCRIPTION SOFTWARE FOR THIS
CORRESPONDENCE AND IT MIGHT HAVE SOME ERRORS, WHICH COULD GREATLY ALTER THE
MEANING, AS I DON'T HAVE TIME TO CORRECT THEM RIGHT NOW.
additionaly THERE WAS SEVERAL FAXES TO THE RJC CIVIL DIVISION BY COUGHLIN ON OR ABOUT
JUNE 13TH, 2012, AND COUGHLIN REQUESTS A COPY OF THOSE OR SOME INDICATION OF WHY
THEY WERE NOT FILED AND COUGHLIN WILL CHECK HIS OWN RECORDS IN THAT REGARD WHEN
HE HAS TIME...HOWEVER, TO THE EXTENT ONE OF THOSE FILINGS WAS A TENANT'S AFFIDAVIT
DIRECTED TOWARDS UNIT 29, LOTS OF PROCEDURAL IMPLICATIONS WILL STEM.
NORTHWIND APARTMENT
ASSOC LLC
1031 XPRESS
NORTHWIND LLC
550
BELLEVUE, WA 98004
Description
Summary
74040
Business Name: NORTHWIND APARTMENTS Owners: NORTHWIND APARTMENT ASSOCIATES, LLC
s Firm Name - Counter - 109351
Filing Information
Filing Number
109351
Filing Date
03/16/2006 12:00:00 AM
Expiration Date
03/16/2011
Business Information
Business Name
000133

RENO RED BOOK

Owner Information
Owner/Corporate Name
JEFFREY G CHANDLER u
104085
Business Name: BOTTS CANDY COMPANY Owners: JENNIFER V CHANDLER, CINDY R VANDERZIEL
Him and him and him and him motion a set of society eviction order of the number of bases one it
went unopposed and
hundred Polk case Coughlin wins in that regard to the notice of hearing by the Reno justice court is
dated July 31,
2012 are not as of the hearing on July 21, 2012 stated July 24, 2012 and him notices on what the
hearing is limited
to quote you may appear on the data show cause why the court should or should not grant motion to
stay the eviction
order in the motion for expedited relief following legal lot coverage utility shut off. If you the. Must be
prepared
to provide testimonial documentary evidence the court which torture position if he failed to appear
karmic
renovation would form a dismiss case. With what the notice does not say is that the hearing will
address the motion
to set aside eviction order Coughlin filed on July 24, 2012 and that which and for which now he
request the court to
rule in his favor or at least provide hearing or at the very and for or at the very least require
Northwind and/or
their qualified attorneys or whoever to file an opposition something under of explaining why their are
three
separate notices for her three separate process affidavits of service for the June 14, 2012 personal
service of a
five-day unlawful detainer affidavit by Robert Ray of Nevada court services that's right there's three
separate ones
and Coughlin's possession now and they bear different things as well isn't that interesting half add to
that the
fact that Nevada court services agreed with Coughlin's assessment that its original on June 14 notice
of unlawful
detainer failure to vacate premises was ineffective and that it listed the wrong forum is or court for
the tenant to
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file a tenant at search engines affidavit as required by law under 40.253 that's not something the
judge piercing
can excised from the law or legislate from the bench out of existence that is a law. The Reno justice
court does not
have jurisdiction with the notice last Sparks justice court the fugitive document for the landlord to file
it
landlord's affidavit and then to manage to get Coughlin arrested based upon a void order that should
never issued
judge Shrader particularly where supervisor of the syllable division Karen Stancil was alerted and well
in advance
by Coughlin through phone calls and mid-June in that June 26 of written correspondence to the court
that included in
the file on the left side of the correspondence and where the Sparks justice court itself fax the Reno
justice court
that a fax alerting it to the problematic aspects of the June 14 notice Coughlin was arrested he went
to jail he
paid bail he did time incurred massive damages it's appalling for judge piercing to ignore all this while
also
sanctioning the unauthorized practice of law by Jeff Chandler Nevada court services who dress up like
they are
Sheriff's and managed to the word court into their name and bang on people store and leave off the
Nevada part so
much so that it and it seems as though they are actually acting with color of law in the screening you
to come out
of your house and bang on the door parted sounds like they are cost of the Sheriff and have to do
exactly what you
said. Those few who don't Nevada court services has something up their sleeve in the form of
attempting to break and
enter and one's residence or sex service of process by as Nevada court services has done to Coughlin
on numerous
occasions sometimes captured on videotape further Nevada court services is trespassed on numerous
occasions like
office property Coughlin however is the only one who's arrested and convicted trespassing and had
reported rehashes
patent trademark office and had impact his ability to practice his chosen profession for which he has
to does have a
law license and actually did that a lot four. Further there's initial conflict in the judge piercing work to
the
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district attorneys office first 12 years of his career and the Washoe County Sheriff and potentially
Washoe County
District Attorney's Office may have it engages the misconduct in connection with the approximately 10
different
incarcerations Coughlin space this year most all connected one where another To the Way, Reno
justice court handles
landlord-tenant matters or fails to apply the law as written and created by the assembly the Senate
i.e. the
legislature Nevada and Carson City to be clear Nevada court services recognize the validity of
Coughlin's argument
that when he announced to them on June 28 at approximately 10 AM to 10:45 AM is where Coughlin
pointed out that the
the June 14 notice listed Sparks justice court that Nevada court services responded by serving in the
amended
declaration of service by license process server on June 28 thereby vitiate in any order lockout order
rescinding
and waving it etc. etc. June 28, 2012 fax from the Sparks justice court to the Reno justice court
contains a fax
Coughlin sent the Sparks justice court on June 26 that at 12 PM noon of that date that faction
Coughlin was 10 pages
the facts from the Sparks justice court the Reno justice court was apparently 13 pages no number of
those pages are
not included in the file of this matter and the Reno justice court back to the three different notices of
unlawful
detainer either stamped by w which doesn't count by the way one needs to sign something attorneys
don't get a stamp
things and file them and then later on claim they didn't commit commit misconduct or her perjury or
rule 11
violation merely because it is sign something Nevada court services continues to just put stamps
instead of actual
signatures and that's an appropriate and under the Aiken case is in Nevada and summary of
proceedings the technical
aspects of notice and due process requirements must be strictly adhered to not run out with the
bathwater by judge
Pearson because he either doesn't like off-line or thinks Coughlin doesn't deserve due process of the
law article
protection because Coughlin's an attorney you know Coughlin's not a license attorney currently needs
not able to
000136
make attorney money or do attorney things or even commit the unauthorized practice of law with
impunity like Nevada
court services because know Coughlin you know of Coughlin was to do so the State Bar would find it
to be a contempt.
Further judge Pearson's order for summary eviction of July 31 is void in several respects one it
purports rule one
units 2971 when unit 71 is not properly before the court unit 71 has its own case numbers of
rev2012-0067 and
rev2012-001082 (the multiplicty is due to, as here, THE RJC shortcutting due process aspects of the
process,
whererin "Orders" by Judges paid quite a bit of money are nothing more than handwritten notes on
Coughlin's own
filings...Some of those such "note ORders" by Judge Schroeder resulte in confusing vis a vis whether
Coguhlin's
IFP's were granted, and necessitated the filing of companion cases for units 45 and 71 in rev20120067 and rev2010068 in rev2012-001082 and rev2012-00183. To simply make Coughlin scapegoated all medicine
blame him for taking of
regardless the July 31 order by judge Pearson in rev 2012 00 1048 purports rule on matters not
noticed in the July
24 notice specifically in that order which reads the court finds eviction was appropriate motion to stay
eviction
order denied motion to set aside eviction order denies motion to contest personal property lien denied
motion on
illegal lockout denied tenant have always property removed is 2971 by 5 PM on August 5, 2012 only
about half of that
order was properly before the court notice litigants that I'm what was notice to the litigants in the July
24 notice
was that the hearing would be limited to the motion to stay eviction order in a motion for expedited
relief
following illegal lockout utility shutoff however the order went on to rule on matters non-there and
noticed
including the motion to set aside the eviction order the motion to contest personal property lien and
that matters
related to the property of a unit not even involved in a case number unit 71 further there required
Coughlin a hub
Allis property removed even earlier than the law requires given that after the 30 day plan under NRS
118 A.460 the
000137
landlord may not dispose of the property until 14 days of pass from mailing to the tenant last known
address a
certified letter. So there and again judge Pearson is violating the law in failing to apply evenly to
Coughlin in
fact he's attempting to exCise protections accorded and Coughlin under Nevada's landlord tenant law
which is the
most pro-landlord law set of laws in the country but that's not good enough for judge piercing he
wants to cut even
more protections out of it when it comes to Coughlin and the reasoning behind that is not clear
though Coughlin has
had some issues with Washoe County District Attorney's Office this year in judge Pearson did spend
the first 12
years of his career there.
Attached in exhibit a are the three different June 14 declarations of service by license process server
Robert (or Ryan?) Wray ..That's right, Coughlin has in his possession three different NOtice of UD
dated 6/14/12 and either "stamped" with "R. Way" or actually containing a handwritten signature by
R. Wray (though the one actually signed lacks a time indication, and they all lack a "manner of
service" or any other particular beyond falsely attesting to have been "personally served". WRay and
NORthwinds manager attempted to break and enter into unit 29 in hopes of effecting "personal
service" upon Coughlin in a unit that had not windows and that had the door closed and locked and
or barred. That is a criminal act and Coughlin is now again hereby complaining about it to the
landlrod, so have fun reading NRS 118A.510's and NRS 118A.390 and I'll see you in Court, and WRay,
you should probably self report to the process server licensing body and hope for the best. Check out
the video fo the 6/28/12 arrest wherein the WCSO's Gomez and Machen tell Chandler to "let us do the
talking, Jeff", then Chandler, dressed up in an outfit and with a company name intended to connote
color of law type authority, purports to trespass Coughlin from the whole place, ie, the entire premises
at 1680 Sky Mountain Dr., depsit Coughlin still having, at the time, one, and perhaps two valid leases,
to units 45 and 71. Further, the Washoe County Detention Center or jail took a tenan'ts affidavit from
Coughlin on or aoround July 15th, 2012 for units 45 and another for unit 71 and due to Coughlin's
indigency, the jail library indicate it would be filed with the rjc....WAs it? LITIGATION HOLD NOTIE
TO THE JAIL AND THE RJC.
From: zachcoughlin@hotmail.com
To: chansen@washoecounty.us
Subject: Reno eviction noticed for Sparks Justice Court
Date: Tue, 26 Jun 2012 09:10:14 -0700
Dear Civil Supervisor Hansen

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
000138
Fax 949 667 7402

Dear Sparks Justice Court,
I called and received permission to file this by fax...I am indigent and request a fee waiver, and failing
that, an opportunity to cure any filing fee deficiency.
To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us;
chansen@washoecounty.us; milllerr@reno.gov
Subject: Reno eviction noticed for Sparks Justice Court
Date: Tue, 26 Jun 2012 07:58:36 -0700
Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful
detainer?) for rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the notice indicates that I
must file a Tenant's Answer with the Sparks Justice Court.
Am I mistaken in viewing this matter to be outside the jurisdiction of the Sparks Justice Court, and
rather, a matter to be handled in Reno Justice Court?
Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court
has 4 judicial days a week, the deadline for filing a special appearance (to contest jurisdiction) and or a
Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he
indicated the WCSO planned to come effectuate an eviction on this date, June 26, 2012. I believe that
would be premature, as Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit
by noon after the fifthfullday (judicial days) and Fridays in Sparks Justice Court are notfull daysin that
sense, and regardless, Sparks Justice Court, I believe, is not the appropriate forum where, as here, the
situs is located in Reno (Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
000139
Civil Division
630 Greenbrae Drive
Sparks, Nevada 89431
(775)353.7603 Phone
(775)352.3004 Fax
Civil Department Supervisor
Chris Hansen
chansen@washoecounty.us
The CivilDivision of Sparks Justice Court is made up of three major functions:
Civil
Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive
damages, an action to obtain possession of property, a writof restitution, or other like actions, legal
counsel is suggested for these types of actions.
Evictions
An act or process of legally dispossessing a person of land or rental property.
Small Claims
An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims
action may be filed with the Sparks Justice Court if one of the following applies to the defendant:
1. They reside within the boundaries of the Sparks Township;
2. They are employed within the boundaries of the Sparks Township; and/or,
3. They do business within the boundaries of the Sparks Township.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
LITIGATION HOLD NOTICE FW: Reno eviction noticed for Sparks Justice Court
9/21/12
Zach Coughlin
To stuttle@washoecounty.us, millero@reno.gov, jmachen@washoecounty.us, brownk@reno.gov, renodire Reply
From: Zach Coughlin(zachcoughlin@hotmail.com)

Sent: Fri 9/21/12 2:36 PM
To:
stuttle@washoecounty.us; millero@reno.gov; jmachen@washoecounty.us; brownk@reno.gov; renodirect@reno.gov;
lstuchell@washoecounty.us; kadlicj@reno.gov; christensend@reno.gov; mkandaras@da.washoecounty.us; apminfo@acg.com;
apminfo@yahoo.com; superior.storage@yahoo.com; 037nor4@acg.com; info@acg-apmi.com; chansen@washoecounty.us;
kstancil@washoecounty.us
000140
2 attachments (total 1164.6 KB)
coughlin ...pdf
Download (78.3 KB)
HotmailActive View
combined ...pdf
Download (1086.2 KB)
Download all as zip
Dear Sirs and Madams,
Please accept this as a LITIGATION HOLD NOTICE REQUIRING THE PRODUCTION AND MAINTENANCE OF ALL MATERIALS,
RECORDINGS, DOCUMENTATION, OR OTHER MATERIALS IN ANY WAY RELATED TO ZACHARY BARKER COUGHLIN AND HIS
TRIALS AND TRIBULATIONS WITH LOCAL LAW ENFORCEMENT, EMERGENCY SERVICES, ET AL WITHIN THE PAST COUPLE
YEARS WITHIN BOTH CIVIL AND CRIMINAL CASES, MATTERS, AND INCIDENTS AND WITHIN ANY OTHER SETTINGS.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us;
stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com; info@acg-apmi.com; rjcweb@wasoecounty.us;
jboles@callatg.com; apminfo@acg.com
Subject: FW: Reno eviction noticed for Sparks Justice Court
Date: Mon, 2 Jul 2012 17:21:54 -0700
NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on
July 29th, 2012"...giving me five days to get my stuff out of unit 29 (the one the subject of Judge
Schroeer's Eviction Order, which was effectively rescinded by their serving a new 5 day unlawful
detainer notice....) as well as units 71 and 45...whicih are two units to which i still have valide lease
agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated they will
arrest me for criminal trespass for accessing any units in the complex, including those to which I
still have a valid possessory or property interest, in violation of 42 usc 1983).
why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel"
000141
good looks and a much higher paying job than I will ever have? What up wit that?
Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed
up and put "Sparks Justice Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer
or Affidavit. Doing so will make the RJC Order by Judge Schroeder null and void (Karen Stancil,
Chief Civil Clerk at RJC admits this, but really, the fault lies with NCS and Northwind, not the
committed professional at the RJC).
The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe
where they have a valid reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.
In
Aikins v. Andrews,91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
predecessor statute to NRS 40.2516 to mean that the alternative five (5) day notice must be given
6
before the tenants can be dispossed and a lease can be validly terminated. The court stated that this
five (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
ttp://www.constitution.org/ussc/506-056a.htm
U.S. Supreme Court

SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
506 U.S. 56SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
SEVENTH CIRCUIT
No. 91-6516
Argued October 5, 1992
Decided December 8, 1992
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-----
'
._------_ __ ' .......

....
.
"""
.__
.
III
7753156715
IN THE JUSTICE COURT OF RENO TOWNSHIP.

IN AND FOR THE COUNTY OF WASHOE. STATE OF NEVADA
Matthew Merliss
LANDLORD/PETITIONER
c/o Richard G. Hill. Chartered and Casey D. Baker, Esq;
652 Forest Street. Reno. Nevada 89509
LANDLORD'S ADDRESS
Zachary Coughlin
TENANT
121 Rjyer Rock, Reno. Nevada
TENANl'S ADDRESS
89503
Case No.
REV 2011-001708
Department NO._ 2
s..
State of Nevada
CQunty of Washoe
_
____
Unlawful Detainer Affidavit
The undersigned petitioner being first duly sworn. d eposes and says:
That your atIian in compliance with NRS 118A. is the landlord of cenain
I.
dwellings or apartments within the jurisdictional confines of Reno Township,

Washoe County. Nevada.
2.
That your affiant rented a certain dwelling or apartment to Melissa Ulloa and Zachary Coughlin
on March 1
located at 121 Rjyer ROck. Reno. NV 89503
20lll....- with periodic rental payments reserved by the month or for a shorter
period
of time,
and
$700.0D
cleaning
or
rental
deposi t s
in eKcess of tlrst month's rent.
paid
in
advance
3.
That the periodic rental agreement has not been waived or altered by a written
agreement of any kind.
4.
That more than thirty/seven days h ave elapsed since the service of the noticCSij$( attached hereto
JOiln:HIi but the above-named tenant bas refused. and still refUses, to vacate and
quil the abovenamed premises.
WHEREFORE. your atIiant prays for an order of this court, directed to the
Sheriff of Washoe County, ordering the abovenamed tenant from the above
mentioned premises. as provided tU( In

stJ BSC RlBEO and SWORN
thIS
day of
.. .
_
___
to
____
beiore me
NRShaPte(
'
40,
.20
'
---;r
---------------------.
I.ANDLORD OR DUI. Y i\UTHORIZED AGENT
NOTAR.Y PUBLIC
PLAINTIFF'S
tlIBIT
D....
____
PLEASE SEE
ATTACHED NOTARY
CERTIFICATE
{cilO ( (\
000164
f@Jiii&% titHe,
$,
'h@
,.
CALIFORNIA
JURAT CERTIFICATE
State of California
County of
_B (Ju.", +,-e
""
_____
_
;q;
Subscribed and sworn to (or a
20-.LL by
t0alihflJ,J
ed) before me on this
day of l2co{
r/''>'s
proved to me on the basis of satisfactory evidence to be the person who appeared before me,
Signature of Notary
ANDREW SPROCk
CommIts\on /I 1933766
Notary Public CIiHomtl
BuH' County
My Comm. Xm AoI24, 2015 f
WITNESS MY HAND AND OFFICIAL SEAL.
(Notary Seal)
OPTIONAL INFORMATION
17ft jurat cOlltained within this document is j" accordall(.f with Califomia law. AllY affidtroil subscribed and sworn to before a notary shall use
the preceding wording or substtmtiaUy similar wording pUT5uant to CiVIl Code foCCt/OIlS 1189 and 8202, A jurat
certfficate cannot be affixed

to a document sent by m ai l or othenvise delivered 10 a no/my puhllC, includmg electronic means, whereby (he signer did not
personally appear before the no/my public. eVen tithe s igner i known hy the notary pu blic The seal and signature cannot be
affixed 10 a document without the correct notm';al wording As an addit IO nal option an ajliant can produce an affidavit on the
same docl.lmettt as the notal"ial certificate wO/'ding 10 eliminate (he use of additional documentation,
DESCRIPTION OF AITACHED DOCUMENT
(Title of document)
CAPACITY CLAIMED BY THE SIGNER
__
IndIVidual
_
(Including jurat)
__
____
Partner
.. Attorney-In-Fact
___
Number of Pages
Corporate Officer
Truslee
Document Dale
___ ___
_
Olher:
..
. . .
___
___ ___
__ ____
(AdditlOnallnfonnalioJl)
MMX
BAN2510.409.1334
www
BayArcaNotary.coIU
000165
0"
_'..
._..
"
_'. ,_".,
000166
NO-CAUSE TERMINATION NOTICE TO VACATE

NRS 40,251(1)
TO:
. n : h :;
---, c!.! y rr....::o!.u gl!:h::: c!! !. a"n"d'-.:,"'y '--'t er'-Z:!. c h!.
C
i . .:
l n
:. "
___
(Tenant)
person claiming thereunder, or occupying

121 River Rok Street, Reno. Nevada 89503
Date of Service:
August 22. 2011
PLEASE TAKE NOTICE that you must surrender and vacate the rental un it
located at:
e R
c
.!. 21 R'_'i,!:..! c k__' t'_'e ...:R!.e o ...:e.!. d ""-,,3'!.....' .'!.v o r ':o !: S"' r et : no H!. : v '- 895"' 0
1
. .
______
_
_
_
You are entftled to a period of:
1,
Seven
(7) judicial
days 1 after service of this notice to vacate and
leave the rental unit (because you are a weekMto-week tenant).

NRS 40,251(1Xa)(1),
X
__
2,
Thirty (30) calendar days after service of this notice to vacate and
leave the fBntal unit (because you have a periodic tenancy which is
not week-to-week), NRS 40,251(1 )(a)(2),
__
3.
Five (5) judicial days after service of this notice to vacate and leave
the rental unit (because you have a tenancy at will),
NRS
40,251(1Xa)(3),
Judicial Days do not include date of service, weekends or legal holidays.
Aptrtmenl
l...dlord NotlCil
No CIU5e Ttrmll'lltion Notiet to Vaetla
Form 111
1 of 5
02006 Nevada Supreme Coun
Revited: .&.priI14, 2006
000167
4.
Seven
(7) judicial days after service of this notice to vacate and
leave the rental unit (because your tenancy is subject to Chapter

118A of the Nevada Revised Statutes and your rental agreement
will expire or terminate as of
, 20----'.
NRS 40.251(I )(bXI XI). (Applies to week-to-week tenancies.)

-L5.
Thirty (30) calendar days after service of this notice to vacate and
leave the rental unit (because your tenancy is subject to Chapter
lISA of the Nevada Revised Statutes and your rental agreement
)N( expiredx>xxlllmtml as of February 26
201L-).
NRS 40.251(1 )(bXI XII). (Applies to all other periodic tenancies.)

Five (5) judicial days after service of this notice to vacate and leave
the rental unit (because you have a recreational vehicle lot tenancy,
pursuant to NRS 40.215(6), NRS 40.251(1)(d).
ATTENTION! If you fa'il to vacate the rental unit by September 23

you will
.201-L-,
be guilty of an unlawful detainer (unlawful possession), and I will start evIction
proceedings against you.
NOTE: If you are 60 years of age or older, or if you have a physical or mental
disability, and your tenancy Is
!!Q1 weekto-week, you may make a written request to me
to be allowed to continue in possession of the rental unit for an additional 30 days past
the time listed on this notice. You must provide me with proof of your age or disability
with your written request. If I reject your request, you have the right to petition the court
to continue in possession of the rental unit for an additional 30 days. If the court denies
your petition, you will
be allowed to continue in possessIon of the rental unit for five (5)
calendar days following the date of entry of the order denying the petition.
Apartmenl
landlord Notice
No C.use Termln.lIon Nodce to V.cate
FQtTTI .1
2 of 5
C200& Nev.da Supreme COlJrt
RIYIIed: April1. 2006
000168
ATTENTION I
THIS NOTICE IS BEING GIVEN PURSUANT TO NEVADA
REVlSED STATUTES.
in
If you d o not comply with this notice you will be
unlawful possession of the rental unit, and you will be subject to the eviction
procedures contained in NRS 40.254 or NRS 40.290 at seq.
,20.
Dated this ;::# day of A.U$ ;t
Matthew Merliss
landlord
c/o Casey D. Saker; Esq.
Address
652 Forest Street, Rena, Nevada 89509
(775) 348-088S
Phone
or Duly Authorized Agent
Casey D. Baker. Esq.

Print Name of landlord or Duly Authorized Agent
Unless you provide written notice to the undersigned within thirty (30) days of receipt of this
Jetter, that the validity oflhis debt is disputed, the undersigned will presume the debt to be valid.
If you do notify the undersigned in writing that all or any portion of the referenced debt is
disputed, a copy ofthe judgment andlor verification of the debt will be obtained and mailed to
you. If the creditor named above is different from the original creditor. the undersigned will,
upon written demand from the consumer, furnish the name and address ofthe original creditor.
FEDERAL LAW REQUIRES THAT WE INFORM YOU THAT THIS IS AN AlTEMPTTO
COLLECT A DEBT AND ANY ANO ALL INFORMATION OBTAINEDWILL BE USED
FOR THAT PURPOSE.
Apirtmel11
Landlotcl No'
No C.U Twmll1.11011 NOlie. to V.c.l.
Fotm'1
3 of 5
e200s Nevad. Supreme Court
Revlsei:l: ,t,plll '.. 200II
000169
AFFIDAVIT/DECLARATION OF SERVICE
On
8-2.1.-
, I served the 'following document:
1\
(Date)
AJo-CAvJrf:
If-'-MI,Jkr'o
)JOT/<-.
f" UACAT
(Name of Document)
at the following time
1.
: Dtf
nd in the following manner:
By delivering a copy to the tenant(s) personally, in the presence of a

witness. (Server, Tenant & Witness Must All Sign).
Signature of Server
Signature or Tenant
Signature of Witness
Print Name of Server
Print Name of Tenant
Print Name of Witness
2.
Because the tenant(s) were absent from their place of residence or from
their
usual
place
of
business,
______
by
leaving
copy
with
person of suitable age and discretion,
at either place and mailing a copy to the' tenant(s) at their place of

residence or place of business.
(Attach United States Postal Service
Certificate of Mailing).
3.
Because the place of residence or business could not be ascertained, or a

person of suitable age or discretion could not be found there, by posting a
copy in a conspicuous place on the property, delivering a copy to a person
there residing, if the person could be found. and mailing a copy to the
tenant(s) at the place where the property is situated. (Attach United States
Postal Service Certfficate of Mailing).
ApaMlent
LandJonl Noliee
No Cau.a TermInation Notice to Vacate
Form '"
4 of 5
Cl20()6 NeYlda Supreme COUM
RevIsed: l 14,2006
000170
I swear the above is true.
Signature:
_
_________ __
_
_
_
SUBSCRIBED AND SWORN to before me this

20
day of
____ _ _
_
"
NOTARY PUBLIC
OR
DEPUTY CLERK
_
_
__
___
___
OR
THE FOLLOWING:
Pursuant to NRS 53.045:
"I declare under penalty of peury under the law of the State of Nevada that the
foregoing is true and correct,"
Executed on
8-ZZ.
Slgnature
--J'I:<'- .z,v/< 6"rJ

}!_o<>SLU-7
C<>uJCT ,JEf(.lIlc6S
>itSU3
Print Name
Apartment
Landkxd Nolle.
No Cauu Termination Notice to VaCit.
fo'm '"
5 of 5
C2006 Nevada Supreme COUi'l
Revi5ed; rlI14, 2006
000171
ffP
Nevada C(}IU/ Services,
475 S Arlington Suite lA
OSr
(Ura"
"""'"
Reno Nevada 89501

,
!:-
- "'_.
02 1P
$000.440
0002861:1394 AUG 22 2011
MAILED FROM Z!P cooe 89!i01
Zachary, Coughlin and I or any others

121 RivC( Rock Street
Reno, NY. 89503
-----
'----
-------_._-
_. .
"
000172
.,----,-
'
,
..
EXH1BIT2,
.. -
;-
, " ..
000173
CERTIFICATEOFSERVICE
Pursuant to NRCP 5(b), I hereby certify that I am an employee of RICHARD G. HILL,
CHARTERED, and that on the d' day of September, 2011, I personally handed at the
4
5
6
7
hearing in the above-referenced matter, a true and correct copy of the foregoing Five Day
otice of Unlawful Detainer for Failure to Vacate Rental Unit - NRS 40.251 (NO-Cause
Termination) and Notice a/Summary Euiction - NRS 40.254 to:
8
9
10
Zachary Coughlin
121 River Rock Street
Reno, Nevada 89503
11
12
13
14
.
BY:
of Richard G. Hill, Chtd.
15
16
17
18
19
20
21
22
23
24
25
26
000174
000175
000176
000177
000178
From: zachcoughl1n
To: 4ba59639-c27b-4b42-ged8-cf4e3de
10-03-12
11:06pa
p. 2
of 4
FILED
12 OCT -4 AM 8: 49
1
2
3
4
Document Code:
STEVE
Zach Coughlin
PO Box 3961
Reno,
NV 89505
Tel and Fax: 949-667-7402
EHOJ TUTTLEJ
I
"E
u:
IJ " r
,
Pro per Tenant or temamtiReal Party in INterest

acting for zach coughlin only, not derek swanson or tahoe quarterly
5
6
JUSTICE COURT RENO TOWNSHIP

WASHOE COUNTY, NEVADA
/!:JC :;J 0 I :J f) 7 J' 'I2J /;L
8
9
UPERIOR MINI STORABGE

Plaintiff/LANDLORD
vs.
10
11
12
EREK SWANSON AND OR TAHOE
UARTERLY; AND JOHNS DOES 1

ROUGH 1 00 AND
13
16
17
18
19
20
21
number by anyone
)
)
)
)
DEPT. NO:;
.:j:I:
'-/
) Tenants or subtenant or real partY in

) interstADswer or Amdavit
)
14
15
CASE NO: have not been provided a case
)
ACHARY BARKER COUGHLm;
)
Pro per Tenant or SublesselReal )
arty in mterest
RJC2012 - 078432
MCPP
MoHon to Contest Personal Property Lien F
.
48892
'\
.
111111111111111mllll 111111
PERSONAL PROPERlY LIEN OR FOR RTURN OF PERSONAL PROPERlY AND

NOTICE OF NON ABANDONMENT
I, Zach Coughlin file this Tenant's Affidavit and or Answer and request a hearing, and a jury trial
22
and allege that I am or have a reasonable basis to so believe, that I am an interested and necessary
23
24
25
party and REQUEST THAT SUPER MINI STORAGE NOT THROW AWAY MY PROPERTY.
I SWEAR UNDER PENALTY OF PERJURY, PURSUANT TO NRS 53.045 THAT THE
26
27
28
CONTENTS HEREIN ARE TRUE TO THE BEST OF MY KNOWLEDGE. I had not received any
notice of the eviction other than hearing the testimony of Ken Grant at the Illegal Lockout hearing
1I3Tenant or subtenant or Rid party In Interest's Anmer ofAFQdayit

000179
yesterday and believe Swanson and Superior and the Grant's have conspired to prevent me from
having such notice, along with the Reno Police Department, in violation of Soldal v. Cook County,
and am curious as to whether any counsel for Superior had a duty to apprise me thereof.
4
5
6
7
8
9

The undersigned does hereby affirm that the preceding document does not contain
the social security number of any person.
DATED this October 3rd, 2012
10
11
_/s/ Zach Coughlin

Zach Coughlin
Tenant or subtenant or real party in interest
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2/3Tenant
or subtenant or real party in interest's Answer of AFfidavit

000180
PROOF OF SERVICE
1
2
3
4
5
6
I, Zach Coughlin, declare:

Tenant or subtenant or real party in interest's Answer of AFfidavit by emailing faxing and or
depoisting a true and correct copy for mailing in the United States postal mail to:
Richard Elmore
Holland and Hart
superior storage
to
Attorneys for Matthew Merliss
9
10
11
Dated this October 3rd, 2012

----------------------------Zach Coughlin
Tenant
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3/3Tenant
or subtenant or real party in interest's Answer of AFfidavit

000181
RENO CIVIL
CASE SUMMARY
CASE No, REV2011-001708
Matthew Merlin
",
Zachary Coughlin
Bonds
Cash Bail Without Notice
$250.00
1212212011
Posted
Loclltion:
Judicial OffICer:
Filed on:
Case Type:
Case Status:
Reno Civil
Srerrnu, Peter
1010612011
Evidion
02JISI2012
Active
Counts:
Cash Bail Without Notice
$250.00
Posted
12I14nOII
Counts:
Ihn:
Current CUt Assignment
Case Number
Court
Date Assigned
Judicial Officer
Landlord
Sferrazza, Peter
Merlin, Matthew
Tenant
REV2011'()()1708
Reno Civil
1010612011
Coughlin, Zachary
Ihlt:
!''>nt:.\
0110111999
Eviction Hearings (0:00 AM)
10J06I2011
Case Filed
10/13/2011
\0/3112011
Notice
-I-_","",cd By: Medill. Mal/hew

Eviction Order Filed
Posled By: Mer/iss. Mal/hew
0510812012
{i) Request for Submission Piled
0612212012
J Request for Submission Filed

&cond Rl!quest for Submission of Morionfor Order to Show Causefiled.
06/2212012
j Plcading Filed
CU\'er Sheetfor Judgmelll of COfIviction ,md Court Orfkr 6118112.
08/0ln012
"
BJ MOlion Filed
To Set Aside Summary Eviction Order
09113/201 2
g:) E.'( Parte

E, I'I/rlr! .'-1011011 /(I (''''rclude COII/empi Cit(l/i(lnfiled
,'",wd (II! (W 1/1 .'flL' (J/ J .J(j I'll
000182
RENO CIVIL
CASE SUMMARY
CASE NO. REV2011-001708

0911312012
0911812012
J Requesl for Submission Filed

Order Filed
Order or Sla , Molion on Con/em Is/
d unlil all a
Landlord Merliss. Matthew

Tolal Charges
Total Payments and Credits
Balam:e OUt 15 of 9/18n0l2
ols are decided. Per Jlld e Serroz!o
66.00
66.00
0.00
Ttnlnt Coughlin. Zachary

Bond Balance as of 911812012
250.00
Tenant Coughlin. Zachary

Bond Balance as of 9/18/2012
2S0.00
"Mil: 2 or l
Pm"..'; om 09 I.Y 71)1} 0" J 16 /' 1/
000183
NO: REV 2011-001708

DEPARTMENT NO. 2
In the Justice Court of Reno Township, County of Washoe

STATEOF NEVADA
MATTHEW MERLISS
ACTION: NOTICE TO VACATE

LANDLORD,
V.
DEMAND: RESTITUTION OF PREMISES
ZACHARY COUGHLIN
CASEY BAKER, ESQ.

652 Forest Street
Reno NY 895909
P.O. Box 2551
Reno NY 89505
TENANT.
ATTY FOR PLAINTIFF,
775-348-0888
FAX # 775-348-0858
Phone Number
ZACHARY COUGHLIN, IN PRO PER

817 North Virginia Street #2
Reno NY 89501
AITY FOR DEFENDANT
775-229-6737
FAX # 775-949-667-7402
Phone Number
DATE
PROCEEDINGS
2011
VOLUME I
OCT
Motion to Proceed in Fonna Pauperis filed and submitted. GRANTED per Judge Sferrazza.dss
T eoant's AnswerlAffidavit to 30 Day No Cause Eviction & Unlawful Detainer; Motion for
Sanctions and Attorney's Fees; Counterclaim for Damages filed. Hearing set for OCTOBER
13,2011 at 8:30 AM. Both parties notified by mail. Lell message for tenant. Spoke to
Landlords attorney. Dss
OCT
OCT
OCT
11
12
13
Motion to Continue filed by Tenant SUBMITTED. ks

Landlord's Opposition to Tenant's Answer/Affidavit to 30 Day No Cause Eviction; Motion for
Sanctions and Attorney's Fees; and Counterclaim for Damages filed. cv
Plaintiff,represented by CASEY BAKER,ESQ.
Defendant, ZACHARY COUGHLIN appeared for a Summary Eviction hearing before Judge
SFERRAZZA.
Hearing held. Tenant's Motion to Continue Denied. If tenant posts rent ofS2,275.oo by 9:00 am,
Monday October 17,2011 a trial will be set for OCTOBER 25,2011 AT 10:00 am.
If tenant does not post the monies, eviction GRANTED at 9:00 am. October 17,2011. Jj
Emergency Ex Parte Motion filed. cv
OCT
OCT
OCT
17
17
17
Opposition to Emergency Ex Parte Motion filed. cv

Emergency Motion To Stay, Set Aside, Vacate Eviction Hearing Order filed. be
Emergency Ex Parte Motion filed. cv
$2,275.00 CASH posted by ZACHARY COUGHLIN, 121 River Rock St., Reno, NY. 89501
Page 1 of6
RJC 2011-001708
000184
OCT
17
OCT
18
OCT
OCT
17
17
!er
Opposition to
gency Motion To Stay Set Aside; v
te Eviction Hearing Order filed. be
Order for emergency Motion To Stay Set Aside; Vacate Eviction Hearing DENIED. Be
Letter returned to court "Notice of Hearing"to Green Action Lawn Service.
Motion for Order Requiring Inspection of Real Property Pursuant to NJCRCP 34 filed.
Ex Parte Motion for Order Shortening Time filed.
Request for Submission of Ex Parte Motion for Order Shortening Time filed.
Order Shortening time SUBMITTED. cv
OCT
18
Errata To Opposition To Emergency Motion To Stay, Set Aside, Vacate Eviction Hearing
OCT
18
OCT
18
OCT
OCT
19
19
Received -Notice of Appeal to District Court. be

Order filed. bc
Request For Audio Copy of Proceedings along with a Motion Informa Pauperis Granted.
Subpoena Duces Tecwn Re Hearing issued to RANDY FISHER.
Subpoena Duces Tecum Re Hearing issued to ZACH NASH. Jj
Subpoena Duces Tecwn Re Hearing issued to NV Energy.be
OCT
OCT
OCT
19
19
20
Certificate arService filed.

Declaration of Casey 0 Baker, Esq. Pursuant to NRS 40.254 filed.
Notice of Entry of Order filed. be
Notice of Appeal to District Court filed. dss

Faxed Emergency Request for Conference Call filed.
Order Shortening Time filed, requiring Inspection of Real Property on Monday the 24th
Of October 20 II at 10:00 A.M. bc

Emergency Request for Hearing submitted. Bc
VOLUMEJI
OCT
20
OCT
24
OCT
25
Emergency Request for Hearing-issues will all be taken care of at the October 25, 2011
Hearing. be
Subpoena Duces Tecum Re Hearing (NV Energy) filed with an Affidavit of Service to Joanne
McMaster, Legal Assistant ON October 20, 2011. jJ
Emergency Demand for Jury Trial and Amended Tenant's Affidavit/Answer/Counterclaim

filed.
Plaintiff, MATTHEW MERLISS appeared and represented by CASEY BAKER, ESQ.

Plaintiffs 1st Witness: Denise Tsuda, NV Energy - represented by Brandon Barkhuff, Esq.
Plaintiff's 2nd Witness: Matthew Merliss
Defendant's lSI Witness: Zachary Coughlin
Defendant's 2nd Witness: Matthew Merliss
Plaintitrs Exhibits: A,B,C,D,E,F,G,H,l marked - A - I admitted

Defendant's Exhibits: 1,2,3,4,5,6,7,8,9 marked - 1-9
admitted
Defendant, ZACHARY COUGHLIN appeared for a Summary Eviction hearing before Judge
SFERRAZZA.
Hearing held.
Landlord has met his burden of proof EVICTION GRANTED effective October 31, 2011 at 5:00
pm. Landlord may in 48 hows from today, inspect the property. Order to be submitted to the
court by noon on Thursday.
Page20f 6
RJC 2011-001708
000185
Jury Trial, not timely. BaiUrent posted

$2275.00 not to be disbursed at this
Deny request f
time. Tenant has 10 days to appeal and posted rent will suffice as appeal bond.
Court finds that there is no Defense of retaliation by the landlord. Tenant's Verbal Motion to Stay,
Denied.jJ
Motion to Set Aside Eviction Order filed. nun
SUBMITTED and DENIED.
Order Requiring Inspection of Real Property SUBMITTED and GRANTED. cv
Memorandum of Costs and Disbursements filed.
Findings of Fact, Conclusions of Law, and Order for Swnmary Eviction SUBMITIED and
GRANTED. Cv
Motion to Set Aside and or Stay Eviction Order/Motion for Sanctions filed. Ce
Note from Judge Peter J. Sferrazza: "Already DENIED the Stay in Court."
OCT
OCT
OCT
26
27
27
OCT 31
NOV I
'
VOLUMEIJI
NOV
NOV
NOV
NOV
NOV
7
7
NOV
NOV
8
8
NOV
NOV
10
Emergency Appeal and Motion to Stay Eviction filed and SUBMITTED.

Letter requesting last hour of CD filed. ks
Notice of Entry of Order filed.
Per Judge Sferrazza: This is an appeal to the District Court so it needs to be transferred there.
ks
Motion to Stay Lockout and Complaint for Illegal Lockout filed. ks
Notice of Hearing filed. (Set for Monday, NOVEMBER 7, 2011 at 8:30 a.m.)
Notice of Appeal to District Court filed.
Motion for Expedited Relief for the Unlawful Removal or Exclusion of the tenant or the
Willful Interruption of Essential Services filed.
Motion to Release Bond filed.
Motion to Stay andlor Vacate Order for Summary Eviction filed.
Motion to Continue in Possession (Elderly or Disabled Tenants Only) filed. ks
Returned mail. Not deliverable as addressed. dss
Plaintiff. represented by Casey Baker, Esq.
Defendant, Zachary Cougbhlin appeared for a Summary Eviction hearing before Judge
Sferrazza.
Hearing held. Decision:
I. Rent deposit to be refunded to plaintiff in the amount of $2275.00.
2. Stay denied.
3. Supercedes bond if stay granted by District Court is 3 times monthly rent or $2700.00. jJ
Affidavit of Service filed.
Request for Submission of Memorandum of Costs and Disbursements filed. dss
Tenants Opposition to Landlord's Memorandum of Fees and Costs and Tenants Memorandum
Of Fees and Costs because Sellers does not preclude Attorneys fee Sanction awards to
Attorney Pro Se Litigants where NRC? is involked as it clearly should be Here filed.
Motion for Sanctions against Merliss and Motion For Sanction against Merliss's Counsel
And Counsel's Law Firm, Personally, Jury Trial Demand filed. be
Correction of Inadvertent Misstatement of Law Pursuant to NRPC 3.3 FILED.
Order Awarding Costs and Attorney's Fees SUBMITTED. ks
Order Awarding Costs and Attorney's Fees filed. ks
Affidavit of Service filed. (LANE KARl HARTMAN served NOVEMBER 2, 2011)
Affidavit of Service filed.
Order for Preparation of Transcript at Public Expense filed.
Page3 of6
RJC 2011-001708
000186
NOV
16
NOV
NOV
16
17
NOV
2
3
NOV
21
Motion to con! Personal Property Lien and for ReturnttrPersonal Property & Motion to Set
Aside or Vacate Atty Fee Award filed.
Verified Complaint for lllegal Lockout or Utility Shutoff filed. Jj
Motion to Waive Transcript Costs at Public Expense and Deposition Costs and Fees filed. ks
SUBMITfED all three for this date.jJ
Request for Audio Copy Proceedings filed. rw
Judge wants hearing set. Unable to reach tenant. File on counter with the Audio cd for him to
pick up.jJ
Opposition to Motion to Waive Transcript Costs and Deposition Costs and Fees at Public
Expense filed.
Oppositon to Motion to Contest Personal Property Lien; Joinder in Motion to Set Aside or
Vacate Attorney Fee Award filed.
Motion for Order to Show Cause filed. dss
Order for Hearing filed.
Motion to Set Bond and Stay Eviction filed.
Designation of Record and Statement of Points on Appeal and Notice of Intent to File Brief
filed.
AffidavitlDeclaration in Support of Motion to Contest Personal Property Lien and for Return
of Personal Property filed.
Certificate of No Transcript filed.
Notice of Appeal filed.
Statement of Proceedings filed.
VOLUME IV
NOV
DEC
28
I
Notice of Posting and Acceptance of Supersedeas/Cost Bond on Appeal submitted. Dss

Notice of Redaction filed. Jj
Opposition to and R
on the Merits All Papers Filed or Submitted
about
Defendant on ::

to
Cause; M"tiom
for Sanctions filed.
AffidavitlDeclaration in Support of Motion to Contest Personal Property Lien and for Return
of Personal Property filed.
Motion to Contest Personal Property Lien and for Return of Personal Property filed.
Order for Hearing filed. (Set for DECEMBER 20, 20 II at 9:45 a.m.)
(Both parties notified by mailing this date) ks
Notice of Entry of Order filed. Dss
Received a check made payable to 'Second Judicial District Court' dated 11/8/11 for $216.00.
(This is for District Court's appeal fee when appeal goes over) ks
Received check #1422 from Zachary Coughlin payable to District Court for appeal fee. jJ
Receipt to Zachary Coughlin from Reno Justice Court for $250.00 for appeal bond and a
receipt for $1.00 for "supersedeas bond".
Emergency Motion for TRO; InjWlction Request for Submission of this Motion Attempting to
Pay Appeal Bond of $250.00 and Supersedeas Whatever it Is filed. Jj
;'f:::;t)o
o
DEC
DEC
DEC
6
8
DEC
12
DEC
DEC
12
14
Page 4 of 6
RJC 2011-001708
000187

DEC
IS
DEC
17
DEC
19
DEC
20
Subpoena Re Hearing issued on DARLENE SHARPE of DICKSON REALTY. Dss

Emergency Ex Parte Motion: Amended Case Appeal Statement. Statement of Record on
Appeal Motion to Set Aside Eviction Order, Emergency Ex Parte Motion for Order Shortening
Time, Motion for TRO and or Injunction Against Landlord's12 19 2011 Property Disposal
Deadline; Amended Case Appeal Statement, Statement of Record on Appeal, Motion to Set
Aside Eviction Order, Emergency Ex Parte Motion for Order Shortening Time;
DESIGNATION OF RECORD AND STATEMENT OF POfNTS ON APPEAL; AND
NOTICE OF fNTENT TO FILE BRlEF; Statement of Proceedings; CERTIFICATE OF NO
TRANSCRIPT; NOTICE OF POSTfNG AND ACCEPTANCE OF SUPERSEDEAS/COST
BOND ON APPEAL filed.
Faxed letter to Judge Clifton, Judge Sferrazza and Casey Baker, Esq. received. (Per Judge
Sferrazzas' notes: Tenant refused to set this for hearing. It is now set for DECEMBER 20,
2011)ks
Order Shortening Time to Answer received. SUBMITTED 12/19/11.
Statement by Jocelyn Jonas, Deputy Clerk.
Statement by Karen Stancil, Chief Civil Clerk.
Letter dated 12116111 to Judge Sferrazza and Reno Justice Court - SUBMITTED 12119/11. ks
Subpoena Re Heaing returned and filed. (served DARLENE SHARPE on DECEMBER IS,
2011)
Letter dated 1211912011 to Judge Clifton and Reno Justice Court. be
Opposition to Coughlin's Second Motion to Contest Personal Property Lien and for Return of
Personal Property filed.
Reply in Support of Motion for Order to Show Cause filed.
Request for Submission of Motion for Order to Show Cause filed.
Order to Show Cause submitted. Dss
Request for Audio Copy of Proceedings filed. gw
VOLUME V
DEC
20
DEC
DEC
DEC
21
21
22
DEC
27
DEC
27
Both parties appeared in front of Judge Sferrazza for a Motion to Contest Personal Property
Lein Hearing. Decision (l)Eviction was not premature and Defendant was given opportunity
To have a hearing or this Motion within 10 days. (2) Order Dictated (3) Exhibits 1 to 7
Admitted. Bc
Order Resolving Motion To Contest Personal Property Lien filed.
District Court Civil Appeal processed. New Case Number is CV 11-03628 Dept. 7.
Letter to all party's advising them of Appeal and the case number.
Notice of Posting and Acceptance of Supersedeas/Cost Bond on Appeal filed.
Tenants Notice that No Agreement or Settlement was made or entered into by Tenant, and that
December 21, 20 II Order of Court was an Order filed.
Notice of Posting supersedeas bond as set by statue where is my stay/request for submission of
All of tenant's outstanding motions filed. ce
Motion for Return of Bond filed. ce
Emergency????filed. ce
Fax from Mr. Coughlin to the Court submitted.
Above com:spondt:m::e reviewed no action necessary. Be
Notice of Entry of Order filed. be
-
DEC
29
Page50f6
RlC
2011-001708
000188
2012
JAN
JAN
FEB
4
12
2
FEB
FEB
15
17
Supplemental Justice Court Appeal Proceedings submitted to District Court. Be

Supplemental Justice Court Appeal Proceedings submitted to District Court. Cv
Notice of Appeal received. (Appealing Order of 12121111)
Motion to Alter or Amend Judgment JCRCP 59; or in the Alternative, Motion to Set Aside or
Vacate 12121/11 Order Resolving Motion on Personal Property Lien (JCRCP60) filed. ks
Request for Submission for Return ofS250.00 Supersedeas Bond filed. SUBMITTED. ks
Order Denying Motion for Return ofS250.00 Supersedeas Bond filed. ks
"PURSUANT TO JUDGE SFERRAZZA's DECEMBER 1, 2011 ORDER, THE

CLERKS CANNOT TAKE ANY MORE PLEADINGS ON THIS CASE UNTIL THE
APPEAL IS REMANDED FROM DISTRICT COURT - PER JUDGE SFERRAZZA
2117112"
FEB 27
RECEIVED ONLY--- Faxed Jury Demand along with a Motion Informa Pauperis. Be
Mailed check forSI.OO (RJC Check # 33148 for a refund) ks
Page6of6
RIC 2011-001708
000189
AFFIDAVIT OF LAURA PETERS

CUSTODIAN OF RECORDS
T 09.
STATE OF NEVADA
ss
3
COUNTY OF WASHOE
..
1
..
['Of NlVADA
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LAURA PETERS, under penalty of perjury, being first duly sworn, deposes and
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says as follows:
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That Affiant is employed as a paralegal for the discipline department of the State
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Bar of Nevada and in such capacity is the custodian of records for the State Bar of
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Nevada;
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That on September 11, 2012, at approximately 4:45 p.m., Zachary Coughlin
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called Affiant to confirm that a hearing was still scheduled to take place on September
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25, 2012.
th
Affiant explained that the hearing would not take place on September 25
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and that date had been scheduled prior to the filing of a formal Complaint.
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Mr. Coughlin reacted as if he had no knowledge of a Complaint.
Affiant then
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explained that, in fact, a copy of the Complaint, sent via certified mail on August 23,
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2012,
from the Reno office of the State Bar,
had been returned and marked
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"unclaimed".
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Affiant further explained that since service had not been affected, a new certified
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copy would go out the next day. Affiant requested that when Mr. Coughlin received said
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copy, he should return the postcard attached to the mailing and his twenty (20) day
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period in which to answer the Complaint would start running at that point.
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However, in speaking to Assistant Bar Counsel Patrick King, it was determined
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that personal service should be affected upon Mr. Coughlin.
Reno Carson messenger
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service was engaged to attempt personal service despite Mr. Coughlin not providing the
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State Bar with a physical address.
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000190
02795
On September 25, 2012, Mr. Coughlin arrived at the Reno office of the State Bar
allegedly expecting a hearing to take place. At that time, Mr. Coughlin was again told,
both by Affiant and Assistant Bar Counsel Patrick King, that no hearing would be taking
place that day and that an answer to the State Bar's Complaint had not been received.
Affiant personally served Mr. Coughlin with a copy of the Complaint on his visit to
th as witnessed by Paula Campbell, an employee of the
the Bar office on September 25
State Bar.
for that day should be taking place because he needed to be removed from temporary
suspension.
Mr. Coughlin insisted that the hearing which had been previously scheduled
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Mr. Coughlin has also been instructed by Assistant Bar Counsel Patrick King that
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he cannot file pleadings with the State Bar via e-mail, which he continues to attempt.
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The Motion to Dismiss, which Mr. Coughlin now insists should be granted as it has gone
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unopposed by the State Bar, was never presented to Affiant for filing but was rather e
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h
mailed prior to Affiant's conversation with Mr. Coughlin on September 11t when Mr.
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Coughlin under no uncertain terms told Affiant that he had not yet received the
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Complaint.
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FURTHER YOUR AFFIANT SAYETH NOT.

Dated this 9th day of October, 2012.
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"\:: ura Peters, Paralegal

Office of Bar Counsel
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SUBSCRIBED AND SWORN to

before me this 9th day of
October, 2012.
PUBLIC
L
000191
02796
000192
000193
000194
000195
000196
000197
.-
'''-
---...
'
FILED
CASE NUMBER: ng 120204 ng-0435 ng-0434
NOV 13 2012
STATE .\R OF NEVADA
STATE BAR OF NEVADA

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NORTHERN NEVADA DISCIPLINARY BOARD
ATE BAR OF NEVADA.

8
ETlTlONER
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ACH COUGHLIN,
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12
)
)
)
)
)
)
ng 12-0204 ng-0435 ng-0434
V BAR 9473
ESPONDENT
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EMERGENCY EX PARTE MOTION TO DISMISS, VACATE, RESET OR POSTPONE

THE 11114/12 HEARING OR OTHERWISE RECOGNIZE THE LACK OF JURISDICTION
TO HOLD IT GIVEN THE NUMEROUS VIOLATIONS OF SCR 105(2)(0 BY THE PANEL
AND THE SBN; INSUFFICIENCY OF SERVICE OF PROCESS, INSUFFICIENCY OF
PROCESS, MOTION FOR MISTRAIL DUE TO FRAUD BY BAR COUNSEL; NRCP 12(e)
Motion for More Definite Statement (especiall}': vis a vis the purported RPC violations in the
"summan: criminal ontempt/transmogrified to a summar)': Disciplin3r)': Panel Hearing"
Traffic Citation Second Bite at the Apple eatcn on 2[28/12 findings b}': CIar and Convicing
Evidence in the ORder of 3/14/12 (and what is n212-0434? is it the 2/28/12 ORder? or the
3/12/12 ORder? or both? MOTION SHOWING GOOD CAUSE TO ALLOW COUGHLIN TO
SUBMIT A RESPONSE OR ANSWER TO WHATEVER EXTENT THE PANEL FEELS HE
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HAS NOT ALREADY DONE SO AND OR INTENDS TO CALL THIS A "PROCEED ON A

DEFAULT BASIS" SITUATION, WHERE COUGHLIN DISPUTES.
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G3r)': Silverman, Esg. email tQ Coughlin 8/13/12: "You do seem tQ be a good law},:er, however.
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At bottom, Steve Harris took hundreds of thousands of dollars and had no temp suspension;
}':ou stole a cand}': bar (at worst). WTF. "
- 1/31-
EMERGENCY EX PARTE MOTION TO DISMISS, VACATE, RESET OR POSTPONE THE 11114112 HEARTNG
OR OTHERWISE RECOGNIZE THE LACK OF JURISDICTION TO HOLD IT GIVEN THE NUMEROUS
VIOLATlONS OF SCR I05(2)(C) BY THE PANEL AND THE SBN; INSUFFICIENCY OF SERVICE OF PROCESS,
INSUFFICIENCY OF PROCESS. MOTION FOR MISTRAIL DUE TO FRAUD BY BAR COUNSEL. etc....
000198
(disclaimer, some of this has been dicated to a transcription software and not proofread
nearly enough...but that is by design, as clearly King and the Panel wish to run this unbifurcated
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Hearing along at warp speed considering all the departures from SCR 105(2)(c) and other attendnat
due process deprivations designed to make Coughlin's work product here as rushed an unnoticed as
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possible) Zach Coughlin representing himself submits the above titled filing on his own behalf.
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I, Zachary B. Coughlin, do hereby declara, pursuant to nrs 53.045, under penalty of perjury, that the
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following is true to the best of my knowledge, for which i have percipient recollections of, except for
those matters which are stated upon information and belief:
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Pat King informed Coughlin in a telephone discussion on Friday, November 9th, 2012 that it
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is the standard practice, done in every disciplinary case, for the Bar to send out the DowSoe, prior to
ti empaneling of the Panel, in violation of SCR 105(2)(c) (further Coughlin disputes the legal
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contention hill makes that SCR 106 somehow insulates anyone with the Panel or Bar from having to
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answer a subpoena or submit to sworn questioning...that rule speaks to suing such people, not
eliciting testimony or discoverable materials), however (and Laub allows for citing to such things) the
recent Disciplinary matter involving Stephen R. Harris, Esq. reveals that King's contention vis a vis
the order of the empaneling of the Panel and the filing by the Bar of its Designation of Witnesses
and Summary of Evidence are, as is King's wont and established practice, quite wrong, to the point
of being fraudulent and seeking to exercise some impermissible control over the Panel, and to steal
Coughlin's due process from him like a rat stealing some cheese. King apparently has to operate
that way because he is completely unaware of how to use a computer (admitting that he thinks
emails are sent from "the Bar's web site" rather than from, say, the account associated with an email
address), is a terrible hunt and peck typist, totally eschews legal research or citation to authority,
cannot manage to throw together an Index to Exhibits in his filings, and otherwise operate in a totally
fraudulent, back room, old boys club way, having his buddy Dan Wong from back in their days at the
AG's Office testify (so designated in the due process raping DowSoE) rather than City Attorney
Allison Ormaas, Esq. regarding 11 TR 26800, the Richard G. Hill, Esq. traffic citation matter wherein
Judge Nash Holmes cooked up a stew comprised of all different types of contempt statutes
(summary, plenary, civil, contempt, misdemeanor, etc....choosing the bits and pieces of each that
provided the least due process to Coughlin, whilst enabling Judge Nash Holmes to achieve her
pretextual goals as expeditiously as possible and with as little requirement that she back up her
ruling with any actual facts, Affidavits, evidence, due process, or specificity) (well, both Ormaas and
Wong indicated to Coughlin that she would not notate in any way or follow up in any way on
Coughlin's reporting to them both the admissions made by RPD Officer Chris Carter, Jr. to Coughlin
incident to Coughlin's custodial arrest upon Richard G. Hill, Esq. signing a criminal complaint for
criminal trespass at Coughlin's former home law office incident to an impermissible summary eviction
proceeding only on a No Cause Basis where the non-payment of rent was neither pled nor noticed.
the in that, in that matter (57507) Harris (whom admitted to misappropriating $750,000 from clients
and whom, as noted in an email to Coughlin, upon Silverman demonstrating the giving back to the
profession that he is known for in reviewing and offering constructive criticism of Coughlin's August
13th, 2012 filing in 61426 and 60838 (which the Bar still has not managed to respond to) by one of
the most respected attorneys in the state, Gary Silverman, Esq., that
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"This disciplinary action was commenced on July 7, 2010. I ROA 1. The
Complaint alleged that attorney Stephen R. Harris violated two ethical rules. I ROA
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3:22-24. Harris answered the Complaint on July 29, 2010. I ROA 12. Harris, who had
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- 2/31 EMERGENCY EX PARTE MOTION TO DISMISS, VACATE, RESET OR POSTPONE THE 11/14/12 HEARING
VIOLATIONS OF SCR 105(2)(C) BY THE PANEL AND THE SBN; INSUFFICIENCY OF SERVICE OF PROCESS,
INSUFFICIENCY OF PROCESS, MOTION FOR MISTRAIL DUE TO FRAUD BY BAR COUNSEL, etc....
000199
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self-reported to Bar counsel eight months earlier, admitted each of the allegations in the
Complaint, and provided a statement in mitigation. I ROA 12-13; Exh. 1, pp. 12-13.
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The case was assigned to a panel of the Northern Nevada Disciplinary Board on
October 1, 2010. I ROA 19; Exh. 1, p.130. The Bar filed its Designation of Witnesses
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and Summary of Evidence on October 7, 2010. I ROA 23-24; Exh. 1, pp. 133-34. The
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Bar filed its Trial Brief on November 1, 2010. I ROA 27-36; Exh. 1, pp. 17-27. Harris
filed his Prehearing Brief on November 3, 2010. I ROA 38-50; Exh. 1, pp. 28-41. An
evidentiary hearing was held on November 9, 2010. II ROA, Tr., p. 5. Harris
acknowledged that his actions violated Nevada Rule of Professional Conduct (NRPC)
1.15 (safekeeping property) and NRPC 8.4(c) (misconduct; engaging in conduct
involving dishonesty, fraud, deceit or misrepresentation), so the Panel's primary task
was to determine the appropriate discipline to be imposed, based on the aggravating and
mitigating circumstances. I ROA 28; Exh. 1, p. 18; Tr. 132:17-133:1."
So, this hearing can no way go forward on 11/14/12. If it does, this Panel will look AWFUL.
First off...I have been trying to take Pat King up on his "come down to the Bar's Office and inspect
the materials" thing since March 2012. Pat either storms off with his box of materials (takes his ball
and goes home) or sends me the cd's finally (after I had already spent money I needed for other
things giving the RMC $35 per audio of a hearing), but refuses to give me the other stuff (like, how
did the April 2009 Order of L. Gardner materialize at the SBN? Then, the Order of 10/30/12 comes
out, and
-Check out the attached USPS "Track & Confirm" for the certified mailing of the NOtice
of Hearing (and the certificate of mailing on that document does not indicate that it includes
the DowSoE, and the DowSoe is not date stamped in the "file" I got in a big box from Sierra
Document Management mentioned as the "copy of the file" (sounds like their was some ex
parte back and forth over how to deal with Coughlin and not wanting him at the SBN Office,
plus Panel Chair Echeverria's Office or the Echeverria Group is about 200 feet from the SBN's
Double R Blvd Office, and SBN Clerk of Court Peters is signing Chair Echeverria's Certificat e
of Mailings?....The only thing Chair Echeverria has ruled in Coughlins "favor" on so far has
actually had the effect of limimting Coughlin's rights under SCR 105(3)(c) to "inspect the file"
at the SBN's office "up to 3 days prior to" the 11/14/12 Hearing (and given that the SBN is
closed on Monday, November 12th, 2012...but anyways, Pat King has repeatedly refused to
allow Coughlin to inspect the file at the SBN before and since 10/31/12...plus, okay, so what,
the SBN says and the ORder decrees Coughlin gets the file (and granted, its nice to get a
fresh copy in a box, even if Coughlin suspects he will ultimately be billed for it somehow, in
one way or another)...but what of the materials new to the file between 10/31/12 and "up to 3
days" prior to the hearing? Where is the access? Further, it took quite some time for that
"copy of the file" to get to Coughlin, whom received it on the first delivery attempt:
70112970000443659543 Priority Mail Delivered November 07, 2012, 3:38 pm RENO, NV 89512
Expected Del ivery By: November 6, 2012 Certified Mail Arrival at Unit November 07, 2012,
7:59 am RENO, NV 89506 Dispatched to Sort Facility November 05, 2012, 4:42 pm RENO, NV
89510 Acceptance November 05, 2012, 10:48 am RENO, NV 89510.
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plus, if you look at the certificat of mailing for the Notice of Hearing (which the big box file, at
least, indicates contained a non file stamped DowSoE (Designation of Witnesses and
Summary of Evidence) as pages 2 and 3 (despite the cert of mailing indicating only that the
Notice of Hearing was sent) of it and that says it was mailed on October 12, 2012 (so what, is
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the SBN and Panel going to say "yeah, but Pat King says "Zach knew about the 11/14/12 date
because I emailed it to him or called him or something"...all while the SBN's Clerk Peters is
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adding Coughlin to her "blocked sender's list" (so she doesn't have any more duties to
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actually investigate Richard Hill, etc. arise in light of somethign Coughlin sends her, like an
exculpatory video? real professional, Clerk Peters...or is the SBN or the Panel going ot say
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"oh, we are moving for default because you technically, in our view, didn't get a "verified"
response on file by the 11/9/12 date we order on 11/1/12 (meaning at the earliest, under the 3
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days constructive service nrcp 6(e) application under SCR 119(3), that Coughlin would have
all of a couple days to whip one together or comply with the order? With all that, is the SBN
and Panel going ot say "oh, zach, that motion or designation didn't make it into the record
5 because we don't don't seem to have a hard copy of it received in the dropbox or
mail....sorry...even though the Order (which came before the 5 days Coughlin had under
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NRCP ...it actually didn't even hit the usps facility until 10/16/12, and it wasn't even availabe
for pickup by Coughlin until 10/22/12, and Coughlin signed for it on 10/27/12....so
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on August 7th, 2012 at 3:38 pm...So

Really funny how in the SBN King Index to the Hearing red book thing Pat leaves out
the whole green tag certified mail thing, or the fact that Laura Peters sworn to Coughlin on
the phone (and maybe in writing by email...and the Affidavit of Peters that Coughlin was only
just privvy to upon getting the big box on 11/7/12 says Pat recognized that Peters gave
Coughlin an indication he was entitled to rely upon vis a vis the returned to the SBN
purported 8/23/12 certified mailing of the Complaint (and, supposedly, the First Designation).
But you know what? Even if the SBN could show the "first class" mailing of that was
recieved by Coughlin? Tell it to 60302 where Garin got Coughlin's whole wrongful term suit
dismissed despite a video of the service, multiple different service attempts, receipt of the
summons and complaint by a multitue of WLS peeps...and exteremely suspect "illegibility"
arguments....topped off by that case that says "actual notice is no substitute for technical
compliance with the rules" regarding service and notice....and even though Pat King and
Laura Peters know that the only envelope they ever mailed to Coughlin (for some weird
reason they departed from what the big box shows to be some practice where they basically
send everythign twice (one certified, once first class at the same time, typically) was a
certified large manilla envelope that Tim of the Vassar Station USPS didn't find the when
previously Coughlin appeared to get it (and certified mail is a big pain in the neck to go get
for us solos when we are in the office when the mail comes...we don't have "staff" to accept
things...so its an hour burned driving down to the post office station". When the Vassar
station finally did notice the large manilla 10/9/12 certified mailin to coughlin in whatever box
it was sitting in, it was then not given to Coughlin because it only had about $1.25 in postage
printed on it in the SBN's red Pitney Boews method...."insufficient postage" return to send.
Coughlin has very, very little money right now. Ridiculously little money, and so requests
this Panel and the Bar to further memorialize that which as already been expressly
permission give to Coughlin for (waiver of subpoena and subpoena duces tecum fees) or that
which has by a combination of express indication and implict permission being accord (for
emailing/fax filing and King's recent indication that everythign Coughlin files in a non email
manner to the SBN is copied to all five Panel members, even the cd/dvd
attachments....couhlin here is essentially requestin and IFP. If Pat or Laura is really serious
about not wanting Coughlin showing up at the SBN...then give a more explicit indication that
e-filing by email will be recongized. Otherwise, given how jammed up Coughlin has been by
the due process SCR 105(2)(c) etc violations here, Coughlin cannot rely on mailign things, at
this poitn he has to shorten the delivery time to get his file stamp and preserve arguments.
And that is not the only marked difference between the "pay David Grundy, Esq." a grip of
cash and kick down $50K to the client security fund" approach in 57507...(don't get me wrong, I like
Stephen R. Harris, Esq. he's good in the Thursday Night Group of lawyers who care and stuff about
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other attorneys...even if he thought I was a newcomer and I'm like, "guy, I been coming to this deal
since '03...all you Johnny Come Latelies....Tom, make this guy put the coffee maker away...and I told
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Stevie, just like they did me: "you sit down and shut up and don't say anything for a year,
period...Nobody cares what you think...your best thinking got you here, jackhole, and, no, I don't
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wanna be your sponsor, get me all coverd in your loser dust"...and nobody was prouder than me
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when the Court just put him back in the game on 11/8/12, bravo. And, its cool, I get convicted on a
"candy bar and some cough drops" rap and get a temporary suspension. Steve? no temporary
suspension. Gary's like: "WTF?". But, clearly from the above, Stevie got his DowSoE sent a full
week after the Panel was announced. My DowSoE was mail 18 days before the Panel was even
announced....Kind of like saying, "hey, we know we are doing a hit piece on you, so we aren't even
going to pretend to follow the dictates of SCR 105(2)(c): "
But, look here, I'm tellin' you I'm coldest when I'm down in the winter, I have exhibits ready to drop
that are going to change this here whole game. Have you ever wondered what would happen if you
Honigsberg gridded all bar members names or ssn's against a "landlord's tenant checker outer "
service, then did a really detailed analysis of how Bar Counsel treated each paticular conviction,
especially vis a vis what sort of SCR 111 Petition was filed (SCR 111(4), or a "serious offense" under
SCR 111(6)?), and what if you added a deeper level of prcessing to see what the original charge
was, then considered the plea bargain and conditions? then what if that was available publicly?
that analysis. Let's do this, SBN. Honestly, I personally think our profession is just brutal on
lawyers, just completely ridiculous the extent to which people get raked over the coals, or at least
certain people. Its way too political how its done. Or maybe not. Maybe its a meritocracy, where if
you have the dough to sick David Grundy on them (and really, Dave's approach seems mostly to be
the "Hey, I want all your medical records five seconds after meeting you, here sign this release,
okay, here's what I want you to do whether you are guilty or not....do the mea culpa then argue
mitigation/coerced confession" tact, whereas I favor more of a "what part of being an attorney means
you don't have rights?" style interaction with the SBN) or you have the skill and tenacity to keep Pat
King honest and not stick you for your due process....the you get a better result. I got a completely
terrible ridiculous result in 2002-2005. Never again will I have an attorney who is not myself. Never.
All I know, is some guys go to 180 AA meetings in 180 days and LAP still rejects them, whereas if
your Beckett, DA, something it turns out a bit different...
(As to the client security fund, granted, is a legitimate thing...and, despit e the fact that I absolutely
went to the wall for my clients throughout all of this stuff, there were instances were their cases were
likely prejudiced due to the impact this stuff has on me (I'm talking to arrests, the evictions, etc., etc.),
and who knows, maybe that client security fund arranged for Paul Freitag, Esq. to take over for me in
Eason v. Eastman. Personally, after reading Paul's letter to me about how he tried to contact me
(something about contacting Hot Mail and Roberto Puentes and Dan Wong...Paul, how about the
contact info listed on www.nvbar.org? Wait, that's right, many people treat the WCBA Directory like
it is the licensing body deciding who is or is not a lawyer in Washoe County (I always cheap out
when it comes to sign up for it...) (whose 1979 letter to the AG yielding an Advisory Opinion I would
like for the RMC Judges to see), but if you saw the reams and reams of westlaw research I did for
Eastman, you might think I stood a good chance of delivering just as, if not more, a compelling work
product...
1. Pat King, Bar Counsel, told Coughlin on September 25th, 2012, when Coughlin showed
up for the hearing that the SBN had calendared, agreed to and noticed, that: "Things don't go your
way becaue you don't take responsibility for your actions". Well, well, well, Pat "Salieri" King. now,
now. How about your responsibility to supervise whoever it was at the SBN who didn't put the
correct postage on that large manilla envelope that apparently contained the only copy of the
October 9th, 2012 Notice of Intent to Take Default (and, upon information and belief, some other
documentation? coughlin swears that he did not received that certified mailing (and the SBN's
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certificate of mailing, that Coughlin only received on November 7th, 2012 when the certified mailing
of the sierra legal duplicating copy of the "filed" (a consolation by the Chair Echeverria to Coughlin in
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exchange for excising one of the very, very few rights Coughlin has here, set forth in SCR 105 ("right
to inspect up to three days before"....so what of inspecting the file between it being sent to the
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printers on November 1, 2012, as admitted to on October 31st, 2012 by Peters when she refused to
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let Coughlin inspect it and again by King in writing on November 1st, 2012, and several times
thereafter in writing and verbally, in violation of SCR 105(2)(c). It is outright appalling the extent to
which PEters, King, and the Chair Echeverria are violating the law and showing no respect at all for
due process. The SBN has filed not proof of service of the summons and complaint sufficient to
satisfy SCR 109 in view of the representations made by the State Bar of Nevada, including those by
Laura Peters on the phone and in writing to Coughlin and found in Peters Affidavit on file in this
matter. The first alleged certified mailing of 8/23/12 is not sufficient to show service where Peters
herself (and this is spoken to in her affidavit) represented that the SBN would not be attempting to
use it to proof service of any sort of the Complaint, but rather, Peters would send, soon after
September 11th, 2012 a certified mailing copy of the SCR 105 SBN v zach Coughlin complaint to
Coughlins SCR 79 address, and that the complaint would not be deemed served or by the SBN, nor
would the SBN attempt to represent in any way that it had been served, until zach coughlin had
signed the return receipt requested and or certified letter signature card and it had been received by
the SBN.
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2. Coughlin might call the Godfather of Family Law in Nevada, Don Gary Silverman, Esq. (and
Maybe Marshal Willick, Esq. if I can get him (but really, the lack of bifurcation here and the scatter
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shot carpet bombing copy and pasting of the RPC and the multitude of Claiborne and 37 cfr 11.25(3)
(a) and (c) (applied by analogy, IN Re schaeffer and STufphh) basis for attackign the various
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"convictions" here makes scant the amoutn of time availabe (especially given the Chairs avowed
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intention to get 'r done in one day (funny, did Steve R. Harris's deal take one day only? or must one
hire David Grundy to get that sort of time with the SBN and Panel?:
Gary Robert Silverman Company: Silverman, Decaria & Kattelman, Chtd. Address: 6140 Plumas St.
Ste. 200 Reno , NV 89519 Phone Number: 775-322-3223 Fax number: 775-322-3649 Email:
silverman@silverman-decaria.com Website: http://www.silverman-decaria.com Admit Date: 11/02/70
should the 11/14/12 hearing go forward, which it clearly should not, at least not in its current
unbifurcated, due process violating, unnoticed, no service of the 10/9/12 NOtice of INtent to Take
Default, no "at least 30 days" service of the Designation of Witness and Summary of Evidence BY
THE PANEL, NOT BY THE SBN, BAR COUNSEL, OR THE CLERK OF THE SBN, under SCR
105(2)(c). SBN also told Coughlin he would not have to pay any witness or subpoena fees and that
Respondent's never have to in these Disciplinary Hearings.
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Vanity Fair doing a hit piece on Sarah Palin thinks the way this thing has been run so far is a bit
uneven-handed. Ann Coulter writing about the shortcomings of a minority immigrant lesbian victim
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of domestic violence disabled single mother whistleblower who was retaliated against's shortcomings
thinks the way this thing has been run so far lacks sensitivity.
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Coughlin incorporates by reference: The Notice filed 11 9 2012 in in the case involving WLS's Paul
Elcano and State Bar of Nevada's Ethic's Committee Member Joseph Garin, Esq. and it is truly
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interesting that the SBN and the Panel seek to plungE headlong into the 11/14/12 hearing that
violates absoltuely every section of NR 105(2)(c) (one of the very, very few provisions of the
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Supreme Court Rules speaking to the due process requirements of these disciplinary hearings
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(which some watching Coughlin circa 2002-2005 might say often devolve into kangaroo courts
where some corrupt bully (some might say Strip Club Spearmint Rhino owner Kevin Kelly, Esq.,
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decade long member of the State Bar of Nevada's Character and Fitness Committee, whose club
allegedly funnels $10 million a year to Vegas cabbies to direct tourists to its doors Coe Swobe
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making' calls there too, just like in 60302 where he is calling Coughlin and his father seeking to do
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WLS's and Elcano's bidding) who chips off his friends (Peter Christiansen, Jr. Esq.) despite saying
the representations would be pro bono (despite receiving $5,000, Christiansen still, on the record,
misled the Character and Fitness Committee into think he was appearing pro bono...the proceeded
to make it clear that the sum and sumbstance of the work he or his office would do for the $5K was
for him to file a six page, rather tepid arrangement worth of a Pre Hearing Brief (containing
admissions that Coughlin did not make related to things Coughlin did not do) and showing up for the
dog and pony show hearing (wherein, after his friends having been paid, C&F Committee Strip Club
Spearmint Rhino ownin' Kevin Kelly, Esq. took a remarkably different tact with applicant for
admission Coughlin (whose admission was delayed despite never having been convicted of a single
crime, based largely on some retaliation that Mark Tratos, Esq. largely admitted to, along with Mary
Lafrance (send me "another" copy of you paper..."what was it about" the "name of the case
involved" (gee Tratos, kind of sounds like you had the version Coughlin submitted with only his
social security number (in compliance with the Boyd School of Law's blind grading policy, which
would have been particulary apt where your own summer associate, Don Prunty, was taking your
July 2001 Cybe law class (as was Coughlin, following his second year of law school, wherein at the
same time he took and passed the July 2001 Nevada Bar Examination, while taking another summar
school class as well) (http://caseinfo.nvsupremecourt.us/public/caseView.do?documentError=1229552%3A+This+document+is+currently+unavailable.+If+you+need+a+copy+of+this+document
%2C+please+contact+Clerk%27s+Office+at+%28775%29684-1600.&csIID=28466
MOTION SHOWING GOOD CAUSE TO ALLOW COUGHLIN TO SUBMIT A RESPONSE

OR ANSWER TO WHATEVER EXTENT THE PANEL FEELS HE HAS NOT ALREADY
DONE SO AND OR INTENDS TO CALL THIS A "PROCEED ON A DEFAULT BASIS"
SITUATION, WHERE COUGHLIN DISPUTES.
to whatever exten the sbn or panel purprts that coughlin has defaulted here, Coughlin
submits thats not the case particularly where the sbn has not filed an valid proof of service of
the complaint, particulary given the admission as to the representations and indicatiosn made
by the sbn, king and peters...further, the notice of intent to take default was only mailed by
certified mail. and the postage was deficient, and the usps wouldn't give it to coughlin, though,
curiously the cerified mailing number for that mailign is not in the big box that strangely
enough...took form november 1, 2012 to november 7th, 2012 to get copied and transported to
coughlin (not exactly blazing speed, huh...and coughllin reported the insufficient postage issue
to king and the sbn in the interim, so...draw your own conclusions...but pat is refusing to amend
any return of service thereto the complaint and or the DowSoW (see attached showing the first
certified scanning of it being in usps possession is from october 16th, 2012, not 10/12/12, and
that the earliest it was presented to coughlins' po box was 10/22/12, through no fault of coughlin
(who complied with scr 79 here...)sbn EMPLOYEE "paula" admitted to Coughlin that Pat
King locked the SBN door "a couple minutes" prior to 5 pm on a day when Coughlin sought to
present someting for filing that arguably could be deemed a "response" (verified to whatever
extent required, under protest, as this situation, where coughlin si representing himself presetn,
arguably a unique circumstances, and coughlin herein incorprates allt eh arguments made in
his recent 61901 filing vis a vis making self represented defenandts subject to such an
impermissible "sworn testimony" view of their own advocacy...But arguably, especially
000204
Coughlin's file stamped 10/31/12 Pre-Hearing MOtion to Dismiss/summary

judgment/memorandum of law should be view as just such a "response", verified to whaver
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Spevack considering extent is required of a self represented respondent here, and where King
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and the SBN should be made to more spcifically set forth that allegations (fairness to opposing
counse? in what way? Judges Nash HOlmes Order is beyond cursory in that regard, and
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utterly devoid of a single fact to support such copy and pasting of the RPC...other than to
suggest asking questions about retaliation is so dilatory as to support a "fairness to opposing
5 counse" rpc violation worthy of a scr 105 complaint....uh....
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"We nevertheless conclude that discipline orders appearing in the Nevada Lawyer may be cited to
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this court for the limited purpose of providing examples of the discipline imposed in similar fact
situations. This approach has also been taken by several other courts. n22
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n22 See. e.g., Berman v. City of Daly City, 21 Cal. App. 4th 276, 26 Cal. Rptr, 2d 493, 496 n.5 (Ct.
App. 1993); Marez v. Dairyland Ins. Co., 638 P.2d 286, 289 n.2 (Colo. 1981); Manderfeld v. Krovitz,
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539 N.W.2d 802, 807 n.3 (Minn. Ct. App. 1995): Leisure Hills of Grand Rapids v. DHS, 480 N.W.2d
149, 151 n.3 (Minn. Ct. App. 1992)." In Re Laub.
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Plus on the sufficiency of the servie and proces and servic of process thing (kings exhibits are blurry
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and not well scanned, and printed on both sides of the page in some instances, which Garin got a
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dismissal for based on arguably less in 60302)...
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I am not so sure Judge McGee didn't have something to do with my temporary suspension. Or
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District Attorney Gammick (both of whom I like and consider friends). I emailed them both about five
hours before I got the efile notice from the Court of the suspension on June 6th, 2012. And like my
friend Gary Silverman, Esq. said in an email to me on August 13th, 2012 when Gary, as is his wont,
took time out of his day to read my ridiculously long (well Grundy's breif for Stevie was 55 pages,
so....and Judge McGee's suggestion to me that mine should be no more than 3 pages is just
insulting. lawyers drone on for 60 pages about widgets but a career of mine that took a lifetime to
build is worth 3 pages? Please. seriously, lawyer's need a Player's Union. And it ain't the Bar.
There's a really big problem in our Bar right now, and I think we all now what it is...Player hatin'.
That's right, I said it. Hell, look at this deal. Here, the Bar is basically the Bench's Rent-aThug...enter Pat "Salieri" King. it is just plain puke worthy the extent to which Patty has covered his
ears, put a blindfold over his eyes, and muzzled himself in his pursuit of cloaking himself in his tired
old mantra "a conviction is indisputable proof of wrongdoing (not according to Claiborne and
Montiero says King seeking to screw up a pending criminal prosecution in 11 cr 063341 is just wrong
where King purports to include it in this Complaint herein (and Coughlin shoudl get and moves for a
continuance of this Bar hearing on 11/14/12 on that basis as well...Its just ridiculous to expect
Coughlin to appear representing Himself at this bar hearing on 11/14/12, then do the same in the
alleged "lost mislaid abandoned" property as larceny case 063341 to pretend like that is fair
(especially where kIng has rigged this deal so that Coughlin's SCR 105(2)(c) rights have all been cut
by about 709%...which is prosecutorial misconduct, and under SCR 119 hopefully something the
Court will address (but also as "possession of stolen property" according to dda young, despite
Staab, double jeopardy and duplicative charges issues, and the fact that the Complaint in that case
fails to allege "from another" or to allege anything with any specificity whatsoever, which is
something Biray Dogan is sure doesn't matter. despite Biray getting $8,000 raises in some of the
worst fiscal years in our nation's history...connection? uh, no comment. so I don't have to
undertake any investigation or ask the Board member Richard G. HIll, Esq. (whose best friend is also
a Board Member, David Hamilton, Esq.,and its pretty unseemly for Board members to be using their
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membership as a club....and when I say "club" I mean like a shiv or shank or something one might
reach for if ish starts to popov in the 'yard...not like a "group" or "committee"...if that is what Hill is
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doing here, which is not for me to say. just sayin' you know what I'm sayin? You know what I'm
sayin. But this Board, funny thing...its comprised of individuals...and they don't always see things the
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same. Look at 57507, Harris's deal. The Chair there was like "oh, hell naw"....) any uncomfortable
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questions....like how Hill lied to get Coughlin arrested (Coughlin hereby incorporates by reference all
his filings in the last 18 months publicly available on the Nevada Supreme Court's website, especially
those in 60838, 61901, 61426, 60302, 60331, 61383, 60630 (which should just be a Mandamus
Petition requiring Longoni and the RMC to quit breaking the law and instead comply with the NRS
189.030 requirement that the RMC Order the transcript prepared and the ROA sent to the District
Court within 10 days of the filing of the Notice of Appeal (and Judge Kenneth Howard's statement on
the record after Coughlin was brought back in in cuffs on 11/30/11 in 11 CR 22176 (and that whole
conviction is completely devoid of any sniff of due process, much less the fact that tribal police are
not allowed to make misdemeanor arrests in Nevada under NRS 171.1255and the "confidential"
60975 (aint so confidential where the publicly available case participant search research show a
SCR 117 "confidential" Disability Petition has been filed against Coughlin, now is it? Also, Coughlin
submitted to the Court on May 24th, 2012 an Opposition to King's May 10th, 2012 SCR 111(6)
Petition on the Walmart and its not in line with what was done in the Noel Gage case (he submitted
an opposition) and there is not a rule that says the Clerk can refuse to file the Opposition Coughlin
submitted on May 24th, 2012 or otherwise make it so some shallow AP article is printed about
Coughlin the day after the Court's Order comes down suspending Coughlin (kinda sounds a bit fed
to that writer, doesn't it? Also, Coughlin's recent filings in 61901 and some other cases (not 60302
though, featuring SBN Ethics Committee member Joe Garin (can I get King's complaint here
dismissed on Garin style "illegible" service of process arguments that are later reclassified as
insufficiency of "process" rather than the previous arguments as to insufficiency of "service" of that
process? King's exhibits (which you just know under the Mirch case will mean all that those Judge's
Order attached as exhibits (and hell, it'll prolly be the case that orders mentioned in those orders
(like Judges Sferrazza's 10/27/11 Findings of Fact, etc. in rjc rev2011-1708 will be thereby
incorporated too, right...except, like in the 11 cr 26405, they will only be relevant to the extent the
prosecution needs 'em...once Coughlin starts referencing them, Chair Echeverria will be on it in a
second with a Judge Howard/Nash/L. and W. Gardner style "how is this relevant" "it's not relevant"
"move on!" "you keep it up and you are going to add to your little record there" (that last one from
Judge Nash Holmes, although she'll tell you no extra judicial communication affected her ability to
preside over that matter, or resullt in the Richard G. Hill gets Coughlin arrest again this time for
jaywalking case in 12 cr 00696 (in the video which coughlin transcribed Hill is seen lying to RPD
Officer Hollingsworth that, on 1/11/12 Coughlin had "lost his appeal" (you mean the one not decided
until 3/30/12, Rich? Kind of like Hill lying to RPD Chris Carter and Sargent Marcia Lopez (see
Coughlin work in 11 cr 26405's recent filigns in the last month, both of which shouldbe essentially
reproduced in N. S. Ct. 61901, but only one of which is (no matter, all that was relevant enough to
put most of it in 60302) being transferred to her on 2/27/12 (lot happened on that day here) purport to
rule on will be deemed "notice" or pled to Coughlin (which doesn't make sense considering there are
3 grievance number on the complaint, yet the 8/23/12 stamped Complaint speaks to things not
mentioned in any of those grievances...)...and speaking of, oh. look there's Keith Loomis, Esq. on the
SBN's fee dispute Committee...sure is interesting who winds up on all these Committees for the
SBN....Kevin Kelly, Esq., owner of the megalithic Las Vegas outpost of multinational strip club chain
Spearmint Rhino has been puttin' in work on the Character & Fitness Committee for ever, great
friends with Peter Christiansen, Jr.) and as a "verified response" (to whatever extent this Panel
intends to hold that Coughlin has to do what Judge Nash Holmes tried to do (ie, swear in the self
representing defendant at the outset, thereby hamstringing them with an impermissible condition that
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the Muni Court Judges are, curiously, not putting on their, er, the Municipalities prosecutors (and
believe me, Allison Ormass, Christopher Hazlett-Stevens, Pamela Roberts, Dan Wong, et al don't
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want know part of everything that comes out of their mouths in court being sworn. And the testify
plenty while trying their cases, in fact, they are really good at it, especially during their closing
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arguments about facts not in evidence and which are not reasonably directed toward admissible
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subject matter to begin with, but rather just cheap shots calculated to render a prejudicial
effect...right Hazlett-Steven's, what with your repeated "pajamas and slippers" blast....Don't see
Judge Nash Holmes talking threatening trash at him from the bench (Judge Holmes couldn't decide
during the 2/27/12 preceding if everything Coughlin said that day was "sworn testimony" or
not...alternately seeming to want it to be, only to constantly interrupt Coughlin during his cross of
Sargent Tarter to say things like "when you testify you can get into that" or "you are not testifying he
is" (and Ormaas's statements in court that day about whether the report or charge sheet or whatever
that had the officer that Sargent Tarter called in to fill out the form (why on earth does Sargent Tarter
need to call someone in to fill out a report, then indicate Tarter signed it, and that didn't deprive
Coughlin his Sixth Amendment right of confrontation or justifying a continuance? Maybe there is a
sensitive reasons why Tarter can't write in his own hand or something (in which case, I mean no
disrespect), or, maybe, his callign in a officer with no percipient recollection indicates some
impermissible action or motive by Tarter (and Tarter testified that he normally give people a warning,
but that Coughlin was being uncooperative (which is something every RPD Officers seems to be
trained to recite from rote along with "well my training and experience indicated to me a search was
appropriate).
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Regarding the apparent greater "due process" accorde to David Grundy's client STephen R. Harris
(which reminds me....Coe Swobe should not be making calls to Coughlin's father, Dr. Timothy D.
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Coughlin, nor should WLS's Paul Elcano seeking to "help" Coughlin (if by "help Zach" they mean
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"hey, Tim, don't let Zach give Elcano any problems, okay? We need you to lean on Zach, Tim."
Yeah, no, Paul and Coe...Coe doesn't need to tell Zach Coughlin "well you really shit on Elcano
there". Not quite Coer (he calls me "Zacker" , it was his call in 2002 that funneled me to Peter
Christiansen, Jr. (and Coe probably didn't know much of anything about Pete...and arguably made
up for any negligence or untoward involvement in that regard where he and Keith Lee, Esq. (founder
of the C&F) got it done in 2004 (after Christiansen and Sanft made it abundantly clear that they
weren't going to get out of bed for less than another $5K, not in so many words...but when Eichman
is like,uh...yeah, your "attorney of record" doesn't seem too "into it" so, um...why don't you prepare a
Notice of Intent to Seek Reconsideration" or something when the abeyance expires in Sept 2003
(which Coughlin did, yet Eichman decided not to submit to the Court...and, to be fair, it probably
would have not had the best chance (although, come to think of it, its was the "two or three pages"
that Judge McGee seemed to suggest Coughlin's recent Motino to Dissolve should be....yet Eichman
just basically unilaterally failed to forward it on to the Court? And if you had Mike Rowe writing you
nasty threatening letters t sit down and shut up like Rowe did in January 2003 to Coughlin...you
probably woudn't be too squeeky a wheel either...which would cost you another year and half of your
career and professional development (why is it only deputy prosecutors get all the trial
experience...and Coughlin gets fired where he attempts to get some in 54844 (incorporate that case
too into Coughlin's respond to Kings Complaint to the extent one is being coerced out of Coughlin
and the Motion to Dismiss or Motion for More definite STatement is not accorded to approriate
NRCP process (clearly Panel Chair Echeverria doesn't believe in waiting to read a Reply to King's
Opposition to bifurcate, as the Chair enters his orders before the 5 days to file one has even run
(consider nrcp 6(e) and the fact that King doesn't email or fax his Opposition to the bifurcate
motion..mailed it on 10/24/12 and the Chair rules on 10/30/12...just like RMC Judge Howard ruling
on Coughlin's various post-trial motions before the City Attorney's office even responds to
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them...nothing says "due process" quite like that. well, except for Judge Howard announcing at trial
that he was refusing to grant Coughlin a continuance in 11 cr 22176 (resulting in 60838) because
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Coughlin failed to appear at the 11/14/12 original trial date. Despite City Attorney roberts having
agreed to a continuance of the 11/30/12 trial date in writing before hand, come trial time she refused
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to, then claimed it was up to Judge Howard anyways. The RMC granted the city attorney a
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continaunce in 11 cr 26405 because Board member Rich Hill need to go on vacation for six weeks
(lew taitel, conflict, rmc defender, took coughlin's case, shouldnta...coughlin was suing his business
partners, who are committing the unauthorized practice of law, that judge pearson and judge
schroeder found permissible in rjc rev2012-001048, which not only wrongfully evicted coughlin, but
resulte in two wrongful arrests of coughlin by the rpd in 12 cr 12420 and rcr2012-067980 (when
Judges fail to follow what the legislature sets out in nrs 40.253, there is a real human cost, and,
apparently, it costs Dan Wong and the bar and the courts, and lots of other people their
relationships, time, judicial resources, etc., etc. Our states landlord tenant law are the harshest
towards tenants to begin with...when Judges "remix" those laws or choose not to faithfully enforce
them (and its particularly suspect where that is done by former prosecutors turned judges where
Coughlin's orientation to the County Sheriff and RPD at this poitn arguably calls for an "alternate
public prosecutor) to be appointed in all past and existing prosecutions of Coughlin, beginning with
the rcr2011-063341 arrest that started all of this off (with a little help from a wrongfull summary
eviction that remixed summary and plenary and went all "JCRLV Rule 44" (despite the RJC not
having complied with JCRCP 83 in fashioning such an application....and don't tell Coughlin he "sh&t
on" Washoe Legal Services". Coughlin, in the last year, has more than paid it forward to the legal
services community in Nevada through his guerilla, impromptu, performance art, improvisational
tenant's rights, prosecutorial and police misconduct addressing advocacy, all gratis, natch. Well, you
can go ahead and thank his momma, Very Special Arts of Nevada's Mary Barker Program Director
(and Obama's staunchest supporter, at least in the Western States, for sure.. caring on the Ruth
Barker legacy of adovacy) for that advocacy, because is has in large part been funded through
generous grants from her, on her $21 an hour paycheck. But you can't thank Marc Ashley, Esq.,
WLS's landlord tenant attorney. YOu could maybe thank Jon Sasser, Esq. some. And Tik
Segerblom. But you can't thank Paul Elcano or the Muni Court Judges for that. Thank Mary
Barker. And you can thank Bo Barker, Esq. too, famed construction defect gure in the State of
Washinton (www.BarkerMartin.com). Haven't heard too much from Robert Coughlin, Esq. (last thing
heard bout him he was prosecutin' defendants denied their Sixth Amendment Right to counsel for
Huber Heights. http://www.daytondailynews.com/news/news/local/defendants-tried-without-lawyersin-huber-heights-/nM9sD/ (http://www.zoominfo.com/#!search/profile/person?
personId=282794556&targetid=profile whom Coughlin hereby supplements to the SBN as included
in his Designation of Witnesses...especially where all the sudden Judge Beesley and Paul Elcano
are being supplemented (Judge Beesley to excuse, apparently, King's reckless and not true
attestation (if it were true, then how did Coughlin file on 6/10/12 something in Cadle Co. v. Keller
(funny, the excellent motion work Coughli did for Keller and Gessin in the NVB adversary
proceedings didn't find its way into the ginormous bate stamped collections of "pleadings created by
Zach Coughlin" in the SBN's files (nor was anything from Coughlin's very, very sold work in the two
Dana Harris cases, the one before Judge Doherty featuring a NRCP 60(b)(4) void for lack of
jursidiction where home state under the UCCJEA was procured through fraud motion that Coughlin
was probably paid, consdiering everything, something liek $50 for....or the work in the Carpentier v.
Aames funding (which Judge Flanagan managed to issue yet another rather suspect sanction
against Coughlin in to go alogn with his apparenlty record setting attorney's fees award agains that
which he had deemed a commercial tenant (at least implicilty, to the extent the summary eviction
where NO Cause all that was pled was upheld) in the richard hill eviction case.. (those sanctions
bring it to the point where any Temporary Restraining Order that Couglin and Flanagans former
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employer may be entitled to prior to Coughlin unloading some "privilege of the participant" laden
testimony directed toward, lets just say, hypotehticaly, an associate getting let go because "not a
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good fit" a couple weeks after an office managers assistant broke up with the new litigation lateral
hire equity partner, the the assistant asks the junior associate out, cue the sudden need for an
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"assignement" to be done for the same Seinfeld character swarming around Trish's departure, even
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though that partner way off in transactional land....and add to that the awkwardness of junior
associate pointing out to new lateral equity hire that us supreme court ruling on a post whatever
whatever cause of action under something something being mandatory authority, for which the
SCR's hold there is a duty to disclose, and you have what? you have an associate booted 'round
christmas time just after developing gastroenteritis incident to the southern pseudo military academy
atmosphere found at that firm...Not sue how that wouldn't kind of call for recusal (Judge L. gArdner
herself signed an ORder of recusal in the next case coughlin appeared as atty on before her, citing,
in her 8/16/11 ORder of Recusal NCJCR 2.11(A)(1) (that's the one where the Judge just flat out
admits they have an actual bias or prejudice, right? we aren't even talking perceived or possiblewe
are talkin' flat out "I am biased and prejudiced against you" admission resulting in recusal (and the
comment is instructive consdering what happened during the settlemen conference in that April 2009
JOshi case: "[3]Judges must be mindful of the effect settlement discussions can have, not only on
their objectivity and impartiality, but also on the appearance of their objectivity and impartiality.
Despite a judges best efforts, there may be instances when information obtained during settlement
discussions could influence a judges decision making during trial, and, in such instances, the judge
should consider whether disqualification may be appropriate. See Rule 2.11(A)(1)."...also " Third
degree of relationship includes the following persons: great-grandparent, grandparent, parent,
uncle, aunt, brother, sister, child, grandchild, great-grandchild, nephew, and niece. See Rule 2.11.
NCJCR's on terminology sections"
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...as the basis for her doing so...that same rationale arguably applies to have required her brother to
recuse himself in the criminal trespass prosecution.. Guess its nice of Judge L. Garner to just flat out
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admit it in her recusal order in Bell v. Greer wherein she cites: Rule2.11.Disqualification.
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(A)A judge shall disqualify himself or herself in any proceeding in which the judges impartiality
might reasonably be questioned, including but not limited to the following circumstances:
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(1)The judge has a personal bias or prejudice concerning a party or a partys lawyer, or
personal knowledge of facts that are in dispute in the proceeding." But to then go on and be
involved in the ghost greivancing here (in the "big box" of the file delivered to Cogulin on 11/7/12
(wow, only 8 days before this huge hearing wherein King has told Coughlin he will get him disbarred,
Mirch-style, coughlin finally gets some access to some of the materials...in violation of the right to
inspect "up to 3 days" in SCr 105(2)(c), and Coughln had been seeking that permission to inspect
continuously all along here, and it is impermissilbe for King to violate the "courthouse sanctuary"
doctrine and purport to impinge on coughlin's inspect right under scr 105(2)(c), especially by shoving
documents into coughlin's jacket upon pulling at the lapel (and its King and Peters that are no
adopting the "Duluth Model" "Power and Control Wheel" abuser style tactics of "playing the victim"
(replete with Peters's "this is harrasment! I am getting a protection ORder whenever her apparent
misconduct resulting in a curtailing of Coughlins' due process rights is broached....ditto for King...see
his baseless and unsupported, devoid of specifics (gee, don't think Paula would quite put it like that
KIng...just because she admitted that king leaves the office early, thereby locking up the "filing office"
prior to "The close of business at 5pm" under NRCP doesn't make Coughlin's conduct as justifying
some "stay away" letter, Pat. get a grip.
000209
Rule 2.11. Disqualification. (A) A judge shall disqualify himself or herself in any proceeding in
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which the judges impartiality might reasonably be questioned, including but not limited to
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the following circumstances: (1) The judge has a personal bias or prejudice concerning a
party or a partys lawyer, or personal knowledge of facts that are in dispute in the proceeding.
(2) The judge knows that the judge, the judges spouse or domestic partner, or a person within the
third degree of relationship to either of them, or the spouse or domestic partner of such a person is:
(a) a party to the proceeding or an officer, director, general partner, managing member, or trustee of
a party; (b) acting as a lawyer in the proceeding; (c) a person who has more than a de minimis
interest that could be substantially affected by the proceeding; or (d) likely to be a material witness in
the proceeding. (3) The judge knows that he or she, individually or as a fiduciary, or the judges
spouse, domestic partner, parent, or child, or any other member of the judges family residing in the
judges household, has an economic interest in the subject matter in controversy or in a party to the
proceeding. (4) [Reserved.] (5) The judge, while a judge or a judicial candidate, has made a public
statement, other than in a court proceeding, judicial decision, or opinion, that commits or appears to
commit the judge to reach a particular result or rule in a particular way in the proceeding or
controversy. (6) The judge: (a) served as a lawyer in the matter in controversy or was associated
with a lawyer who participated substantially as a lawyer in the matter during such association; (b)
served in governmental employment and in such capacity participated personally and substantially
as a lawyer or public official concerning the proceeding, or has publicly expressed in such capacity
an opinion concerning the merits of the particular matter in controversy; (c) was a material witness
concerning the matter; or (d) previously presided as a judge over the matter in another court. (B) A
judge shall keep informed about the judges personal and fiduciary economic interests and make a
reasonable effort to keep informed about the personal economic interests of the judges spouse or
domestic partner and minor children residing in the judges household. (C) A judge subject to
disqualification under this Rule, other than for bias or prejudice under paragraph (A)(1), may disclose
on the record the basis of the judges disqualification and may ask the parties and their lawyers to
consider, outside the presence of the judge and court staff, court officials and others subject to the
judges direction and control, whether to waive disqualification. If, following the disclosure, the parties
and lawyers agree, without participation by the judge or court staff, court officials and others subject
to the judges direction and control, that the judge should not be disqualified, the judge may
participate in the proceeding. The agreement shall be incorporated into the record of the proceeding.
COMMENT [1] Under this Rule, a judge is disqualified whenever the judges impartiality might
reasonably be questioned, regardless of whether any of the specific provisions of paragraphs (A)(1)
through (6) apply. For example, if a judge were in the process of negotiating for employment with a
law firm, the judge would be disqualified from any matters in which that law firm appeared, unless the
disqualification was waived by the parties after disclosure by the judge. [2] A judges obligation not
to hear or decide matters in which disqualification is required applies regardless of whether a
motion to disqualify is filed. [3] The rule of necessity may override the rule of disqualification. For
example, a judge might be required to participate in judicial review of a judicial salary statute, or
might be the only judge available in a matter requiring immediate judicial action, such as a hearing
on probable cause or a temporary restraining order. In matters that require immediate action, the
judge must disclose on the record the basis for possible disqualification and make reasonable efforts
to transfer the matter to another judge as soon as practicable. [4] The fact that a lawyer in a
proceeding is affiliated with a law firm with which a relative of the judge is affiliated does not itself
disqualify the judge. If, however, the judges impartiality might reasonably be questioned under
paragraph (A), or the relative is known by the judge to have an interest in the law firm that could be
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substantially affected by the proceeding under paragraph (A)(2)(c), the judges disqualification is
required. [4A] The filing of a judicial discipline complaint during the pendency of a matter does not of
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itself require disqualification of the judge from presiding over the litigation. The judges decision to
recuse in such circumstances must be resolved on a case-by-case basis. [5] A judge should
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disclose on the record information that the judge believes the parties or their lawyers might
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reasonably consider relevant to a possible motion for disqualification, even if the judge
believes there is no basis for disqualification. (Judge W. Gardner only did this upon Coughlin
prompting for it...) A judge making such a disclosure should, where practicable, follow the
procedure set forth in Rule 2.11(C). [6] Economic interest, as set forth in the Terminology section,
means ownership of more than a de minimis legal or equitable interest (Coughlin's law license is a
14th amendment property right, and Judge L. Gardners reputation as a jurist, to whatever extent she
felt is impinged by 54844, may invoked this provision here). Except for situations in which a judge
participates in the management of such a legal or equitable interest, or the interest could be
substantially affected by the outcome of a proceeding before a judge, it does not include: (1) an
interest in the individual holdings within a mutual or common investment fund; (2) an interest in
securities held by an educational, religious, charitable, fraternal, or civic organization in which the
judge or the judges spouse, domestic partner, parent, or child serves as a director, officer, advisor,
or other participant; (3) a deposit in a financial institution or deposits or proprietary interests the judge
may maintain as a member of a mutual savings association or credit union, or similar proprietary
interests; or (4) an interest in the issuer of government securities held by the judge.
.probably wouldn't be such an issue if there weren't $5K sanction for filing motions that do point out
"gee, yeah, that might be kind of important if RCS/QLS is owned by the law firm on the case, and
they are sending out the summary judgment motions to one who is no longer attorney of record or
doing so in the bankruptcy matrix or listing the wrong court and or case number in the caption (funny,
anything like that by Coughlin gets a WDCR 10 rejection by Matheus, not to mention that WDCR 37
or whatever that sets for exactly the court lines on the caption have to say basis, and wDCR r 17 or
18 or whatever) (especially given the great possibilities int eh BK setting for making the bank/lender
prove standing, Rule 3001 or whatever) .that, while not formatted that great, did manage to set out
the exact method to win that case, some rather elegant points of law that many would miss (and
Couglin wouldn't have gotten there were it not for the initial assist from Michael Lehrners, and some
general shaman meets arms dealer by way of Mecca direction from one Geoffrey Lynn Giles, Esq.)
to king's Boss, David Clark, and, upon information and belief, Coughlin's then client, Peter Eastman,
prior the the May 10th, 2012 filing by King, regarding matters still requiring King's non comment to
Eastman under SCR 121 (how is it that Eastman and King are the only two people in the world who
makes comments to Coughlin about "the b#n#r*p#c# Court won't let you" do this or that in the first
couple days of May 2012 if King isn't violating SCR 121 to Eastman (who magically was able to
afford Freitag all the sudden, despite having failed to pay Coughlin anything on the $3,500 flat fee to
represent Eastman in CV11-00820 - EASON INSURANCE VS. PETER EASTMAN. ETAL (B6).
Whether there is some connection to the Zach Coughlin v. Jeff Nichols case in the RJC, and whether
Nichols just told lie after lie at the hearing (and, whether that is easily provable, Jeff...keep smilin',
buddy....and whether Coughlin was punched in the face by somebody on or around March 30th,
2012, whether that somebody is a former WCSO Deputy, and whether Nichols and he not only
managed ot get Nichols about 6 hours of high end research for free (well, not according to the deal)
on the whole gift/loan $130K unsecured promissory loan form the older english professor family
friend thing...resulting in some, an attorney subject to yet another wrongful eviction (its fraud to post
a No Cause Eviction notice then file a tenant's affidavit alleging non payment of rent on the day of
the hearing, Gayle...and Sue...just because the attorney's pre hearing mOtion pointed out all the
terrible obstacles you would be facing in proceeding under a no cause notice (and if the eviction
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order in rjc 2012-000374 is faxed to the RJC, as Casey Baker, Esq. testified on 6/18/12, that all such
orders are (and contrary to RJC indications....even private attorenys rely on the RJC to fax those
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lockout orders to the Sheriff's...and if the 3/15/12 lockout order in that summary eviction (the one the
attorney was subject to about 5 hours after the hearing, where a default was granted for a hearing
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notice as starting at 8:30 am, despite the fax header on the eviction order indicatign the signed
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Lockout Order was faxed to the Sheriff at 8:24 am....? Which brings up the question...since Baker's
testimony is that even landlord's with high end private attorney's like Hill rely on (as that is the usual
course and custom according to RJC Karen Stancil, for such orders to be faxed to the wCSO the day
they are entered, or the next day at the latest)...then where, oh where, is the proof of when the RJC
faxed teh 10/25/11 Eviction Decision and Order that Judge Sferrazza signed in rjc rev2011-001708
and which Deputy Machen lists as having "personally served" Coughlin, on 11/1/11 at 4:30
pm...despite Machen (who made the arrest in rcr2012-06798, on june 28th, 2012, despite judge
schroeder and the rjc being well aware of the deficiency of the notice under 40.253 in that the
unauthorized practicioner of law (the call themselves an "eviction consulting and process serving
company"...isn't that cute?) Nevada Court services, biz partners with Lew Taitel (the RMC court
appointed defender who appeared for Coughlin the trespass case before Judge W. Gardner (brother
to the L. gardner who recused herself from a randomly assigned case that Coughlin was atty of
record on on 8/10/11 in Case Description: FV11-02864 - ROBERT A BELL VS JESSICA F GREER
(D11) -. Filing Date: 10-Aug-2011...which coincidentall (god shot,anyone?) just so happens to not
only establish that (and this was done in so many, many other ways regardless) that Coughlin held
himself out and was a commercial tenant at 121 River Rock ST., practicing law (and a mattress biz
to boot, Coughlin Memory Foam) HIll's summary eviction of commercial tenant Coughlin on a NO
Cause notice was jurisdictionally void (to whatever extent the october 18th, 2011 filing by Coughlin of
a notice of appeal and depositing that $2,275 didn't divest Judge SFerrazza, under Mack v. Mack
Manley of jurisdictio nto hold the "Trial" on 10/25/11 that he noticed in writing ("the use of the term
"Trial" was unfortunate, You Honor" said HIll's associate Casey Baker, who has now hightailed it on
back to Kentucky now that he and HIll are about to have some serious 'splainin' to do)...And as to the
"verified response or Answer" Echeverria and kIng are so keen on....is yours a verified Complaint,
Pat? Are the Judges oRders verified? Does Judge Nash HOlmes's pastiche of what she likes best
of the differetn types of contempt in NEvada and beyond based upon some Affidavit by a marshal as
to some restroom hapennings? Were is that "not in the immediate presence" not "under the court's
watchful eye" affidavit. and Judge Howards tack on 3 minutes of trial audion in 11 cr 22176 seeks to
mislead Coughlin not only as to who has to pay up front or not for the transcript attendnat to an
appeal fo the petty larceny conviction (which is void anyways given it stems from an arrest by a tribal
police officer, violative of nrs 171.1255 (and at the trial wal-mart's Thomas Frontino and the RSIC
officers Braunworth and Crawford admitted that no citizen's arrest was effectuated upon Coughlin,
with Frontino making especially clear (it seemed he had been coached to do so, likely to help his
employer wal-mart in seeking to avoid any "wrongful shopkeeper's arrest" lawsuits by just letting the
tribal police take whatever fall might stem from something like that (not likely, right?....but the price to
pay for that, City of Reno, Walmart, and RSIC is that nrs 171.1255 rears its ugly head makes that
whole arrest, and therefore conviction, null and wrongful, and there's some question that need be
asked of Roberts et al about prosecutin' based upon such arrests made in violation of Nevada law.
Much less Roberts putting on the perjured testimony of Frontino and Crawford, and maybe
Braunworth, to the extent he could remember anything more than his name while testifying at trial, or
understand a single question asked of him that day (and Judge HOward refused to allow Coughlin to
testify in his own behalf in that regard, an inviolable right....after expecting Coughlin to cheerfully face
the same "can you repeat the question" that cause Judge Howard to boil over and deny Coughlin his
right to testify, when Braunworth greeted every question asked by Coughlin with that same "can you
repeat the question?". , which, given she is an attorney (to borrow from the approach taken with
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Coughlin by the three RMC Judges with Coughlin, even when he was "Not an attorney" under King's
view (Coughlin as suspended on 6/7/12, which W. Gardner admitted to being apprised of prior to the
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6/18/12 trial in the trespass matter (all of this is great stuff under Claiborne and 37 CFR 11.25(a) and
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(c)....
BUT YEAH, TO BE CLEAR, COULD TAKES ADVANTAGE OF THE FULL RANGE OF SPEVACK,
WHILST ALSO HEREBY SUPPLEMENTING HIS PREVIOUS ANSWER OR RESPONSE MADE
UNDER PROTESTT (GIVEN THE BASIS FOR A DISMISSAL AND OTHER DUE PROCESS,
SERVICE NOTICE DEFICIENCIES) TO INDICATE, AS HIS OWN ATTORNEY (DID STEVE
HARRIS HAVE TO FILE A VERIFIED ANSWER OR RESPONSE TESTIFYING UNDER OATH AS
TO EACH AND EVERY ALLEGATIONS OR DID DAVID GRUNDY GET TO ADOVATE ON HIS
BEHALF UNDER A NRCP 11 STANDARD? (WELL, OKAY Harris apparently admitted the two RPC
violations he was charged with...but, hey, that brings up, how is it, under the Mirch notice arguments
that will undoubtedly be made, Coughlin is not subject to the "copy and paste the entire contents of
the rpc then issue a general and competely vague ruling/laundry list recitation of how coughlin
violated every one of the (but Judge Nash Holmes contradicts her "clear and convicing" findings by
commenting "there certainly seems to be an issue of whether he violated that", with regard to pretty
much all of the RPC violations/allegations/suggestions of a violation....). How is it Harris is charged
with only two RPC's, yet Coughlin is apparently, in an unbifrcuated hearing, expeted to defend
against the "copy and paste every RPC in the book" incident to the "convictions" in Judge Nash
Holmes Order (and you know king will argue all her orders are incorproated by reference to whatever
extent his complaint doesn't specificaly pled them...)? oH, wait, the SBN's King will say Coughlin
can't even "Relitigate" Jduge Nash Holmes "convictions" of Coughlin (even the ones she made in
violation of the 10 day rule to make sua sponte nrcp 59(a) alterantiosn or amendments to her void
anyways 2/28/12 Order (she takes a second swing at the bat on in her 3/12/12 ORder purporting to
re-rule on things she already issued a "misdemeanor criminal contempt conviction" on in her 2/28/12
ORder...in her 3/12/12 order (nrs 178.405, nrs 5.010 precluded even holding that hearing anyways),
and all those orders seek to transmogrify a traffic citation trial into a Summary Disciplinary SCR 105
Hearing...."wow", indeed.
judge Howard is known for having contempt for defendants before him who went to Reno High
School. this is known. judge howard himself went to Reno High before becoming the first Student
Body President at Hug High, then playing football for a year at UNR. Coughlin has been told by
various people that Judge Howard is especially predisposed to take a draconian approach to a
certain type of defendant who went to Reno High....and so when Coughlin filed a motion on 11/29/11
in 11 cr 22176 citing the Duke Lacrosee rape case as a parallel to pamela roberts, esq.'s approach
in that petty larceny prosecution...well...(About that "failure to appear' on 11/14/12, Judge Howard,
was wrong about that, Coughlin certainly did appear, in "jail reds" and cuffs, as he was in custody
incident to the lies of Dr. Merliss and Hill and the RPD resulting in the criminal trespass arrest and 3
days in jail in 11 cr 26405...the jail brought Coughlin to court on 11/14/12...but didn't bring him into
the courtroom for trial (no one is sayin' why...maybe it was because Coughlin was in "reds" (the type
of jail scrubs one wears indicates some things..."reds" basically means "mental case" or something
and the jail has always put coughlin in "administrative segregation" ...meaning fo th 46 days Coughlin
spent in jail since August 2011 (various stints of about 7, 1, 3, 3, 1, 3, 5, 8, 1, and 18 days each (3 for
"summary contempt" by Judge Howard despite Howard going against his own Bench Book in failing
to grant counsel to Coughlin...even though Aigersinger is mandatory authority and even though
Howard's pre trial order did not expressly preclude the possibility of jail time...it merely indicated that
jail time was not involved in the "standard sentence"...which is not the same thing as saying there
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was "no possibility of jail time" sufficient to preclude the attachment of the Sixth Amendment. and
judge howard.
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http://medboard.nv.gov/newsletters/vol24.htm:
"...And Dr. Timothy D. Coughlin, MD, former President of the Nevada Health Professionals
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Assistance Foundation and instrumental in the Diversion Program, Dr. Coughlin has more than
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fifteen (now twenty-five, but its not a competition) years of experience in identifying, intervening, and
monitoring physicians with chemical dependency, dual diagnosis, and disruptive behaviors. We feel
very fortunate to have him as our new president...." did mention that his son's character, "is bedrock"
at the June 2002 resumption of the C&F Committee Hearing (wherein Coughlin was more
preapproved given his going along with the one attorney (Kelly said "we will give you a list of three
attroney's who will reprresent you pro bono" (Coe Swobe called with one name and one name
only...Peter Christiansen, Jr. (who may have some things to update his admission application about
from his Wyoming days) who, while taking $5K up front and without any fee agreement or other
details as to the scope of representation upon announcing, when first meeting with Coughlin "this
ain't no pro bono deal, man" ) only to then show up at the June 2002 hearing an mislead the
Committee into think his 6 or so page Pre Hearing Brief and "advocacy" that day was done "pro
bono" (and thus partially excusing was what a rather tepid arrangement at best...to say nothing of all
the failing to send this or that to Eichman and the Bar and otherwise dropping every ball possible
along the way between 2002-2005 when finally Christiansen, Sanft, and the de facto attorney on the
case, legal assistant Kelly Huff (and the microtelco fax confirmations prove both they and Eichman
recieved the Reconsideration filing Coughlin prepared and submitted in compliance with Eichmann's
directions, yet, which Eichmann later admitted she unilaterally decided not to forward on to the
Nevada Supreme Court for consideration at the end of the abeyance period incident to that Court's
December 2012 deferral Order )(what do you do when you are 25? not go with the attorney the Bar
calls you up and directs you to?and that "it takes fire to make steel" (being an SEC fullback with
tailback speed on scholarship from Dayton, Ohio for Tulane from 1965-1968, then going straight to
medical school, and doing a residency at Duke has given "Tim" (just kidding, Dad) a sort of gruff
charm all his own) in a hearing before a Spearmint Rhino Strip Club owning Character and Fitness
Committee Member, Kevin Kelly. Esq.. Kelly was then a member, and subsequently Chairman at
points in his decade long run on that Committee, and took Coughlin on a three hour tour of
moralizing in the first February 2002 insufficiently notice "Hearing" (Dean Morgan shows up to
testify, unnoticed to Coughlin, and by the time the change of address got the notice ot Coughlin he
had about 6 days advance notice of the hearing....(at that February 2002 Hearing, then C&F
Committee Chairman Mike Rowe joined in with his aghast horror at the treatment poor 'lil Mark
Tratos was exposed to in "snippy" email between he and Coughlin upon Tratos "losing' Coughlin
term paper in the summer 2001 Cyber Law course, and see attached materials detaling Rowes
subsequently threatening letters to, basically, go along with the Christiansen/Kelly,
uh..."arrangement"...."how much money does your father make? What kind of car do you drive?"
asks Kelly at the February 2002 credit application interview, er, C&F Committee Hearing (and Jon
Bailey, at the informal conference weeks previous thereto made Bryant Gumbel's pretentious style
seem downright folksy in comparision.)(that Coughlin was taking along with and ADR course during
the summer following his second year of law school, during which time he was one of two people
that year to pass the Nevada Bar Examination as a second year law student. Coughlin was tenth in
his class at Boyd, graduatin in December 2001 (didn't go to the graduation ceremony and had to nix
plans for his 88 year old second wave on Omaha Beach D-Day Normandy veteran grandfather
James Theodore Coughlin to attend given Phil Burns, law school dean who didn't go to law school
Christine Smith, and Mary LaFrance/Mark Tratos dragging on an "investigation" into academic
propriety that predictably turned up jack (actually, now Assemblyman William Horne was one of the
students who saw Coughlin turn his paper in that day, along with another couple students signing
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affidavits to that fact, and its ironic, given Mr. Horne and fellow BSL early days alumn Jason Frierson
were, along with Segerblom and WLS's Sasser so instrumental in adding the requirement in NR
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40.253 that the landlord must list the forum to file the tenant's affidavit, especially consdiering the
arrest in rcr2012-067980 and the summary eviction by "eviction consulting and process service"
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company Nevada Court Services in RJC rev2012-001048). Coughlin is also know to have some
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idea of the chances of a shot or argument going in, as well as how to get to the free throw line:
http://www.niaa.com/sports/bkb/2012-13/releases/Basketball-_Boys_(2012).pdf
http://www.nfhs.org/recordbook/SearchResults.aspx?criteria=coughlin
and its a complex rich relationship with Coe Swobe, who is, indeed, as Mr. Silverman says "the grey
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immanence" of that segment of the Bar....and Gary should know, as he himself, as you all know, is
the "Yellow Grandeloquence"....coughlin tries to be the Chartreuse Exuberance, but often must settle
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for being the Burgandy Deliberance. )...Mr. Silverman's assessment of this Panel's approached is
succinty stated in the follow email to Coughlin (which is generously gave his time to write after
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reviewing Coughlin, incorporated by reference into this proceeding 60838 and 61426 filing with the
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N.S. Ct on 8/13/12, in Mr. Silverman writing:

re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
Gary Silverman (silverman@silverman-decaria.com)Add to contacts 8/13/12 To:
Zach Coughlin From:
Gary Silverman (silverman@silverman-decaria.com)
This sender is in your safe list. Sent:
Mon 8/13/12 11:28 AM To: Zach
Coughlin (zachcoughlin@hotmail.com) I think this is waaaaay too complex and
detailed. Give them a procedural history and whether there is a final judgment in the
crim case and point out that your temporary suspension is akin to a permanent
death of your practice. Or, if true, say you....(redacted) now have access to your
meds and are ok. I can't think this pleading is going to help you much...it is too long,
repetitive and does not seem to deal with why the temp suspension is simply wrong
or harsh. If you can't make your case in 3-5 pp, you can't make your case in 35.
You do seem to be a good lawyer, however. At bottom, Steve Harris took
hundreds of thousands of dollars and had no temp suspension; you stole a
candy bar (at worst). WTF. " Stephen R. Harris, Esq. was reinstated to the
practice of law by Order of the Nevada Supreme Court (upon the SBN waiving its
SCR 116 appeal rights by stipulation) on November 8th, 2012.
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As to Coughlin's 6/7/12 temporary suspension ORder, only three justices signed it (one of
whom has recused himself from another case, 60302 or 60317 between Coughlin and Washoe Legal
Services, and Garin's, SBN Ethics Committee Member's REspondent Brief of 10/22/12 will make
Coughlin's arguments regarding service and process and due process deficiciencies herein seem
magnanimous by comparison), one of whom was Chuck's (and Chuck is a dear friend...and a
disclaimer...all this criticism of Judges is coming from one who could never imagine the stress and
burden that being a Judge must entail...it must literally weigh on one like a thousand pounds
everyday...but Coughlin is the son of a Judge Whisperer and only doing that which comes naturally
to him...and he's going to love these Judges through this...because this is where the healing starts,
and we got their bags packed (their spouses were more than willing to help with that, no surprise,
there) and a plane ticket to Biloxi, and the car is runnin' outside, and when they come back, better
than ever, they are going to be just as welcome as the flowers in May...as long as they take this
"come to Jesus" talk to heart and proceed accordingly) very, very close friend..., whose old law clerk
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used to find his way to Thursdays , who had some dealings with noted "Judge Whisperer" Dr.
Timothy D. Coughlin, MD, and who some used to see once in a while on thursday, but not so much
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anymore since he got on with the NNDB...but just be honest with what you are doing what you do
over. Dont say its to help someone when its really to issue a beat down for those with power. Look
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at the Beckett case. Look at Harris's. When you start mixing medicine and mental health into
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disciplinary contexts, the tryants first leverage is "concern" and "treatment". In my time as a
domestic violence attorney (which is by far the best training any young attorney could possibly get,
thanks Paul Elcano and Caryn Sternlicht) Typically the hardest people to win over or please when in
situations like mine are those in recovery. They are extra, extra hard on you, preacher's daughter,
coaches son, theme. And often they are zealots who lack perspective. And Pat King and other bar
counsel's of the past say things that indicate they see me as this young man and how a 5 or 6 year
suspension would really just be a blip in my career in the grand scheme of things. I went an had an
sit down with King for a couple hours a week ago, and generally it was pretty positive, but clearly
King has no intention of moving the process along (he is banking on me signing on to a SCR 117
petition and actually expects me to believe the bar will succeed in having me permanently disbarred
over a candy bar so soon after Steve Harris's deal, which I found out some new salacious details
about, from Pat King, no less...), the suspension was June 7th, 2012, and the Order called for a
formal hearing before the Disciplinary Board, yet no mention of one being scheduled some 2 months
later, I call to schedule one and the say the first available hearing date is 2 months out,....you see
where this is going...its going to be a suspension of over 6 months requiring an Order of the
Supreme Court for reinstatement under SCR 116 as opposed to something like Drakulich got when
he had a DUI hit and run (10 day suspension).
I listen to Chuck, just not exactly to what he says to me about what I should do, I more listen to the
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actions than the words. I learned from watching him 'bout five years agoor whenever it was the the
Temporary Pro's committee thing was all over his case, and he was just battling back at them,
counterpunches. Because there is room in the law for that, and any doctrine that says you have to
confess to show mitigation is just such a perversion of our system of justice...whether this is a
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"privilege with conditions" or not...Cardozo....

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I am not real pleased with Judge William Gardner. I currently have a I just had to write the United
States Patent and Trademark Office a letter reporting my conviction for trespass. This could get
ugly for Judge W. Gardner as well if I have to litigate the crap out of that conviction (reciprocal
discipline rules with the USPTO allow for a showing that, basically, if the proceeding from which the
conviction stems was so wholly devoid of due process, then the USPTO does not have to follow suit
with reciprocal discipline....). I was in the Associated Press about the Wal-Mart candy bar thing on
June 8th, 2012, and still he manages to find me guilty of criminal trespass incident to a civil eviction
proceeding (even where Sferrazza completely departed from the express dictates of NRS 40.253(6)
by ordering me to deposit $2,275 worth of rent escrow into the Justice Court in a summary eviction
proceeding a week before the hearing, then continued to have the RJC hold onto that money for
another 12 days, during which I was supposed to somehow hire movers and rent a moving truck and
move a home office full of property, while also allowing Richard Hill in for an inspection....and
Sferrazza further kept 10 times the amount of money required for a stay on appeal whilst denying the
stay....then Richard Hill gets Sferrazza to sign an Order that transfers the right to that rent escrow
deposit of $2,275 to Hill's client despite the fact that Sferrazza's Order as orally pronounced
indicated the money would remain mine, but retained by the RJC in the meantime as an appeal
bond...and I get suspended for allegedly consuming a candy bar while shopping for an paying for
$83.82 of groceries?). And Judge W. Gardner ruled all of that was irrelevant, while also refusing to
recuse himself despite his providing the RMC and Judge Nash Holmes his sister's Order for
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Sanctions ($1,000 worth of attorney's fees in a divorce case from March 2009 under NRS 7.085),
which, apparently, the RMC promptly provided to Pat King and the State Bar and which is now the
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subject of a formal complaint or grievance against me....and, further, Judge W. Gardner worked for
the Reno City Attorney as a prosecutor as recently as two years ago and there is (hopefully not)
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reason to believe their is "impending litigation" given the extent to which my professional career has
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arguably been ruined by the misconduct of both the Reno City Attorney prosecutors (putting on
testimony they know to be false by both the Wal-Mart associate and the RSIC Police, given the
testimony about Coughlin's not provided a driver's license and that allegation supposedly providing
the rationale or probable cause for effecting a custodial arrest for a misdemeanor occurring outside
the officer's presence...despite the fact that the surveillance video from Wal-Mart's interrogation
room, dispatch reports, and jail intake inventory records, and the officer's own arrest reports (which
the video clearly shows him copying information from Coughlin's driver's license onto) all clearly
establish that the office was provided Coughlin's Nevada driver's license, despite his sworn
testimony to the contrary, and therfore, a Fourth Amendment violating impermissible search
occurred, and the fruit of the poison tree should not be the main basis for innuendo leading to
Coughlin's petty theft conviction of cough drops, particulary where the testimony of both Wal-Mart's
Frontino and RSIC Officer Crawford was expressly disproved with hard evidence (comparing the
receipt of $83.82 worth of groceries purchased with the UPC from the receipt Wal-Mart prepared
containing the UPCs of the allegedly stolen cough melts clearly shows that the UPC of the cough
melts does, in fact, appear on that receipt for $83.82, whereas both of those witnesses testified that it
did not and that Coughlin did not have any such cough melts rung up or paid for).
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Nevada Code of Judicial Conduct Rule2.4.External Influences on Judicial Conduct.
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(A)A judge shall not be swayed by public clamor or fear of criticism.

(B)A judge shall not permit family, social, political, financial, or other interests or
relationships to influence the judges judicial conduct or judgment. (RMC Judges admit to
stragegy sessions vis a vis "adding to your little record, there" to quote a menacing
commentary by Judge Nash Holmes in the conext of her sound byte: "i don't care about
retaliation, I don't care about corruption, I don't care about bribery...all that is relevant is the
Bouldevard Stop...")
(C)A judge shall not convey or permit others to convey the impression that any person or
organization is in a position to influence the judge.
COMMENT
[1]An independent judiciary requires that judges decide cases according to the law and facts,
without regard to whether particular laws or litigants are popular or unpopular with the public, the
media, government officials, or the judges friends or family. Confidence in the judiciary is eroded if
judicial decision making is perceived to be subject to inappropriate outside influences.
Member of the judges family means a spouse, domestic partner, child, grandchild, parent,
grandparent, or other relative or person with whom the judge maintains a close familial relationship.
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See Rules 3.7, 3.8, 3.10, and 3.11.
http://www.leg.state.nv.us/courtrules/scr_cjc.html
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Impending matter is a matter that is imminent or expected to occur in the near future. See Rules
2.9, 2.10, 3.13, and 4.1.
25 Impartial, impartiality, and impartially mean absence of bias or prejudice in favor of, or against,
particular parties or classes of parties, as well as maintenance of an open mind in considering issues
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that may come before a judge. See Canons 1, 2, and 4, and Rules 1.2, 2.2, 2.10, 2.11, 2.13, 3.1,
3.12, 3.13, 4.1, and 4.2.
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Nevada Code of Judicial Conduct Rule2.11.Disqualification.
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personal knowledge of facts that are in dispute in the proceeding.
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(2)The judge knows that the judge, the judges spouse or domestic partner, or a person within
the third degree of relationship to either of them, or the spouse or domestic partner of such a person
is:
(a)a party to the proceeding or an officer, director, general partner, managing member, or
trustee of a party;
(b)acting as a lawyer in the proceeding;
(c)a person who has more than a de minimis interest that could be substantially affected by
the proceeding; or
(d)likely to be a material witness in the proceeding.
(3)The judge knows that he or she, individually or as a fiduciary, or the judges spouse,
domestic partner, parent, or child, or any other member of the judges family residing in the judges
household, has an economic interest in the subject matter in controversy or in a party to the
proceeding.
(4)[Reserved.]
(5)The judge, while a judge or a judicial candidate, has made a public statement, other than in a
court proceeding, judicial decision, or opinion, that commits or appears to commit the judge to reach
a particular result or rule in a particular way in the proceeding or controversy.
(6)The judge:
(a)served as a lawyer in the matter in controversy or was associated with a lawyer who
participated substantially as a lawyer in the matter during such association;
(b)served in governmental employment and in such capacity participated personally and
substantially as a lawyer or public official concerning the proceeding, or has publicly expressed in
such capacity an opinion concerning the merits of the particular matter in controversy;
(c)was a material witness concerning the matter; or
(d)previously presided as a judge over the matter in another court.
(B)A judge shall keep informed about the judges personal and fiduciary economic interests and
make a reasonable effort to keep informed about the personal economic interests of the judges
spouse or domestic partner and minor children residing in the judges household.
(C)A judge subject to disqualification under this Rule, other than for bias or prejudice under
paragraph (A)(1), may disclose on the record the basis of the judges disqualification and may ask
the parties and their lawyers to consider, outside the presence of the judge and court staff, court
officials and others subject to the judges direction and control, whether to waive disqualification. If,
following the disclosure, the parties and lawyers agree, without participation by the judge or court
staff, court officials and others subject to the judges direction and control, that the judge should not
be disqualified, the judge may participate in the proceeding. The agreement shall be incorporated
into the record of the proceeding.
COMMENT
[1]Under this Rule, a judge is disqualified whenever the judges impartiality might reasonably be
questioned, regardless of whether any of the specific provisions of paragraphs (A)(1) through (6)
apply. For example, if a judge were in the process of negotiating for employment with a law firm, the
judge would be disqualified from any matters in which that law firm appeared, unless the
disqualification was waived by the parties after disclosure by the judge.
[2]A judges obligation not to hear or decide matters in which disqualification is required applies
regardless of whether a motion to disqualify is filed.
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[3]The rule of necessity may override the rule of disqualification. For example, a judge might be
required to participate in judicial review of a judicial salary statute, or might be the only judge
available in a matter requiring immediate judicial action, such as a hearing on probable cause or a
temporary restraining order. In matters that require immediate action, the judge must disclose on the
record the basis for possible disqualification and make reasonable efforts to transfer the matter to
another judge as soon as practicable.
[4]The fact that a lawyer in a proceeding is affiliated with a law firm with which a relative of the
judge is affiliated does not itself disqualify the judge. If, however, the judges impartiality might
reasonably be questioned under paragraph (A), or the relative is known by the judge to have an
interest in the law firm that could be substantially affected by the proceeding under paragraph (A)(2)
(c), the judges disqualification is required.
[4A]The filing of a judicial discipline complaint during the pendency of a matter does not of itself
require disqualification of the judge from presiding over the litigation. The judges decision to recuse
in such circumstances must be resolved on a case-by-case basis.
[5]A judge should disclose on the record information that the judge believes the parties or their
lawyers might reasonably consider relevant to a possible motion for disqualification, even if the judge
believes there is no basis for disqualification. A judge making such a disclosure should, where
practicable, follow the procedure set forth in Rule 2.11(C).
[6]Economic interest, as set forth in the Terminology section, means ownership of more than a
de minimis legal or equitable interest. Except for situations in which a judge participates in the
management of such a legal or equitable interest, or the interest could be substantially affected by
the outcome of a proceeding before a judge, it does not include:
(1)an interest in the individual holdings within a mutual or common investment fund;
(2)an interest in securities held by an educational, religious, charitable, fraternal, or civic
organization in which the judge or the judges spouse, domestic partner, parent, or child serves as a
director, officer, advisor, or other participant;
(3)a deposit in a financial institution or deposits or proprietary interests the judge may
maintain as a member of a mutual savings association or credit union, or similar proprietary
interests; or
(4)an interest in the issuer of government securities held by the judge.
Nevada Code of Judicial Conduct Rule3.10.Practice of Law.Unless otherwise permitted by

law, a judge shall not practice law. A judge may act pro se and may, without compensation, give
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legal advice to and draft or review documents for a member of the judges family but is prohibited
from serving as the family members lawyer in any forum.
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[1]A judge may act pro se in all legal matters, including matters involving litigation and matters
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involving appearances before or other dealings with governmental bodies. A judge must not use the
prestige of office to advance the judges personal or family interests. See Rule 1.3.
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Rule1.3.Avoiding Abuse of the Prestige of Judicial Office.A judge shall not abuse the prestige
of judicial office to advance the personal or economic interests of the judge or others, or allow
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others to do so.
COMMENT
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[1]It is improper for a judge to use or attempt to use his or her position to gain personal
advantage or deferential treatment of any kind. For example, it would be improper for a judge to
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allude to his or her judicial status to gain favorable treatment in encounters with traffic officials.
Similarly, a judge must not use judicial letterhead to gain an advantage in conducting his or her
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personal business.
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[2]A judge may provide a reference or recommendation for an individual based upon the judges
personal knowledge. The judge may use official letterhead if the judge indicates that the reference is
personal and if there is no likelihood that the use of the letterhead would reasonably be perceived as
an attempt to exert pressure by reason of the judicial office.
[3]Judges may participate in the process of judicial selection by cooperating with appointing
authorities and screening committees, and by responding to inquiries from such entities concerning
the professional qualifications of a person being considered for judicial office or by submitting on
official letterhead letters to such entities endorsing or opposing the person.
[4]Special considerations arise when judges write or contribute to publications of for-profit
entities, whether related or unrelated to the law. A judge should not permit anyone associated with
the publication of such materials to exploit the judges office in a manner that violates this Rule or
other applicable law. In contracts for publication of a judges writing, the judge should retain sufficient
control over the advertising to avoid such exploitation."
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Showing out for one's sister is arguably "advancing the personal or economic interests of the
judge or others" in violation of NCJCR 1.3. And some might, for similar reasons (especially in light of
the 2011 scandal wherein the Reno Muncipal Court attributed some $700K that went missin' to "data
entry errors" and stuff) that Judge Nash Holmes put Coughlin on blast with her 2/28/12 Contempt
Order and Issuance of Sanctiosn in 11 TR 26800 (and somehow, despite it not being within 10 days,
and therefore outside her jurisdiction to alter or amend the civil contempt finding that Judge Nash
HOlmes base her 2/28/12 order on (NRS 22.100 is a civil statute, ie, its not the criminal contempt
misdemeanor that Judge Nash Holmes remixed it to be a la NRS 199.340: (NRS 199.340 Criminal
contempt. Every person who shall commit a contempt of court of any one of the following kinds shall
be guilty of a misdemeanor: 1. Disorderly, contemptuous or insolent behavior committed during the
sitting of the court, in its immediate view and presence, and directly tending to interrupt its
proceedings or to impair the respect due to its authority; 2. Behavior of like character in the presence
of a referee, while actually engaged in a trial or hearing pursuant to an order of court, or in the
presence of a jury while actually sitting in the trial of a cause or upon an inquest or other proceeding
authorized by law; 3. Breach of the peace, noise or other disturbance directly tending to interrupt the
proceedings of a court, jury or referee; 4. Willful disobedience to the lawful process or mandate of a
court; 5. Resistance, willfully offered, to its lawful process or mandate; 6. Contumacious and unlawful
refusal to be sworn as a witness or, after being sworn, to answer any legal and proper interrogatory;
7. Publication of a false or grossly inaccurate report of its proceedings; or 8. Assuming to be an
attorney or officer of a court or acting as such without authority.)
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Uh...no on the ghostwriting gessin allegations. as to the richard g. hills unsigned, unsworn
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grievance, need more clarification as to the variosu allegatiosn hill makes, until then, a blanket
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denial. blanket denial of all allegations against coughlin in any way pled in King's SCr 105 complain
at issue here.
correct to Coguhlin's Deisgnation of Wtiness...it was error to whatever extent any suggstion was
made that coughlin fails to oppose judge nash holmes, or anyone testiying by phone, period.
absolutely not agreeing to that.
Both Judge W. and Judge L. Gardner should be required to testify, along with Judge Nash Holmes
as to what letterhead was used, the passing of the April 2009 Order sanctioning Coughlin from
Judge L. to her brother, Judge W. Gardner, and his passing that Order to "the other RMC Judges",
which Judge W. Gardner appears to have admitted to having done, on the record, during the 4/10/12
Hearing in the trespass matter 11 CR 26406, as the RMC's Administrative Judge, to the other RMC
Judges (including Judge Howard, who had Coughlin's 11 CR 22176 before him then, and Judge
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Nash Holmes, who had Coughlin's 11 TR 26800 before her, and whom was transferred from D1, by
Judge W. Gardner, Coughlin's 12 CR 00696 on 2/27/12 (very curious date and timing for such a
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transfer given all the other things that occured on 2/27/12 with Coughlin's Appeal in the Judge Elliot
case involving Washoe Legal Services (CV11-01955), more eflex rejections thereof by Lori Matheus,
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(there is just a lof of Judges whom are former prosecutors seemingly issuing a beat down of
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Coughlin here, in part on behalf of Washoe Legal Services and Paul Elcano (whom holds himself out
as a close personal friend of Judge L. Gardner, District Attorney Gammick (Elcano announced this in
anticipation of WLS being awarded the ECR Program contract, which arguably violates the Sixth
Amendment...basically, Washoe Legal Services is an entity that holds itself out as one thing...but
there sure are a lot of prosecutors and former prosecutors working that marionette's strings). (RMC
Judge W. Garder is the brother of the Judge Linda Gardner who was apparently extremely upset that
Coughlin not only didn't came to her and Springgate's coercive "settle or else" onslaught minutes
before the Trial on April 12, 2009 (Judge L. Gardner, during an impromptu Settlement Conference
angrily hissed at Coughlin's client, Bharti Joshi "don't listen to your attorney!", and, with Joshi by his
side, snapped at Coughlin "shut up!", the proceeding to say she was offering Coughlin suggestions
on how to try his case in the Trial, only to explode in rage at Coughlin when he thanked her for his
suggestions but indicated he needed to try the case in a manner that aligned with zealously
adovcating for his client's interests, and not with an overly weighted concern for Mr. Springgate's
profit margin or the Court's intentions regarding the doling out of its judicial resources. Coughlin
filed the Mandamus Petition against her in 54844 (containing inflammatory material related to the
coercive practices with with Judge L. Gardner sought to extract an agreement to John Springgate,
Esq's illusory settlement proposal (Springgate's proposal was not fraudulent or anything, but it is not
accurate or fair to suggest that Coughlin was being vexatious to meet the NRS 7.085 standard that
the Legislature created with med mal cases in mind (if they only could have imagined the perverted
applications to which it is put these days...basically there is a lot of gang bangin' people out of their
due process goin' on these days under the rubric of some feigned cry of "vexatiousness!". Please.
Further, it is beyond supportable the extent to which Judge Howard, Nash, and Gardner make
rulings on relevancy based upon an impermissible goal, to quote Keith Loomis, Esq. (RMC court
appointed defender, whose "work" in the jails must be seen to be believed (Loomis does nothing that
a laminated poster couldn't do, sort of like a "hey, here are your Workplace Rights" laminated deal in
the breakroom...well actually, Loomis does not even do that much, he actively and aggresively sets
the table for the prosecutor's from the Reno City Attorney's Office. They have a real routine goin'
down there. Further, then Master Linda Gardner was apparently rather upset that Coughlin pointed
out that she seemed to be overstepping her jurisdiction a bit, outside of that accord her in NRS
33.018 in a TPO wherein another local attorney, Richard Molezzo, Esq. line up opposite Coughlin, in
FV08-03380 - BRENDA SANTIAGO VS XRHSTOS VAXEVANIS Filing Date: Tuesday , September
09th, 2008) 30-OCT-2008 04:47 PM Obj to Master's Recommendation Entry: APPLICANT'S
OBJECTION TO MASTER'S RECOMMENDATIONS 08-JAN-2009 11:46 AM Application for Setting
Entry: Obj. to Master's Rec re TPO; 2/23/09 @ 9:00 am 23-FEB-2009 09:39 AM Heard ... Entry:
MASTER'S RECOMMENDATION AFFIRMED. nm/cd 23-FEB-2009 09:41 AM ***Minutes Entry:
2/23/09 OBJECTION HEARING - Transaction 611628 - Approved By: NOREVIEW : 02-232009:09:41:22 24-FEB-2009 01:29 PM Ord After Hearing... Entry: DENYING OBJECTION TO
MASTER'S RECOMMENDATION. The February 23rd, 2009 Hearing on the Objection to Master
Gardner's Recommendations that Coughlin filed (relating to Master Gardner giving a car and or that
car's title to the individual Coughlin's client sought protection from, despite their apparently having a
shared interest therein, and there being a legitimate dispute as to the documentation, and the fact
that a TPO Hearing is not the appropriate setting for such subject matter, especially where Master
Gardner lacked jurisdiction to rule as she did. Perhaps Coughlin's firing from WLS in 60302 is why
WLS"s landlord tenant attorney Mark Ashley, Esq. regularly refuses to advocate with any zeal on
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behalf of this tenant client's, as Coughlin observed on March 15th, 2012 when Coughlin appeared to
content the eviction brought against him in (again, in another No Cause Eviction against Coughlin
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where he was arguably a commercial tenant and the Notice served was a No Cause Eviction Notice
only, though there is some indication, at least from a docket entry in that matter RJC rev2012-
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000374, that Gayle Kern, Esq. and or Sue King (unauthorized practitioner of law property manager
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for Western Nevada Management, Inc.) responded fraudulently to Coughlin's Pre-Hearing Brief in
that matter that pointed out the difficulties ahead for their client, Park Terrace Town Home's HOA in
light of various problems with the Notice and matters pled by PTTHOA (basically, the Notice was No
Cause and non-payment was not alleged (until, perhaps the day of the Hearing, a review of the
Landlord's Affidavit is necessary, as is the proof of service thereof, and the proof of service of Judge
Schroeder's Orders in that matter and an inquiry into why the RJC failed to file Coughlin's Notice of
Appeal thereof on March 16th, 2012 (the implication is that Gayle Kern and, some might say, the
RJC went out of their way to avoid a repeat of the Merliss v Couglhin eviction case involving Richard
Hill and Casey Baker (RJC Rev2011-001708). When Coughlin appeared for the summary eviction
proceeding in the RJC on March 15th, 2012 his case was already decided against him on a default
basis, despite the fact that the Hearing was to start at 8:30 am, and the fax sheet of the Eviction
Order signed by Judge Schroeder indicates a time of 8:24 am. Nonetheless, Coughlin sat around in
court to observe Ashley's advocacy (Coughlin was able to listen to Ashley and his Paralegal,
Christine Saito, conduct business as the Landlord Tenant attorney and paralegal at Washoe Legal
Services for 18 months, having offices within whispering distance of each other, from September
2007 to Coughlin's firing by WLS Executive Director Elcano in May 2009 (See Elcano's attached
letters detailing that the firing was solely predicated upon Judge L. Gardner's April 2009 Order
sanctioning Coughlin in the Joshi divorce matter DV08-01168 (that spawned the Mandamus Petition
by Coughlin against Judge L. Gardner 54844). Judge L. Gardner recused herself from the next case
she had Coughlin appearing on assigned to her, Bell v Greer, FV11-04268...which arguably
presented the same basis for her brother to recuse himself inthe criminal trespass prosecution of
Coughlin. attached my Emergency Ex Parte Motion (perhaps not "ex parte" given Bar Counsel was
provided it). Also, please note, the October 9th, 2012 certificate of mailing by the SBN for the Notice
of Intent to Take Default was never served on me in any way shape or form until I received the copy
of the "entire" file form Sierra Legal Duplicating. The State Bar of Nevada knows this. They put the
wrong postage on the certified mail envelope containing the Notice of Intent to Take Default. When I
went to pick it up "Tim" USPS counter attendant at the Vassar Postal Station here in downtown Reno
refused to allow me to pick up that certified mailing given that is was about $5.00 deficient in
postage. I did not have $5.00 and it is not be responsibility to pay it, as far as I know. In fact, I have
asked the Bar and this Panel to allow me to proceed in forma pauperis in this matter, and am doing
so again here (I am flat broke, I have a 1996 Honda Accord, rent a room for $300 a month, have less
than $200 in my bank account, no stocks, no bonds).
Also King is attemptign to do something really weasely here (nothing new for King) in backtrackign
on what he told Coughlin Bar Counsel Clark had given Coughlin authority to do (ie, issue subpoenas
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despite being a suspended attorney...King is now trying to argue some necessarily ultra redundant
interpreation fo that wherein he was merely relaying a message from Clark that, yes, Coughlin had
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authority to have SBN Clerk of Court Peters (whom King constantly plays marionette master to,
despite whatever he says when the lights are on that conduct) issue supboenas which Coguhlin
25 could then have served (and Peters told Coughlin he didn't have to pay witness or subpoena fees,
and in fact, that now Respondents do in these matters.
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I have been mislead or lied to by the SBN in numerous ways in this proceeding. I was told I could issue subpoenas despite
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being a suspended attorney (and there is case law that says even when suspended, one is still an "attorney"). I was told I
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would not be required to pay subpoena fees. I was told the August 23rd, 2012 certified mailing would absolutely not be
used to prove proof of service of the Complaint in this matter, SBN v. Coughlin. Yet a review of the files reveals that the
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SBN and Panels only Return of Service (and see SBN Ethics Committee Member Joseph Garin's recent Brief in 60302
seeking to dismiss my entire wrongful termination lawsuit against Washoe Legal Services) for a real ironic example of
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just why the hearing on November 14th, 2012 must not go forward. It is fraudulent for the State Bar of Nevada to stipulate
with me that the August 23rrd, 2012 certified mailing of the Complaint is alleges was sent and that Clerk of Court Peters
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admits to having received back on September 10th, 2012 would never be cited to as effecting service of the Complaint
upon me or otherwise put forward as proof of return of service etc. Now the SBN seeks to get around the inconvenient
5 fact that, instead of holding my hearing on September 25th, 2012 (Clerk Peters told me it was on the calendar, I was
noticed of it in writing, I agreed to that date for the Hearing amongst a choice of dates, etc..) Bar Counsel King attempted
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to shove a document he alleges was the Complaint in my suit jacket, then persisted in ordering Clerk of Court Peters
(whom King alternately claims to have separation from and no authority over with ordering her not to file my Motion to
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Dismiss, attempting to reneg on stipluations and representations made by the SBN, etc). Further, it is wrong for Clerk of
Court Peters to be signing the certificates of mailing for both the SBN and for the Panel Chair. Additionally, under SCR
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105(2)(c), it is the Panel that must send the Respondent the Notice of Hearing "at least 30 days" prior to the Hearing date,
and that Notice must include with it the Designation of Witnesses and Summary of Evidence, and it must be served in the
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same manner as the Complaint. It is impermissible for Pat King to attempt to mail out the Notice of the Hearing and
Designation of Witnesses weeks before the Panel is even announced (how can you possibly be pretending to take your
10 duty as a Panel member seriously when you are essentially showing up the day of the first game, skipping all the practices
and pre-season games....we all saw how that turned out for Bret Farve in his last season. It is appalling to me that you
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intend to hold this hearing given these blatant violations of SCR 105(2)(c), but when you add to that the fraudulent
conduct of Pat King, in failing to amend his and or Clerk of Court Peters certificate of mailiing or return of service for the
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purported certified mailing (and, contrary to the SBN's established practice detailed in the certificates of mailing I have
review upon finally being granted a copy of the "file", though, the rule says I get to go to the SBN's offices and review
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certain things "up to three days"...not have Pat King and Laura Peters manufacture some nonsense about why I am not
allowed at the building or otherwise violating my rights (which is something King and Peters do everytime they get
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caught violating the rules.) Further, I have been (and some might say this was largely by design) jammed into having this
Disciplinary Hearing on November 14th, 2012 in impermissible proximity to the petty larceny trial in rcr2011-063341
15 (see Montiero for why it is not even appropriate for King to be seeking to force me to prejudice my defense in that matter)
on November 19th, 2012, in Department 2, before Judge Sferrazza, whom presided over the summary eviction/unlawful
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detainer "Trial" from my former home law office that the criminal trespass arrest, jaywalking arrest (King's Complaint
doesn't manage to specify that the January 12th, 2012 arrest was for jaywalking outside my former home law office
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shortly after my collecting video evidence revealed the fraud attendant to Hill's contractor havig used my own plywood to
board up the back porch of the property....Hill, also, at that time, went and got a TPO that was based largely upon an
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outright lie, ie, that I "climbed up on" the contractor Phil Stewart's truck). I believe this Panel should review (I cannot
affor the $35 to $70 for the video of the two hearings on Hill's Motion for Order to Show Cause of January 20th, 2012 (the
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Order to Show Cause was served by RMC Marsm hal Harley, despite what WCSO Deputy Machen said he personally
served in his affidavit (Machen also lied about personally serving the eviction lockout order for HIll, and HIll lied at the
20 trespass trial when he testified that Machen "posted it on the door becaues you ran away", Hill also lied at trial when he
alleged the Reno PD announced themselves as law enforcement and issued a lawful order to emerge form the basement
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prior to the landlord kicking in the door, and Hill also lied about whether anyone that day warned Coughlin to leave the
property prior to Hill's signing the criminal complaint to affect a custodial arrest for criminal trespass).
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Additionally. I moved recently, and updated my SCR 79 address in compliance with that Supreme Court Rule well within
the 30 days of my moving. Further, I filed an official Change of Address with the USPS, and that caused delays in
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receiving my mail incident to the typical forwarding procedures of the USPS, and I have the yellow stickers on the
envelopes to prove it. Further, besides submitting an official Change of Address form to the Vassar Station on October
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5th, 2012, Coughlin wrote the SBN on October 14th, 2012, and provided his new 1471 E. 9th St. mailing and physical
address, in addition to updating the online portal and the NV CLE Board even prior to that, all in compliance with SCR
25 79.
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I do not consent to service or notice of anything electronically in this proceeding, but I do appreciate
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being copied on such things via email and fax)
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Bar Counsel Patrick O. King has clearly become very intimidated by the Panel, and especially it's
Chair, John Echeverria, indicating a real withering desire for proceeding with this case but helpless in
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the face of a command from higher up, and arguably outside of the permissible authority or exertion
of influence of those from which it emanates. King has been especially critical of the NNDB and
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Panel for its actions in connection with the recent reinstatement of Stephen R. Harris, Esq.,
(reinstated to the practice of law on November 8th, 2012) as has Gary Silverman, Esq.:
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intersting that the SBN and the Panel seek to plung headlong into the 11/14/12 hearing that violates
absoltuely every section of NR 105(2)(c) (one of the very, very few provisions of the Supreme Court
Rules speaking to the due process requirements of these disciplinary hearings (which some
watching Coughlin circa 2002-2005 might say often devolve into kangaroo courts where some
corrupt bully (some might say Strip Club Spearmint Rhino owner Kevin Kelly, Esq., decade long
member of the State Bar of Nevada's Character and Fitness Committee, whose club allegedly
funnels $10 million a year ot Vegas cabbies to direct tourists to its doors..Coe Swobe making' calls
there too, just like in 60302 where he is calling Coughlin and his father seeking to do WLS's and
Elcano's bidding) who chips off his friends (Peter Christiansen, Jr. Esq.) despite saying the
respresentations would be pro bono (despite receiving $5,000, Christiansen still, on the record,
for him to file a six page, rather repid arrangment worth of a Pre Hearing Brief (containing
dog and pony s how hearing (wherein, his friends having been paid, C&F Committee Strip Club
crime, based largely on some retatliation that Mark Tratos, Esq. largely admitted to, along with Mary
Lafrance (don't recall Jessica Wolf, Esq. (one of two students name in an email about missig papers
in that summer 2001 cyber law class, and Anderson and Morishita indicate, as past patent attorney
in Tratos's firm, that Tratos had "lost" other students papers before too..something tratos had to
admit under oath in 2007) send me "another" copy of you paper..."what was it about" the "name of
the case involved" (gee Tratos, kind of sounds like you had the version Coughlin submitted with only
his social security number (in compliance with the Boyd School of Law's blind grading policy, which
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000224
Judge W. Gardner made some extremely curious statements during the proceedings in the criminal
2
trespass case. Included amongst these was a statement that he "could not remember" or "was not
sure" if he ever saw or was aware of the formal complaint filed by the RMC and or RMC Judge Nash
3
Holmes against Coughlin with the State Bar of Nevada and whether or not that submission to the
State Bar included a copy of the April 2009 Order by Judge W. Gardner's sister, Family Court Judge
L. Gardner, sanctioning Coughlin $1,000 for "vexatious conduct" incident to Coughlin representing a
5 domestic violence victim on behalf of a legal aid organization (in Nevada Supreme Court case
number 54844, Coughlin v. District Court) wherein Coughlin was actually arguing a position that is
6
clearly the majority viewpoint throughout American jurisprudence:
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
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Then Judge W. Gardner indicated, on the record, while insisting upon proceeding with Coughlin's
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criminal trespass trial, despite Gardner's fellow RMC Judge Nash Holmes filing a complaint with the
State Bar of Nevada seeking to have Coughlin declared incompetent or disabled and, therefore,
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unable to practice law, that various Order by RMC Judge Nash Holmes and other materials which
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Judge W. Gardner admitted to reviewing and or being aware of did not bring into question Coughlin's
competency. Further, Gardner's Order of Conviction finding Coughlin guilty of criminal trespass, as
announced in open court in RMC 11 CR 26405, as announced from the bench on June 18th, 2012,
indicated it rested upon clearly inappropriate or irrelevant facts or matters not in evidence (Gardner
supported his Order by referring to emails allegedly from the landlord's attorney that were not
introduced into evidence, supposedly providing the warning necessary for a trespass conviction
under RMC 8.10.010, despite testimony that Coughlin was repeatedly issued written warnings to the
landlord's counsel that Coughlin did not agree to accepting service or notice of anything incident to
the summary eviction proceeding via electronic means. This contrasts sharply with Judge Gardners
ruling that he would not consider Coughlin's argument that the Reno Justice Court, in the summary
eviction proceeding in RJC REV2011-001708 was actually divested of jurisdiction by Coughlin filing
a Notice of Appeal following an initial hearing (see attached NRCP 60(b) Motion to Set Aside
Eviction Order) or deem an evidence thereof to have been put into evidence despite Coughlin 's
seeking to do so and despite Coughlin's court appointed Counsel, Keith Loomis, prior to his
withdrawal, arguing in court at a preliminary hearing, that such a divesting of jurisdiction did in fact
vitiate the import of any such Order of Summary Eviction. Mack-Manley v. Manley, 122 Nev. 849
(2006), Sarpy v. de la Houssaye, 217 So.2d 783 (1969).
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Now, consider all that in conjunction with Coughlin spending 18 days in jail from July 3, 2012 to July
21st 2012 incident to a non-noticed bail hearing wherein Judge W. Gardner raised Coughlin's bail for
an arrest for disturbing the peace, proof of car insurance, and failure to secure a load on one's
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vehicle (proof of insurance was provided via a pdf on a Coughlin's smart phone to the arresting
officer, and the disturbing the peace charges relates to conduct allegedly occurring outside the
22
officer's presence, and where that conduct is misdemeanor, Nevada law prohibits a custodial arrest
23
being made...so the Reno Police Department is left justifying the decision to make a custodial arrest
based upon a traffic citation carrying a $175 fine (failure to secure a load on one's vehicle)
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Just sayin'. Someone starts effing with my USPTO license, that's federal, what am I supposed to do,
not question the adequacy of the due process provided in the proceeding leading to my convictions
and therefore suspension of my law license and damage to my professional reputation? 37 CRF
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11.25(3)(a) and 11.25(3)(c) call for me to do just that.
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000225
1
Dated this November 12th 2012:
2
__________________________
Zachary Barker Coughlin, Esq. (Nevada law license temporarily suspended, USPTO license in tact,
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and given permission to issue subpoenas by SBN Chief Bar Counsel David Clark, Esq. and firing up
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that whole 11.25(b)(3) engine)
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000226
proof of service/certificate of mailing
i zach coughlin placed this 11 12 12 Emergency Ex Parte Motion to Dismiss or Quash or Otherwise
Challenge Sufficiency of Service and of Process, of Complaint and Notice of Intent to Take Default
and DoWSoE; and Preserving for Appeal Objection to All other Due Process Violations; and
10
UNDER PROTEST...RESPONSE TO COMPLAINT in the mail with postage, and or transmitted a
digital copy to all of those who have either expressly or implicitly agreed to service via digital
transmission (plus Pat "Salieri" King told me the SBN takes anything I file and provides a stamped
copy to all 5 member of the Panel immediately and that I could rely on that), in the mail for pickup...
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dated november 12th, 2012.
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____________
zach coughlin
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respondent
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000227
1
index to exhibits:
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1. exhibit 1: various relevant materials (also see the audio fo all the hearings Coughlin has previously provide on cd/dvd
and via electronic digitally verifiable transmission, especially the RMC cases and teh April 2009 Joshi Trail from which
3
ng12-0435 stems). 3,088 pages (3,088 pages, and pat king has been sending his exhbiit in illegible blurry form, printed on
both sides of the paper)
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000228
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000235
5
6
ZACH COUGHLIN,
PETITIONER
Nov 14 2012 11:53 a.m.
IN THE NEVADA SUPREME COURT Tracie K. Lindeman
V.
NNDB, STATE BAR OF NEVADA,

PRESIDENT OF STATE BAR FLAHERTY.
10 RESPONDENT
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PETITION FOR WRIT OF MANDAMUS

AND TRO ORDERING PANEL AND BAR
TO SUSPEND 11/14/12 HEARING UNTIL
DUE PROCESS REQUIREMENTS,
NOTICE, SERVICE SCR 105(2)(C) ARE
ANYWHERE NEAR COMPLIED WITH
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.
PETITION FOR WRIT OF MANDAMUS AND TRO ORDERING PANEL AND BAR TO
SUSPEND 11/14/12 HEARING UNTIL DUE PROCESS REQUIREMENTS, NOTICE, SERVICE
SCR 105(2)(C) ARE ANYWHERE NEAR COMPLIED WITH
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Gary Silverman, Esq. email to Coughlin 8/13/12: "You do seem to be a good lawyer, however.
At bottom, Steve Harris took hundreds of thousands of dollars and had no temp suspension;
you stole a candy bar (at worst). WTF. "
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(disclaimer, some of this has been dicated to a transcription software and not proofread
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nearly enough...but that is by design, as clearly King and the Panel wish to run this unbifurcated
Hearing along at warp speed considering all the departures from SCR 105(2)(c) and other attendnat
due process deprivations designed to make Coughlin's work product here as rushed an unnoticed as
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possible) Zach Coughlin representing himself submits the above titled filing on his own behalf.
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I, Zachary B. Coughlin, do hereby declara, pursuant to nrs 53.045, under penalty of perjury, that the
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following is true to the best of my knowledge, for which i have percipient recollections of, except for
those matters which are stated upon information and belief:
Pat King informed Coughlin in a telephone discussion on Friday, November 9th, 2012 that it
is the standard practice, done in every disciplinary case, for the Bar to send out the DowSoe, prior to
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ti empaneling of the Panel, in violation of SCR 105(2)(c) (further Coughlin disputes the legal
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000236
1
contention hill makes that SCR 106 somehow insulates anyone with the Panel or Bar from having to
answer a subpoena or submit to sworn questioning...that rule speaks to suing such people, not
2
eliciting testimony or discoverable materials), however (and Laub allows for citing to such things) the
recent Disciplinary matter involving Stephen R. Harris, Esq. reveals that King's contention vis a vis
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the order of the empaneling of the Panel and the filing by the Bar of its Designation of Witnesses
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and Summary of Evidence are, as is King's wont and established practice, quite wrong, to the point
of being fraudulent and seeking to exercise some impermissible control over the Panel, and to steal
Coughlin's due process from him like a rat stealing some cheese. King apparently has to operate
that way because he is completely unaware of how to use a computer (admitting that he thinks
emails are sent from "the Bar's web site" rather than from, say, the account associated with an email
address), is a terrible hunt and peck typist, totally eschews legal research or citation to authority,
cannot manage to throw together an Index to Exhibits in his filings, and otherwise operate in a totally
fraudulent, back room, old boys club way, having his buddy Dan Wong from back in their days at the
AG's Office testify (so designated in the due process raping DowSoE) rather than City Attorney
Allison Ormaas, Esq. regarding 11 TR 26800, the Richard G. Hill, Esq. traffic citation matter wherein
Judge Nash Holmes cooked up a stew comprised of all different types of contempt statutes
(summary, plenary, civil, contempt, misdemeanor, etc....choosing the bits and pieces of each that
provided the least due process to Coughlin, whilst enabling Judge Nash Holmes to achieve her
pretextual goals as expeditiously as possible and with as little requirement that she back up her
ruling with any actual facts, Affidavits, evidence, due process, or specificity) (well, both Ormaas and
Wong indicated to Coughlin that she would not notate in any way or follow up in any way on
Coughlin's reporting to them both the admissions made by RPD Officer Chris Carter, Jr. to Coughlin
incident to Coughlin's custodial arrest upon Richard G. Hill, Esq. signing a criminal complaint for
criminal trespass at Coughlin's former home law office incident to an impermissible summary eviction
proceeding only on a No Cause Basis where the non-payment of rent was neither pled nor noticed.
the in that, in that matter (57507) Harris (whom admitted to misappropriating $750,000 from clients
and whom, as noted in an email to Coughlin, upon Silverman demonstrating the giving back to the
profession that he is known for in reviewing and offering constructive criticism of Coughlin's August
13th, 2012 filing in 61426 and 60838 (which the Bar still has not managed to respond to) by one of
the most respected attorneys in the state, Gary Silverman, Esq., that
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"This disciplinary action was commenced on July 7, 2010. I ROA 1. The
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Complaint alleged that attorney Stephen R. Harris violated two ethical rules. I ROA
3:22-24. Harris answered the Complaint on July 29, 2010. I ROA 12. Harris, who had
self-reported to Bar counsel eight months earlier, admitted each of the allegations in the
Complaint, and provided a statement in mitigation. I ROA 12-13; Exh. 1, pp. 12-13.
The case was assigned to a panel of the Northern Nevada Disciplinary Board on
October 1, 2010. I ROA 19; Exh. 1, p.130. The Bar filed its Designation of Witnesses
and Summary of Evidence on October 7, 2010. I ROA 23-24; Exh. 1, pp. 133-34. The
Bar filed its Trial Brief on November 1, 2010. I ROA 27-36; Exh. 1, pp. 17-27. Harris
filed his Prehearing Brief on November 3, 2010. I ROA 38-50; Exh. 1, pp. 28-41. An
evidentiary hearing was held on November 9, 2010. II ROA, Tr., p. 5. Harris
acknowledged that his actions violated Nevada Rule of Professional Conduct (NRPC)
1.15 (safekeeping property) and NRPC 8.4(c) (misconduct; engaging in conduct
involving dishonesty, fraud, deceit or misrepresentation), so the Panel's primary task
was to determine the appropriate discipline to be imposed, based on the aggravating and
mitigating circumstances. I ROA 28; Exh. 1, p. 18; Tr. 132:17-133:1."
So, this hearing can no way go forward on 11/14/12. If it does, this Panel will look AWFUL.
First off...I have been trying to take Pat King up on his "come down to the Bar's Office and inspect
000237
1
the materials" thing since March 2012. Pat either storms off with his box of materials (takes his ball
and goes home) or sends me the cd's finally (after I had already spent money I needed for other
2
things giving the RMC $35 per audio of a hearing), but refuses to give me the other stuff (like, how
did the April 2009 Order of L. Gardner materialize at the SBN? Then, the Order of 10/30/12 comes
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out, and
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-Check out the attached USPS "Track & Confirm" for the certified mailing of the NOtice
of Hearing (and the certificate of mailing on that document does not indicate that it includes
the DowSoE, and the DowSoe is not date stamped in the "file" I got in a big box from Sierra
Document Management mentioned as the "copy of the file" (sounds like their was some ex
parte back and forth over how to deal with Coughlin and not wanting him at the SBN Office,
plus Panel Chair Echeverria's Office or the Echeverria Group is about 200 feet from the SBN's
Double R Blvd Office, and SBN Clerk of Court Peters is signing Chair Echeverria's Certificat e
of Mailings?....The only thing Chair Echeverria has ruled in Coughlins "favor" on so far has
actually had the effect of limimting Coughlin's rights under SCR 105(3)(c) to "inspect the file"
at the SBN's office "up to 3 days prior to" the 11/14/12 Hearing (and given that the SBN is
closed on Monday, November 12th, 2012...but anyways, Pat King has repeatedly refused to
allow Coughlin to inspect the file at the SBN before and since 10/31/12...plus, okay, so what,
the SBN says and the ORder decrees Coughlin gets the file (and granted, its nice to get a
fresh copy in a box, even if Coughlin suspects he will ultimately be billed for it somehow, in
one way or another)...but what of the materials new to the file between 10/31/12 and "up to 3
days" prior to the hearing? Where is the access? Further, it took quite some time for that
"copy of the file" to get to Coughlin, whom received it on the first delivery attempt:
70112970000443659543 Priority Mail Delivered November 07, 2012, 3:38 pm RENO, NV 89512
Expected Del ivery By: November 6, 2012 Certified Mail Arrival at Unit November 07, 2012,
7:59 am RENO, NV 89506 Dispatched to Sort Facility November 05, 2012, 4:42 pm RENO, NV
89510 Acceptance November 05, 2012, 10:48 am RENO, NV 89510.
plus, if you look at the certificat of mailing for the Notice of Hearing (which the big box file, at
least, indicates contained a non file stamped DowSoE (Designation of Witnesses and
Summary of Evidence) as pages 2 and 3 (despite the cert of mailing indicating only that the
Notice of Hearing was sent) of it and that says it was mailed on October 12, 2012 (so what, is
the SBN and Panel going to say "yeah, but Pat King says "Zach knew about the 11/14/12 date
because I emailed it to him or called him or something"...all while the SBN's Clerk Peters is
adding Coughlin to her "blocked sender's list" (so she doesn't have any more duties to
actually investigate Richard Hill, etc. arise in light of somethign Coughlin sends her, like an
exculpatory video? real professional, Clerk Peters...or is the SBN or the Panel going ot say
"oh, we are moving for default because you technically, in our view, didn't get a "verified"
response on file by the 11/9/12 date we order on 11/1/12 (meaning at the earliest, under the 3
days constructive service nrcp 6(e) application under SCR 119(3), that Coughlin would have
all of a couple days to whip one together or comply with the order? With all that, is the SBN
and Panel going ot say "oh, zach, that motion or designation didn't make it into the record
because we don't don't seem to have a hard copy of it received in the dropbox or
mail....sorry...even though the Order (which came before the 5 days Coughlin had under
NRCP ...it actually didn't even hit the usps facility until 10/16/12, and it wasn't even availabe
for pickup by Coughlin until 10/22/12, and Coughlin signed for it on 10/27/12....so
26
on August 7th, 2012 at 3:38 pm...So

Really funny how in the SBN King Index to the Hearing red book thing Pat leaves out
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the whole green tag certified mail thing, or the fact that Laura Peters sworn to Coughlin on
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000238
1
the phone (and maybe in writing by email...and the Affidavit of Peters that Coughlin was only
just privvy to upon getting the big box on 11/7/12 says Pat recognized that Peters gave
2
Coughlin an indication he was entitled to rely upon vis a vis the returned to the SBN
purported 8/23/12 certified mailing of the Complaint (and, supposedly, the First Designation).
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But you know what? Even if the SBN could show the "first class" mailing of that was
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recieved by Coughlin? Tell it to 60302 where Garin got Coughlin's whole wrongful term suit
dismissed despite a video of the service, multiple different service attempts, receipt of the
summons and complaint by a multitue of WLS peeps...and exteremely suspect "illegibility"
arguments....topped off by that case that says "actual notice is no substitute for technical
compliance with the rules" regarding service and notice....and even though Pat King and
Laura Peters know that the only envelope they ever mailed to Coughlin (for some weird
reason they departed from what the big box shows to be some practice where they basically
send everythign twice (one certified, once first class at the same time, typically) was a
certified large manilla envelope that Tim of the Vassar Station USPS didn't find the when
previously Coughlin appeared to get it (and certified mail is a big pain in the neck to go get
for us solos when we are in the office when the mail comes...we don't have "staff" to accept
things...so its an hour burned driving down to the post office station". When the Vassar
station finally did notice the large manilla 10/9/12 certified mailin to coughlin in whatever box
it was sitting in, it was then not given to Coughlin because it only had about $1.25 in postage
printed on it in the SBN's red Pitney Boews method...."insufficient postage" return to send.
Coughlin has very, very little money right now. Ridiculously little money, and so requests
this Panel and the Bar to further memorialize that which as already been expressly
permission give to Coughlin for (waiver of subpoena and subpoena duces tecum fees) or that
which has by a combination of express indication and implict permission being accord (for
emailing/fax filing and King's recent indication that everythign Coughlin files in a non email
manner to the SBN is copied to all five Panel members, even the cd/dvd
attachments....couhlin here is essentially requestin and IFP. If Pat or Laura is really serious
about not wanting Coughlin showing up at the SBN...then give a more explicit indication that
e-filing by email will be recongized. Otherwise, given how jammed up Coughlin has been by
the due process SCR 105(2)(c) etc violations here, Coughlin cannot rely on mailign things, at
this poitn he has to shorten the delivery time to get his file stamp and preserve arguments.
And that is not the only marked difference between the "pay David Grundy, Esq." a grip of
cash and kick down $50K to the client security fund" approach in 57507...(don't get me wrong, I like
Stephen R. Harris, Esq. he's good in the Thursday Night Group of lawyers who care and stuff about
other attorneys...even if he thought I was a newcomer and I'm like, "guy, I been coming to this deal
since '03...all you Johnny Come Latelies....Tom, make this guy put the coffee maker away...and I told
Stevie, just like they did me: "you sit down and shut up and don't say anything for a year,
period...Nobody cares what you think...your best thinking got you here, jackhole, and, no, I don't
wanna be your sponsor, get me all coverd in your loser dust"...and nobody was prouder than me
when the Court just put him back in the game on 11/8/12, bravo. And, its cool, I get convicted on a
"candy bar and some cough drops" rap and get a temporary suspension. Steve? no temporary
suspension. Gary's like: "WTF?". But, clearly from the above, Stevie got his DowSoE sent a full
week after the Panel was announced. My DowSoE was mail 18 days before the Panel was even
announced....Kind of like saying, "hey, we know we are doing a hit piece on you, so we aren't even
going to pretend to follow the dictates of SCR 105(2)(c): "
But, look here, I'm tellin' you I'm coldest when I'm down in the winter, I have exhibits ready to drop
that are going to change this here whole game. Have you ever wondered what would happen if you
Honigsberg gridded all bar members names or ssn's against a "landlord's tenant checker outer "
service, then did a really detailed analysis of how Bar Counsel treated each paticular conviction,
000239
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especially vis a vis what sort of SCR 111 Petition was filed (SCR 111(4), or a "serious offense" under
SCR 111(6)?), and what if you added a deeper level of prcessing to see what the original charge
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was, then considered the plea bargain and conditions? then what if that was available publicly?
that analysis. Let's do this, SBN. Honestly, I personally think our profession is just brutal on
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lawyers, just completely ridiculous the extent to which people get raked over the coals, or at least
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certain people. Its way too political how its done. Or maybe not. Maybe its a meritocracy, where if
you have the dough to sick David Grundy on them (and really, Dave's approach seems mostly to be
the "Hey, I want all your medical records five seconds after meeting you, here sign this release,
okay, here's what I want you to do whether you are guilty or not....do the mea culpa then argue
mitigation/coerced confession" tact, whereas I favor more of a "what part of being an attorney means
you don't have rights?" style interaction with the SBN) or you have the skill and tenacity to keep Pat
King honest and not stick you for your due process....the you get a better result. I got a completely
terrible ridiculous result in 2002-2005. Never again will I have an attorney who is not myself. Never.
All I know, is some guys go to 180 AA meetings in 180 days and LAP still rejects them, whereas if
your Beckett, DA, something it turns out a bit different...
(As to the client security fund, granted, is a legitimate thing...and, despit e the fact that I absolutely
went to the wall for my clients throughout all of this stuff, there were instances were their cases were
likely prejudiced due to the impact this stuff has on me (I'm talking to arrests, the evictions, etc., etc.),
and who knows, maybe that client security fund arranged for Paul Freitag, Esq. to take over for me in
Eason v. Eastman. Personally, after reading Paul's letter to me about how he tried to contact me
(something about contacting Hot Mail and Roberto Puentes and Dan Wong...Paul, how about the
contact info listed on www.nvbar.org? Wait, that's right, many people treat the WCBA Directory like
it is the licensing body deciding who is or is not a lawyer in Washoe County (I always cheap out
when it comes to sign up for it...) (whose 1979 letter to the AG yielding an Advisory Opinion I would
like for the RMC Judges to see), but if you saw the reams and reams of westlaw research I did for
Eastman, you might think I stood a good chance of delivering just as, if not more, a compelling work
product...
1. Pat King, Bar Counsel, told Coughlin on September 25th, 2012, when Coughlin showed
up for the hearing that the SBN had calendared, agreed to and noticed, that: "Things don't go your
way becaue you don't take responsibility for your actions". Well, well, well, Pat "Salieri" King. now,
now. How about your responsibility to supervise whoever it was at the SBN who didn't put the
correct postage on that large manilla envelope that apparently contained the only copy of the
October 9th, 2012 Notice of Intent to Take Default (and, upon information and belief, some other
documentation? coughlin swears that he did not received that certified mailing (and the SBN's
certificate of mailing, that Coughlin only received on November 7th, 2012 when the certified mailing
of the sierra legal duplicating copy of the "filed" (a consolation by the Chair Echeverria to Coughlin in
exchange for excising one of the very, very few rights Coughlin has here, set forth in SCR 105 ("right
to inspect up to three days before"....so what of inspecting the file between it being sent to the
printers on November 1, 2012, as admitted to on October 31st, 2012 by Peters when she refused to
let Coughlin inspect it and again by King in writing on November 1st, 2012, and several times
thereafter in writing and verbally, in violation of SCR 105(2)(c). It is outright appalling the extent to
which PEters, King, and the Chair Echeverria are violating the law and showing no respect at all for
due process. The SBN has filed not proof of service of the summons and complaint sufficient to
satisfy SCR 109 in view of the representations made by the State Bar of Nevada, including those by
Laura Peters on the phone and in writing to Coughlin and found in Peters Affidavit on file in this
matter. The first alleged certified mailing of 8/23/12 is not sufficient to show service where Peters
herself (and this is spoken to in her affidavit) represented that the SBN would not be attempting to
use it to proof service of any sort of the Complaint, but rather, Peters would send, soon after
September 11th, 2012 a certified mailing copy of the SCR 105 SBN v zach Coughlin complaint to
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Coughlins SCR 79 address, and that the complaint would not be deemed served or by the SBN, nor
would the SBN attempt to represent in any way that it had been served, until zach coughlin had
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signed the return receipt requested and or certified letter signature card and it had been received by
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the SBN.
2. Coughlin might call the Godfather of Family Law in Nevada, Don Gary Silverman, Esq. (and
Maybe Marshal Willick, Esq. if I can get him (but really, the lack of bifurcation here and the scatter
shot carpet bombing copy and pasting of the RPC and the multitude of Claiborne and 37 cfr 11.25(3)
(a) and (c) (applied by analogy, IN Re schaeffer and STufphh) basis for attackign the various
"convictions" here makes scant the amoutn of time availabe (especially given the Chairs avowed
intention to get 'r done in one day (funny, did Steve R. Harris's deal take one day only? or must one
hire David Grundy to get that sort of time with the SBN and Panel?:
Gary Robert Silverman Company: Silverman, Decaria & Kattelman, Chtd. Address: 6140 Plumas St.
Ste. 200 Reno , NV 89519 Phone Number: 775-322-3223 Fax number: 775-322-3649 Email:
silverman@silverman-decaria.com Website: http://www.silverman-decaria.com Admit Date: 11/02/70
should the 11/14/12 hearing go forward, which it clearly should not, at least not in its current
unbifurcated, due process violating, unnoticed, no service of the 10/9/12 NOtice of INtent to Take
Default, no "at least 30 days" service of the Designation of Witness and Summary of Evidence BY
THE PANEL, NOT BY THE SBN, BAR COUNSEL, OR THE CLERK OF THE SBN, under SCR
105(2)(c). SBN also told Coughlin he would not have to pay any witness or subpoena fees and that
Respondent's never have to in these Disciplinary Hearings.
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interesting that the SBN and the Panel seek to plungE headlong into the 11/14/12 hearing that
violates absoltuely every section of NR 105(2)(c) (one of the very, very few provisions of the
Supreme Court Rules speaking to the due process requirements of these disciplinary hearings
(which some watching Coughlin circa 2002-2005 might say often devolve into kangaroo courts
where some corrupt bully (some might say Strip Club Spearmint Rhino owner Kevin Kelly, Esq.,
decade long member of the State Bar of Nevada's Character and Fitness Committee, whose club
allegedly funnels $10 million a year to Vegas cabbies to direct tourists to its doors Coe Swobe
making' calls there too, just like in 60302 where he is calling Coughlin and his father seeking to do
WLS's and Elcano's bidding) who chips off his friends (Peter Christiansen, Jr. Esq.) despite saying
the representations would be pro bono (despite receiving $5,000, Christiansen still, on the record,
for him to file a six page, rather tepid arrangement worth of a Pre Hearing Brief (containing
dog and pony show hearing (wherein, after his friends having been paid, C&F Committee Strip Club
crime, based largely on some retaliation that Mark Tratos, Esq. largely admitted to, along with Mary
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Lafrance (send me "another" copy of you paper..."what was it about" the "name of the case
involved" (gee Tratos, kind of sounds like you had the version Coughlin submitted with only his
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social security number (in compliance with the Boyd School of Law's blind grading policy, which
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MOTION SHOWING GOOD CAUSE TO ALLOW COUGHLIN TO SUBMIT A RESPONSE

OR ANSWER TO WHATEVER EXTENT THE PANEL FEELS HE HAS NOT ALREADY
DONE SO AND OR INTENDS TO CALL THIS A "PROCEED ON A DEFAULT BASIS"
SITUATION, WHERE COUGHLIN DISPUTES.
to whatever exten the sbn or panel purprts that coughlin has defaulted here, Coughlin
submits thats not the case particularly where the sbn has not filed an valid proof of service of
the complaint, particulary given the admission as to the representations and indicatiosn made
by the sbn, king and peters...further, the notice of intent to take default was only mailed by
certified mail. and the postage was deficient, and the usps wouldn't give it to coughlin, though,
curiously the cerified mailing number for that mailign is not in the big box that strangely
enough...took form november 1, 2012 to november 7th, 2012 to get copied and transported to
coughlin (not exactly blazing speed, huh...and coughllin reported the insufficient postage issue
to king and the sbn in the interim, so...draw your own conclusions...but pat is refusing to amend
any return of service thereto the complaint and or the DowSoW (see attached showing the first
certified scanning of it being in usps possession is from october 16th, 2012, not 10/12/12, and
that the earliest it was presented to coughlins' po box was 10/22/12, through no fault of coughlin
(who complied with scr 79 here...)sbn EMPLOYEE "paula" admitted to Coughlin that Pat
King locked the SBN door "a couple minutes" prior to 5 pm on a day when Coughlin sought to
present someting for filing that arguably could be deemed a "response" (verified to whatever
extent required, under protest, as this situation, where coughlin si representing himself presetn,
arguably a unique circumstances, and coughlin herein incorprates allt eh arguments made in
his recent 61901 filing vis a vis making self represented defenandts subject to such an
impermissible "sworn testimony" view of their own advocacy...But arguably, especially
Coughlin's file stamped 10/31/12 Pre-Hearing MOtion to Dismiss/summary
judgment/memorandum of law should be view as just such a "response", verified to whaver
Spevack considering extent is required of a self represented respondent here, and where King
and the SBN should be made to more spcifically set forth that allegations (fairness to opposing
counse? in what way? Judges Nash HOlmes Order is beyond cursory in that regard, and
utterly devoid of a single fact to support such copy and pasting of the RPC...other than to
suggest asking questions about retaliation is so dilatory as to support a "fairness to opposing
counse" rpc violation worthy of a scr 105 complaint....uh....
"We nevertheless conclude that discipline orders appearing in the Nevada Lawyer may be cited to
this court for the limited purpose of providing examples of the discipline imposed in similar fact
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situations. This approach has also been taken by several other courts. n22
n22 See. e.g., Berman v. City of Daly City, 21 Cal. App. 4th 276, 26 Cal. Rptr, 2d 493, 496 n.5 (Ct.
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App. 1993); Marez v. Dairyland Ins. Co., 638 P.2d 286, 289 n.2 (Colo. 1981); Manderfeld v. Krovitz,
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539 N.W.2d 802, 807 n.3 (Minn. Ct. App. 1995): Leisure Hills of Grand Rapids v. DHS, 480 N.W.2d
149, 151 n.3 (Minn. Ct. App. 1992)." In Re Laub.
Plus on the sufficiency of the servie and proces and servic of process thing (kings exhibits are blurry
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and not well scanned, and printed on both sides of the page in some instances, which Garin got a
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dismissal for based on arguably less in 60302)...

I am not so sure Judge McGee didn't have something to do with my temporary suspension. Or
District Attorney Gammick (both of whom I like and consider friends). I emailed them both about five
hours before I got the efile notice from the Court of the suspension on June 6th, 2012. And like my
friend Gary Silverman, Esq. said in an email to me on August 13th, 2012 when Gary, as is his wont,
took time out of his day to read my ridiculously long (well Grundy's breif for Stevie was 55 pages,
so....and Judge McGee's suggestion to me that mine should be no more than 3 pages is just
insulting. lawyers drone on for 60 pages about widgets but a career of mine that took a lifetime to
build is worth 3 pages? Please. seriously, lawyer's need a Player's Union. And it ain't the Bar.
There's a really big problem in our Bar right now, and I think we all now what it is...Player hatin'.
That's right, I said it. Hell, look at this deal. Here, the Bar is basically the Bench's Rent-aThug...enter Pat "Salieri" King. it is just plain puke worthy the extent to which Patty has covered his
ears, put a blindfold over his eyes, and muzzled himself in his pursuit of cloaking himself in his tired
old mantra "a conviction is indisputable proof of wrongdoing (not according to Claiborne and
Montiero says King seeking to screw up a pending criminal prosecution in 11 cr 063341 is just wrong
where King purports to include it in this Complaint herein (and Coughlin shoudl get and moves for a
continuance of this Bar hearing on 11/14/12 on that basis as well...Its just ridiculous to expect
Coughlin to appear representing Himself at this bar hearing on 11/14/12, then do the same in the
alleged "lost mislaid abandoned" property as larceny case 063341 to pretend like that is fair
(especially where kIng has rigged this deal so that Coughlin's SCR 105(2)(c) rights have all been cut
by about 709%...which is prosecutorial misconduct, and under SCR 119 hopefully something the
Court will address (but also as "possession of stolen property" according to dda young, despite
Staab, double jeopardy and duplicative charges issues, and the fact that the Complaint in that case
fails to allege "from another" or to allege anything with any specificity whatsoever, which is
something Biray Dogan is sure doesn't matter. despite Biray getting $8,000 raises in some of the
worst fiscal years in our nation's history...connection? uh, no comment. so I don't have to
undertake any investigation or ask the Board member Richard G. HIll, Esq. (whose best friend is also
a Board Member, David Hamilton, Esq.,and its pretty unseemly for Board members to be using their
membership as a club....and when I say "club" I mean like a shiv or shank or something one might
reach for if ish starts to popov in the 'yard...not like a "group" or "committee"...if that is what Hill is
doing here, which is not for me to say. just sayin' you know what I'm sayin? You know what I'm
sayin. But this Board, funny thing...its comprised of individuals...and they don't always see things the
same. Look at 57507, Harris's deal. The Chair there was like "oh, hell naw"....) any uncomfortable
questions....like how Hill lied to get Coughlin arrested (Coughlin hereby incorporates by reference all
his filings in the last 18 months publicly available on the Nevada Supreme Court's website, especially
those in 60838, 61901, 61426, 60302, 60331, 61383, 60630 (which should just be a Mandamus
Petition requiring Longoni and the RMC to quit breaking the law and instead comply with the NRS
189.030 requirement that the RMC Order the transcript prepared and the ROA sent to the District
Court within 10 days of the filing of the Notice of Appeal (and Judge Kenneth Howard's statement on
the record after Coughlin was brought back in in cuffs on 11/30/11 in 11 CR 22176 (and that whole
conviction is completely devoid of any sniff of due process, much less the fact that tribal police are
not allowed to make misdemeanor arrests in Nevada under NRS 171.1255and the "confidential"
60975 (aint so confidential where the publicly available case participant search research show a
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SCR 117 "confidential" Disability Petition has been filed against Coughlin, now is it? Also, Coughlin
submitted to the Court on May 24th, 2012 an Opposition to King's May 10th, 2012 SCR 111(6)
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Petition on the Walmart and its not in line with what was done in the Noel Gage case (he submitted
an opposition) and there is not a rule that says the Clerk can refuse to file the Opposition Coughlin
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submitted on May 24th, 2012 or otherwise make it so some shallow AP article is printed about
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Coughlin the day after the Court's Order comes down suspending Coughlin (kinda sounds a bit fed
to that writer, doesn't it? Also, Coughlin's recent filings in 61901 and some other cases (not 60302
though, featuring SBN Ethics Committee member Joe Garin (can I get King's complaint here
dismissed on Garin style "illegible" service of process arguments that are later reclassified as
insufficiency of "process" rather than the previous arguments as to insufficiency of "service" of that
process? King's exhibits (which you just know under the Mirch case will mean all that those Judge's
Order attached as exhibits (and hell, it'll prolly be the case that orders mentioned in those orders
(like Judges Sferrazza's 10/27/11 Findings of Fact, etc. in rjc rev2011-1708 will be thereby
incorporated too, right...except, like in the 11 cr 26405, they will only be relevant to the extent the
prosecution needs 'em...once Coughlin starts referencing them, Chair Echeverria will be on it in a
second with a Judge Howard/Nash/L. and W. Gardner style "how is this relevant" "it's not relevant"
"move on!" "you keep it up and you are going to add to your little record there" (that last one from
Judge Nash Holmes, although she'll tell you no extra judicial communication affected her ability to
preside over that matter, or resullt in the Richard G. Hill gets Coughlin arrest again this time for
jaywalking case in 12 cr 00696 (in the video which coughlin transcribed Hill is seen lying to RPD
Officer Hollingsworth that, on 1/11/12 Coughlin had "lost his appeal" (you mean the one not decided
until 3/30/12, Rich? Kind of like Hill lying to RPD Chris Carter and Sargent Marcia Lopez (see
Coughlin work in 11 cr 26405's recent filigns in the last month, both of which shouldbe essentially
reproduced in N. S. Ct. 61901, but only one of which is (no matter, all that was relevant enough to
put most of it in 60302) being transferred to her on 2/27/12 (lot happened on that day here) purport to
rule on will be deemed "notice" or pled to Coughlin (which doesn't make sense considering there are
3 grievance number on the complaint, yet the 8/23/12 stamped Complaint speaks to things not
mentioned in any of those grievances...)...and speaking of, oh. look there's Keith Loomis, Esq. on the
SBN's fee dispute Committee...sure is interesting who winds up on all these Committees for the
SBN....Kevin Kelly, Esq., owner of the megalithic Las Vegas outpost of multinational strip club chain
Spearmint Rhino has been puttin' in work on the Character & Fitness Committee for ever, great
friends with Peter Christiansen, Jr.) and as a "verified response" (to whatever extent this Panel
intends to hold that Coughlin has to do what Judge Nash Holmes tried to do (ie, swear in the self
representing defendant at the outset, thereby hamstringing them with an impermissible condition that
the Muni Court Judges are, curiously, not putting on their, er, the Municipalities prosecutors (and
believe me, Allison Ormass, Christopher Hazlett-Stevens, Pamela Roberts, Dan Wong, et al don't
want know part of everything that comes out of their mouths in court being sworn. And the testify
plenty while trying their cases, in fact, they are really good at it, especially during their closing
arguments about facts not in evidence and which are not reasonably directed toward admissible
subject matter to begin with, but rather just cheap shots calculated to render a prejudicial
effect...right Hazlett-Steven's, what with your repeated "pajamas and slippers" blast....Don't see
Judge Nash Holmes talking threatening trash at him from the bench (Judge Holmes couldn't decide
during the 2/27/12 preceding if everything Coughlin said that day was "sworn testimony" or
not...alternately seeming to want it to be, only to constantly interrupt Coughlin during his cross of
Sargent Tarter to say things like "when you testify you can get into that" or "you are not testifying he
is" (and Ormaas's statements in court that day about whether the report or charge sheet or whatever
that had the officer that Sargent Tarter called in to fill out the form (why on earth does Sargent Tarter
need to call someone in to fill out a report, then indicate Tarter signed it, and that didn't deprive
Coughlin his Sixth Amendment right of confrontation or justifying a continuance? Maybe there is a
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sensitive reasons why Tarter can't write in his own hand or something (in which case, I mean no
disrespect), or, maybe, his callign in a officer with no percipient recollection indicates some
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impermissible action or motive by Tarter (and Tarter testified that he normally give people a warning,
but that Coughlin was being uncooperative (which is something every RPD Officers seems to be
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trained to recite from rote along with "well my training and experience indicated to me a search was
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appropriate).
Regarding the apparent greater "due process" accorde to David Grundy's client STephen R. Harris
(which reminds me....Coe Swobe should not be making calls to Coughlin's father, Dr. Timothy D.
Coughlin, nor should WLS's Paul Elcano seeking to "help" Coughlin (if by "help Zach" they mean
"hey, Tim, don't let Zach give Elcano any problems, okay? We need you to lean on Zach, Tim."
Yeah, no, Paul and Coe...Coe doesn't need to tell Zach Coughlin "well you really shit on Elcano
there". Not quite Coer (he calls me "Zacker" , it was his call in 2002 that funneled me to Peter
Christiansen, Jr. (and Coe probably didn't know much of anything about Pete...and arguably made
up for any negligence or untoward involvement in that regard where he and Keith Lee, Esq. (founder
of the C&F) got it done in 2004 (after Christiansen and Sanft made it abundantly clear that they
weren't going to get out of bed for less than another $5K, not in so many words...but when Eichman
is like,uh...yeah, your "attorney of record" doesn't seem too "into it" so, um...why don't you prepare a
Notice of Intent to Seek Reconsideration" or something when the abeyance expires in Sept 2003
(which Coughlin did, yet Eichman decided not to submit to the Court...and, to be fair, it probably
would have not had the best chance (although, come to think of it, its was the "two or three pages"
that Judge McGee seemed to suggest Coughlin's recent Motino to Dissolve should be....yet Eichman
just basically unilaterally failed to forward it on to the Court? And if you had Mike Rowe writing you
nasty threatening letters t sit down and shut up like Rowe did in January 2003 to Coughlin...you
probably woudn't be too squeeky a wheel either...which would cost you another year and half of your
career and professional development (why is it only deputy prosecutors get all the trial
experience...and Coughlin gets fired where he attempts to get some in 54844 (incorporate that case
too into Coughlin's respond to Kings Complaint to the extent one is being coerced out of Coughlin
and the Motion to Dismiss or Motion for More definite STatement is not accorded to approriate
NRCP process (clearly Panel Chair Echeverria doesn't believe in waiting to read a Reply to King's
Opposition to bifurcate, as the Chair enters his orders before the 5 days to file one has even run
(consider nrcp 6(e) and the fact that King doesn't email or fax his Opposition to the bifurcate
motion..mailed it on 10/24/12 and the Chair rules on 10/30/12...just like RMC Judge Howard ruling
on Coughlin's various post-trial motions before the City Attorney's office even responds to
them...nothing says "due process" quite like that. well, except for Judge Howard announcing at trial
that he was refusing to grant Coughlin a continuance in 11 cr 22176 (resulting in 60838) because
Coughlin failed to appear at the 11/14/12 original trial date. Despite City Attorney roberts having
agreed to a continuance of the 11/30/12 trial date in writing before hand, come trial time she refused
to, then claimed it was up to Judge Howard anyways. The RMC granted the city attorney a
continaunce in 11 cr 26405 because Board member Rich Hill need to go on vacation for six weeks
(lew taitel, conflict, rmc defender, took coughlin's case, shouldnta...coughlin was suing his business
partners, who are committing the unauthorized practice of law, that judge pearson and judge
schroeder found permissible in rjc rev2012-001048, which not only wrongfully evicted coughlin, but
resulte in two wrongful arrests of coughlin by the rpd in 12 cr 12420 and rcr2012-067980 (when
Judges fail to follow what the legislature sets out in nrs 40.253, there is a real human cost, and,
apparently, it costs Dan Wong and the bar and the courts, and lots of other people their
relationships, time, judicial resources, etc., etc. Our states landlord tenant law are the harshest
towards tenants to begin with...when Judges "remix" those laws or choose not to faithfully enforce
them (and its particularly suspect where that is done by former prosecutors turned judges where
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Coughlin's orientation to the County Sheriff and RPD at this poitn arguably calls for an "alternate
public prosecutor) to be appointed in all past and existing prosecutions of Coughlin, beginning with
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the rcr2011-063341 arrest that started all of this off (with a little help from a wrongfull summary
eviction that remixed summary and plenary and went all "JCRLV Rule 44" (despite the RJC not
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having complied with JCRCP 83 in fashioning such an application....and don't tell Coughlin he "sh&t
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on" Washoe Legal Services". Coughlin, in the last year, has more than paid it forward to the legal
services community in Nevada through his guerilla, impromptu, performance art, improvisational
tenant's rights, prosecutorial and police misconduct addressing advocacy, all gratis, natch. Well, you
can go ahead and thank his momma, Very Special Arts of Nevada's Mary Barker Program Director
(and Obama's staunchest supporter, at least in the Western States, for sure.. caring on the Ruth
Barker legacy of adovacy) for that advocacy, because is has in large part been funded through
generous grants from her, on her $21 an hour paycheck. But you can't thank Marc Ashley, Esq.,
WLS's landlord tenant attorney. YOu could maybe thank Jon Sasser, Esq. some. And Tik
Segerblom. But you can't thank Paul Elcano or the Muni Court Judges for that. Thank Mary
Barker. And you can thank Bo Barker, Esq. too, famed construction defect gure in the State of
Washinton (www.BarkerMartin.com). Haven't heard too much from Robert Coughlin, Esq. (last thing
heard bout him he was prosecutin' defendants denied their Sixth Amendment Right to counsel for
Huber Heights. http://www.daytondailynews.com/news/news/local/defendants-tried-without-lawyersin-huber-heights-/nM9sD/ (http://www.zoominfo.com/#!search/profile/person?
personId=282794556&targetid=profile whom Coughlin hereby supplements to the SBN as included
in his Designation of Witnesses...especially where all the sudden Judge Beesley and Paul Elcano
are being supplemented (Judge Beesley to excuse, apparently, King's reckless and not true
attestation (if it were true, then how did Coughlin file on 6/10/12 something in Cadle Co. v. Keller
(funny, the excellent motion work Coughli did for Keller and Gessin in the NVB adversary
proceedings didn't find its way into the ginormous bate stamped collections of "pleadings created by
Zach Coughlin" in the SBN's files (nor was anything from Coughlin's very, very sold work in the two
Dana Harris cases, the one before Judge Doherty featuring a NRCP 60(b)(4) void for lack of
jursidiction where home state under the UCCJEA was procured through fraud motion that Coughlin
was probably paid, consdiering everything, something liek $50 for....or the work in the Carpentier v.
Aames funding (which Judge Flanagan managed to issue yet another rather suspect sanction
against Coughlin in to go alogn with his apparenlty record setting attorney's fees award agains that
which he had deemed a commercial tenant (at least implicilty, to the extent the summary eviction
where NO Cause all that was pled was upheld) in the richard hill eviction case.. (those sanctions
bring it to the point where any Temporary Restraining Order that Couglin and Flanagans former
employer may be entitled to prior to Coughlin unloading some "privilege of the participant" laden
testimony directed toward, lets just say, hypotehticaly, an associate getting let go because "not a
good fit" a couple weeks after an office managers assistant broke up with the new litigation lateral
hire equity partner, the the assistant asks the junior associate out, cue the sudden need for an
"assignement" to be done for the same Seinfeld character swarming around Trish's departure, even
though that partner way off in transactional land....and add to that the awkwardness of junior
associate pointing out to new lateral equity hire that us supreme court ruling on a post whatever
whatever cause of action under something something being mandatory authority, for which the
SCR's hold there is a duty to disclose, and you have what? you have an associate booted 'round
christmas time just after developing gastroenteritis incident to the southern pseudo military academy
atmosphere found at that firm...Not sue how that wouldn't kind of call for recusal (Judge L. gArdner
herself signed an ORder of recusal in the next case coughlin appeared as atty on before her, citing,
in her 8/16/11 ORder of Recusal NCJCR 2.11(A)(1) (that's the one where the Judge just flat out
admits they have an actual bias or prejudice, right? we aren't even talking perceived or possiblewe
are talkin' flat out "I am biased and prejudiced against you" admission resulting in recusal (and the
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comment is instructive consdering what happened during the settlemen conference in that April 2009
JOshi case: "[3]Judges must be mindful of the effect settlement discussions can have, not only on
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their objectivity and impartiality, but also on the appearance of their objectivity and impartiality.
Despite a judges best efforts, there may be instances when information obtained during settlement
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discussions could influence a judges decision making during trial, and, in such instances, the judge
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should consider whether disqualification may be appropriate. See Rule 2.11(A)(1)."...also " Third
degree of relationship includes the following persons: great-grandparent, grandparent, parent,
uncle, aunt, brother, sister, child, grandchild, great-grandchild, nephew, and niece. See Rule 2.11.
NCJCR's on terminology sections"
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...as the basis for her doing so...that same rationale arguably applies to have required her brother to
recuse himself in the criminal trespass prosecution.. Guess its nice of Judge L. Garner to just flat out
Rule2.11.Disqualification.
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admit it in her recusal order in Bell v. Greer wherein she cites:
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personal knowledge of facts that are in dispute in the proceeding." But to then go on and be
involved in the ghost greivancing here (in the "big box" of the file delivered to Cogulin on 11/7/12
(wow, only 8 days before this huge hearing wherein King has told Coughlin he will get him disbarred,
Mirch-style, coughlin finally gets some access to some of the materials...in violation of the right to
inspect "up to 3 days" in SCr 105(2)(c), and Coughln had been seeking that permission to inspect
continuously all along here, and it is impermissilbe for King to violate the "courthouse sanctuary"
doctrine and purport to impinge on coughlin's inspect right under scr 105(2)(c), especially by shoving
documents into coughlin's jacket upon pulling at the lapel (and its King and Peters that are no
adopting the "Duluth Model" "Power and Control Wheel" abuser style tactics of "playing the victim"
(replete with Peters's "this is harrasment! I am getting a protection ORder whenever her apparent
misconduct resulting in a curtailing of Coughlins' due process rights is broached....ditto for King...see
his baseless and unsupported, devoid of specifics (gee, don't think Paula would quite put it like that
KIng...just because she admitted that king leaves the office early, thereby locking up the "filing office"
prior to "The close of business at 5pm" under NRCP doesn't make Coughlin's conduct as justifying
some "stay away" letter, Pat. get a grip.
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Rule 2.11. Disqualification. (A) A judge shall disqualify himself or herself in any proceeding in
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which the judges impartiality might reasonably be questioned, including but not limited to
the following circumstances: (1) The judge has a personal bias or prejudice concerning a
party or a partys lawyer, or personal knowledge of facts that are in dispute in the proceeding.
(2) The judge knows that the judge, the judges spouse or domestic partner, or a person within the
third degree of relationship to either of them, or the spouse or domestic partner of such a person is:
(a) a party to the proceeding or an officer, director, general partner, managing member, or trustee of
a party; (b) acting as a lawyer in the proceeding; (c) a person who has more than a de minimis
interest that could be substantially affected by the proceeding; or (d) likely to be a material witness in
the proceeding. (3) The judge knows that he or she, individually or as a fiduciary, or the judges
spouse, domestic partner, parent, or child, or any other member of the judges family residing in the
judges household, has an economic interest in the subject matter in controversy or in a party to the
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proceeding. (4) [Reserved.] (5) The judge, while a judge or a judicial candidate, has made a public
statement, other than in a court proceeding, judicial decision, or opinion, that commits or appears to
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commit the judge to reach a particular result or rule in a particular way in the proceeding or
controversy. (6) The judge: (a) served as a lawyer in the matter in controversy or was associated
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with a lawyer who participated substantially as a lawyer in the matter during such association; (b)
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served in governmental employment and in such capacity participated personally and substantially
as a lawyer or public official concerning the proceeding, or has publicly expressed in such capacity
an opinion concerning the merits of the particular matter in controversy; (c) was a material witness
concerning the matter; or (d) previously presided as a judge over the matter in another court. (B) A
judge shall keep informed about the judges personal and fiduciary economic interests and make a
reasonable effort to keep informed about the personal economic interests of the judges spouse or
domestic partner and minor children residing in the judges household. (C) A judge subject to
disqualification under this Rule, other than for bias or prejudice under paragraph (A)(1), may disclose
on the record the basis of the judges disqualification and may ask the parties and their lawyers to
consider, outside the presence of the judge and court staff, court officials and others subject to the
judges direction and control, whether to waive disqualification. If, following the disclosure, the parties
and lawyers agree, without participation by the judge or court staff, court officials and others subject
to the judges direction and control, that the judge should not be disqualified, the judge may
participate in the proceeding. The agreement shall be incorporated into the record of the proceeding.
COMMENT [1] Under this Rule, a judge is disqualified whenever the judges impartiality might
reasonably be questioned, regardless of whether any of the specific provisions of paragraphs (A)(1)
through (6) apply. For example, if a judge were in the process of negotiating for employment with a
law firm, the judge would be disqualified from any matters in which that law firm appeared, unless the
disqualification was waived by the parties after disclosure by the judge. [2] A judges obligation not
to hear or decide matters in which disqualification is required applies regardless of whether a
motion to disqualify is filed. [3] The rule of necessity may override the rule of disqualification. For
example, a judge might be required to participate in judicial review of a judicial salary statute, or
might be the only judge available in a matter requiring immediate judicial action, such as a hearing
on probable cause or a temporary restraining order. In matters that require immediate action, the
judge must disclose on the record the basis for possible disqualification and make reasonable efforts
to transfer the matter to another judge as soon as practicable. [4] The fact that a lawyer in a
proceeding is affiliated with a law firm with which a relative of the judge is affiliated does not itself
disqualify the judge. If, however, the judges impartiality might reasonably be questioned under
paragraph (A), or the relative is known by the judge to have an interest in the law firm that could be
substantially affected by the proceeding under paragraph (A)(2)(c), the judges disqualification is
required. [4A] The filing of a judicial discipline complaint during the pendency of a matter does not of
itself require disqualification of the judge from presiding over the litigation. The judges decision to
recuse in such circumstances must be resolved on a case-by-case basis. [5] A judge should
disclose on the record information that the judge believes the parties or their lawyers might
reasonably consider relevant to a possible motion for disqualification, even if the judge
believes there is no basis for disqualification. (Judge W. Gardner only did this upon Coughlin
prompting for it...) A judge making such a disclosure should, where practicable, follow the
procedure set forth in Rule 2.11(C). [6] Economic interest, as set forth in the Terminology section,
means ownership of more than a de minimis legal or equitable interest (Coughlin's law license is a
14th amendment property right, and Judge L. Gardners reputation as a jurist, to whatever extent she
felt is impinged by 54844, may invoked this provision here). Except for situations in which a judge
participates in the management of such a legal or equitable interest, or the interest could be
substantially affected by the outcome of a proceeding before a judge, it does not include: (1) an
interest in the individual holdings within a mutual or common investment fund; (2) an interest in
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securities held by an educational, religious, charitable, fraternal, or civic organization in which the
judge or the judges spouse, domestic partner, parent, or child serves as a director, officer, advisor,
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or other participant; (3) a deposit in a financial institution or deposits or proprietary interests the judge
may maintain as a member of a mutual savings association or credit union, or similar proprietary
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interests; or (4) an interest in the issuer of government securities held by the judge.
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.probably wouldn't be such an issue if there weren't $5K sanction for filing motions that do point out
"gee, yeah, that might be kind of important if RCS/QLS is owned by the law firm on the case, and
they are sending out the summary judgment motions to one who is no longer attorney of record or
doing so in the bankruptcy matrix or listing the wrong court and or case number in the caption (funny,
anything like that by Coughlin gets a WDCR 10 rejection by Matheus, not to mention that WDCR 37
or whatever that sets for exactly the court lines on the caption have to say basis, and wDCR r 17 or
18 or whatever) (especially given the great possibilities int eh BK setting for making the bank/lender
prove standing, Rule 3001 or whatever) .that, while not formatted that great, did manage to set out
the exact method to win that case, some rather elegant points of law that many would miss (and
Couglin wouldn't have gotten there were it not for the initial assist from Michael Lehrners, and some
general shaman meets arms dealer by way of Mecca direction from one Geoffrey Lynn Giles, Esq.)
to king's Boss, David Clark, and, upon information and belief, Coughlin's then client, Peter Eastman,
prior the the May 10th, 2012 filing by King, regarding matters still requiring King's non comment to
Eastman under SCR 121 (how is it that Eastman and King are the only two people in the world who
makes comments to Coughlin about "the b#n#r*p#c# Court won't let you" do this or that in the first
couple days of May 2012 if King isn't violating SCR 121 to Eastman (who magically was able to
afford Freitag all the sudden, despite having failed to pay Coughlin anything on the $3,500 flat fee to
represent Eastman in CV11-00820 - EASON INSURANCE VS. PETER EASTMAN. ETAL (B6).
Whether there is some connection to the Zach Coughlin v. Jeff Nichols case in the RJC, and whether
Nichols just told lie after lie at the hearing (and, whether that is easily provable, Jeff...keep smilin',
buddy....and whether Coughlin was punched in the face by somebody on or around March 30th,
2012, whether that somebody is a former WCSO Deputy, and whether Nichols and he not only
managed ot get Nichols about 6 hours of high end research for free (well, not according to the deal)
on the whole gift/loan $130K unsecured promissory loan form the older english professor family
friend thing...resulting in some, an attorney subject to yet another wrongful eviction (its fraud to post
a No Cause Eviction notice then file a tenant's affidavit alleging non payment of rent on the day of
the hearing, Gayle...and Sue...just because the attorney's pre hearing mOtion pointed out all the
terrible obstacles you would be facing in proceeding under a no cause notice (and if the eviction
order in rjc 2012-000374 is faxed to the RJC, as Casey Baker, Esq. testified on 6/18/12, that all such
orders are (and contrary to RJC indications....even private attorenys rely on the RJC to fax those
lockout orders to the Sheriff's...and if the 3/15/12 lockout order in that summary eviction (the one the
attorney was subject to about 5 hours after the hearing, where a default was granted for a hearing
notice as starting at 8:30 am, despite the fax header on the eviction order indicatign the signed
Lockout Order was faxed to the Sheriff at 8:24 am....? Which brings up the question...since Baker's
testimony is that even landlord's with high end private attorney's like Hill rely on (as that is the usual
course and custom according to RJC Karen Stancil, for such orders to be faxed to the wCSO the day
they are entered, or the next day at the latest)...then where, oh where, is the proof of when the RJC
faxed teh 10/25/11 Eviction Decision and Order that Judge Sferrazza signed in rjc rev2011-001708
and which Deputy Machen lists as having "personally served" Coughlin, on 11/1/11 at 4:30
pm...despite Machen (who made the arrest in rcr2012-06798, on june 28th, 2012, despite judge
schroeder and the rjc being well aware of the deficiency of the notice under 40.253 in that the
unauthorized practicioner of law (the call themselves an "eviction consulting and process serving
company"...isn't that cute?) Nevada Court services, biz partners with Lew Taitel (the RMC court
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appointed defender who appeared for Coughlin the trespass case before Judge W. Gardner (brother
to the L. gardner who recused herself from a randomly assigned case that Coughlin was atty of
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record on on 8/10/11 in Case Description: FV11-02864 - ROBERT A BELL VS JESSICA F GREER
(D11) -. Filing Date: 10-Aug-2011...which coincidentall (god shot,anyone?) just so happens to not
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only establish that (and this was done in so many, many other ways regardless) that Coughlin held
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himself out and was a commercial tenant at 121 River Rock ST., practicing law (and a mattress biz
to boot, Coughlin Memory Foam) HIll's summary eviction of commercial tenant Coughlin on a NO
Cause notice was jurisdictionally void (to whatever extent the october 18th, 2011 filing by Coughlin of
a notice of appeal and depositing that $2,275 didn't divest Judge SFerrazza, under Mack v. Mack
Manley of jurisdictio nto hold the "Trial" on 10/25/11 that he noticed in writing ("the use of the term
"Trial" was unfortunate, You Honor" said HIll's associate Casey Baker, who has now hightailed it on
back to Kentucky now that he and HIll are about to have some serious 'splainin' to do)...And as to the
"verified response or Answer" Echeverria and kIng are so keen on....is yours a verified Complaint,
Pat? Are the Judges oRders verified? Does Judge Nash HOlmes's pastiche of what she likes best
of the differetn types of contempt in NEvada and beyond based upon some Affidavit by a marshal as
to some restroom hapennings? Were is that "not in the immediate presence" not "under the court's
watchful eye" affidavit. and Judge Howards tack on 3 minutes of trial audion in 11 cr 22176 seeks to
mislead Coughlin not only as to who has to pay up front or not for the transcript attendnat to an
appeal fo the petty larceny conviction (which is void anyways given it stems from an arrest by a tribal
police officer, violative of nrs 171.1255 (and at the trial wal-mart's Thomas Frontino and the RSIC
officers Braunworth and Crawford admitted that no citizen's arrest was effectuated upon Coughlin,
with Frontino making especially clear (it seemed he had been coached to do so, likely to help his
employer wal-mart in seeking to avoid any "wrongful shopkeeper's arrest" lawsuits by just letting the
tribal police take whatever fall might stem from something like that (not likely, right?....but the price to
pay for that, City of Reno, Walmart, and RSIC is that nrs 171.1255 rears its ugly head makes that
whole arrest, and therefore conviction, null and wrongful, and there's some question that need be
asked of Roberts et al about prosecutin' based upon such arrests made in violation of Nevada law.
Much less Roberts putting on the perjured testimony of Frontino and Crawford, and maybe
Braunworth, to the extent he could remember anything more than his name while testifying at trial, or
understand a single question asked of him that day (and Judge HOward refused to allow Coughlin to
testify in his own behalf in that regard, an inviolable right....after expecting Coughlin to cheerfully face
the same "can you repeat the question" that cause Judge Howard to boil over and deny Coughlin his
right to testify, when Braunworth greeted every question asked by Coughlin with that same "can you
repeat the question?". , which, given she is an attorney (to borrow from the approach taken with
Coughlin by the three RMC Judges with Coughlin, even when he was "Not an attorney" under King's
view (Coughlin as suspended on 6/7/12, which W. Gardner admitted to being apprised of prior to the
6/18/12 trial in the trespass matter (all of this is great stuff under Claiborne and 37 CFR 11.25(a) and
(c)....
BUT YEAH, TO BE CLEAR, COULD TAKES ADVANTAGE OF THE FULL RANGE OF SPEVACK,
WHILST ALSO HEREBY SUPPLEMENTING HIS PREVIOUS ANSWER OR RESPONSE MADE
UNDER PROTESTT (GIVEN THE BASIS FOR A DISMISSAL AND OTHER DUE PROCESS,
SERVICE NOTICE DEFICIENCIES) TO INDICATE, AS HIS OWN ATTORNEY (DID STEVE
HARRIS HAVE TO FILE A VERIFIED ANSWER OR RESPONSE TESTIFYING UNDER OATH AS
TO EACH AND EVERY ALLEGATIONS OR DID DAVID GRUNDY GET TO ADOVATE ON HIS
BEHALF UNDER A NRCP 11 STANDARD? (WELL, OKAY Harris apparently admitted the two RPC
violations he was charged with...but, hey, that brings up, how is it, under the Mirch notice arguments
that will undoubtedly be made, Coughlin is not subject to the "copy and paste the entire contents of
the rpc then issue a general and competely vague ruling/laundry list recitation of how coughlin
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violated every one of the (but Judge Nash Holmes contradicts her "clear and convicing" findings by
commenting "there certainly seems to be an issue of whether he violated that", with regard to pretty
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much all of the RPC violations/allegations/suggestions of a violation....). How is it Harris is charged
with only two RPC's, yet Coughlin is apparently, in an unbifrcuated hearing, expeted to defend
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against the "copy and paste every RPC in the book" incident to the "convictions" in Judge Nash
Holmes Order (and you know king will argue all her orders are incorproated by reference to whatever
extent his complaint doesn't specificaly pled them...)? oH, wait, the SBN's King will say Coughlin
5 can't even "Relitigate" Jduge Nash Holmes "convictions" of Coughlin (even the ones she made in
violation of the 10 day rule to make sua sponte nrcp 59(a) alterantiosn or amendments to her void
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anyways 2/28/12 Order (she takes a second swing at the bat on in her 3/12/12 ORder purporting to
re-rule on things she already issued a "misdemeanor criminal contempt conviction" on in her 2/28/12
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ORder...in her 3/12/12 order (nrs 178.405, nrs 5.010 precluded even holding that hearing anyways),
and all those orders seek to transmogrify a traffic citation trial into a Summary Disciplinary SCR 105
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Hearing...."wow", indeed.
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judge Howard is known for having contempt for defendants before him who went to Reno High
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School. this is known. judge howard himself went to Reno High before becoming the first Student
Body President at Hug High, then playing football for a year at UNR. Coughlin has been told by
various people that Judge Howard is especially predisposed to take a draconian approach to a
certain type of defendant who went to Reno High....and so when Coughlin filed a motion on 11/29/11
in 11 cr 22176 citing the Duke Lacrosee rape case as a parallel to pamela roberts, esq.'s approach
in that petty larceny prosecution...well...(About that "failure to appear' on 11/14/12, Judge Howard,
was wrong about that, Coughlin certainly did appear, in "jail reds" and cuffs, as he was in custody
incident to the lies of Dr. Merliss and Hill and the RPD resulting in the criminal trespass arrest and 3
days in jail in 11 cr 26405...the jail brought Coughlin to court on 11/14/12...but didn't bring him into
the courtroom for trial (no one is sayin' why...maybe it was because Coughlin was in "reds" (the type
of jail scrubs one wears indicates some things..."reds" basically means "mental case" or something
and the jail has always put coughlin in "administrative segregation" ...meaning fo th 46 days Coughlin
spent in jail since August 2011 (various stints of about 7, 1, 3, 3, 1, 3, 5, 8, 1, and 18 days each (3 for
"summary contempt" by Judge Howard despite Howard going against his own Bench Book in failing
to grant counsel to Coughlin...even though Aigersinger is mandatory authority and even though
Howard's pre trial order did not expressly preclude the possibility of jail time...it merely indicated that
jail time was not involved in the "standard sentence"...which is not the same thing as saying there
was "no possibility of jail time" sufficient to preclude the attachment of the Sixth Amendment. and
judge howard.
http://medboard.nv.gov/newsletters/vol24.htm:
"...And Dr. Timothy D. Coughlin, MD, former President of the Nevada Health Professionals
Assistance Foundation and instrumental in the Diversion Program, Dr. Coughlin has more than
fifteen (now twenty-five, but its not a competition) years of experience in identifying, intervening, and
monitoring physicians with chemical dependency, dual diagnosis, and disruptive behaviors. We feel
very fortunate to have him as our new president...." did mention that his son's character, "is bedrock"
at the June 2002 resumption of the C&F Committee Hearing (wherein Coughlin was more
preapproved given his going along with the one attorney (Kelly said "we will give you a list of three
attroney's who will reprresent you pro bono" (Coe Swobe called with one name and one name
only...Peter Christiansen, Jr. (who may have some things to update his admission application about
from his Wyoming days) who, while taking $5K up front and without any fee agreement or other
details as to the scope of representation upon announcing, when first meeting with Coughlin "this
ain't no pro bono deal, man" ) only to then show up at the June 2002 hearing an mislead the
Committee into think his 6 or so page Pre Hearing Brief and "advocacy" that day was done "pro
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bono" (and thus partially excusing was what a rather tepid arrangement at best...to say nothing of all
the failing to send this or that to Eichman and the Bar and otherwise dropping every ball possible
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along the way between 2002-2005 when finally Christiansen, Sanft, and the de facto attorney on the
case, legal assistant Kelly Huff (and the microtelco fax confirmations prove both they and Eichman
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recieved the Reconsideration filing Coughlin prepared and submitted in compliance with Eichmann's
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directions, yet, which Eichmann later admitted she unilaterally decided not to forward on to the
Nevada Supreme Court for consideration at the end of the abeyance period incident to that Court's
December 2012 deferral Order )(what do you do when you are 25? not go with the attorney the Bar
calls you up and directs you to?and that "it takes fire to make steel" (being an SEC fullback with
tailback speed on scholarship from Dayton, Ohio for Tulane from 1965-1968, then going straight to
medical school, and doing a residency at Duke has given "Tim" (just kidding, Dad) a sort of gruff
charm all his own) in a hearing before a Spearmint Rhino Strip Club owning Character and Fitness
Committee Member, Kevin Kelly. Esq.. Kelly was then a member, and subsequently Chairman at
points in his decade long run on that Committee, and took Coughlin on a three hour tour of
moralizing in the first February 2002 insufficiently notice "Hearing" (Dean Morgan shows up to
testify, unnoticed to Coughlin, and by the time the change of address got the notice ot Coughlin he
had about 6 days advance notice of the hearing....(at that February 2002 Hearing, then C&F
Committee Chairman Mike Rowe joined in with his aghast horror at the treatment poor 'lil Mark
Tratos was exposed to in "snippy" email between he and Coughlin upon Tratos "losing' Coughlin
term paper in the summer 2001 Cyber Law course, and see attached materials detaling Rowes
subsequently threatening letters to, basically, go along with the Christiansen/Kelly,
uh..."arrangement"...."how much money does your father make? What kind of car do you drive?"
asks Kelly at the February 2002 credit application interview, er, C&F Committee Hearing (and Jon
Bailey, at the informal conference weeks previous thereto made Bryant Gumbel's pretentious style
seem downright folksy in comparision.)(that Coughlin was taking along with and ADR course during
the summer following his second year of law school, during which time he was one of two people
that year to pass the Nevada Bar Examination as a second year law student. Coughlin was tenth in
his class at Boyd, graduatin in December 2001 (didn't go to the graduation ceremony and had to nix
plans for his 88 year old second wave on Omaha Beach D-Day Normandy veteran grandfather
James Theodore Coughlin to attend given Phil Burns, law school dean who didn't go to law school
Christine Smith, and Mary LaFrance/Mark Tratos dragging on an "investigation" into academic
propriety that predictably turned up jack (actually, now Assemblyman William Horne was one of the
students who saw Coughlin turn his paper in that day, along with another couple students signing
affidavits to that fact, and its ironic, given Mr. Horne and fellow BSL early days alumn Jason Frierson
were, along with Segerblom and WLS's Sasser so instrumental in adding the requirement in NR
40.253 that the landlord must list the forum to file the tenant's affidavit, especially consdiering the
arrest in rcr2012-067980 and the summary eviction by "eviction consulting and process service"
company Nevada Court Services in RJC rev2012-001048). Coughlin is also know to have some
idea of the chances of a shot or argument going in, as well as how to get to the free throw line:
http://www.niaa.com/sports/bkb/2012-13/releases/Basketball-_Boys_(2012).pdf
http://www.nfhs.org/recordbook/SearchResults.aspx?criteria=coughlin
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and its a complex rich relationship with Coe Swobe, who is, indeed, as Mr. Silverman says "the grey
immanence" of that segment of the Bar....and Gary should know, as he himself, as you all know, is
the "Yellow Grandeloquence"....coughlin tries to be the Chartreuse Exuberance, but often must settle
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for being the Burgandy Deliberance. )...Mr. Silverman's assessment of this Panel's approached is
succinty stated in the follow email to Coughlin (which is generously gave his time to write after
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reviewing Coughlin, incorporated by reference into this proceeding 60838 and 61426 filing with the
N.S. Ct on 8/13/12, in Mr. Silverman writing:
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re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
Gary Silverman (silverman@silverman-decaria.com)Add to contacts 8/13/12 To:
Zach Coughlin From:
Gary Silverman (silverman@silverman-decaria.com)
This sender is in your safe list. Sent:
Mon 8/13/12 11:28 AM To: Zach
Coughlin (zachcoughlin@hotmail.com) I think this is waaaaay too complex and
detailed. Give them a procedural history and whether there is a final judgment in the
crim case and point out that your temporary suspension is akin to a permanent
death of your practice. Or, if true, say you....(redacted) now have access to your
meds and are ok. I can't think this pleading is going to help you much...it is too long,
repetitive and does not seem to deal with why the temp suspension is simply wrong
or harsh. If you can't make your case in 3-5 pp, you can't make your case in 35.
You do seem to be a good lawyer, however. At bottom, Steve Harris took
hundreds of thousands of dollars and had no temp suspension; you stole a
candy bar (at worst). WTF. " Stephen R. Harris, Esq. was reinstated to the
practice of law by Order of the Nevada Supreme Court (upon the SBN waiving its
SCR 116 appeal rights by stipulation) on November 8th, 2012.
As to Coughlin's 6/7/12 temporary suspension ORder, only three justices signed it (one of
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whom has recused himself from another case, 60302 or 60317 between Coughlin and Washoe Legal
Services, and Garin's, SBN Ethics Committee Member's REspondent Brief of 10/22/12 will make
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Coughlin's arguments regarding service and process and due process deficiciencies herein seem
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magnanimous by comparison), one of whom was Chuck's (and Chuck is a dear friend...and a
disclaimer...all this criticism of Judges is coming from one who could never imagine the stress and
burden that being a Judge must entail...it must literally weigh on one like a thousand pounds
everyday...but Coughlin is the son of a Judge Whisperer and only doing that which comes naturally
to him...and he's going to love these Judges through this...because this is where the healing starts,
and we got their bags packed (their spouses were more than willing to help with that, no surprise,
there) and a plane ticket to Biloxi, and the car is runnin' outside, and when they come back, better
than ever, they are going to be just as welcome as the flowers in May...as long as they take this
"come to Jesus" talk to heart and proceed accordingly) very, very close friend..., whose old law clerk
used to find his way to Thursdays , who had some dealings with noted "Judge Whisperer" Dr.
Timothy D. Coughlin, MD, and who some used to see once in a while on thursday, but not so much
anymore since he got on with the NNDB...but just be honest with what you are doing what you do
over. Dont say its to help someone when its really to issue a beat down for those with power. Look
at the Beckett case. Look at Harris's. When you start mixing medicine and mental health into
disciplinary contexts, the tryants first leverage is "concern" and "treatment". In my time as a
domestic violence attorney (which is by far the best training any young attorney could possibly get,
thanks Paul Elcano and Caryn Sternlicht) Typically the hardest people to win over or please when in
situations like mine are those in recovery. They are extra, extra hard on you, preacher's daughter,
coaches son, theme. And often they are zealots who lack perspective. And Pat King and other bar
counsel's of the past say things that indicate they see me as this young man and how a 5 or 6 year
suspension would really just be a blip in my career in the grand scheme of things. I went an had an
sit down with King for a couple hours a week ago, and generally it was pretty positive, but clearly
King has no intention of moving the process along (he is banking on me signing on to a SCR 117
petition and actually expects me to believe the bar will succeed in having me permanently disbarred
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over a candy bar so soon after Steve Harris's deal, which I found out some new salacious details
about, from Pat King, no less...), the suspension was June 7th, 2012, and the Order called for a
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formal hearing before the Disciplinary Board, yet no mention of one being scheduled some 2 months
later, I call to schedule one and the say the first available hearing date is 2 months out,....you see
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where this is going...its going to be a suspension of over 6 months requiring an Order of the
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Supreme Court for reinstatement under SCR 116 as opposed to something like Drakulich got when
he had a DUI hit and run (10 day suspension).
I listen to Chuck, just not exactly to what he says to me about what I should do, I more listen to the
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actions than the words. I learned from watching him 'bout five years agoor whenever it was the the
Temporary Pro's committee thing was all over his case, and he was just battling back at them,
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counterpunches. Because there is room in the law for that, and any doctrine that says you have to
confess to show mitigation is just such a perversion of our system of justice...whether this is a
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"privilege with conditions" or not...Cardozo....
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I am not real pleased with Judge William Gardner. I currently have a I just had to write the United
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States Patent and Trademark Office a letter reporting my conviction for trespass. This could get
ugly for Judge W. Gardner as well if I have to litigate the crap out of that conviction (reciprocal
discipline rules with the USPTO allow for a showing that, basically, if the proceeding from which the
conviction stems was so wholly devoid of due process, then the USPTO does not have to follow suit
with reciprocal discipline....). I was in the Associated Press about the Wal-Mart candy bar thing on
June 8th, 2012, and still he manages to find me guilty of criminal trespass incident to a civil eviction
proceeding (even where Sferrazza completely departed from the express dictates of NRS 40.253(6)
by ordering me to deposit $2,275 worth of rent escrow into the Justice Court in a summary eviction
proceeding a week before the hearing, then continued to have the RJC hold onto that money for
another 12 days, during which I was supposed to somehow hire movers and rent a moving truck and
move a home office full of property, while also allowing Richard Hill in for an inspection....and
Sferrazza further kept 10 times the amount of money required for a stay on appeal whilst denying the
stay....then Richard Hill gets Sferrazza to sign an Order that transfers the right to that rent escrow
deposit of $2,275 to Hill's client despite the fact that Sferrazza's Order as orally pronounced
indicated the money would remain mine, but retained by the RJC in the meantime as an appeal
bond...and I get suspended for allegedly consuming a candy bar while shopping for an paying for
$83.82 of groceries?). And Judge W. Gardner ruled all of that was irrelevant, while also refusing to
recuse himself despite his providing the RMC and Judge Nash Holmes his sister's Order for
Sanctions ($1,000 worth of attorney's fees in a divorce case from March 2009 under NRS 7.085),
which, apparently, the RMC promptly provided to Pat King and the State Bar and which is now the
subject of a formal complaint or grievance against me....and, further, Judge W. Gardner worked for
the Reno City Attorney as a prosecutor as recently as two years ago and there is (hopefully not)
reason to believe their is "impending litigation" given the extent to which my professional career has
arguably been ruined by the misconduct of both the Reno City Attorney prosecutors (putting on
testimony they know to be false by both the Wal-Mart associate and the RSIC Police, given the
testimony about Coughlin's not provided a driver's license and that allegation supposedly providing
the rationale or probable cause for effecting a custodial arrest for a misdemeanor occurring outside
the officer's presence...despite the fact that the surveillance video from Wal-Mart's interrogation
room, dispatch reports, and jail intake inventory records, and the officer's own arrest reports (which
the video clearly shows him copying information from Coughlin's driver's license onto) all clearly
establish that the office was provided Coughlin's Nevada driver's license, despite his sworn
testimony to the contrary, and therfore, a Fourth Amendment violating impermissible search
occurred, and the fruit of the poison tree should not be the main basis for innuendo leading to
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Coughlin's petty theft conviction of cough drops, particulary where the testimony of both Wal-Mart's
Frontino and RSIC Officer Crawford was expressly disproved with hard evidence (comparing the
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receipt of $83.82 worth of groceries purchased with the UPC from the receipt Wal-Mart prepared
containing the UPCs of the allegedly stolen cough melts clearly shows that the UPC of the cough
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melts does, in fact, appear on that receipt for $83.82, whereas both of those witnesses testified that it
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did not and that Coughlin did not have any such cough melts rung up or paid for).
Nevada Code of Judicial Conduct Rule2.4.External Influences on Judicial Conduct.
(A)A judge shall not be swayed by public clamor or fear of criticism.
(B)A judge shall not permit family, social, political, financial, or other interests or
relationships to influence the judges judicial conduct or judgment. (RMC Judges admit to
stragegy sessions vis a vis "adding to your little record, there" to quote a menacing
commentary by Judge Nash Holmes in the conext of her sound byte: "i don't care about
retaliation, I don't care about corruption, I don't care about bribery...all that is relevant is the
Bouldevard Stop...")
(C)A judge shall not convey or permit others to convey the impression that any person or
organization is in a position to influence the judge.
COMMENT
[1]An independent judiciary requires that judges decide cases according to the law and facts,
without regard to whether particular laws or litigants are popular or unpopular with the public, the
media, government officials, or the judges friends or family. Confidence in the judiciary is eroded if
judicial decision making is perceived to be subject to inappropriate outside influences.
Member of the judges family means a spouse, domestic partner, child, grandchild, parent,
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grandparent, or other relative or person with whom the judge maintains a close familial relationship.
See Rules 3.7, 3.8, 3.10, and 3.11.
http://www.leg.state.nv.us/courtrules/scr_cjc.html
Impending matter is a matter that is imminent or expected to occur in the near future. See Rules
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2.9, 2.10, 3.13, and 4.1.
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Impartial, impartiality, and impartially mean absence of bias or prejudice in favor of, or against,
particular parties or classes of parties, as well as maintenance of an open mind in considering issues
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that may come before a judge. See Canons 1, 2, and 4, and Rules 1.2, 2.2, 2.10, 2.11, 2.13, 3.1,
3.12, 3.13, 4.1, and 4.2.
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Nevada Code of Judicial Conduct Rule2.11.Disqualification.
personal knowledge of facts that are in dispute in the proceeding.
(2)The judge knows that the judge, the judges spouse or domestic partner, or a person within
the third degree of relationship to either of them, or the spouse or domestic partner of such a person
is:
(a)a party to the proceeding or an officer, director, general partner, managing member, or
trustee of a party;
(b)acting as a lawyer in the proceeding;
(c)a person who has more than a de minimis interest that could be substantially affected by
the proceeding; or
(d)likely to be a material witness in the proceeding.
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(3)The judge knows that he or she, individually or as a fiduciary, or the judges spouse,
domestic partner, parent, or child, or any other member of the judges family residing in the judges
household, has an economic interest in the subject matter in controversy or in a party to the
proceeding.
(4)[Reserved.]
(5)The judge, while a judge or a judicial candidate, has made a public statement, other than in a
court proceeding, judicial decision, or opinion, that commits or appears to commit the judge to reach
a particular result or rule in a particular way in the proceeding or controversy.
(6)The judge:
(a)served as a lawyer in the matter in controversy or was associated with a lawyer who
participated substantially as a lawyer in the matter during such association;
(b)served in governmental employment and in such capacity participated personally and
substantially as a lawyer or public official concerning the proceeding, or has publicly expressed in
such capacity an opinion concerning the merits of the particular matter in controversy;
(c)was a material witness concerning the matter; or
(d)previously presided as a judge over the matter in another court.
(B)A judge shall keep informed about the judges personal and fiduciary economic interests and
make a reasonable effort to keep informed about the personal economic interests of the judges
spouse or domestic partner and minor children residing in the judges household.
(C)A judge subject to disqualification under this Rule, other than for bias or prejudice under
paragraph (A)(1), may disclose on the record the basis of the judges disqualification and may ask
the parties and their lawyers to consider, outside the presence of the judge and court staff, court
officials and others subject to the judges direction and control, whether to waive disqualification. If,
following the disclosure, the parties and lawyers agree, without participation by the judge or court
staff, court officials and others subject to the judges direction and control, that the judge should not
be disqualified, the judge may participate in the proceeding. The agreement shall be incorporated
into the record of the proceeding.
COMMENT
[1]Under this Rule, a judge is disqualified whenever the judges impartiality might reasonably be
questioned, regardless of whether any of the specific provisions of paragraphs (A)(1) through (6)
apply. For example, if a judge were in the process of negotiating for employment with a law firm, the
judge would be disqualified from any matters in which that law firm appeared, unless the
disqualification was waived by the parties after disclosure by the judge.
[2]A judges obligation not to hear or decide matters in which disqualification is required applies
regardless of whether a motion to disqualify is filed.
[3]The rule of necessity may override the rule of disqualification. For example, a judge might be
required to participate in judicial review of a judicial salary statute, or might be the only judge
available in a matter requiring immediate judicial action, such as a hearing on probable cause or a
temporary restraining order. In matters that require immediate action, the judge must disclose on the
record the basis for possible disqualification and make reasonable efforts to transfer the matter to
another judge as soon as practicable.
[4]The fact that a lawyer in a proceeding is affiliated with a law firm with which a relative of the
judge is affiliated does not itself disqualify the judge. If, however, the judges impartiality might
reasonably be questioned under paragraph (A), or the relative is known by the judge to have an
interest in the law firm that could be substantially affected by the proceeding under paragraph (A)(2)
(c), the judges disqualification is required.
[4A]The filing of a judicial discipline complaint during the pendency of a matter does not of itself
require disqualification of the judge from presiding over the litigation. The judges decision to recuse
in such circumstances must be resolved on a case-by-case basis.
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[5]A judge should disclose on the record information that the judge believes the parties or their
lawyers might reasonably consider relevant to a possible motion for disqualification, even if the judge
believes there is no basis for disqualification. A judge making such a disclosure should, where
practicable, follow the procedure set forth in Rule 2.11(C).
[6]Economic interest, as set forth in the Terminology section, means ownership of more than a
de minimis legal or equitable interest. Except for situations in which a judge participates in the
management of such a legal or equitable interest, or the interest could be substantially affected by
the outcome of a proceeding before a judge, it does not include:
(1)an interest in the individual holdings within a mutual or common investment fund;
(2)an interest in securities held by an educational, religious, charitable, fraternal, or civic
organization in which the judge or the judges spouse, domestic partner, parent, or child serves as a
director, officer, advisor, or other participant;
(3)a deposit in a financial institution or deposits or proprietary interests the judge may
maintain as a member of a mutual savings association or credit union, or similar proprietary
interests; or
(4)an interest in the issuer of government securities held by the judge.
Nevada Code of Judicial Conduct Rule3.10.Practice of Law.Unless otherwise permitted by
law, a judge shall not practice law. A judge may act pro se and may, without compensation, give
legal advice to and draft or review documents for a member of the judges family but is prohibited
from serving as the family members lawyer in any forum.
COMMENT
[1]A judge may act pro se in all legal matters, including matters involving litigation and matters
involving appearances before or other dealings with governmental bodies. A judge must not use the
prestige of office to advance the judges personal or family interests. See Rule 1.3.
Rule1.3.Avoiding Abuse of the Prestige of Judicial Office.A judge shall not abuse the prestige
of judicial office to advance the personal or economic interests of the judge or others, or allow
others to do so.
COMMENT
[1]It is improper for a judge to use or attempt to use his or her position to gain personal
advantage or deferential treatment of any kind. For example, it would be improper for a judge to
allude to his or her judicial status to gain favorable treatment in encounters with traffic officials.
Similarly, a judge must not use judicial letterhead to gain an advantage in conducting his or her
personal business.
[2]A judge may provide a reference or recommendation for an individual based upon the judges
personal knowledge. The judge may use official letterhead if the judge indicates that the reference is
personal and if there is no likelihood that the use of the letterhead would reasonably be perceived as
an attempt to exert pressure by reason of the judicial office.
[3]Judges may participate in the process of judicial selection by cooperating with appointing
authorities and screening committees, and by responding to inquiries from such entities concerning
the professional qualifications of a person being considered for judicial office or by submitting on
official letterhead letters to such entities endorsing or opposing the person.
[4]Special considerations arise when judges write or contribute to publications of for-profit
entities, whether related or unrelated to the law. A judge should not permit anyone associated with
the publication of such materials to exploit the judges office in a manner that violates this Rule or
other applicable law. In contracts for publication of a judges writing, the judge should retain sufficient
control over the advertising to avoid such exploitation."
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Showing out for one's sister is arguably "advancing the personal or economic interests of the
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judge or others" in violation of NCJCR 1.3. And some might, for similar reasons (especially in light of
the 2011 scandal wherein the Reno Muncipal Court attributed some $700K that went missin' to "data
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entry errors" and stuff) that Judge Nash Holmes put Coughlin on blast with her 2/28/12 Contempt
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Order and Issuance of Sanctiosn in 11 TR 26800 (and somehow, despite it not being within 10 days,
and therefore outside her jurisdiction to alter or amend the civil contempt finding that Judge Nash
HOlmes base her 2/28/12 order on (NRS 22.100 is a civil statute, ie, its not the criminal contempt
misdemeanor that Judge Nash Holmes remixed it to be a la NRS 199.340: (NRS 199.340 Criminal
contempt. Every person who shall commit a contempt of court of any one of the following kinds shall
be guilty of a misdemeanor: 1. Disorderly, contemptuous or insolent behavior committed during the
sitting of the court, in its immediate view and presence, and directly tending to interrupt its
proceedings or to impair the respect due to its authority; 2. Behavior of like character in the presence
of a referee, while actually engaged in a trial or hearing pursuant to an order of court, or in the
presence of a jury while actually sitting in the trial of a cause or upon an inquest or other proceeding
authorized by law; 3. Breach of the peace, noise or other disturbance directly tending to interrupt the
proceedings of a court, jury or referee; 4. Willful disobedience to the lawful process or mandate of a
court; 5. Resistance, willfully offered, to its lawful process or mandate; 6. Contumacious and unlawful
refusal to be sworn as a witness or, after being sworn, to answer any legal and proper interrogatory;
7. Publication of a false or grossly inaccurate report of its proceedings; or 8. Assuming to be an
attorney or officer of a court or acting as such without authority.)
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Uh...no on the ghostwriting gessin allegations. as to the richard g. hills unsigned, unsworn
grievance, need more clarification as to the variosu allegatiosn hill makes, until then, a blanket
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denial. blanket denial of all allegations against coughlin in any way pled in King's SCr 105 complain
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at issue here.
correct to Coguhlin's Deisgnation of Wtiness...it was error to whatever extent any suggstion was
made that coughlin fails to oppose judge nash holmes, or anyone testiying by phone, period.
absolutely not agreeing to that.
Both Judge W. and Judge L. Gardner should be required to testify, along with Judge Nash Holmes
as to what letterhead was used, the passing of the April 2009 Order sanctioning Coughlin from
Judge L. to her brother, Judge W. Gardner, and his passing that Order to "the other RMC Judges",
which Judge W. Gardner appears to have admitted to having done, on the record, during the 4/10/12
Hearing in the trespass matter 11 CR 26406, as the RMC's Administrative Judge, to the other RMC
Judges (including Judge Howard, who had Coughlin's 11 CR 22176 before him then, and Judge
Nash Holmes, who had Coughlin's 11 TR 26800 before her, and whom was transferred from D1, by
Judge W. Gardner, Coughlin's 12 CR 00696 on 2/27/12 (very curious date and timing for such a
transfer given all the other things that occured on 2/27/12 with Coughlin's Appeal in the Judge Elliot
case involving Washoe Legal Services (CV11-01955), more eflex rejections thereof by Lori Matheus,
(there is just a lof of Judges whom are former prosecutors seemingly issuing a beat down of
Coughlin here, in part on behalf of Washoe Legal Services and Paul Elcano (whom holds himself out
as a close personal friend of Judge L. Gardner, District Attorney Gammick (Elcano announced this in
anticipation of WLS being awarded the ECR Program contract, which arguably violates the Sixth
Amendment...basically, Washoe Legal Services is an entity that holds itself out as one thing...but
there sure are a lot of prosecutors and former prosecutors working that marionette's strings). (RMC
Judge W. Garder is the brother of the Judge Linda Gardner who was apparently extremely upset that
Coughlin not only didn't came to her and Springgate's coercive "settle or else" onslaught minutes
before the Trial on April 12, 2009 (Judge L. Gardner, during an impromptu Settlement Conference
angrily hissed at Coughlin's client, Bharti Joshi "don't listen to your attorney!", and, with Joshi by his
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side, snapped at Coughlin "shut up!", the proceeding to say she was offering Coughlin suggestions
on how to try his case in the Trial, only to explode in rage at Coughlin when he thanked her for his
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suggestions but indicated he needed to try the case in a manner that aligned with zealously
adovcating for his client's interests, and not with an overly weighted concern for Mr. Springgate's
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profit margin or the Court's intentions regarding the doling out of its judicial resources. Coughlin
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filed the Mandamus Petition against her in 54844 (containing inflammatory material related to the
coercive practices with with Judge L. Gardner sought to extract an agreement to John Springgate,
Esq's illusory settlement proposal (Springgate's proposal was not fraudulent or anything, but it is not
accurate or fair to suggest that Coughlin was being vexatious to meet the NRS 7.085 standard that
the Legislature created with med mal cases in mind (if they only could have imagined the perverted
applications to which it is put these days...basically there is a lot of gang bangin' people out of their
due process goin' on these days under the rubric of some feigned cry of "vexatiousness!". Please.
Further, it is beyond supportable the extent to which Judge Howard, Nash, and Gardner make
rulings on relevancy based upon an impermissible goal, to quote Keith Loomis, Esq. (RMC court
appointed defender, whose "work" in the jails must be seen to be believed (Loomis does nothing that
a laminated poster couldn't do, sort of like a "hey, here are your Workplace Rights" laminated deal in
the breakroom...well actually, Loomis does not even do that much, he actively and aggresively sets
the table for the prosecutor's from the Reno City Attorney's Office. They have a real routine goin'
down there. Further, then Master Linda Gardner was apparently rather upset that Coughlin pointed
out that she seemed to be overstepping her jurisdiction a bit, outside of that accord her in NRS
33.018 in a TPO wherein another local attorney, Richard Molezzo, Esq. line up opposite Coughlin, in
FV08-03380 - BRENDA SANTIAGO VS XRHSTOS VAXEVANIS Filing Date: Tuesday , September
09th, 2008) 30-OCT-2008 04:47 PM Obj to Master's Recommendation Entry: APPLICANT'S
OBJECTION TO MASTER'S RECOMMENDATIONS 08-JAN-2009 11:46 AM Application for Setting
Entry: Obj. to Master's Rec re TPO; 2/23/09 @ 9:00 am 23-FEB-2009 09:39 AM Heard ... Entry:
MASTER'S RECOMMENDATION AFFIRMED. nm/cd 23-FEB-2009 09:41 AM ***Minutes Entry:
2/23/09 OBJECTION HEARING - Transaction 611628 - Approved By: NOREVIEW : 02-232009:09:41:22 24-FEB-2009 01:29 PM Ord After Hearing... Entry: DENYING OBJECTION TO
MASTER'S RECOMMENDATION. The February 23rd, 2009 Hearing on the Objection to Master
Gardner's Recommendations that Coughlin filed (relating to Master Gardner giving a car and or that
car's title to the individual Coughlin's client sought protection from, despite their apparently having a
shared interest therein, and there being a legitimate dispute as to the documentation, and the fact
that a TPO Hearing is not the appropriate setting for such subject matter, especially where Master
Gardner lacked jurisdiction to rule as she did. Perhaps Coughlin's firing from WLS in 60302 is why
WLS"s landlord tenant attorney Mark Ashley, Esq. regularly refuses to advocate with any zeal on
behalf of this tenant client's, as Coughlin observed on March 15th, 2012 when Coughlin appeared to
content the eviction brought against him in (again, in another No Cause Eviction against Coughlin
where he was arguably a commercial tenant and the Notice served was a No Cause Eviction Notice
only, though there is some indication, at least from a docket entry in that matter RJC rev2012000374, that Gayle Kern, Esq. and or Sue King (unauthorized practitioner of law property manager
for Western Nevada Management, Inc.) responded fraudulently to Coughlin's Pre-Hearing Brief in
that matter that pointed out the difficulties ahead for their client, Park Terrace Town Home's HOA in
light of various problems with the Notice and matters pled by PTTHOA (basically, the Notice was No
Cause and non-payment was not alleged (until, perhaps the day of the Hearing, a review of the
Landlord's Affidavit is necessary, as is the proof of service thereof, and the proof of service of Judge
Schroeder's Orders in that matter and an inquiry into why the RJC failed to file Coughlin's Notice of
Appeal thereof on March 16th, 2012 (the implication is that Gayle Kern and, some might say, the
RJC went out of their way to avoid a repeat of the Merliss v Couglhin eviction case involving Richard
Hill and Casey Baker (RJC Rev2011-001708). When Coughlin appeared for the summary eviction
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proceeding in the RJC on March 15th, 2012 his case was already decided against him on a default
basis, despite the fact that the Hearing was to start at 8:30 am, and the fax sheet of the Eviction
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Order signed by Judge Schroeder indicates a time of 8:24 am. Nonetheless, Coughlin sat around in
court to observe Ashley's advocacy (Coughlin was able to listen to Ashley and his Paralegal,
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Christine Saito, conduct business as the Landlord Tenant attorney and paralegal at Washoe Legal
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Services for 18 months, having offices within whispering distance of each other, from September
2007 to Coughlin's firing by WLS Executive Director Elcano in May 2009 (See Elcano's attached
letters detailing that the firing was solely predicated upon Judge L. Gardner's April 2009 Order
sanctioning Coughlin in the Joshi divorce matter DV08-01168 (that spawned the Mandamus Petition
by Coughlin against Judge L. Gardner 54844). Judge L. Gardner recused herself from the next case
she had Coughlin appearing on assigned to her, Bell v Greer, FV11-04268...which arguably
presented the same basis for her brother to recuse himself inthe criminal trespass prosecution of
Coughlin. attached my Emergency Ex Parte Motion (perhaps not "ex parte" given Bar Counsel was
provided it). Also, please note, the October 9th, 2012 certificate of mailing by the SBN for the Notice
of Intent to Take Default was never served on me in any way shape or form until I received the copy
of the "entire" file form Sierra Legal Duplicating. The State Bar of Nevada knows this. They put the
wrong postage on the certified mail envelope containing the Notice of Intent to Take Default. When I
went to pick it up "Tim" USPS counter attendant at the Vassar Postal Station here in downtown Reno
refused to allow me to pick up that certified mailing given that is was about $5.00 deficient in
postage. I did not have $5.00 and it is not be responsibility to pay it, as far as I know. In fact, I have
asked the Bar and this Panel to allow me to proceed in forma pauperis in this matter, and am doing
so again here (I am flat broke, I have a 1996 Honda Accord, rent a room for $300 a month, have less
than $200 in my bank account, no stocks, no bonds).
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Also King is attemptign to do something really weasely here (nothing new for King) in backtrackign
on what he told Coughlin Bar Counsel Clark had given Coughlin authority to do (ie, issue subpoenas
despite being a suspended attorney...King is now trying to argue some necessarily ultra redundant
interpreation fo that wherein he was merely relaying a message from Clark that, yes, Coughlin had
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authority to have SBN Clerk of Court Peters (whom King constantly plays marionette master to,
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despite whatever he says when the lights are on that conduct) issue supboenas which Coguhlin
could then have served (and Peters told Coughlin he didn't have to pay witness or subpoena fees,
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and in fact, that now Respondents do in these matters.
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I have been mislead or lied to by the SBN in numerous ways in this proceeding. I was told I could issue subpoenas despite
being a suspended attorney (and there is case law that says even when suspended, one is still an "attorney"). I was told I
20 would not be required to pay subpoena fees. I was told the August 23rd, 2012 certified mailing would absolutely not be
used to prove proof of service of the Complaint in this matter, SBN v. Coughlin. Yet a review of the files reveals that the
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SBN and Panels only Return of Service (and see SBN Ethics Committee Member Joseph Garin's recent Brief in 60302
seeking to dismiss my entire wrongful termination lawsuit against Washoe Legal Services) for a real ironic example of
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just why the hearing on November 14th, 2012 must not go forward. It is fraudulent for the State Bar of Nevada to stipulate
with me that the August 23rrd, 2012 certified mailing of the Complaint is alleges was sent and that Clerk of Court Peters
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admits to having received back on September 10th, 2012 would never be cited to as effecting service of the Complaint
upon me or otherwise put forward as proof of return of service etc. Now the SBN seeks to get around the inconvenient
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fact that, instead of holding my hearing on September 25th, 2012 (Clerk Peters told me it was on the calendar, I was
noticed of it in writing, I agreed to that date for the Hearing amongst a choice of dates, etc..) Bar Counsel King attempted
25 to shove a document he alleges was the Complaint in my suit jacket, then persisted in ordering Clerk of Court Peters
(whom King alternately claims to have separation from and no authority over with ordering her not to file my Motion to
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Dismiss, attempting to reneg on stipluations and representations made by the SBN, etc). Further, it is wrong for Clerk of
Court Peters to be signing the certificates of mailing for both the SBN and for the Panel Chair. Additionally, under SCR
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105(2)(c), it is the Panel that must send the Respondent the Notice of Hearing "at least 30 days" prior to the Hearing date,
and that Notice must include with it the Designation of Witnesses and Summary of Evidence, and it must be served in the
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EMERGENCY EX PARTE MOTION TO DISMISS, VACATE, RESET OR POSTPONE THE 11/14/12 HEARING
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same manner as the Complaint. It is impermissible for Pat King to attempt to mail out the Notice of the Hearing and
Designation of Witnesses weeks before the Panel is even announced (how can you possibly be pretending to take your
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duty as a Panel member seriously when you are essentially showing up the day of the first game, skipping all the practices
and pre-season games....we all saw how that turned out for Bret Farve in his last season. It is appalling to me that you
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intend to hold this hearing given these blatant violations of SCR 105(2)(c), but when you add to that the fraudulent
conduct of Pat King, in failing to amend his and or Clerk of Court Peters certificate of mailiing or return of service for the
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purported certified mailing (and, contrary to the SBN's established practice detailed in the certificates of mailing I have
review upon finally being granted a copy of the "file", though, the rule says I get to go to the SBN's offices and review
5 certain things "up to three days"...not have Pat King and Laura Peters manufacture some nonsense about why I am not
allowed at the building or otherwise violating my rights (which is something King and Peters do everytime they get
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caught violating the rules.) Further, I have been (and some might say this was largely by design) jammed into having this
Disciplinary Hearing on November 14th, 2012 in impermissible proximity to the petty larceny trial in rcr2011-063341
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(see Montiero for why it is not even appropriate for King to be seeking to force me to prejudice my defense in that matter)
on November 19th, 2012, in Department 2, before Judge Sferrazza, whom presided over the summary eviction/unlawful
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detainer "Trial" from my former home law office that the criminal trespass arrest, jaywalking arrest (King's Complaint
doesn't manage to specify that the January 12th, 2012 arrest was for jaywalking outside my former home law office
9
shortly after my collecting video evidence revealed the fraud attendant to Hill's contractor havig used my own plywood to
board up the back porch of the property....Hill, also, at that time, went and got a TPO that was based largely upon an
10 outright lie, ie, that I "climbed up on" the contractor Phil Stewart's truck). I believe this Panel should review (I cannot
affor the $35 to $70 for the video of the two hearings on Hill's Motion for Order to Show Cause of January 20th, 2012 (the
11
Order to Show Cause was served by RMC Marsm hal Harley, despite what WCSO Deputy Machen said he personally
served in his affidavit (Machen also lied about personally serving the eviction lockout order for HIll, and HIll lied at the
12
trespass trial when he testified that Machen "posted it on the door becaues you ran away", Hill also lied at trial when he
alleged the Reno PD announced themselves as law enforcement and issued a lawful order to emerge form the basement
13
prior to the landlord kicking in the door, and Hill also lied about whether anyone that day warned Coughlin to leave the
property prior to Hill's signing the criminal complaint to affect a custodial arrest for criminal trespass).
14
Additionally. I moved recently, and updated my SCR 79 address in compliance with that Supreme Court Rule well within
the 30 days of my moving. Further, I filed an official Change of Address with the USPS, and that caused delays in
15 receiving my mail incident to the typical forwarding procedures of the USPS, and I have the yellow stickers on the
envelopes to prove it. Further, besides submitting an official Change of Address form to the Vassar Station on October
16
5th, 2012, Coughlin wrote the SBN on October 14th, 2012, and provided his new 1471 E. 9th St. mailing and physical
address, in addition to updating the online portal and the NV CLE Board even prior to that, all in compliance with SCR
17
79.
18
I do not consent to service or notice of anything electronically in this proceeding, but I do appreciate
19
being copied on such things via email and fax)
20
21
22
23
Bar Counsel Patrick O. King has clearly become very intimidated by the Panel, and especially it's
24
Chair, John Echeverria, indicating a real withering desire for proceeding with this case but helpless in
the face of a command from higher up, and arguably outside of the permissible authority or exertion
of influence of those from which it emanates. King has been especially critical of the NNDB and
26
Panel for its actions in connection with the recent reinstatement of Stephen R. Harris, Esq.,
(reinstated to the practice of law on November 8th, 2012) as has Gary Silverman, Esq.:
25
27
28
000261
2
intersting that the SBN and the Panel seek to plung headlong into the 11/14/12 hearing that violates
3
absoltuely every section of NR 105(2)(c) (one of the very, very few provisions of the Supreme Court
4
5
6
10
11
12
13
14
15
16
17
18
Rules speaking to the due process requirements of these disciplinary hearings (which some
watching Coughlin circa 2002-2005 might say often devolve into kangaroo courts where some
corrupt bully (some might say Strip Club Spearmint Rhino owner Kevin Kelly, Esq., decade long
member of the State Bar of Nevada's Character and Fitness Committee, whose club allegedly
funnels $10 million a year ot Vegas cabbies to direct tourists to its doors..Coe Swobe making' calls
there too, just like in 60302 where he is calling Coughlin and his father seeking to do WLS's and
Elcano's bidding) who chips off his friends (Peter Christiansen, Jr. Esq.) despite saying the
respresentations would be pro bono (despite receiving $5,000, Christiansen still, on the record,
for him to file a six page, rather repid arrangment worth of a Pre Hearing Brief (containing
dog and pony s how hearing (wherein, his friends having been paid, C&F Committee Strip Club
crime, based largely on some retatliation that Mark Tratos, Esq. largely admitted to, along with Mary
Lafrance (don't recall Jessica Wolf, Esq. (one of two students name in an email about missig papers
in that summer 2001 cyber law class, and Anderson and Morishita indicate, as past patent attorney
in Tratos's firm, that Tratos had "lost" other students papers before too..something tratos had to
admit under oath in 2007) send me "another" copy of you paper..."what was it about" the "name of
the case involved" (gee Tratos, kind of sounds like you had the version Coughlin submitted with only
his social security number (in compliance with the Boyd School of Law's blind grading policy, which
19
20
Judge W. Gardner made some extremely curious statements during the proceedings in the criminal
21
trespass case. Included amongst these was a statement that he "could not remember" or "was not
sure" if he ever saw or was aware of the formal complaint filed by the RMC and or RMC Judge Nash
Holmes against Coughlin with the State Bar of Nevada and whether or not that submission to the
23
State Bar included a copy of the April 2009 Order by Judge W. Gardner's sister, Family Court Judge
L. Gardner, sanctioning Coughlin $1,000 for "vexatious conduct" incident to Coughlin representing a
24
domestic violence victim on behalf of a legal aid organization (in Nevada Supreme Court case
number 54844, Coughlin v. District Court) wherein Coughlin was actually arguing a position that is
25 clearly the majority viewpoint throughout American jurisprudence:
22
26
Then Judge W. Gardner indicated, on the record, while insisting upon proceeding with Coughlin's
27
criminal trespass trial, despite Gardner's fellow RMC Judge Nash Holmes filing a complaint with the
28
000262
1
State Bar of Nevada seeking to have Coughlin declared incompetent or disabled and, therefore,
unable to practice law, that various Order by RMC Judge Nash Holmes and other materials which
2
Judge W. Gardner admitted to reviewing and or being aware of did not bring into question Coughlin's
competency. Further, Gardner's Order of Conviction finding Coughlin guilty of criminal trespass, as
3
announced in open court in RMC 11 CR 26405, as announced from the bench on June 18th, 2012,
4
5
6
10
11
indicated it rested upon clearly inappropriate or irrelevant facts or matters not in evidence (Gardner
supported his Order by referring to emails allegedly from the landlord's attorney that were not
introduced into evidence, supposedly providing the warning necessary for a trespass conviction
under RMC 8.10.010, despite testimony that Coughlin was repeatedly issued written warnings to the
landlord's counsel that Coughlin did not agree to accepting service or notice of anything incident to
the summary eviction proceeding via electronic means. This contrasts sharply with Judge Gardners
ruling that he would not consider Coughlin's argument that the Reno Justice Court, in the summary
eviction proceeding in RJC REV2011-001708 was actually divested of jurisdiction by Coughlin filing
a Notice of Appeal following an initial hearing (see attached NRCP 60(b) Motion to Set Aside
Eviction Order) or deem an evidence thereof to have been put into evidence despite Coughlin 's
seeking to do so and despite Coughlin's court appointed Counsel, Keith Loomis, prior to his
withdrawal, arguing in court at a preliminary hearing, that such a divesting of jurisdiction did in fact
vitiate the import of any such Order of Summary Eviction. Mack-Manley v. Manley, 122 Nev. 849
(2006), Sarpy v. de la Houssaye, 217 So.2d 783 (1969).
12
Now, consider all that in conjunction with Coughlin spending 18 days in jail from July 3, 2012 to July
21st 2012 incident to a non-noticed bail hearing wherein Judge W. Gardner raised Coughlin's bail for
13
an arrest for disturbing the peace, proof of car insurance, and failure to secure a load on one's
vehicle (proof of insurance was provided via a pdf on a Coughlin's smart phone to the arresting
14
officer, and the disturbing the peace charges relates to conduct allegedly occurring outside the
15
16
officer's presence, and where that conduct is misdemeanor, Nevada law prohibits a custodial arrest
being made...so the Reno Police Department is left justifying the decision to make a custodial arrest
based upon a traffic citation carrying a $175 fine (failure to secure a load on one's vehicle)
17
Just sayin'. Someone starts effing with my USPTO license, that's federal, what am I supposed to do,
not question the adequacy of the due process provided in the proceeding leading to my convictions
18
and therefore suspension of my law license and damage to my professional reputation? 37 CRF
11.25(3)(a) and 11.25(3)(c) call for me to do just that.
19
20
Dated this November 12th 2012:
21
__________________________
Zachary Barker Coughlin, Esq. (Nevada law license temporarily suspended, USPTO license in tact,
and given permission to issue subpoenas by SBN Chief Bar Counsel David Clark, Esq. and firing up
23
that whole 11.25(b)(3) engine)
22
24
25
26
27
28
000263
proof of service/certificate of mailing
i zach coughlin placed this 11 12 12 Emergency Ex Parte Motion to Dismiss or Quash or Otherwise
Challenge Sufficiency of Service and of Process, of Complaint and Notice of Intent to Take Default
and DoWSoE; and Preserving for Appeal Objection to All other Due Process Violations; and
10
UNDER PROTEST...RESPONSE TO COMPLAINT in the mail with postage, and or transmitted a
digital copy to all of those who have either expressly or implicitly agreed to service via digital
transmission (plus Pat "Salieri" King told me the SBN takes anything I file and provides a stamped
copy to all 5 member of the Panel immediately and that I could rely on that), in the mail for pickup...
11
12
13
14
15
dated november 12th, 2012.
16
17
____________
zach coughlin
18
respondent
19
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21
22
23
24
25
26
27
28
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000408
ZACH COUGHLIN,
Appellant,
vs.
WASHOE LEGAL SERVICES, A
NEVADA CORPORATION; KATHY
BRECKENRIDGE, INDIVIDUALLY
AND IN HER CAPACITY AS BOARD
PRESIDENT OF WLS; TODD
TORVINEN, INDIVIDUALL AND IN
HIS CAPACITY AS WLS BOARD
MEMBER; PAUL ELCANO,
INDIVIDUALLY AND IN HIS
CAPACITY AS EXECUTIVE DIRECTOR
OF WLS; CARYN STERNLICHT,
INDIVIDUALLY AND IN HER
CAPACITY AS WLS ATTORNEY; JON
SASSER, INDIVIDUALLY AND IN HIS
CAPACITY AS WLS AGENT; KAREN
SABO, INDIVIDUALLY AND IN HER
CAPACITY AS WLS ATTORNEY;
MELISSA MANGIARACINA,
INDIVIDUALLY; MARC A. ASHLEY,
INDIVIDUALLY AND IN HIS
CAPACITY AS WLS ATTORNEY; AND
ZANDRA LOPEZ, INDIVIDUALLY AND
IN HER CAPACITY AS WLS
EMPLOYEE,
Respondents.
No. 60317
FILED
NOV 2 6 2012
ORDER DISMISSING APPEAL

On February 28, 2012, this matter was docketed without
the requisite filing fee. That same day, this court issued a notice directing
appellant to pay the filing fee within 10 days. The notice further advised
that failure to pay the fee within 10 days would result in the dismissal of
this matter. To date, appellant has not paid the filing fee. Respondents
SUPREME COURT
OF
NEVADA
-37 1 1 9
000409
(0) 1947A me
have filed motions seeking the dismissal of this appeal. Although

appellant filed an opposition, he has not demonstrated good cause for
failing to pay the filing fee. Accordingly, cause appearing, the motions are
granted and this appeal is dismissed.
It is so ORDERED.
, C.J.
cc: Zachary B. Coughlin

Guild Russell Gallagher & Fuller
Olson, Cannon, Gormley, Angulo & Stoberski
Brian A. Gonsalves
Lipson Neilson Cole Seltzer & Garin, P.C.
Washoe District Court Clerk
SUPREME COURT
OF
NEVADA
2
(0) 1947A
000410
:\\,
"
j'
IN THE JUSTICE
20!2 NOV 26 PH I: 33
COURT OF R.
q
HIP
IN AND FOR THE COUNTY OF W
HEllO iU:;'ICE COURT

OF NEVADA
HO
3
4
THE STATE O F N EVADA,

Plaintiff,
RCR 2012-065630
v.
DEPT:
7
ZACHARY BARKER COUGHLIN,

Defendant.
MOTION FOR ORDER PROHIBITING THE DEFENDANT FROM FAXING ANY

DOCUMENTATION TO THE WASHOE COUNTY DISTRICT ATTORNEY'S O F FICE
10
11
12
COMES NOW,
the State of Nevada,
by and through RICHARD A.
13
GAMMICK,
14
District Attorney,
15
granting the State's Motion For Order Prohibiting the Defendant From
16
Faxing Any Documentation to the Washoe County District Attorney's
17
Office. This Motion is based upon the attached Points and Authorities
18
III
19
III
20
III
21
III
22
III
23
III
24
III
25
III
26
III
District Attorney of Washoe County,
and Zach Young,
Deputy
and hereby moves this Honorable Court for an Order
000411
and any oral and/or documentary evidence that may be presented at a
hearing on this matter.
AF FIRMATION PURSUANT TO NRS 2 3 9B.03 0
4
5
6
7
The undersigned does hereby affirm that the preceding

document does not contain the social security number of any person.
DATED this
,;JG-f "
day of
J1 O\/{/dJ1 kLeA.::
'
2012.
RICHARD A. GAMMICK
District Attorney
Washoe County, Nevad
9
10
11
12
By
__________
+_
+------------
ZACH
Deputy Di
13
14
15
16
17
18
19
20
21
22
23
24
25
26
1126 4 3 6 3 7 79
000412
POINTS AND AUTHORITIES
2
3
Ie
On January 14,
2012,
Statement of
the Case
Zachary Barker Coughlin
(hereinafter
"the
Defendant") was arrested by the Reno Police Department for Misuse of
the 911 Emergency System. He now stands charged,
Criminal Complaint,
or Obstructing a Public Officer. During the pendency of this matter,
Mr. Coughlin also had a separate criminal case pending against him
before the Reno Justice Court in case number RCR2011-063341.
10
11
by way of an Amended
with a misdemeanor count of Resisting,
case concluded by way of verdict on November 20,

During the pendency of these two cases,
Delaying,
This
2012.
the Defendant has sent
12
numerous and voluminous faxes to the Washoe County District
13
Attorney's Office
14
Defendant sent a 61-page fax to the WCDA on November 13,
15
approximately 2:16 a.m.
16
Exhibit 1. The Defendant also,
17
a 146-page fax to the WCDA concerning case number RCR2011-063341j
18
this was sent on November 22,
19
is after said case was concluded in the Reno Justice Court. See
20
Coversheet of Fax,
21
sent several other faxes to the WCDA regarding case number RCR2011-
22
063341,
23
5:17 a.m.,
24
232-page fax on October 19,
25
Coversheet of Fax,
(hereinafter
"the WCDA).
In the instant case,
See Coversheet of Fax,
the
2012 at
Attached Hereto as
over the recent holiday weekend,
2012 at approximately 12:11 a.m.,
sent
which
Attached Hereto as Exhibit 2. The Defendant has
including a 33-page fax on August 29,

see Coversheet of Fax,
2012 at approximately
Attached Hereto as Exhibit 3;
2012 at approximately 1:31 a.m.,
Attached Hereto as Exhibit 4;
see
and a 40-page fax on
26
000413
2012 at ap proximately 6:22 p.m. See Coversheet of Fax,
November 13,
Attached Hereto as Exhibit 5.
The State now seeks an Order from this Court prohibiting the
3
4
Defendant from sending faxes to the WCDA.
II
ARGUMENT
The faxes that the Defendant has sent to the WCDA contain
6
7
ramblings by the Defendant without any cohesiveness or clarity,
sometimes duplicative of previous faxes sent,
other emails,
correspondence,
are
and typically attach
or narratives of the Defendant which
10
are irrelevant to any pending criminal case being prosecuted by the
11
WCDA. To the best of the undersigned's knowledge,
12
no substantive value or other reason for the Defendant to send such
13
voluminous and repeated faxes,
14
least one occasion and ran through reams of paper. These supplies of
15
a government agency,
16
drained due to the Defendant's actions;
17
as such conduct is occurring during a budget crisis.
18
Further,
there is absolutely
which has drained the ink supply on at
which are funded by taxpayer money,
are being
such is particularly alarming
sending faxes to the WCDA is improper as the Defendant
19
is represented by counsel. All communication with the WCDA by the
20
Defendant should go through his attorney of record. However,
21
the Defendant is allowed to represent himself in proper person,
22
has been broached,
23
or unnecessarily use State resources. Should the Defendant,
24
through his attorney or in proper person,
even if
as
these faxes serve no purpose other than to annoy

either
wish to file any motions or
25
26
1
There are several
other faxes sent to the WCDA from the Defendant,
and the
State
provides these as a basis for the instant Motion.
000414
other pleadings,
WCDA.
he should be required to serve a hard copy on the
He has clearly abused any ability to send faxes to the WCDA.

Finally,
based on the history of the Defendant repeatedly faxing
the WCDA,
the State believes that this Motion is necessary to prevent
any further faxes,
which assuredly will occur.
6
7
8
III.
CONCLUSION
The State respectfully requests that this Court enter an Order

prohibiting the Defendant from faxing the WCDA.
9
10
11
12
13
A F F IRMAT ION PURSUANT TO NRS 239B.030

The undersigned does hereby affirm that the preceding
document does not contain the social security number of any person.
DATED this
()
\.Q
day of
(\(
2012.
14
R ICHARD A. GAMMICK
District Attorney
Washoe County, Nevada
15
16
17
By
18
____
ZAC
Dep
19
--
----------------
rict Attorney
20
21
22
23
24
25
26
000415
CERT I F ICATE O F FORWARD ING

I hereby certify that I am an employee of the Washoe County
2
3
District Attorney's Office and that,
copy of the foregoing document,
mail,
on this date,
I forwarded a true
through the Washoe County interagency
addressed to:
B IRAY DOGAN, D E PUTY PUBLIC DEFENDER

S. CENTER STREET
R ENO, NEVADA 8 95 01
DATED this
35 0
c9
ay of
c\V-11A-1u..-1
2012.
10
11
12 .
13
14
15
16
17
18
19
20
21
22
23
24
25
26
000416
Index of Exhibits
2
3
1.
2.
3.
4.
12
Cover sheet of August 29 ,
2012
Cover sheet of October 19 ,
2012
1 page
10
11
2012 ,
1 page
8
9
Cover sheet of November 22 ,

1 page
6
7
2012
1 page
4
5
5 .
2012
1 Ease
13
14
15
16
17
18
19
20
21
22
23
24
25
26
000417
EXHIBIT
EXHIBIT
000418
to: 6b6J6953-c376-4d28-a98b-bbc96J8
4IIIt
From: zachcoughlin
11-13-12
2:16am
p. 1
of 61
ax
FACSIMILE
Date:
11/13/2012
To:
From:
6b636953-c376-4d28-a98b-bbc96383b936generaI693298
zachcoughlin
Subject:
000419
EXHIBIT
EXHIBIT
000420
....
....
....
....... ----
1"' .
--
FACSIMILE
Date:
11/22/2012
To:
From:
zachcoughlin
Subject:
000421
- --
EXHIBIT
EXHIBIT
000422
To: 6b636953-cJ76-4d28-a98b-bbc9638
From: zachcough11n
FACSIMILE
Date:
8/29/2012
To:
From:
zachcoughlin
Subject:
pre-trial brief/statement
000423
EXHIBIT
EXHIBIT
000424
rrom: zacncougnl1n
10-19-12
1:31am
p. 1
of 232
FACSIMILE
Date:
10/19/2012
To:
From:
zachcoughlin
Subject:
Duke Lacrosse rape case
000425
EXHIBIT
EXHIBIT
000426
....
... ",
....
....'L,LpUI
p,
J.
FACSIMILE
Date:
11/13/2012
To:
From:
zachcoughlin
Subject:
000427
Ui.
.U
000428
CASE NUMBER:
ng 12-0204 ng-0435 ng-0434
..
..
\
r
4
5
STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY B
'E.O
\
J
r-\' 'Lu\1
0
o'J '3
\n
't O tJ{l
)
)
) ng 12-0204 ng-0435 ng-0434
)
)
)
TATE BAR OF NEVADA,

8
ETlTlONER
9
10
ACH COUGHLIN,
11
12
V BAR 9473
ESPONDENT
13
14
15
16
MOTION FOR NEW TRIAL OR FORMAL DISCIPLINARY HEARING

17
18
Zach Coughlin, respondent, files this on his own behalf.

19
F ACTS AND LA W
20
21
22
Richard Hill, Esq. has testified under oath twice (at the criminal trespass trial in
Coughlin's Disciplinary Hearing on
23
24
26405 on 6/18/12 and at
11/14/12) that Coughlin failed to assert that he was a commercial tenant
during the summary eviction proceedings directed to Coughlin's former home law office. However, Coughlin
clearly did, including within the following:
25
26
The Standard Rental Agreement entered into evidence and attached to numerous pleadings in the summary
eviction proceeding/Unlawful Detainer Trial of Coughlin's former home law office contains the following
language:
28
-
In}-
MOTION FOR NEW T RIAL OR FORMAL

DISCIPLINARY HEARING
NOTICE OF HILL AND BAKER'S MALFEASANCE
000429
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Document Code:
Zach Coughlin
Nevada Bar No: 9473 (temporarily suspended)
1471 E. 9th St. Reno, NV
RENO NV, 89512
Tele and Fax: 949-667-7402
pro se TENANT'S/Subtenant
PLEASE NOTE ADDRESS CHANGE
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IN THE RENO JUSTICE COURT OF THE STATE OF NEVADA

PARK TERRACE TOWNHOMES HOA,
)
WESTERN NEVADA MANAGEMENT, SUE )
KING, GAYLE KERN, ET AL,
)
) Case No: RJC REV 2012-000374
)
LANDLORD,
) Dept No: D3 JUDGE SCHROEDER
vs.
)
)
ZACH COUGHLIN,
)
)
)
TENANT.
NOTICE OF CLERK'S OFFICE AND COURT'S FAILUR TO FILE COUGHLIN'S NOTICE
OF APPEAL, REQUEST THAT IT DO SO NOW, AND MOTION FOR RELIEF FROM
JUDGMENT OF 3/15/12 AND ORDER OF 5/15/12 IN LIGHT OF NEWLY DISCOVERED
EVIDENCE AND FRAUD, AND NRCP 60(B)(4)
COMES NOW, TENANT, ZACH COUGHLIN, by and through his attorney, Zach Coughlin,
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Esq. And hereby moves this Court for the above relief, particularly in light of the void for lack of
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jursidiction aspect of the Eviction Order in this case, as Couglin pled a commercial tenancy, but the
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30 day Notice was for No Cause, but, magically, the Landlord's Affidavit, filed the day of the hearing
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on 3/15/12, suddenly says the eviction was for "non-payment of rent", which is even more curious
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given the Motion work Coughlin filed prior to the hearing detailing the difficulties under Glazier and
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Lippis given the unique employment for rent trade arrangement present herein...
- 1 NOTICE OF CLERK'S OFFICE AND COURT'S FAILURe TO FILE COUGHLIN'S NOTICE OF APPEAL, REQUEST
THAT IT DO SO NOW, AND MOTION FOR RELIEF FROM JUDGMENT OF 3/15/12 AND ORDER OF 5/15/12 IN
LIGHT OF NEWLY DISCOVERED EVIDENCE AND FRAUD, AND NRCP 60(B)(4)
000457
Also, the 3/15/12 hearing in this matter was was set for 8:30, but the fax of the Order of Eviction
says it was sent at 8:24 am, therefore, there is ambiguity whether Coughlin was even late for the
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8/15/12 hearing. Also find attached proof of a "Change of Address" being provided to the RJC/Court
Administrator Steve Tuttle on April 16th, 2012 (in addition to numerous filings baring the then
current PO BOX 3961 address for Coughlin, and further, WNM's Sue King has been held out as a
managerial agent and even practitioner of law for Park Terrace and conduit for Gayle Kern, and
providing a change of address to King on May 9th, 2012 makes the fact that Kern's offics apparently
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sent Notice of Entry of Order to a then outdate address, prejudicial to Coughlin's ability to challenge
the 5/15/12 ORder and or responde to the cessation of any tolling that may have been in place (but
really, Coughlin filed a Notice of Appeal on 3/16/12, though the RJC failed to file stamp it, so that
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divested the RJC of Jursidiction, and now the RJC is late in processing the appeal, motion for stay,
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and motion to set appeal bond or supersedeas bond. nrs 40.400 makes NRCP 60b4 applicable here.
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further the lockout of 3/15/12 was done before constructive service was effected (other than by the
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break in with guns drawn bit the wcso does...which is not in compliance with the law...its something
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the Sheriff's office made up)...

LEGAL ARGUMENT
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I. Summary of Facts:
Park Terrace at least by name e-mail from Coughlin to gang sometime in April attached as an
exhibit alerted her and therefore Park Terrace in Gaelic earnest to Coughlin's new PO Box 3961
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address however the notice of entry of order were sent to an old PO Box and Coughlin and Coughlin
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never received it until months later further there is a fraud bases for seeking a new trial and that the
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studio Reno has tempted Coughlin committed by coercive measures directed at his parents further
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Coughlin was 8 min. late to court that day and in the audio of the hearing court staff can be heard
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urging Joe Schrader to call Coughlin's case despite the fact that he was not present despite the fact
that the justice court admits that Joe Schrader had planned to call a different case first and a seeming
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apparent attempt to dispose of Coughlin's case at the first opportunity Coughlin t Kern's voice on the
tape the hearing of 3 15 12 where she alleges how absolutely fair it would be to granted defaul;t
despite the fraud on the part of Ms. Kern Park Terrace townhomes and Western Nevada management
seems apparent to the extent that they filed a nonpayment affidavit on the day of the hearing to go
along with the no cause eviction notice only after being served a motion by Coughlin pointing out the
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difficulty with face glacier and let us pursuing a no cause eviction where arguably Coughlin and/or
any extent that our back and for shared unit of lessor were proceeding as tenants under some sort of
employment for rent relationship such as that set forth in glacier additionally to the extent the
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Coughlin was holding out that address as his home office a no cause eviction against a commercial
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tenant i.e. where rent is not pled is impermissible under NRS 118 a and NRS 40.253 particularly
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where it was not applied nor alleged or proven that the lease is terminated it's just nonsense for Park
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Terrace kerning came and Sheila Lester to the alleging that Coughlin was a squatter when at the
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hearing on March 15, 2012, Lester and or King admitted that former Western Nevada management
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manager Robin Bataldo received express approval from either Lester and/or other members of the
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homeowners Association to enter into the lease agreement it had with Allaback and Foreshee. Further
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Coughlin has an excusable neglect bases rating eight math late today hearing giving the fraud on the
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part of NV energy in the nicest Postal Service apparently in concert with King and/or Kern and
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Western Nevada management in managing to deprive Coughlin about electricity and a key to his
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mailbox where they demanded some sort of written rental agreement even where Nevada law under
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NRS 118A.160 pleasantly provides a leased can be oral.
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000459
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Further at this point Coughlin seeks to have Joe Schrader recuse himself from any cases
involving him getting the statements Joe Schroeder made to Coughlin at the January 31 extension
hearing it Richard Hills protection order where Coughlin sought to address the use of process and
obstruction of justice apparent by Richard Hills making false statements to officer Hollingsworth (a
videotape by Coughlin captures the fact that Hill had told Hollingsworth Coughlin Atari lost Gail one
January 12, 2012 `it was not decided until March 30th, 2012 in CV11-03628 (the appeal of the
summary eviction, now before the Nevada Supreme Court in 60331 and 61383) and where both
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Richard G Hill and his associate Casey Baker filed in NRCP 11 violating motions on November 21,
2011 and January 20th, 2011 (the first in the trial court, the second in District Court) containing
affidavits entered declarations that violate NRCP 56(g), and particularly after viewing the video
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tapes of those incidents clipping those film by Hill himself (Hill and Merliss's fraud is set forth in
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excruciating detail in the attached Motions in 61901 (SCR 111(4) Petition by SBN re: Coughlin's
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trespass conviction) and in 11 cr 26405 (the June 18th, 2012 criminal trespass trial against Coughlin
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wherein HIll and Baker testified).
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Further basis for seeking to Schrader's recusal herein relates to the eviction order he signed in
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Northwind apartments versus Coughlin in inev2012-001048 on June 27th, 2012 despite Coughlin's
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multiple correspondences with both the sparks Reno Justice Court, Washoe County Sheriff's office
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Reno Police Department and the civil division of the Reno justice court (see attache 6/26/12 and
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7/2/12 emails by Coughlin to the RJC and Sparks Justice Court, and Coughlin has learned that a fax
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from the sparks justice court at around noon on June 28 made its way to the Reno justice court and
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apparently Joe Schrader though some pages the facts appear to be missing but suffice to say it alerts
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the Reno justice court as to the fact that Coughlin submitted for filing attendance affidavit to the
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sparks justice court on June 26, 2012 which the Reno justice court was already aware of at bedtime
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on June 27, 2004 Winter Schrader sign the order evicting Coughlin based upon a landlord's affidavit
submitted by Nevada court services which was engaged in the unauthorized practice of law at the
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time and continued to be even at the July 31, 2012 hearing in that matter which spawned an order
which will exceeded the scope of the notice of the hearing and in fact purported to rule upon other
leases. NRCP 11 requires that corporations such as Northwind's apartment Associates Incorporated
not appear pro se and that it must be represented by an attorney court in nothing and the Nevada
statutes allows for anything other than posting eviction notice by landlord's agent and NRS 40.253.
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Further bases for seeking judge Schroeder's recusal from this matter stems from the apparent
fact that he is listed in the docket in a criminal matter against Coughlin in RCR2012-065630 (a
fraudulent arrest based upon retaliatory motives by the Reno Police Department including but not
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limited to that stemming from Coughlin's obtaining a videotaped admission by Sgt. Lopez has
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wrought on the part herself Sgt. Carter Richard Hill and Dr. meritless incidents eviction as set forth in
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detail in the attached filings in 61901 and 11 CR 26405 and in the videos Hill films of the arrest all
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submitted along with the CD attached to this motion and copied to the justice court in digital format
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by electronic transmission is the means of a courtesy copy. As seen in the docket attached in Exhibit
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1 Joe Schrader is listed as presiding over the February 27, 2012 status conference 065630 involving
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right of in in DDA young at 1:30 PM from which judge Clifton signed an order for competency
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evaluation at 1:31 PM which young did not he and his violation of NRS 178 by filing later that day in
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opposition emotion Coughlin's motion appear as cocounsel in which upon information believed and
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upon a reading of judge owns his March 14, 2012 letter State Bar owns was aware of that order
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for competency evaluation in G herself violated NRS 178. 405 by persisting in holding a trial in yet
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another matter where and Richard Hill was able to stick local law-enforcement on Coughlin this time
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a traffic citation three of them issued to Coughlin upon his venturing to Hill's office after being
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released from three days in jail incident to the fraudulent November 13, 2011 criminal trespass
complaint Hill signed an arrest which was predicated upon lies by Hill, Dr. Merliss (and CAsey
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Baker co-opted Hill's lies, in violation of a NRCP 11 given Baker had access as an associate to the
videos Hill and Merliss filmed on scene on 11/13/11) and Reno police on videotape. See a Reno
Marshall Harley just before that trial the Judge Nash Holme's persisted in holding despite her
awareness of an order for competency evaluation being entered or at least being sought by Mr.
Duggan Alaska public defenders and/or Mr. Yong of the District Attorney's Office. Coughlin doesn't
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know Judge Shroeder at all (Coughlin's one appearance in front of Judge Schroeder resulted in Judge
Schroder exclaiming "do you want to go to jail!" at Coughlin and Coughlin first topic of Hill's visa
process at the January 31, 2012 extension. On Hill's fraudulent tax order and he may well be a fine
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jurist and a good man but there's just been too many disturbing coincidences connected with Joe
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Schroeder's rulings. Further bases for setting aside the default stemming from Coughlin means being
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8 min. late March 15 hearing arise from the fact that Coughlin was wrongfully incarcerated for five
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days by Judge Nash Holmes on 2/27/12 to 3/3/12 incidents or her order fining him in summary
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criminal contempt despite the fact that her order rests upon allegations of conduct not occurring
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allegedly an immediate presence of the court but rather in her March 12, 2012 order from the
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owns recounts something a court-martial told her he spied Coughlin doing in a bathroom stall during
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a restroom break something about taking apart a smart phone something something regardless it's not
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appropriate for summary adjudication kind of like all these objections of commercial tenant Coughlin
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where the nonpayment of rent has not been noticed by the landlord such as in the eviction by Richard
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Hill on 1708 and in this seeking Gail Kern deal here in 374. Coughlin's father is John Physician yet
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somehow the city Arena thinks it's okay to send out multiple officers and social workers she can have
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Coughlin committed this despite the fact that the appearance of impropriety arises where the city
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Arena has a vested interest in discrediting Coughlin given the enormous number of wrongful arrest it
is subject to Coughlin to this year. Further the Reno justice court has some issues that Coughlin
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would like to ask it about particularly regarding the failure to file a notice of appeal in this matter
threesome importance by Coughlin faxing 1 Into This Court and other students and talk about this or
that not having a signature but the notice of appeal itself does have a signature on it and it should've
been filed and the same is true of what Coughlin submitted for filing on December 26, 2011 in
rev2012-001708 following the December 20, 2011 hearing on Coughlin's motion to contest personal
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property lien which Hill alleges he was able to control the Reno justice court in its failing to set or
hold that hearing within 10 days required by statute from Coughlin's November 16, 2011 filing of a
Motion to contest personal property lien in a matter. Then there is the fact that in that summary
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eviction from Coughlin's commercial home office where the nonpayment of rent was not pled or
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noticed that Joe Sferrazza ruled at the October 13, 2011 hearing that Coughlin had met his burden of
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establishing a genuine issue of material fact at which point just Rosin noticed him that there would be
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a trial only if Coughlin would deposit into the Reno justice court of rent escrow account which
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Nevada law does not permit the Reno justice court to require and the judges of the Reno justice court
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had a meeting on just this issue back to the fact that large AC under Nevada just core rules civil
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procedure 83 and/or 84 has not followed the appropriate procedure in implementing what is
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essentially a corollary justice court ruled Las Vegas rule 44 which may only be done after publishing
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the rule and receiving approval from the Nevada Supreme Court
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CONCLUSION
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PleasE finally file the NOtice of Appeal and or GRANT A NEW TRIAL OR ALTER OR
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AMEND THE summary eviction order or order of May 15th, 2012 or otherwise reconsider it,
000463
AFFIRMATION PURSUANT TO NRS 239B.030
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The undersigned does hereby affirm that the preceding document does not contain the social
security number of any person.
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Dated: 11/4/ 2012
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/S/ Zach Coughlin________

Zach Coughlin,Esq.
pro se tenant/subtenant
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000464
PROOF OF SERVICE
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Pursuant to NRCP 5(b), I certify that I served a copy of the foregoing document upon the
following party by electronically filing on NOvember 4th, 2012 and therefore serving upon
registered efiler:
sue king, gayle kern western nevada property management, Park terrace towhnhomes HOA
804 Mill Street Reno, NV 89502
(775) 284-4434 and faxed to
kern ad PTTHOA 7753246173
and King and WNM at 7752844465
Gayle A. Kern. Ltd. Address: 5421 Kietzke Lane Suite 200 Reno , NV 89511 Phone Number: 775324-5930 Fax number: 775-324-6173 Email: gaylekern@kernltd.com attoreny for Park Terrace
THOA
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Dated this 11/14/12

/S/ Zach Coughlin
Zach Coughlin
pro se tenant/subtenant
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000465
INDEX TO EXHIBITS
1. various filings and documentation and videos/audio on cd attached to hard copy and digitally
transmitted to court and oppsoing counsel as well.
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000466
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Nov 27 2012 11:39 a.m.
Tracie K. Lindeman
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ZACH COUGHLIN,
9 PETITIONER
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V.
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STATE BAR OF NEVADA

]ACH COUGHLIN,
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NV BAR 9473
13 RESPONDENT
)
) 62104
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motion for extension of time to pay filing fee or show good cause why hasn't been and or apply
for ifp fee waiver nrap 24
Zach Coughlin, respondent, files this on his own behalf.
FACTS AND LAW
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Just like clockwork, immediately after teh 11/25 and 11/23/12 emails to Judge Gardner,
Garin, Elcano, the NNDB, Bar Counsel and the Panel, comes the ORder dismssing 60317:
coughlin has had two trials in last week, request short bit of time to fill title's of documents actions.
Supplemental to 11 23 12 correspondence regarding

discovery in Joshi 54844, April 2009 Order sanctioning
Coughlin
Sent: Sun 11/25/12 1:41 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (je@eloreno.com) (je@eloreno.com);
- 1/25 -
000467
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(patrickk@nvbar.org) (patrickk@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net);

(cvellis@bhfs.com) (cvellis@bhfs.com); (jgarin@lipsonneilson.com) (jgarin@lipsonneilson.com);
(pelcano@washoelegalservices.org) (pelcano@washoelegalservices.org);
(linda.gardner@washoecounty.us) (linda.gardner@washoecounty.us)
1 attachment
03018 to 03041 Judge Linda Gardner listed by SBN King as greivant in ng12-0435 fyi
prosecutorial misconduct blog smaller size.pdf (10.5 MB)
I believe I informed WLS of this previously, but I did try to have discovery send out in Joshi, but
Deborah Pringle and then WLS Office Manager Robin Kunce indicated it would take something on
the order of six weeks to get a check cut for anything, such as for witness fees or those associated
with a subpoena duces tecum, and the Trial of March 12th, 2009 in Joshi was not far out enough to
account for such an unanticipated indication from WLS as to what would be required to conduct what
Judge Gardner indicated in her April 2009 Order as the sort of discovery she felt would be necessary
to rebut an inference of vexatiousness for not immediately caving to Mr. Springgate's Siragusa
argument. Further, it was never my understanding that either Ms. Santiago or myself "agreed" to
then Master Gardner entering an Order "resolving" the dispute as to the car title in the Temporary
Protection Order hearing in Santiago v. Vaxevanis.
What is interesting is that, on one hand, Mr. Elcano is being told to fire me or else by CAAW and
Tahoe Women's Services for allegedly not being zealous enough in advocating their agendas, er, for
the victims of domestic violence in the Carnine and Haubl matters, , Further, in early January 2009,
WLS's Rhonda Harrison is saying "eat me" to Coughlin when he attempts to use the upstairs
restroom at WLS. Couglin sens a written complaint about that to Mr. Elcano, and he holds a meeting
with Coughlin which results in, as Mr. Elcano testified at the Disciplinary Hearing, his "standing by
my employee". It would seem true that Mr. Elcano did jut that, at that time (ie, stand by his
employee, Coughlin). In fact, it was during a face to face meeting with Coughlin in February 2009
or so that Elcano told Coughlin about the appraisals of Coughlin's work by Judge Gardner and Master
Edmondson, with both, essentially, giving Coughlin a "thumb's up" review (ie, good enough work
not to be fired, etc.). It was at that point that Mr. Elcano casually mentioned that he had done
something in the past for Judge Gardner (it didn't sound as ominous coming from Paul as it does
when I write it....) and that, essentially, that was some indicia of reliability as to Judge Gardner's
candor to Elcano in assessing Coughlin's work at that time, and therefore, Mr. Elcano was reinforced
in his belief in his position that it would be inappropriate to let CAAW and Tahoe Women's
Services, essentially, tell him who to fire or not.
Outlook Print Message
But the irony is that I was fired, according to Mr. Elcano's letters to me of May 1, 2009 and May 7,
2009 because of the April 13th, 2009 Order by Judge Linda Gardner finding my conduct at trial to be
vexatious. It is inaccurate and overly convenient to now attempt to remix that assessment, as Mr.
Elcano did in his testimony on 11/14/12 to indicate my advocacy was merely 'incompetent'. Further,
testimonial evidence is evidence, as such, Judge Gardner's Order is inaccurate to the extent is
suggests no evidence was put on as to, say a Tonopah formula approach is determing the alimony
question. Whereas Judge Gardner found I advocated too zealously on behalf of a battered woman (to
the point of vexatiousness, no less), Tahow Women's Services and CAAW had, in close proximity
and previous to Judge L. Gardner's April 2009 Order, complained that I did not advocate strenously
enough, apparently (Mr. Elcano has refused to release those writings to me).
Tahoe Women's Services (which apparently changed its name to something less gender
polarizing upon Coughlin's critique thereof, as it is now known as Crisis Intervention
Services) provided a written complaint about Coughlin's performanc eot Elcano in FV0802254 - PAOLA C. PEREZ HAUBL VS. ANDREW A. CRAIG. Coughlin hereby requests,
again, a copy thereof.
Likewise, the Committee to Aid Abused Women (CAAW) (no name change as of yet)
complaint in writing to Elcano about Coughlin with respect to his representation of Michelle
Carnine in a TPO and or divorce matter. Coughlin hereby requests a copy of any written
complaints submitted by anyone with respect to either of those Carnine matters:
CASE NO. FV08-02021 MICHELLE CARNINE OBO STORMY VS. BRADLEY
CARNINE CASE NO. DV08-01532 MICHELLE CARNINE VS. BRADLEY CARNINE
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The funny thing is, for prosecutors (and see Judge Gardner's apparent "FYI"
correspondence to the State Bar of Nevada's Pat King in NG12-0435, bate stamping
indicating Judge Linda Gardner as the grievant, and the blog entry related to prosecutorial
misconduct being taken note of place directly after the fate stamped folder name listing
Judge L. Gardner as the grievant in that 0435 case...with both Judge L. Gardner and her
brother, RMC Judge W. Gardner being lifelong prosecutors before taking the bench, like
most judges in Washoe County, though they are two of the rare exceptions who did not go
to McGeorge).
Some might say the District Attorney and Reno City Attorney Offices influence as
prosecutors extends to the District,Justice, and Municipal Courts to an impermissible
extent...and now, with the firing of Coughlin from Washoe Legal Services, and the entering
into the Early Case Resolution (ECR) contract between the WCDA's Office and WLS to
deliver some sort of approach that some say violates the Sixth Amendment, local legal aid
is impermissibly influence by local prosecutors, so much so that, regardless of what the
legislature may enact (often in response to the tireless advocacy by those such as WLS's
Jon Sasser, especially regarding AB226 in the landlord tenant context along with Coughlin's
Boyd School of Law early, unaccredited days, classmates, Assemblymen William Horne and
Jason Frierson, in conjunction with Tik Segerblom). A quick look at a retaliatory arrest and
eviction of Coughlin this year reveals a disturbing pattern of the local judiciary being overly
influenced by the prosecutor's office, and taking a markedly laissez faire approach to
prosecutorial misconduct, in marked contrast to the seemingly overly aggressive approach
by lifelong prosecutor's turned judges RMC Judge Nash Holmes, RMC Judge Kenneth
Howard, RMC Judge William Gardner, and Second Judicial District Court Judge Linda
Gardner in "protecting the public" from the work of one Zachary Barker Coughlin, Esq.
(whom has held himself out as an attorney who takes on cases of prosecutorial and police
misconduct...a type of attorney whom the SBN's Patrick O. King seems to have carved out
a specialty in prosecuting, right, James Andre Boles, Esq, the attorney whom has most
consistently sued local law enforcement for wrongful arrest and other police misconduct,
just now being harrassed by the SBN in In Re the Discipline of James Andre Boles, Esq.?
Is SBN Bar Counsel Patrick O. King, Esq. puttin' in work for prosecutors and police alike?):
Further, during the numerous retaliatory prosecutions this year of Coughlin, a multitude of
prosecutorial misconduct has been apparent, inlcuding DDA Zach Young (McGeorge '04)
making argument in filings with the Reno Justice Court in RCR2011-063341 that alleged
communitcations between ECOMM/911 dispatch and the RPD in relation to the arrest of
8/20/11 (the one that started the entire 16 month ordeal off) that contained communications
from dispatch to the RPD of "a possible fight", which DDA Young and RPD Officer Nick
Duralde (whose wife, Jessica Duralde was working that night at a 911 dispatcher and
whose voice may be on the tapes only released by Reno City Attorney Skau on 11/13/12
incident to an Emergency Hearing on Motions to Quash Coughlin's subpoenas (and, really,
Judge Sferrazza admitted later that the hearing was also based on Motion to Quash that
were not even filed, but rather just a sua sponte overall intention by Judge Sferrazza, the
longest tenured Mayor in Reno's history, a former Chairman, Vice-Chairman and Washoe
County Commissioner from 1998-2007, to Quash pretty much every subpoena Coughlin
drafted in any way related to anyone in goverment).
The prosecutorial misconduct has been detailed at length in Couglin's filing with the Nevada
Supreme Court this year, save, perhaps the new instances where DDA Young's assertions
of dispatch alerting RPD Officers of "a possible fight" prior to their arriving to respond on
8/20/11 (and the utility thereof incident to the Hearing on Coughlin's Motion to Suppress)
has been thoroughly disproved by City Attorney Skau's only finally releasing those tapes on
11/13/12, after he secured Coughlin's attendane at a Hearing on his Motion to Quash
Subpoenas by alleging the court had granted him the power to effect service thereof by
emailing Coughlin (and Coughlin SBN form Disciplinary Hearing was held the next day
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11/14/12, where Judge Linda Gardner's bailiff was assigned to the affair, the same bailiff
present at the April 12th, and 17th, 2009 Trial dates in the Joshi matter that became 60302
and 54844. Judge Gardner's brother also refused to recuse himself from the criminal
trespass prosecution of Coughlin incident to an arrest at his former home law office.
Coughlin has detailed the prosecutorial misconduct of City Attorney's Roberts (in 60838)
and Hazlett-Stevens (in 61901) in addition to that of DDA Zach Young (three different
prosecutions, each one more retaliatory than the last) and the multitude of violations of the
stay required by NRS 178.405 (in consideration of NRS 5.071, especially).
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Richard Hill, Esq. has testified under oath twice (at the criminal trespass trial in 26405 on 6/18/12 and at
Coughlin's Disciplinary Hearing on 11/14/12) that Coughlin failed to assert that he was a commercial tenant
during the summary eviction proceedings directed to Coughlin's former home law office. However, Coughlin
clearly did, including within the following:
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The Standard Rental Agreement entered into evidence and attached to numerous pleadings in the summary
eviction proceeding/Unlawful Detainer Trial of Coughlin's former home law office contains the following
language:
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on page 1 of 3: "Resident further may use the premises for any commercial enterprise..."
also on page 1 of 3: "11. OCCUPANCY: Occupancy of the premises is limited to 2 adults 2 Children, and
shall be used for a residence and for other purposes."
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email to Hill on 8/17/11: " Well, repairing crumbling steps is not super cheap. Matt seems to have forgotten
about these written deals entirely. Lets say it cost $600 to repair steps, well, where does that leave Matt's
estimate of what I owe? The steps have been repaired. As has the garbage disposal and other items. The
window is still broken, Matt never responded to requests for the cost of noxious weed ordinance fine
avoiding landscaping the previous season (I wouldl, for now, take the same $350 I agreed to this season,
which is surely less than Matt paid the crew of 4 men to service the neighboring house for 8 hours recently)
with jagged edges of glass exposed, and an entryway with grip strips and wooden planks that are in disrepair.
I have a law office to run and cannot both pay rent and be the pro bono handyman for the absentee landlord
while he is off travelling to Amsterdam and B angkok. I made a very reasonable offer to Matt to fix it."
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page 3 of Coughlin's Tenant's Answer on September 6th, 2011 ( in the false start case rev2011-001492, that
Judge Sferrazza later boostrapped notice from, so...): "I have a law office to run and cannot both pay rent
and be the pro bono handyman for the absentee landlord while he is off travelling to Amsterdam and
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Bangkok. I made a very reasonable offer to Matt to fix it. I made an incredibly reasonable offer to Matt to
have the seasonal noxious weed ordinance fine avoiding weeding taken care of for $350, which he
enthusiastically agreed to, then a landscaping crew promptly came and ripped up a faux grass installation
that had cost me a great deal of time and money to put in place, then refused to put that personal property
back on my rental property at all, leaving it on the sidewalk and in the street."
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page 4 of the 9/6/11 Tenan'ts Answer: "Landlord has violated NRS 118A.290 in his failure to repair, well after
14 days of written notice, items such as a broken front bedroom window (complete with jagged exposed
edges of glass), fallen insulation that has appeared to resulted in the creation of potentially toxis mold when
it came in contact with the ground below, which lacked a vapor shield, a toilet with a defective was ring, the
front stairs to Tenant's home/office came to a state of disrepair, replete with crumbling risers that
presented a safety hazard and liability issues. Landlord agreed to a significant rent deduction in exchange for
arranging to have the work done and paying for the work itself, yet now Landlord seems to have forgotten
these written correspondences, etc."
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Also on page 4:
"57 Am. Jur. Proof of Facts 3d 127, Commercial Tenant's Remedies Where Landlord Fails to Keep Premises
in Condition Fit or Suitable for Commercial Use. 25 Causes of Action 2d 493, Cause of Action for Breach of
Implied Warranty of Habitability"
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page 11: :Now where that becomes truly abhorent is when it contributes to hard working small business
people being thrown out of offices and homes they have paid good money to rent to Californian landlords
who are constantly in Amsterdamn or Bangkok and who constantly seem to forget about that tenant's
request to make this or that habitable, such that a habitual tendency to ignore tenants complaints arises,
usually followed by a retaliatory eviction when the tenant tires of being a stooge for the landlord."
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Page 26 and 27 of that 9/6/11 Tenant's Answer contains the following:
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"To magunda@aol.com From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Fri 8/12/11 1:24 AM To:
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magunda@aol.com Dear Matt, I was mistaken in my correspondence below. It was the June 2011 rent, not May 2011, for
which you approved, in writing, my deducting $350 for my "taking care of the weeds". I have the written approval and I
would imagine your "sent folder" should have it as well. With respect to May, any shortfall is going to be Melissa's
responsibility. Please provide a copy of the alleged $600 rent check you received from Melissa on or about 5/6/11. I
realize you may not feel that way, and, technically, you may have some valid arguments, however, I certainly gave
Melissa my entire share of the rent for May. If it proves true that she only sent you a partial rent payment, then I will need
to review the relevant precedent and consider my options. I was not aware the power was in your name, however, I will
protect my legal right to have the power put in my name in my residence. I cannot stress enough that no one, NO ONE, is
to enter 121 River Rock St., Reno NV 89501 without my express written prior approval, and even then, only in my
presence shall anyone ever be permitted to enter the dwelling while I am it's tenant. I appreciate your consideration and
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efforts to educate me with respect to the laws of landlord tenant. I have developed some physical reactions to the mold
issues that I alerted you of earlier and request that you respond to my written requests and inquiries in that regard.
Sincerely,
Zach Coughlin, Esq.
Attorney at Law
121 River Rock St.
Reno, NV 89509
775-338-8118
Licensed in the State of Nevada From: zachcoughlin@hotmail.com " (emphasis added).
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October 5th, 2011 email from Coughlin to Baker:

"From: ZC [mailto:zachcoughlin@hotmail.com] Sent: Wednesday, October 05, 2011 12:54 AM To: Casey
Baker; Richard G. Hill Casey Baker Subject: RE: Interruption of essential services
The power was turned off at about 10am today out of the blue with no warning whatsoever. NVEnergy says it
was in Merliss's name. Your representation in the face of what seems quite clearly bad faith by your client,
and perhaps you, may be sanctionable. Sudden and complete disruption of a service as essential as energy,
during the 5 days accorded by law, while simultaneously conducting a bad faith, inspection, which you
elected to abandon just before undertaking, wasting my time, is surely going to reflect poorly on your firm.
Further your clients actions in maintaining the power bill in his name arguably alters whatever you might
think the lease says. All this bad faith malicious and reprehensible conduct has damaged my law practice and
cost me monetarily. And your assistant shows up in an 80K mercedes compressor with a video camera trying
to go through a private home and law office without meeting the requirements "
Plus the commercial tenancy aspect/law office (and possibly mattress business) was discussed in phone calls
with Baker prior to the 10/13/11 summary eviction proceeding and again prior to the 10/25/11 "Trial".
Coughlin's 10/15/12 email to cdbaker@richardhillaw.com contains the following:
"Choosing Whether to File A Summary or Formal Eviction Action
In most cases, the landlord can choose whether to file a summary or formal eviction action. However, there are
circumstances under which summary eviction cannot be used. For instance, summary eviction is not available for:
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2) Eviction of commercial tenants for other than nonpayment of rent
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(See NRS 40.254)
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Using location for a "commercial" law practice, you filed a no cause, ie, "for other than Outlook Print
Message
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nonpayment of rent, not based in law or fact, Rule 11, plus this escrow thing gets put asunder. NRS
40.254 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant from
certain types of property. Lease allows for use for commercial purposes. Void, void, void! NJCRCP
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59, 60... "

In a 9/14/11 email to cdbaker@richardhillaw.com, Coughlin informs Baker and Hill of the commercial tenancy again in
writing: "The overhead light in the front office is dangling. Please make that habitable to."
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Also, the following correspondence:

"RE: Interruption of essential services
From: ZC (zachcoughlin@hotmail.com)
Sent:
Wed 10/05/11 12:54 AM
To:
Casey Baker (cdbaker@richardhillaw.com); Richard G. Hill Casey Baker (rhill@richardhillaw.com)
The power was turned off at about 10am today out of the blue with no warning whatsoever. NVEnergy says it was in
Merliss's name. Your representation in the face of what seems quite clearly bad faith by your client, and perhaps you, may
be sanctionable. Sudden and complete disruption of a service as essential as energy, during the 5 days accorded by law,
while simultaneously conducting a bad faith, inspection, which you elected to abandon just before undertaking, wasting
my time, is surely going to reflect poorly on your firm. Further your clients actions in maintaining the power bill in his
name arguably alters whatever you might think the lease says. All this bad faith malicious and reprehensible conduct has
damaged my law practice and cost me monetarily. And your assistant shows up in an 80K mercedes compressor with a
video camera trying to go through a private home and law office without meeting the requirements for service and
notice, much less purpose and good faith of an inspection under NRS. I am making a documentary."
Page 2 of Coughlin's Affidavit in Support of Motion for Summary Judgement (and the RJC mixed up the order of that
Motion for Summary Judgment and the Affidavit Attached thereto, so the Motion should be file stamped, but instead, the
affidavit is...) file stamped October 25th, 2011 (at 10:10 am with Baker personally served a copy by Coughlin prior to the
"Trial" of that date, at page 2: "4. Internet connection costs, car battery problems, gas, opportunity costs, lost business,
and other costs where incurred by the undersigned as a direct result of the unnoticed electricity shut oft: an essential
service and were occasioned by the emergency situation created by Merliss's and NY Energy's un-noticed shut off of an
essential service, electricity, to Coughlin's home law office."
Page 3, of the 10/25/11 Motion for Summary Judgement/Trial Statement by Coughlin: "...does
not entitle a
Chico, California neurologist to retaliate against a lifelong Reno resident who has
served as a Legal Aid Organization attorney merely because that tenant does not
appreciate having his home law office subject to the various problems which NRS
118a.510 prevents Dr. Merliss from relatiating against the undersigned for seeking
redress for." "...Additional protected complaints include crumbling stairs to the front entrance of the home law
office..."
Page 5 of the 10/25/11 Motion/Trial Statement by Coughlin: "The Green Action crew admitted to Coughlin (and Coughlin
was prevented from submitting video and audio recordings into the record by Judge Sferrazza, despite the salient
importance to Coughlin's counterclaims any statements they made would have as to whether Dr. Merliss is responsible for
or ratified the property damage to Coughlin careful wool green law carpet installation, which was laid, cut, and notched
around the house and exterior fence in a very exacting manner, only to be converted by the Green Action crew and left in
the street and sidewalk near the house, creating a theft hazard and exigent situation in which the undersigned's law
practice suffered economic damages and Coughlin was required to. take immediate action to mitigate the damages.
If the Reno Justice Court wants to implement something similar to Justice Court Rule 44 of Las Vegas, it must first have
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the rule approved by the Supreme Court of Nevada. Sec, Nevada JCRCP RULE 83. "RULES BY JUSTICE COURTS:
Each justice or justice court in a township with more than one justice, by action of a"
Also, on page 7, on 10/25/11 Coughlin wrote: "Oh, and, the same day, Baker and a videographer showed up to the home
law office to do a videotaped inspection and to fix habitability issues, only to make some lame attempts to find a
breach rather than just conduct the inspection they had billed hours on to arrange."
On page 9 of the 10/25/11 Motion for Summary Judgement/Motion for Sanctions/Trial Statement in RJC rev2011-001708
filed by Coughlin it reads: "(Mr. Baker can't be troubled to makc reasonably diligent inquiry, like reading the 20 pages of
emails Coughlin provided him chronicling the written noti.:es of habitability issucs, the agreed to rent deducdtions by his
client, and the rent portions Baker's client has already recovered from Coughlin's former co-tenant and the arrangemnets
and agreements Dr. Merliss made in writing with that former co-tenant, Melissa Ulloa, whereby Dr. Merliss and Ms.
Ulloa made arrangments for her to repay Dr. Merliss the portions of rent for which Ms. Ulloa took the undersigneds usual
share of the rcnt and failed to forward it on to Dr. Merliss (as was the co-tenants establ ished practice for the 18 months in
which they cohabitated at the residence/office the rented from Dr. Merliss). This is also a Motion to Strike Baker's
outrageous allegations of "lying"."
Page 19: "he full $1,000 should be awarded, in part for the $500 worth of perishable and groceries spoliating, but further
for the business and opportunity costs to Coughlin occasioned by the emergency situation created by Merliss's and NV
Energy's un-noticed shut off of an essential service, electricity, to Coughlin's home law office. NRS 118A.390 allows
tenant's to sue the landlord for $1,000 in statutory damages, plus actual damages. Merliss should be ordered to pay the
full $1,000 in statutory damages, plus actual damages of another $2,200 dollars ($400 in perishables and groceries lost,
plus 5.5 billable hours attorney time at $200/hr, plus a $700 red adult male Gary Fisher Mountain Bike was stolen from
Coughlin's back yard upon NV Energy's un-noticed entrance into the backyard, which is gated, and exiting leaving the
gate wide open. The Lease Agrement is clear in holding Dr. Merliss responsible for such damages to Coughlin's
property."
Page 21: "Nev. JCRCP RULE 109. SETTING OF TRIAL IN ACTIONS PURSUANT TO NRS 40.290...(a) In no case
shall a trial on the merits be set less than 20 calendar days after service of summons and complaint. Coughlin cited this
rule in open court on October 17th, yet counsel Baker informed the Court that it did not apply to eviction actions. It
certainly does apply. Now, the trial set for October 25th, is arguably no longer a summary eviction proceeding under
NRS 40.253, as such, the requirements of a plenary unlawful detainer action must be followed. Further, Nevada's JCRCP
Rule 109 applies, and the trial date of October 25th does not comply with the dictates of Nev. JCRCP 109. As such,
Coughlin states his objection to this trial for the record. Indeed, there has been no service of summons and complaint in
this matter, yet, Coughlin is being subject to all sorts of plenary requirements without, seemingly, being afforded any of
the plenary protections of full unlawful detainer actions."
Page 5 of Coughlin's November 8th, 2011 Motion for Sanctions in RJC Rev2011-001708 also clearly rebuts Hill's
contention that Coughlin failed to allege his was a commercial tenancy, impermissilbly subject to a No Cause Summary
Eviction where non-payment of rent was neither pled nor noticed: "shut off to Coughlin's home/law office, and usually
within some ultra short summary process time period for which Coughlin would need to be preparing for some summary
hearing, even though the dictates of NRS 40.254 clearly require a plenary hearing, and where Merliss's whole case is void
in light of the failure to file the USPS Certificate of Mailing in relation to proof of service and notice of the documents for
which such is required."
Also, page 8 therein reiterates Coughlin's previous assertion: "I have a law office to run and cannot both pay rent and be
the pro bono handyman for the absentee landlord..."
On page 10 of that 11/8/11 Motion for Sanctions, Coughlin wrote: "Coughlin noted to Baker that sueh clients oft-times
get attorney's in trouble. particularly with regard to Rule 11 violalions, especially when a litigation involves something
of such primary importance to a litigant as his home/office. Coughlin queried Baker as to what, exactly. Baker had
done to verify that the debts Merliss was alleging were "based in law or fact"". Baker was curiously evasive and or non
responsive in the various questions Coughlin posed in this respect when he was not displaying a complete an utter lack
ofknowledge with regard to the disputes between landlord and tenant. including ""hether his client had agreed to any rt:nt
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deductions, had been made aware of any property damage caust:d by the landlord's agents or employees, had failed to
cure any habitability issues his client had been informed of in writing for a period over 14 days since past, etc."
Page 16: "22. All the materials and arguments contained in Coughlin's original Tenant's Answer and Motion for Sanctions
and Motion for Clarification are hereby incorporated by reference. Coughlin obtained the directed estimates for the
repair of the crumbling stairs/steps/risers at the home/office's entryway steps. Following Merliss's instructing yielded
a cost of $ 1.250 for the repair of the stairs. A $350 rent deduction lor one seasons of noxious weed ordinance was agreed
to in writing by Merliss. another was agreed to implicitly tor a total yard work rent deduction 0[$750, This is all detailed
in painstakingly clear emails to and from the landlord and tenant attached to the original Tenant's Answer. Similarly, the
disposal repair came to $ I25. Coughlin's law practice. and life in general, ha . been adversely impacted a great deal by
Mcrliss's misdeeds as a landlord."
Page 17: "Further Baker asserts to the court that Coughlin has somehow impeded Baker and his brownshirted
videographer from entering Coughlin's home law office, opposing party domicile, with a videographer and who knows
what else, and for some purpose for which Baker cares not to clarify or delimit in any way, and yct stilL Coughlin in no
way prevented Baker from so conducting any "inspection"."
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SELECTIONS FROM THE TRANSCRIPT OF THE 10/13/11 SUMMARY EVICTION PROCEEDING AND
THE 10/25/11 UNLAWFUL DETAINER "TRIAL":
Judge: I will allow you to testify as to what happened and why you believe the summary
eviction should not be applicable in this case. If you establish a case to my satisfaction then I
will set it over to trial, right? But at this point you havent done that.
Defendant: Yes sir Your Honor.
Judge: Youve come in to argue a motion to dismiss based on failure to comply with notice
and other issues which I denied at this point. So you can sit down and if you
want to test the fire as to why this should not be a summary eviction I will
permit you to do so.
Defendant: Even were this to go forward as a summary eviction Your Honor I would just like
to state for the record I am moving for a continuance based upon the unduly
prejudicial nature of the shutting off the electricity in the middle of the five
days that you were here.
Judge: Well you were here quite some time ago and knew all about this, so thats denied.
You first came in here to court and back in this court dismissed the prior case
in case number 1492 trying to find the date at which
Defendant: I believe it was the 26th Your Honor of September the hearing approximately.
(page 10 of unofficial "Transcript" and at 8:52 am on the certified audio transcript from 10/13/11 in rev2011-001708).
Judge: I will allow you to testify as to what happened and why you believe the summary eviction should not be applicable
in this case. If you establish a case to my satisfaction then I will set it over to trial, right? But at this point you havent
done that.
Defendant: Yes sir Your Honor.
Judge: Youve come in to argue a motion to dismiss based on failure to comply with notice and other issues which I
denied at this point. So you can sit down and if you want to test the fire as to why this should not be a summary eviction I
will permit you to do so.
Defendant: Even were this to go forward as a summary eviction Your Honor I would just like to state for the record I am
moving for a continuance based upon the unduly prejudicial nature of the shutting off the electricity in the middle of the
five days that you were here.
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Judge: Well you were here quite some time ago and knew all about this, so thats denied. You first came in here to court
and back in this court dismissed the prior case in case number 1492 trying to find the date at which
Defendant: I believe it was the 26th Your Honor of September the hearing approximately.,,,
"Judge: Wait a second sir, no you may not what am asking you for is to establish a prima facie case of retaliatory eviction
through your testimony and then if I determine and establish the prima facie case then well set it over for trial.
Defendant: Yes sir Your Honor...."
...
"Judge: Yeah and [inaudible 0:48:58] that they are his agents I find they are in independent contractor and so if you
deposit the rent by Monday at 9:00 oclock with the court in the amount of 2275 I will continue this for trial on the
merits to determine whether or not there really is a habitability issue. If the rent is not deposited then there will be no
continuance the eviction will be granted forthwith on Monday morning at 9:00 oclock. And furthermore the court is now
making any finding other than that you have made an argument about habitability and that you are entitled to trial on
that issue if you deposit the rent. Alright but you are not entitled to trial if you dont deposit the rent. And I have given
you credit based on your allegation which is, which I do not find was substantiated today; I simply find that you made that
allegation, that this is what you were owed. And so if you deposit the rent then we will set this for trial and it will be the
following week after that on the same court day. The same day of the week.
Defendant: Tuesdays and Thursday. So on the Tuesday it will be at 10:00 AM.
Judge: What day is that?" (page 27 of transcript from 10/13/11 in rev2011-001708).
From the audio and unofficial written transcript of the "Trial" on 10/25/11:
"Judge: And we have a trial. Okay, the next is Matthew Merliss versus Casey -- oh, I'm sorry, versus Zachary Coughlin.
Casey Baker represents the plaintiff in this matter and this was the time set for determination on the no cause eviction and
-- are the parties ready to proceed?"
...(at the 10:02 mark of the first audio file from 10/25/11 the following ensues):
"Judge: Well, I accept that you did and that's why we're having the trial today. (page 32 from 10/25/11)
Defendant: And that's -- I'm glad you bring that up. You said trial, Your Honor. You didnt
say summary eviction, you didnt say summary execution. You said trial, plenary-Judge: Trial on a retaliatory nature of the eviction. I assumed you made a prima facie case on
that as there's no trial on the issue. It is summary as to whether or not you were given
notice served, which the court finds you were, with a notice to terminate your lease.
Defendant: If I can just quickly interject for the record, Your Honor-Judge: Unless you had -- unless you have a lease to show that you're not there at will at this
point.
Defendant: There -- for the record, there was no certificate in my name, US Postal Service
certificate mailing on file with respect to a notice. In the context of summary eviction
proceedings, courts are directed to adhere very strictly to the notes requirements given the
summary nature of it. That's one safeguard that is insisted upon.
A right to a jury trial is granted by the United States Supreme Court from -- in summary -- in
eviction cases. Jury trial is an absolute right for all citizens in the United States. I said it's a
1970s case. I think it might be called Pearson. I believe I cite to it in my case. I don't know
that a certificate of mailing is required whereas Mr. Baker did. He had apparently a process
server, post something on the door and contest to that. I think that might be a
[INDISCERNIBLE 12:40] Supreme Court to clarify the statute at some point.
I know I spent too much time on that, Your Honor, but when you say trial, it's -- well, the
most important thing, Your Honor, to get across from my point of view, is that 40.253(6)
says that when the court, as you just indicated you did imply that there is a material issue
of fact, it's a pause-- 10/25 -
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Judge: No, I didnt imply that there was. I found that you made a prima facie case--" (page
33)
Judge: With respect to habitability and so I set it for a trial today on that issue. But the
separate issue is whether you have any defense, which you havent given me, to the no
cause eviction, which-Defendant: And I do and I can speak to that briefly, Your Honor, just-Judge: They're two separate things. Well, you're not under oath, sir, so you're arguing now
and I didnt -- I let you have some latitude, but the question is do you
have any facts to present to the court today?
Defendant: Yes, Your Honor, but just one last introductory matter-Judge: Okay.
Defendant: Is that 40.253(6) says once the court has found there's a prima facie showing,
the court must pause and convert this to a full-scale unlawful detainer
action with a complaint and the 20-days notice incident to Rule 109 of
the summary eviction proceedings, so -- and we don't have that
here. ..."
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Any later attempts by Baker to confuse the issue do not change the fact that the
above was said and ordered, and thereby, in addition to Coughlin's filing a notice of appeal
on October 18th, 2011, another basis for divesting the RJC of jurisdiction to enter any Order
thereafter (including those on 10/25/11 and 10/27/11, exists).
Contrary to the assertion in Repondent's Answering Brief in CV11-03628 at page 5 (ie, that "Coughlin
affirmatively waived any argument that NRS Chapter 118A does not apply by basing his entire defense
(retaliation/habitability) on what he alleged were violations of that chapter...." (Coughlin Note: one, there is
more to the defense, and two, Coughlin didn't say 118A didn't apply, just that NRS 40.253 is not permissible
against commercial tenant's where the non-payment of rent is not pled, particularly for the events under which
this matter rose at the times of relevant import and consdering what law then applies). Respondent continued:
"Additionally, since Coughlin never timely raised the argument below, it cannot form the basis for any relief
on appeal..." But, the fact is, Coughlin did raise that argument, in his October 17th, 2011 filing (see page 97-99
of ROA, Vol. 1), and at the hearing, and in other filings. It is Respondent who nows must fact the fact that his
failure to raise his arguments in opposition to that position put forth by Appellant bar him from now so doing.
(See Respondent's Opposition, failing to so counter Coughlin's argument, at page 108, ROA, Vol.1). But
"[p]arties `may not raise a new theory for the first time on appeal, which is inconsistent with or different from
the one raised below.'" Dermody v. City of Reno, 113 Nev. 207, 210, 931 P.2d 1354, 1357 (1997) (quoting
Powers v. Powers, 105 Nev. 514, 516, 779 P.2d 91, 92 (1989)). This rule is not meant to be harsh, overly
formalistic, or to punish careless litigators. Rather, the requirement that
parties may raise on appeal only issues which have been presented to the district court maintains the efficiency,
fairness, and integrity of the judicial system for all parties. Boyers v. Texaco Refining and Marketing, Inc., 848
F.2d 809, 812 (7th Cir.1988). This is the case becaue Coughlin plead and established that he was a commercial
tenant even beyond the October 17th, 2011 filing....(p. 240, 248 of ROA, Vol. 1, Tenant's Answer identifies
rental as "Plaintiff's home law office", etc...:"especially in light of the recent bad faith attempts to inspect with
recording equipment plaintiff's home law office hours after having the power shut off at plaintiff's home law
office where landlord had, apparently, a delinquent utility bill assigned to the property tenant rents, and where
no notice was provided to tenant of the impending interruption of essential services, causing attorney tenant
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Coughlin's law practice damages." Additionally, at page 11 of the Answering Brief, Respondent admits that
the REntal Agreement permitted Coughlin's commercial use of the property, regardless of Respondent's
attempts to make arguments in the record based upon what Respondent's think some witness who never
testified might have said had she done so.... also...
Coughlin clearly preserved his objection to the lower court exceeding the jurisdiction accord it under NRS
40.253(6) at ROA, Vol. 1, p 95-96, clearly invoked NRS 118A.290 (page 98 of ROA, Vol.1), Respodent
clearly only served a 5 day unlawful detainer notice of the No Cause Eviction variety and therefore failed to
allege non-payment of rent against this commercial tennant (p. 269 ROA Vol.1) and Coughlin clearly pled that
he was a commercial tenant (p. 160-164, 196, 240, ROA Vol. 1, and page 9-11, ROA Vol. 2, and as set forth
previously above). It is patently dishonest an violative of the Rules of Professional conduct regarding candor to
a tribunal and fairness to opposing counsel for Respondent's counsel to suggest they are blind sided by the
argument that this summary evicdtion involved a commercial tenant. However, Respondnent's counsel does
just that in its Answering Brief in CV11-03628 (p. 6 of that Answering Brief): "3. Granting a no-cause
summary eviction against a "commercial" tenant Coughlin now argues that he was a "commercial" tenant, and
therefore not subject to summary eviction. He first raised this argument in his "opposition to motion for order
to show cause," which he filed on December 5, 2011, six weeks after the eviction was granted 31. ROA, Vol.
IV, pp. 253-261. (That is not true Coughlin raised the issue in the Justice Court case, both in the hearing and in
his filing of October 17th, 2011, plead as a commercial tenant, and cited to the law forbidding the use of
summary eviciton procedures against commercial tenants where the non-payment of rent is not noticed or
alleged...further NRCP 60(b)(4) will allow for challenging the Eviction Order as void for lack of subject matter
jurisdiction (NRS 40.400 makes NRCP applicable). Merliss addressed it in his reply filed the following day.32
First, Coughlin has the law wrong. Summary evictions are available against a tenant of any property that is
subject to NRS Chapter 118A, which Merliss' property unquestionably was.33 (well, actually, not against
commercial tenant's where the non-payment of rent is not pled or noticed, as here).
And, actually, and this is awesome, really, Coughlin did in fact raise the whole issue of NRS
40.253 forbidding the use of a summary eviction procedure against a commercial tenant where the nonpayment of rent is not alleged in his Emergency Motion filed October 17th, 2011, page 99, ROA, Vol. 1: "In
most cases, the landlord can choose whether to lile a summary or f011l1al eviction action. However, there are
circumstances under which summary eviction cannot be used. For instance. summary eviction is not available
for: 2) Eviction of commercial tenants for other than nonpayment of rent (See NRS 40.254) Using location for
a "commercial" law practice, you filed a no cause, ie, "for other than nonpayment of rent. not based in law or
fact, Rule 11, plus this escrow thing gets put asunder." Plus, at page 108-115 of the ROA Vol. 1, Respondent
failed to ever address Coughlin's argument that the court lacked jurisdiction to proceed under a summary
eviction statute (see pages 16 and 17 of the filing in the Nevada Supreme Court Richard G. Hill, Esq. was
served in 60331 on August 27th, 2012, then ask how much candor to the tribunal Hill displayed in his
testimony of 11/14/12 at Coughlin's Disciplinary Hearing, largely stemming from Hill's own 1/14/12
grievance against Coughlin in ng12-0204) against a commercial tenant where the non-payment of rent was
not notice or pled....So, under Polk, Respondent's failure to file any opposition to that argument is taken as an
admission. At some point, Court's sua sponte chipping in arguments on behalf of this tag team of Respondent's
attorney's and their phalanx of legal assistants who make enough to push Mercedes SL600 sport couples
equipped with V12 engines, when considering all that is in opposition to lil' ol crazy Zach Coughlin's legal
dribble....well, it all just seems kind of unfair, doesn't it. Also, page 259 of Vol. 4. of the ROA makes clear that
Coughlin preserved his arguments related to the voidness of any summary eviction order where the "service"
thereof was as deeply flawed as the attempted service in this matter of such an Order.
Further, Hill's sworn testimony at the Formal Disciplinary Hearing of 11/14/12 in NG12-0204 was just
as dishonest, lacking candor to the tribunal and fairness to opposing counsel as was his sworn testimony at the
criminal trespass trial upon which a conviction against Coughlin was rendered on 6/18/12. At that Trial,
Coughlin asked Hill, under oath: "Q Did you have any discussion as to whether or not the lease allowed for the
tenant to be practicing law at that location? (Page -39- of official certified transcript on file in the appeal of that
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11 CR 26405 conviction in CR12-1262) A (by Richard G. Hill, Esq.) The residential lease did not prohibit it.
We did come to understand that you didn't have a business license, so we didn't feel that you were lawfully
conducting a business in premises.
Having reviewed virtually everything that you have filed in that case, Mr. Coughlin, it's my
understanding"..."That you did not raise-"... "you did not assert that argument in the Justice Court. You have
appealed the case to the District Court, and the appeal has been decided adversely to you. That case is over,
you're bound. It's done."
The complete portion of the transcript is found below:
"BY MR. COUGHLIN:
Q Did you ever have any conversation with your client about whether this was a
commercial tenant that he was seeking to evict? A I don't recall that conversation.
Page -37Q Are you aware of whether or not there is an express prohibition against using
(inaudible) eviction proceedings against commercial tenants where the non-payment of
rent is not alleged or noticed?
MR. HAZLETT-STEVENS: Judge, I'm going to object as that calls for a legal conclusion
for this witness. THE COURT: Well, I don't know how it's relevant is what I'm -I
understand what you're saying, Mr. Hazlett-Stevens. How is the issue of whether someone
is a commercial client, or a commercial tenant rather, relevant to this case, Mr. Coughlin?
MR. COUGHLIN: Well, Your Honor, I think it's possible that even ifthe City were able
to establish that the eviction order was appropriately served, which I do not believe they
will be able to do, that nonetheless, that Order will be void and that Judge Sferrazza did
not have a jurisdictional basis for rendering it and that there is an express prohibition
against using (inaudible) eviction proceedings to evict commercial tenants.
Where, as here, in the non-payment of rent, was not alleged. Despite what Mr. Hill might
be saying here, when it came time to put it on paper and face Rule 11, and put it to the
Court, Mr. Hill and Mr. Baker didn't want to do that. They just said no THE
COURT: Okay, you are losing me when you begin to ramble on, Mr. Coughlin.
Specifically, my question was how is the question as to whether or not you are a
commercial tenant relevant? And the more you wax on, the more I get -I'm not an expert
in landlord and tenant, and I begin to get detached from the issue here.
Page -38MR. COUGHLIN: I understand, Your Honor. That's what's so interesting about this case,
Your Honor.
THE COURT:
MR. COUGHLIN:
THE COURT:
relevant. MR. COUGHLIN: I just want you to tell me how it's relevant.
I am, Your Honor.
Mr. Coughlin, I just want you to tell me how it's
I will. This is a civil eviction that meets criminal
trespass nexus here. It's relevant in that if the civil eviction order lacks a basis, a
jurisdictional basis, for it to be ordered, it is what, under 60(b), void. Therefore, to the
extent the City is trying to say a warning did exist in that a notice was posted or it was
personally served. If it's void, that's a legal impossibility.
THE COURT: Okay, I'm going to allow you to ask a couple of questions about your
status as a commercial tenant or a residential tenant (inaudible) from Mr. Hill, and Mr.
Hill, do your best to answer those questions.
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I'm trying to give Mr. Coughlin a great deal of leeway here on cross-examination, in the
spirit of getting all the evidence for the Court.
So, go ahead, Mr. Coughlin. BY MR. COUGHLIN:
Q You said you spoke with your client in August and were aware that the tenant was an
attorney?
A Yes.
Q Did you have any discussion as to whether or not the lease allowed for the tenant
to be practicing law at that location?
Page -39A The residential lease did not prohibit it. We did come to understand that you didn't
have a business license, so we didn't feel that you were lawfully conducting a business in
premises.
Having reviewed virtually everything that you have filed in that case, Mr. Coughlin, it's
my understanding-.
COUGHLIN: I'm going to ask you not to go on here.
THE WITNESS: That you did not raise-.
COUGHLIN: Just answer my question, sir.
MR. HAZLETT-STEVENS: I would like him to answer -I would like him to -Judge. I
would like the attorney not to interrupt the answer to the question. THE COURT: Mr.
Coughlin, you ask these questions of a witness where they are opened ended questions.
They are not l'vIR.
COUGHLIN: It's not a blank check.
THE COURT: Listen, listen. When you are asking open ended questions, and you are not
utilizing leading questions on cross-examination, the witness is entitled to answer those
questions, and you're going to be stuck with the answer, and I think you understand that.
So, Mr. Hill, go ahead and briefly finish up what you were saying. THE WITNESS:
Thank you, sir.
Mr. Coughlin, you raised -you did not assert that argument in the Justice Court. You have
appealed the case to the District Court, and the appeal has been decided adversely to you.
That case is over, you're bound. It's done.
Page -40THE COURT: Okay, thank you, Mr. Hill. Mr. Coughlin, next question.
MR. COUGHLIN: Yes, sir, Your Honor. I appreciate the point of expertise on asking
leading questions on cross. That was something I was not intending to do. BY MR.
COUGHLIN:
Q Mr. Hill, you just testified that in August, your client and you had a discussion as to
whether or not the lease allowed for a commercial use, is that correct?
A Mr. Coughlin, I recall examining the document almost immediately. Whether I had a
discussion or not with my client or not, I don't recall.
Q I thought you just testified that you did, and you two just talked about how I didn't have
a business license. Was that not true?
A No, sir. No, sir. What I said was that he informed me that you were an attorney. At a
subsequent time, we contacted the City and ascertained that you did not have a business
license.
Q Okay, when you entered the property in November MR.
HAZLETT-STEVENS: Judge, that question exceeds the scope of my direct examination.
There is no evidence that he entered any property in November. That was just not part of
my direct at this point.
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THE COURT: Alright, Mr. Coughlin, Mr. Hill, in some substance, has testified that he
was contacted by a client to commence eviction proceedings where you were a resident
based on an issue that primarily concerned lack of rent, and he began to further up on that
Page - 41-"
Also, later in that Trial:
"Q Did you have any discussion as to whether or not the lease allowed for the tenant
to be practicing law at that location?
Page -39A The residential lease did not prohibit it. "
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"Sferrazza ultimately determined did not exist, and you did not prove. Q So your
office converted it to a no cause summary eviction notice?
A More precisely, sir, the decision was made to forego the rent eviction and simply do
a 30-day no cause.
Q Okay, and if subsequently the tenant was considered a commercial tenant,
would that not be tantamount to sort of a wrong side legal surgery?
Page -43A Well, I don't quite understand your metaphor, sir. But the fact of the matter is it was
a residence. The fact that you were illegally conducting a business there, a side issue,
number one.
Number two, you didn't raise it in the Justice Court.
Q You say it was a residence. Is it zoned for just residential use?
A I don't have any idea, sir.
Q Well, why did you say it was a residence if you don't have something to base that
upon?
A That's what the lease said, and there was no lawful business being conducted.
Q The lease said -did the lease say a commercial use was acceptable?
A I don't know, Mr. Coughlin.
Q Well, how can you testify to what the lease said if you don't recall?
A I'm giving you my best recollection, Mr. Coughlin. Q Okay, now whether or not the
lease -you said the first thing you did was you read that lease.
A That's not what I said.
Q Well, did you say something substantially similar to that earlier when you were
testifying? A I said I almost certainly looked at the document almost immediately.
Page -44Q Okay, so you -after your office has billed 60 grand, you aren't sure whether or not
the lease said something about it being commercial use acceptable?
MR. HAZLETT-STEVENS: Judge, he's asked and answered that question already.
There's no evidence as to the 60 grand (inaudible).
THE COURT: Yeah, that's assuming a fact not in evidence. I'm going to sustain the
objection. BY MR. COUGHLIN:
Q Did your office bill approximately $60,000 to (inaudible)?
MR. HAZLETT-STEVENS: Objection, relevance.
THE COURT: Sustained. It's irrelevant, Mr. Coughlin. I've
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addressed that issue. Mr. Hill's financial arrangement with his client is irrelevant to
this trespassing case. I'm really not legally interested in the amount of money he billed
nor received. I think it's irrelevant. MR. COUGHLIN: I'm not offering to prove the
truth of the matter asserted in what he billed. I'm offering it THE
COURT: I'm telling you it's irrelevant. That's a hearsay issue whether it's been offered
to prove the truth, and quite frankly, I'm making a judicial determination that his
relationship with his client related to finances is irrelevant to this trespassing case.
So, I'm going to not allow any questions related to that line of inquiry. So, let's move
on to our next question. MR. COUGHLIN: Yes, sir.
Page -45BY MR. COUGHLIN:
Q Was the issue of whether or not the lease allowed for a
commercial use a very important issue in that summary eviction proceeding
from which this criminal trespass (inaudible)? A Are you asking was that an important
consideration in
my being able to undertake the assignment? The answer is no.
As to what exactly you did or said -(inaudible -both talking).
Q No, I'm asking you if it was important as to whether or
not it was permissible to pursue a summary eviction proceeding if it's a
commercial tenant where you are only alleging non-payment of rent.
THE COURT: If you can answer that, Mr. Hill, go ahead.
THE WITNESS: I didn't hear it, and I'm not sure that I can
understand it. But if you'd like to try again, I'll-THE COURT: Go ahead and rephrase the question, Mr. Coughlin. Speak loudly and
clearly and Mr. Hill will do his best to answer
that question.
BY MR. COUGHLIN:
Q Was it an important consideration to your office in the course of representing
Dr. Merliss whether or not the lease agreement allowed for use of the premises
for a commercial use?
A No.
Q You are testifying that your office's representation of Dr. Merliss did not
include a careful consideration of whether or not the lease allowed for a
commercial use of the premises?
Page -46MR. HAZLETT-STEVENS: Asked and answered, Judge. He said no.
THE WITNESS: That wasn't the question. The question was whether
THE COURT: I got three things going on here, and we're making an oral record so
let's try to keep it civil to the extent we're able to. Mr. Hazlett-Stevens has raised an
objection to the question. Mr. Coughlin, do you want to respond to that?
MR. COUGHLIN: Yes, sir. Mr. Hazlett-Stevens said it was asked and answered, I
believe?
MR. HAZLETT-STEVENS: Yes, there was an objection asked and answered after he
said no to the previous question, asked slightly differently.
THE COURT: What's your response to Mr. Hazlett-Stevens?
MR. COUGHLIN: It was seeking clarification because I was surprised to hear no to
such an important issue.
MR. HAZLETT-STEVENS: Surprise doesn't overcome.
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THE COURT: Okay, as a matter of clarification, so the record is clarified, ask the
question again, and Mr. Hill, let's see if we can answer that question to the best of
your ability. Go ahead, Mr. Coughlin.
BY MR. COUGHLIN:
Q Mr. Hill, did you just testifY that you did not feel it was an important consideration
in representing your client to determine whether or not the lease in question would
permit commercial use?
A No, it's not important. We were hired to evict you, and
Page -47that was the assignment.
Q Okay, so if the law has an express dictate prohibiting the use of summary
eviction proceedings against commercial tenants where the non-payment of rent
is not alleged or served as an eviction notice, would that present a situation
where it would be an important consideration?
A Mr. Coughlin, I'm having a real tough time following
your question.
Q Okay.
THE COURT: Go ahead and rephrase the question, Mr. Coughlin.
THE WITNESS: You've made it in small pieces.
THE COURT: Hang on, Mr. Hill. Rephrase the question. Let me tell you, I'm giving
you a great deal ofleeway on cross-examination in fairness to you, and we're getting
into issues that really, really exceed the scope of the direct examination. And I'm
willing to give you a great deal of leeway, but at some point, the leeway limitation
comes to an end. So, go ahead and ask one more question related to this. Try to make
it specific, and then Mr. Hill will do his best to answer that question.
MR. COUGHLIN: Yes, sir, Your Honor. Just quickly, I'm a little green on this, but he
opened the door quite a bit, too.
THE COURT: Go ahead and ask a question, Mr. Coughlin.
BY MR. COUGHLIN: Q You just testified that you did not feel it was an important
consideration whether or not the lease allowed for commercial
Page -48
use, correct?
A Yeah, it was not that important.
Q Okay, would it become important if your entire case, or the order which you
prepared for your client was void because there is no jurisdictional basis for
entering such an order?
A If your presumptions were correct, which they're not, then it would become
important. But since you're wrong, it was not important.
Besides that, you didn't raise it. Q Was the fact that the property was being used
for a commercial purpose set forth in the tenant's affidavit?
A I don't know.
Q You don't know?
A I do not recall.
Q You just testified that it wasn't raised, so how could you do that with a straight
face, and then answer you don't recall now?
THE COURT: Mr. Coughlin, he's answered the question that he doesn't recall.
Your comments become argumentative so let's We're getting into an area where
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I'm not going to litigate in this Court the merits of the landlord/tenant
relationship, nor the -ultimately the basis for the eviction.
Mr. Hill has testified to a limited degree what he's done, and if you have anything
relevant to what he said, go ahead and ask it. If not, I think it would be a good
time to terminate your cross-examination unless you have any other relevant
questions."
Page -49 of the official transcript from the CR12-1262 appeal for the 6/18/12 criminal
trespass trial in 11 CR 26405.
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also, consider Casey Baker's malfeasance and the fact that Coughlin hereby swears
under penalty of perjury, pursuant to NRS 53.045, that the locksmith who conducted
the lockout on 11/1/11, Sean Cheathum, told Coughlin that the lockout occurred no
earlier than 4:48pm and, in fact, it was a real rush and point of issue with Baker and
the WCSO to get it done prior to the clock striking 5 pm on 11/1/11. Further,
Coughlin subpoened the Reno Justice Court in accord with the SBN/NNDB/Panel's
indicationg as to the particular SCR 105(4) and NRCP 45 application attendant and
attachign to Coughlin's Disciplinary Hearing, however the RJC failed to respond and
fraud by Pat King prevented Coughlin from as fully asserting his right to a
continuance or to make a show cause motion releative thereto at the 11/14/12 hearing.
WCSO Civil Division Roxy Silve told Coughlin the WCSO will effect lockouts even
where they know over "24 hours" has passed since their office received the lockout
orders" as the WCSO office feels entitled to do it how they like to and thinks they can
walk over tenant's in violation of the law, purposefully and willfully. Silva has
slammed the phone down several times when speaking with Coughlin and offered
evasive and vague answer respecting when her office FIRST received either of the
eviction orders in rev2011-001708, and further silva, and Stuchell have indicated that
the faxed eviction orders they received from the RJC (and the RJC's Karen Stancil has
indicated it is the customary practice and policy of the RJC to fax such eviction orders
over the day they are signed or the next day at the latest) are taken from the wcso fax
machine, and bare a fax header indicating the time of receipt of the order, at which
point an employee manually enters a time into a software program that refeclts not
when the faxed order was received, but rather the time at which the employee
undertakes manually typing into the softward program a representation of when they
pulled the order off the fax machine. silva and stuchell then indicate that no copy or
record of that fax with the fax header indicating the time of transmission or receipt is
kept, but rather that exact printout is filed with the Affidavit of Service after the
lockout is conduct by the wcso, which the RJC totally disputed to Coughlin and has
not been Coughlin's experience either)... Coughlin similarly supoened the WCSO and
it is unclear whether Coughlin coudl hire them to serve the subpoenas on themselves o
whether they and or Mary Kandaras waived service thereof or are conflicted out of
seeking to quash such subpoenas. See the attach Reno Carson Messenger receipt
showing delivery of the Lockout Order to the WCSO at 4:45 pm on 10/31/11 (and
note WCSO's Deputy Machen lists both the 10/25/11 Order and the 10/27/11 Orders
as both being "personally served" (his supervisor Stuchell later admitted that only
means "posted on the door when no one is home)...
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NRS 40.253 requires lockout orders incident to evictions contain an "order directing
the sheriff or constable of the county to remove the tenant within 24 hours after
receipt of the order"
NRS 40.253:
"3. A notice served pursuant to subsection 1 or 2 must:
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(1) Of the tenants right to contest the matter by filing, within the time specified in subsection 1
for the payment of the rent or surrender of the premises, an affidavit with the court that has
jurisdiction over the matter stating that the tenant has tendered payment or is not in default in the
payment of the rent;
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(2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may
issue a summary order for removal of the tenant or an order providing for the nonadmittance of
the tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours
after receipt of the order
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(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the
justice court of the township in which the dwelling, apartment, mobile home or commercial
premises are located or to the district court of the county in which the dwelling, apartment, mobile
home or commercial premises are located, whichever has jurisdiction over the matter. The
court may thereupon issue an order directing the sheriff or constable of the county to
remove the tenant within 24 hours after receipt of the order. The affidavit must state or
contain:
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(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the first
months rent, by the tenant.
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(7) A statement that the written notice was served on the tenant in accordance with NRS 40.280.
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(b) Except when the tenant has timely filed the affidavit described in subsection 3 and a filestamped copy of it has been received by the landlord or the landlords agent, and except when the
landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may, in a
peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
otherwise.
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the
information contained in the affidavit, and the filing by the landlord of the affidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the
hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice
provided for in this section. If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a summary
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order for removal of the tenant or an order providing for the nonadmittance of the tenant. If the
court determines that there is a legal defense as to the alleged unlawful detainer, the court shall
refuse to grant either party any relief, and, except as otherwise provided in this subsection, shall
require that any further proceedings be conducted pursuant to NRS 40.290 to 40.420, inclusive.
The issuance of a summary order for removal of the tenant does not preclude an action by the
tenant for any damages or other relief to which the tenant may be entitled. If the alleged unlawful
detainer was based upon subsection 5 of NRS 40.2514, the refusal by the court to grant relief does
not preclude the landlord thereafter from pursuing an action for unlawful detainer in accordance
with NRS 40.251.
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a
motion, file a motion with the court, on a form provided by the clerk of the court, to dispute the
amount of the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 for
the inventory, moving and storage of personal property left on the premises. The motion must be
filed within 20 days after the summary order for removal of the tenant or the abandonment of the
premises by the tenant, or within 20 days after:
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whichever is later.
8. Upon the filing of a motion pursuant to subsection 7, the court shall schedule a hearing on the
motion. The hearing must be held within 10 days after the filing of the motion. The court
shall affix the date of the hearing to the motion and order a copy served upon the landlord
by the sheriff, constable or other process server. At the hearing, the court may:
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(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230
and any accumulating daily costs; and
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(b) Order the release of the tenants property upon the payment of the charges determined to be
due or if no charges are determined to be due...."
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Richard Hill purported to be able to keep the RJC from giving Coughlin a hearing for six weeks,
until December 20th, 2011, thereby implying an improper ability to influence a tribunal, in his
November 21st, 2011 email to Coughlin
Baker's sworn testimony on 6/18/12:
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that correct? A That's correct. Q After which Mr. Coughlin was no longer allowed to be
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there, is that correct? A That's correct. Q So, the Findings of Facts, Conclusions of Law and
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Order of Eviction found in your favor, Mr. Merliss's favor, rather, and the date of eviction was as
of October 31" at 5:00 p.m., correct? A That's correct. That's what we announced in Court and put
on that Findings of Fact. Q And that Order said that anyone there after that date could be
removed, is that correct? A That was the command given to the Sheriff. Q "Shall be removed." A
Yes.
Page -66Q
Did you serve that document on Mr. Coughlin in any fashion? A Notice of Entry of Order or
anything like that? Or was that served by the Court on him?
A The way it works is the Court -after the Court enters the Order, the Court forwards it to the
Sheriff. Q Okay.
A And the Sheriff goes out and enforces the order.
Q Okay, now I'm going to draw your attention to the date of November 13th, 201 1.
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THE COURT: What was that date again?

MR. HAZLETT-STEVENS: November 13, 2011, Your Honor.
THE COURT: Okay, give me just a second, counsel.
MR. HAZLETT-STEVENS: Certainly, Judge.
THE COURT: I'm making some notes here regarding some dates.
MR. HAZLETT-STEVENS: And I'm going to withdraw that question, Your Honor, so if you
don't want to jot that note down, you don't have to at this point.
THE COURT: Okay, I'm looking at something else, okay. Go ahead. Thank you, counsel. BY
MR. HAZLETT-STEVENS:
Q I'm going to draw your attention to the date of November 1 st, 2011. Do you recall what you
were doing that day?
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A Yes, I was actually off of work that day. I was at home.

Page -67Q Okay. A But I was basically on stand-by because I knew that the eviction was going to happen.
Q Okay, and did you actually eventually respond or have to come to the area of 121 River Rock?
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A Yes.
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Q Why?
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A The way it works, again, I'm sorry to keep doing this.

Q Please, please, please, you are educating us all.
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A You have to wait for the Sheriff to contact you.

Q Okay.
A The Sheriffs Deputies are sent out with several of these things on the days that they do them,
however, they do them every day. You can try to shoot for a specific time, but you are at the
mercy of the Sheriffs Deputy's schedule. Some lockouts take longer than others. They try to give
you lead time.
I had spoken with the Sheriffs Deputy already, I believe, on Friday the 28th Q Okay. A I
believe. It was either that, or I contacted him on his cell phone. But I came back in
(inaudible) do the lockouts.
THE COURT: I'm sorry?
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THE WITNESS: I came back in so we could do the lockout, to meet the Sheriffs Deputies at the
property after the Sheriff calls. Q Okay, and so you actually did go to 121 River Rock?
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A Yes.
Q And were there Sheriffs Deputies there?
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A I got there first.
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Q Okay.
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A Along with a member of our staff.

Q Okay.
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A And then two Sheriff's Deputies arrived.
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Q Okay.
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A And then we had to wait for the locksmith.
Q Okay, when the Sheriff's Deputies arrived, did they have any documents in their hand? A
I believe they had -yes, they had their copies of the Findings of Fact, and Order for
Summary Eviction. Q Okay, and do you recall what the deputies, or one or both of those
deputies did with the Findings of Facts and Order of Eviction?
A Yes.
Q Please tell.
A Once -the short answer is they take you to the door.
Q Okay.
A I can tell you the process, if you want.
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Q Please, tell us what happened.

A When the locksmith finally arrived, the Sheriffs bang on the door, announce their
presence, "Open up, police, sheriff."
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There was no response. At that point, everybody stands back. They get the locksmith to go ahead
and open the door. He opens the door.
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The Sheriffs go in. They clear the property, make sure nobody is there. Then they came back out
and they tape it to the door.
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Q Okay, and you said the locksmith was there, too?
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A Correct.
Q What did the locksmith do?
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A The locksmith, his first task was to open the front door.
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Q Okay.
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A After he did that, and after the Sheriff clears the property, then he changes the locks, re-keys the
locks.
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Q Okay.
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A On the front door and the back door.
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Q Okay, and what did the -were there new keys associated with re-keying the locks?
A Yes.
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Q What did the locksmith do with the new keys?
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A Gave them to me.
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Q Okay.
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A It was either me, or Sherry Hill, who was also with me from my office. I think he gave to me. Q
I'm sorry? A I think he gave them to me. Q Okay, and so thus, the old keys that were formerly
associated with that lock would no longer work, is that correct?
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A That's my understanding.
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000488
Conclusion:
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Please consider those issues set forth herein and drop Hill's grievance and file this as a
formal grievance against Hill and Casey Baker, Esq. and SCR 104(3) against Bar Counsel for
their failure to investgiate Hill and Baker's malfeasance.
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Dated this November 26th, 2012:
__________________________
Zachary Barker Coughlin
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000489
CERTIFICATE OF SERVICE:
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Pursuant to NRCP 5(b), and SCR 105(4) and the previous admission and indications by the
SBN/NNDB/Panel, I do hereby certiffy that, on this date, I, Zach Coughlin I deposited in the United
States mail at Reno, Nevada, in a sealed envelope, postage prepaid, a true and correct copy of the
foregoing MOTION FOR NEW TRIAL; MOTION FOR MISTRIAL; MOTION TO STRIKE;
MOTION FOR ARREST OF JUDGMENT and or electronically served (via electronic method of
transmission previously given express permission to utilize by those with requisite authority to
provide it, upon which Couglin reasonably relied and or relies)
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Dated November 26th, 2012.

____________
Zach Coughlin
Repondent
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000490
index to exhibits:
1. exhibit 1: various relevant materials including Declaration of Zach Coughlin.
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000491
Print
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Supplemental to 11 23 12 correspondence regarding

discovery in Joshi 54844, April 2009 Order sanctioning
Coughlin
Sent: Sun 11/25/12 1:41 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (je@eloreno.com) (je@eloreno.com);
(patrickk@nvbar.org) (patrickk@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net);

(cvellis@bhfs.com) (cvellis@bhfs.com); (jgarin@lipsonneilson.com) (jgarin@lipsonneilson.com);
(pelcano@washoelegalservices.org) (pelcano@washoelegalservices.org);
(linda.gardner@washoecounty.us) (linda.gardner@washoecounty.us)
1 attachment
03018 to 03041 Judge Linda Gardner listed by SBN King as greivant in ng12-0435 fyi
prosecutorial misconduct blog smaller size.pdf (10.5 MB)
I believe I informed WLS of this previously, but I did try to have discovery send out in Joshi, but
Deborah Pringle and then WLS Office Manager Robin Kunce indicated it would take something on
the order of six weeks to get a check cut for anything, such as for witness fees or those associated
with a subpoena duces tecum, and the Trial of March 12th, 2009 in Joshi was not far out enough to
account for such an unanticipated indication from WLS as to what would be required to conduct what
Judge Gardner indicated in her April 2009 Order as the sort of discovery she felt would be necessary
to rebut an inference of vexatiousness for not immediately caving to Mr. Springgate's Siragusa
argument. Further, it was never my understanding that either Ms. Santiago or myself "agreed" to
then Master Gardner entering an Order "resolving" the dispute as to the car title in the Temporary
Protection Order hearing in Santiago v. Vaxevanis.
What is interesting is that, on one hand, Mr. Elcano is being told to fire me or else by CAAW and
Tahoe Women's Services for allegedly not being zealous enough in advocating their agendas, er, for
the victims of domestic violence in the Carnine and Haubl matters, , Further, in early January 2009,
WLS's Rhonda Harrison is saying "eat me" to Coughlin when he attempts to use the upstairs
restroom at WLS. Couglin sens a written complaint about that to Mr. Elcano, and he holds a meeting
with Coughlin which results in, as Mr. Elcano testified at the Disciplinary Hearing, his "standing by
my employee". It would seem true that Mr. Elcano did jut that, at that time (ie, stand by his
employee, Coughlin). In fact, it was during a face to face meeting with Coughlin in February 2009
or so that Elcano told Coughlin about the appraisals of Coughlin's work by Judge Gardner and Master
Edmondson, with both, essentially, giving Coughlin a "thumb's up" review (ie, good enough work
not to be fired, etc.). It was at that point that Mr. Elcano casually mentioned that he had done
something in the past for Judge Gardner (it didn't sound as ominous coming from Paul as it does
when I write it....) and that, essentially, that was some indicia of reliability as to Judge Gardner's
candor to Elcano in assessing Coughlin's work at that time, and therefore, Mr. Elcano was reinforced
in his belief in his position that it would be inappropriate to let CAAW and Tahoe Women's
Services, essentially, tell him who to fire or not.
000492

file:///R|/...2%20email%20to%20elcano%20gardner%20panel%20sbn%20et%20al%20garin%200204%2060302%20.htm[11/27/2012 12:39:34 AM]
But the irony is that I was fired, according to Mr. Elcano's letters to me of May 1, 2009 and May 7,
2009 because of the April 13th, 2009 Order by Judge Linda Gardner finding my conduct at trial to be
vexatious. It is inaccurate and overly convenient to now attempt to remix that assessment, as Mr.
Elcano did in his testimony on 11/14/12 to indicate my advocacy was merely 'incompetent'. Further,
testimonial evidence is evidence, as such, Judge Gardner's Order is inaccurate to the extent is
suggests no evidence was put on as to, say a Tonopah formula approach is determing the alimony
question. Whereas Judge Gardner found I advocated too zealously on behalf of a battered woman (to
the point of vexatiousness, no less), Tahow Women's Services and CAAW had, in close proximity
and previous to Judge L. Gardner's April 2009 Order, complained that I did not advocate strenously
enough, apparently (Mr. Elcano has refused to release those writings to me).
Tahoe Women's Services (which apparently changed its name to something less gender
polarizing upon Coughlin's critique thereof, as it is now known as Crisis Intervention
Services) provided a written complaint about Coughlin's performanc eot Elcano in FV08
02254 - PAOLA C. PEREZ HAUBL VS. ANDREW A. CRAIG. Coughlin hereby requests,
again, a copy thereof.
Likewise, the Committee to Aid Abused Women (CAAW) (no name change as of yet)
complaint in writing to Elcano about Coughlin with respect to his representation of Michelle
Carnine in a TPO and or divorce matter. Coughlin hereby requests a copy of any written
complaints submitted by anyone with respect to either of those Carnine matters:
CASE NO. FV08-02021 MICHELLE CARNINE OBO STORMY VS. BRADLEY

CARNINE CASE NO. DV08-01532 MICHELLE CARNINE VS. BRADLEY CARNINE
The funny thing is, for prosecutors (and see Judge Gardner's apparent "FYI"
correspondence to the State Bar of Nevada's Pat King in NG12-0435, bate stamping
indicating Judge Linda Gardner as the grievant, and the blog entry related to prosecutorial
misconduct being taken note of place directly after the fate stamped folder name listing
Judge L. Gardner as the grievant in that 0435 case...with both Judge L. Gardner and her
brother, RMC Judge W. Gardner being lifelong prosecutors before taking the bench, like
most judges in Washoe County, though they are two of the rare exceptions who did not go
to McGeorge).
Some might say the District Attorney and Reno City Attorney Offices influence as
prosecutors extends to the District,Justice, and Municipal Courts to an impermissible
extent...and now, with the firing of Coughlin from Washoe Legal Services, and the entering
into the Early Case Resolution (ECR) contract between the WCDA's Office and WLS to
deliver some sort of approach that some say violates the Sixth Amendment, local legal aid
is impermissibly influence by local prosecutors, so much so that, regardless of what the
000493
legislature may enact (often in response to the tireless advocacy by those such as WLS's
Jon Sasser, especially regarding AB226 in the landlord tenant context along with Coughlin's
Boyd School of Law early, unaccredited days, classmates, Assemblymen William Horne and
Jason Frierson, in conjunction with Tik Segerblom). A quick look at a retaliatory arrest and
eviction of Coughlin this year reveals a disturbing pattern of the local judiciary being overly
influenced by the prosecutor's office, and taking a markedly laissez faire approach to
prosecutorial misconduct, in marked contrast to the seemingly overly aggressive approach
by lifelong prosecutor's turned judges RMC Judge Nash Holmes, RMC Judge Kenneth
Howard, RMC Judge William Gardner, and Second Judicial District Court Judge Linda
Gardner in "protecting the public" from the work of one Zachary Barker Coughlin, Esq.
(whom has held himself out as an attorney who takes on cases of prosecutorial and police
misconduct...a type of attorney whom the SBN's Patrick O. King seems to have carved out
a specialty in prosecuting, right, James Andre Boles, Esq, the attorney whom has most
consistently sued local law enforcement for wrongful arrest and other police misconduct,
just now being harrassed by the SBN in In Re the Discipline of James Andre Boles, Esq.?
Is SBN Bar Counsel Patrick O. King, Esq. puttin' in work for prosecutors and police alike?):
Further, during the numerous retaliatory prosecutions this year of Coughlin, a multitude of
prosecutorial misconduct has been apparent, inlcuding DDA Zach Young (McGeorge '04)
making argument in filings with the Reno Justice Court in RCR2011-063341 that alleged
communitcations between ECOMM/911 dispatch and the RPD in relation to the arrest of
8/20/11 (the one that started the entire 16 month ordeal off) that contained communications
from dispatch to the RPD of "a possible fight", which DDA Young and RPD Officer Nick
Duralde (whose wife, Jessica Duralde was working that night at a 911 dispatcher and
whose voice may be on the tapes only released by Reno City Attorney Skau on 11/13/12
incident to an Emergency Hearing on Motions to Quash Coughlin's subpoenas (and, really,
Judge Sferrazza admitted later that the hearing was also based on Motion to Quash that
were not even filed, but rather just a sua sponte overall intention by Judge Sferrazza, the
longest tenured Mayor in Reno's history, a former Chairman, Vice-Chairman and Washoe
County Commissioner from 1998-2007, to Quash pretty much every subpoena Coughlin
drafted in any way related to anyone in goverment).
The prosecutorial misconduct has been detailed at length in Couglin's filing with the Nevada
Supreme Court this year, save, perhaps the new instances where DDA Young's assertions
of dispatch alerting RPD Officers of "a possible fight" prior to their arriving to respond on
8/20/11 (and the utility thereof incident to the Hearing on Coughlin's Motion to Suppress)
has been thoroughly disproved by City Attorney Skau's only finally releasing those tapes on
11/13/12, after he secured Coughlin's attendane at a Hearing on his Motion to Quash
Subpoenas by alleging the court had granted him the power to effect service thereof by
emailing Coughlin (and Coughlin SBN form Disciplinary Hearing was held the next day
000494
11/14/12, where Judge Linda Gardner's bailiff was assigned to the affair, the same bailiff
present at the April 12th, and 17th, 2009 Trial dates in the Joshi matter that became 60302
and 54844. Judge Gardner's brother also refused to recuse himself from the criminal
trespass prosecution of Coughlin incident to an arrest at his former home law office.
Coughlin has detailed the prosecutorial misconduct of City Attorney's Roberts (in 60838)
and Hazlett-Stevens (in 61901) in addition to that of DDA Zach Young (three different
prosecutions, each one more retaliatory than the last) and the multitude of violations of the
stay required by NRS 178.405 (in consideration of NRS 5.071, especially).
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000495
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Chief Marshal Roper and Marshal Harley on setting the record straight
in NG12-0435
Sent: Fri 11/23/12 4:09 PM
To: roperj@reno.gov (roperj@reno.gov); harleyj@reno.gov (harleyj@reno.gov); je@eloreno.com
(je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com (cvellis@bhfs.com);
eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
patrickk@nvbar.org (patrickk@nvbar.org); christensend@reno.gov (christensend@reno.gov);
mike@tahoelawyer.com (mike@tahoelawyer.com); davidc@nvbar.org (davidc@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); stuttle@washoecounty.us (stuttle@washoecounty.us); wongd@reno.gov
(wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov); mkandaras@da.washoecounty.us
(mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us); jleslie@washoecounty.us
(jleslie@washoecounty.us); holmesd@reno.gov (holmesd@reno.gov)
Dear Panel, Judge Nash Holmes, Chief Roper, Marshal Harley, Bar Counsel, et al,
I apologize for using email to communicate here, but my current indigency and time
constraints so require it. Further, I in no way wish to violate any Orders by any of the
RMC Judges respecting emailing or contacting the RMC in connection with specific
cases, and submit this limited correspondence in the hopes that my interpretation of any
such Orders is in line with reality and will forgive at least this limited use of email
outside of any attempt to file anything in any of the matters in which I am a party
before the RMC. The exigency involved here relates primarily to the enormous
deference that will be given to the Panel's decision in the SBN v. Coughlin disciplinary
matter, and my desire to have the Panel afforded every opportunity to have all essential
information necessary to arrive at a just decision at its disposal. What follows is in part
a request and in part a recognition of the extent to which Judge Nash Holmes's action
during the 2/27/12 Trial in 11 TR 26800 may likely have been the best thing to have
had done, owing to her vast experience in these and a great deal many other matters,
and, hopefully, will have an upbeat result stemming therefrom.
At the Double R Blvd. Northern Office of the State Bar of Nevada, RMC Judge Nash
Holmes, on 11/14/12, testified under oath and indicated something along the lines of
the following:
000496
file:///R|/1%20a%20NEW%20temp/11%2023%2012%20fax%20to%20SBN%20containing%20four%20recent%20emails%200204.htm[11/23/2012 4:12:05 PM]
During the 11 TR 26800 "simple traffic citation Trial" on 2/27/12, starting at about 3
pm, Judge Holmes interrogated Coughlin as various points throughout the Trial as to
whether he was recording the proceedings (without permission), and or whether he had
a "recording device" (whether every laptop anyone brings to Court would be
considered a "recording device" to Judge Holmes is not exactly clear).
Judge Holmes then testified that after an initial round of interrogation of Coughlin as to
whether he was recording the proceedings and or had a "recording device" that
Coughlin got "all sneakity" and said he was not, but then "quote, 'took the Fifth' then
immediately asked to be allowed to use the restroom...and I ordered Marshal Joel
Harley to accompany him there...and it was reported to me that while in the restroom
Coughlin disassembled a recording device and hid some part of it in the restroom..."
(Coughlin recounts this testimony from memory, and admittedly, it is far from
verbatim).
It is categorically false (though not necessarily maliciously so) for Judge Nash Holmes to
assert, in the audio record on 3/12/12 the order of events and when she asked Coughlin her
questions about recording, considering when a restroom break took place and exactly what it
is she asked Coughlin and when, and what his responses were, and when some allegations by
"the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio
transcript reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering
from some extreme form of mental illness. during the trial I asked the defendant attorney
repeatedly if he was recording the proceedings he denied that vehemently a few times and
then he quote took the fifth a few other times and then he requested to be excused to go
to the bathroom and the Marshal later reported to me that while the gentleman was in the
bathroom he disassembled a recording device in his pocket and took the memory out of it
and it was later found in that, uh, by the Marshal no one else had gone into the bathroom
and that was retrieved and it was put into his possession at the Sheriff's office and when
they booked him into jail for the contempt charge that was booked into evidence and I
asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme
Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
000497
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
Perhaps NRS 178.405 in the context of NRS 5.073 should have some baring on anything said or done
or Ordered by Judge Nash Holmes following her statement at the 7 minute mark that "It appears to me
in this case that the defendant is suffering from some extreme form of mental illness." To the extent
any question of Coughlin's competency was communicated to or brought to Judge Nash Holmes
attention prior to the 2/27/12 3:00pm start of the Trial in 11 TR 26800, that proceeding should have
been stayed or suspended, especially if the WCPD's Office made such communnications in close
temporal proximity to the 1:31 pm 2/27/12 Order for Competency Evaluation by Judge Clifton in
RCR2011-065630. And arguably, given the same office (in a broad sense) in which DDA Z. Young and
DDA Kandaras work, it is arguably a basis for conflicting out the WCDA's Office from any one of the
three prosecutions is has maintained against Coughlin this year (especially considering the issues related
to whether the WCSO's timely effected the lockout of 11/1/11 in the eviction from Coughlin's former
home law office, which, given the recent admissions by the locksmith there that day, and the Reno
Carson Messenger receipt from the day prior, and Casey Baker, Esq's testimony related to his
interactions with the WCSO on October 28th, 2012 during his sworn testimony at the criminal trespass
trial before RMC Judge Garder on 6/18/12, and the RJC's failure to even move to Quash Coughlin's
subpoenaing records related to the fax logs and confrimation of transmission or receipt incident to the
RJC's "usual custom and practice" of faxing eviction Orders to the WCSO for service (like those in the
Richard Hill/Casey Baker Summary Eviction "Trial" involving Coughlin's former home law office, and the
"within 24 hours of receipt" language found within NRS 40.253 (the Order is void or invalid after that
point, in which case, it would mean Hill and or Baker were the trespassers, not Coughlin, regardless, its
inappropriate for RMC court appointed defender Loomis to categorically refuse to assert any claim of
right defense that such a criminal trespass defendant may wish to assert for, say, Richard Hill admits to
charging the same rent under a "storage of personal property" that was previously charged for "full use
and occupancy". Nonetheless, posting an Eviction Order that does not contain stay away language
(much less the fact that is does not have the required "within 24 hours" language called for by the
statute) is not tantamount to posting a no trespassing sign, further, Hazlett-Stevens making arguments
in his closing as to matters not in evidence (allegations of living in the residence) is reversible error, and
for Judge Gardner to do as Judge Howard did, an prevent the City Attorney from even having to Oppose
Coughlin's Motion for New Trial, is further indication of the extent to which Coughlin's reactions during
the 2/27/12 Trial, however offputting, are not totally unfounded. Further, that which Judge Nash
Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be
testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her
mental processes" loophole, as he has done. But, actually, a review of the Hardesty/Mirch dynamic
may dictate that Coughlin would have been fairly limited in that regard anyways, nonetheless, Judge
Nash Holmes appeared, to her credit, and answered some questions. The answers revealed an
opportunity put forward now to clear some things up, though the constraints of the Disciplinary Hearing
format, some disagreements over what the SBN communicated to Coughlin with respect to the rules
that would be applied to him vis a vis NRCP 45 subpoenas (whether, he, as a suspended attorney could
issues a subpoena (Coughlin maintains the Bar/Panel/Board did give him such authority) and whether
000498
any witness fee or subpoena decus tecum fee must be paid by Coughlin (Coughlin maintains he was
provided indications upon which he reasonably relied that he would not be so required in additions to
the rules or practicies attached to the service thereof), and other factors severely limited the extent to
which the opportunity created by Judge Nash Holmes testimony was realized to its full potential. That
necessitated this correspondence. Coughlin recalls the first time he saw opposing counsel allege he
was lying in a filing, it was one of the early one's by Richard Hill's former associate Casey Baker, alleging
"outright lies". It was upsetting, especially considering how unfair and baseless the allegations
seemed...and Coughlin nows wishes he would have done and said some things differently incident to
his testimony relative to RPD Sargent Tarter and Judge Nash Holmes's own testimony, and intends to
address the extent to which objectionable conduct by opposing counsel can often times become a sort
of learned characteristic perpetuating a race to, if not the ethical gutter, at least a preponderance of
Rambo litigating. To some extent the incidents with Marshal Harley and RCA Ormaas may be fallout
from that. Important too, however, is to consider whether the "courthouse sanctuary" doctrine has
some application, however confusing it may be, where the WCSO may be hired by private parties to
conduct service, and the Marshals are only extending intra-governmental courtesies in assisting in the
manner in which Marshal Harley did on 2/27/12. Richard Hill gets the "oopsies" a lot. Oppsie, I
asked for $20K in attorney's fee incident to a summary eviction at the trial court level, despite that not
being supportable under NRS 69.020, Hill says. Oopsie, I left the window unit air conditioner in the
exposed to the street by the Lakemill lodge window at your former home law office, which was then
robbed, but for which I still managed to charge you full rental value at full use and occupancy rates,
though I had you subject to an arrest for custodial trespass anyways, Hill and Baker say.
(at the 9 minute 48 second mark of the first audio file attached from 2/27/12)
"Judge: Sir, I would like you to raise your hand to be sworn, because its my experience that people who
represent themselves tend to testify a whole lot when they are asking other people questions, so let's
just start that way and then we won't have to do it later, so swear him in and then we'll get going
Marshal: Testimony (inaudible)...you are about to (inaudible) understand (inaudible) truth, whole truth,
nothing but truth, solemnly?
Coughlin: Yes, Sir?"
However, from there, throughout the Trial Judge Nash Holmes interrupts Coughlin during his
questioning of Tarter to indicate to Coughlin that he is asking questions and not testifying, or that he
will have an opportunity to make some point when its his turn to testify, if he chooses to testify, etc.,
etc, and eventually Judge Nash Holmes asks Coughlin, after the restroom break, if he intends to testify
on his own behalf..."Nor does the trial judge's speculation that Appellant might use his closing
argument to present unsworn testimony." Soto, 139 S.W.3d at 857.
000499
The transcript from the 2/27/12 certified audio recording of the traffic citation Trial
at the 1 hour and 6 minute 18 second mark of the running time (yes the certified audio transcript is
provided in a FTR format that necessitates installing TheRecord Player, but for the ease of the
receipients of this correspondnece, Coughlin convereted the audio therein exactly as it was into a more
workable format, .mp3 files, split into two files for 2/27/12 (before and after the one restroom break)
and one file for the continuation fo the trial on 3/12/12) of file one:
Judge Nash Holmes (Judge): Sir, Mr. Coughln, sit down, I am done with you.
Coughlin: Just to preserve for the record, Your Honor.
Judge: Sit down, sit down, your're done. For the record the defendant is looking in his pockets and
behind his back and turning around and clowning around and showing utter disprespect for this court
and if you say another word or do another little antic like that you are going out of this Court in
handcuffs. Do you have any other witnesses? Prosecutor?
Prosecutor Ormaas: No, Your Honor, the City rests.
Judge: Sir, do you wish to testify?
Coughlin: Can I call Officer Tarter as my own witness?
Judge: you can call anyone you wish to testify.
Coughlin: I am sorry, Your Honor, but I really need to use the restroom.
Judge: You have two minutes. Marshal (Harley), you will escort him to the restroom, don't take
anything with you, Sir...
Coughlin: Can I take my notes with me?
Judge:No, turn them upside down.
Coughlin: Can I take the one page?
Judge: No, turn them upside down.
Coughlin: Really?
Judge: Turn them upside down. Marshal you will go with him to the restroom.
Coughlin: Will I be able to go into the stall alone? Just checking.
Judge: You have two minutes. You have two minutes.
Coughlin: Okay.
000500
(that ends the first audio file attached for 2/27/12, which represents the entirety of the proceeding
prior to the ONLY restroom break during that Trial)
(Start of the second audio file of 2/27/12, which represents the entirety of the proceedings of that day
following the ONLY restroom break of the day).
Coughlin: (re-enters courtroom): Thank you, Your Honor.
Judge: Okay, we are back on the record in 11 TR 26800. Mr. Coughlin, are you recording these
proceedings?
Coughlin: No, Your Honor.
Judge: Do you have any sort of devices in your pocket?
Coughlin: I believe what is in my pocket is private, Your Honor.
Judge: I want to know if you have any sort of recording devices in your pocket!
Coughlin: I believe that is a Fourth Amendment issue, Your Honor.
Judge: I am asking you, are you are recording anything from these proceedings in your pocket without
Court permission?
Coughlin: I believe that is a Fourth Amendment issue.
Judge: Sir?
Coughlin: And, no, I'm not.
Judge: Okay, proceed, do you have any questions for this witness (RPD Sargent John Tarter) that are
different from the area that we gave gone over already.
Coughlin: Well, I would like to ask a follow up on the rolling stop citation..." (thereafter Judge Nash
Holmes does not ask any other questions of Coughlin in any way related to recording or recording
devices, nor did Judge Nash Holmes ask any questions of anyone related to recording or recording
devices besides. Judge Nash Holmes did ask, before the restroom break, of Coughlin, if Coughlin had
any evidence or proof to support his contention that he attempted to provide to either Reno City
Attorney Wong or Ormaas discovery or information related to the statement to Coughlin, incident to
the November 13th, 2011 custodial criminal trespass arrest of Coughlin at his former law office incident
to an impermissible summary eviction of a commercial tenant not based on the non-payment of rent
(ie, a No Cause Eviction Notice was posted and a Landlord's Affidavit alleged a No Cause basis for
proceeding).
000501
On the second audio file from 2/27/12, at the 5 minute mark, the follow occurs on the record:
"Coughlin: was I there? Do I remember the name of the other officer who was there with him who
went into Richard Hill's law office for twenty minutes with him and hung out?
Judge: If you mention the name Richard Hill again I am going to hold you in contempt because I have
told you repeatedly to stick to the relevant issues about the boulevard stop."
(At the 11:17 minute mark of the second audio from 2/27/12 the following occurs on the record):
Judge: Officer (RPD Sargent Tarter), you are excused. Sir, do you intend to testify?
Coughlin: Yes, Your Honor.
Judge: Then testify, you don't need to take the stand, you can testify right there, you don't have to ask
yourself questions, just give me a short narrative version of what happened, and don't refer to yourself
in the third person, he was sworn in at the beginning of the case, don't refer to yourself in the third
person, just tell me what happened.
Coughlin: Yes, your honor, I reported a bribe to Sargent Tarter, then he retaliated against me.
Judge: Sir! Sir! Keep it relevant!
Reno City Attorney Ormaas: Objection, move to strike!
Judge: Keep it relevant about whether or not the boulevard stop occurred and what happened:
Coughlin: Sargent Tarter perjured his testimony today
Judge: Sir, Sir, answer about the boulevard stop.
Coughlin: Yes, Your Honor, this incident occurred when I went over to Richard Hill's office.
Judge: Sir.
Coughlin: I can't get into that? Okay.
Judge: Sir, boulevard stop.
Coughlin: Sargent Tarter lied today when he...
Judge: All right, Sir!
Coughlin: about the boulevard stop, I am saying...I disagree
Judge: take him into custody, you are in contempt of court, you will spend the next five days in jail, this
court is finished, this matter is continued
000502
Coughlin: Your Honor I move for a stay, I have a trial..and I have clients who need me
Judge: that is your problem, Sir. For the record you are in contempt of court because you have been
insubordinate, you have disregarded all of my requests, directions, orders, cajoling, my efforts to get
you to follow the instructions of the court, to act like a lawyer, or even to act like a defendant
representing himself in this court, you have made faces, belittled, you have argued, you have played,
you have been ridiculous in this courtroom and brought up issues that are irrelevant and immaterial
and to disrupt this proceeding, and there are only five or six people here that you could disrupt, you
have done everything you can to divert from the matter at question and to keep us from resolving the
issue of whether or not you have committed the traffic violation of the boulevard stop, and you are in
utter contempt of this court and have done nothing to deal with the facts of this case...you are being an
obstinate jackass, I am having a hard time believing you are a lawyer, you obviously missed the class on
on evidence, courtroom decorum and on criminal law..."
Coughlin was taken into custody whereupon a search incident to arrest was performed in the holding
area/back room of the RMC by Marshal Joel Harley with Marshal Scott Coppa assisting, and Marshal
Coppa was one of two Marshals transporting Coughlin to the Washoe County Detention Facility where
he served the 5 days in jail Judge Nash Holmes ordered (and the RMC refused to return the $100 that
Coughlin's mother paid into the RMC when counter clerk "Tom" promised her the Court would issue an
Order resulting in Coughlin being released from jail one day early...however, aside from the WCDC
walking Coughlin down in handcuffs from his cell to the booking desk and back, there was no release
from custody and Coughlin's mother was not returned her $100 payment in exchange for an early
release by either the RMC or the WCDC.
While conducting the search incident to arrest, RMC Marshal Harley went through Coughlin's pockets
and took out a simple flip style cell phone, a smart phone, a micro sd card, and an electronic shaver.
Upon taking possession of the micro sd card Marshal Harley immediately began interrogating
Coughlin as to whether it would work with the smartphone, then directed another Marshal to "go tell
the Judge that Coughlin was recording!" without any other support for such an accusation. None of
this occurred in the restroom and Chief Marshal Roper has indicated to Coughlin that Marshal Harley, in
carrying out Judge Nash Holmes Order to escort Coughlin to the restroom, did not actually go in the
restroom, but rather waited outside its door.
I ask that Chief Marshal Roper, Marshal Harley, and Marshal Coppa correct the misrepresentations
made by Judge Nash Holmes (whether or not they were purposeful or where something was lost in
translation and the affidavit requirement of NRS 22.030 for "contempt not in the immediate presence
of the Court" was not followed by Judge Nash Holmes incident to her 2/28/12 Order, wherein Judge
Nash Holmes writes, on page 2 of her 2/28/12 Order Finding the Defendnat in Contempt of Court and
Imposing Sanctions: "The matter was called at apprxoimately 3:00p.m. and concluded withoua verdict
000503
about 4:30 p.m. after the court held the defendnat in criminal contempt of court for his behavior and
activites committed in the direct presence of this court during the trial. The court finds that
defendant's contemptuous conduct conside of his ....deceitful...behavior during trial, all of which
appeard to be done to vex an annoy the court, the witness, and the opposing party, and to disrupt the
trial process. The court finds that the following occurred, and constitute contempt...."9) defendant's
lying to the court in response to direct questions posed by the court with regard to his recording the
proceedings...(page 3)...The court finds that the defendnat's actions were intentional and done in utter
disregard and contempt for the court, an in the presence of the cour, for purposes of disrupting and
delaying the proceedins and dishonoring the rule of law and this court, and constitute the misdemeanor
of criminal contempt, a violation of NRS 22.010. Good cause appearing therefore, the following
sanctions are imposed: IT IS ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at
the Wahoe County Regional Detnetion Facility for the term of five (5) days, from the time he was taken
into custody on this court's order on February 27, 2012, and that sentence shall not be reduced for any
reason..." The time stamping on that 2/28/12 Order Finding the Defendant in Contempt of Court
and Imposing Sanctions indicate "3:47". Washoe County Sheriff's Office personnel Deputy Hodge,
Patricia Beckman, RMC
Somehow, in her 2/28/12 Order (and during the Trial) Judge Nash Holmes found it relevant that,
allegedly, the RPD "gave Coughlin a break" over his driver's license being expired (actually, Coughlin's
then valid, current, driver's license was being withheld by Richard G. Hill, Esq., as Coughlin reported to
Sargent Tarter...and it was likely an old DL that the RPD is referring to as "expired" when mentioning
the "break", which, again, was somehow relevant enough to find its way into the Order, but the
withholding of Coughlin's then current, valid DL by Hill was sustained as irrelevant during the Trial (and
in fact seems to have been one of a myriad of vague basis for issuing a summary criminal contempt
Order requiring then licensed attorney with client's depending upon him, Coughlin, immediately being
taken to the WCDC for 5 days in jail...).
Coughlin hereby requests the RMC, WCDA, and WCDC to indicate the extent to which his property was
booked into his personal property at the WCDC, only to have the WCDC and or WCDA release the
property to the City of Reno Marshals the following day, well after any timeframe to conduct a search
incident to arrest (NNDB Member Mary Kandaras was involved in this matter, and in fact, despite Judge
Nash Holmes ordering the property released on 3/30/12, it took until 4/7/12 and approval by Mary
Kandaras before the property was so released. wcso12-1805 c-47951.
With local attorney Pam Wilmore standing, watching, and or hearing/participating in the conversations,
on or about March 21st, 2012 WCSO's P. Beckman handed Coughlin a note that read "Per Judges
Orders, call Marshal Deighton" and provided a phone number for Coughlin to seek further explanation
as to the admission that the City of Reno Marshals had returned to the jail on 2/28/12 and retrieved
items of Coughlin's personal property, including his "flip" phone, his smart phone, and his micro sd
card. Deputy Hodge's admission that, contrary to the indications by WCSO Cummings and000504
Campbell
that the micro sd card was released to Coughlin's agent on 2/29/12, but rather, was not so release,
combined with his statement that the smartphone, micro sd card, etc. were released to the Marshals
because it would be easier for Coughlin to get his property back through them, reveal that a search not
incident to arrest occurred here by the RMC on 2/28/12 and or the City of Reno Marshals, or, to be fair,
at least some sort of "seizure" did (especially considering that upon the smartphone and micro sd card
finally being returned to Coughlin on or about 4/7/12 by WCSO Deputy Iver, Brandi Berriman, and
Patricia Beckman (and only after "Maddy" got approval from DDA Kandaras, and after Coughlin was
threatened with abuse of process by Deputy Beatson). The RMC's Marilyn Tognoni also made some
indications respecting the smartphone and micro sd card to Coughlin. Perhaps, the allusion
to wcso12-1805 c-47951 in Judge Nash Holmes 3/30/12 Order Releasing Coughlin's property indicates
whether a warrant or some other lawful Order allowed for the Marshals to retrieve those items a day
after they were booked into Coughlin's personal property at the jail...but Coughlin has not been
provided any such Warrant or Order and hereby requests that he be so provided a copy of it now, and
that, given important data was lost to Coughlin upon his discovery the micro sd card and smartphone
had been wiped, that any copies of the data then stored therein be provided to Coughlin (the Diaz case
in the Ninth Circuit seems to provided a great deal of latitude to law enforcement to search digital data
within the reach of one whom is subject to a custodial arrest, and perhaps even copy it...in which
case....is would be appreciate if a copy thereof could be provided to Coughlin, and some compensation
for the extent to which his 32 GB micro sd card was rendered useless upon its return, as was his HTC
G2 cell phone (which never quite worked the same from then on and was rendered totally inoperative
a short time thereafter...the 32 GB micro sd card having an approximate value of $85 and the HTC G2
smartphone a used value of around $175.00).
I know I write in the third person sometimes (its tough representing yourself, especially when time
requires lots of copying and pasting, etc., etc) and that it can appear awkward.
I would appreciate the parties receiving this correspondence who have any knowledge of the events
detailed herein (especially with respect to the false accusations related to recordings, disassembling,
and hiding component parts of devices in the RMC restroom as detailed on the record on 3/12/12 in 11
TR 26800 and again in Judge Nash Holmes testimony at the 11/14/12 Disciplinary Hearing for NG12
0434 (and NG12-0204, and NG12-0435) to set the record straight.
For a verbatim or close to it transcription of what Judge Nash Holmes testified to at the Disciplinary
Hearing on 11/14/12 (including those matters she purported to repeat details related to what variosu
RMC Marshals told her regarding Coughlin, on would likely need get the transcript or any recordings
from the CCR assigned to that Hearing, Carol Hummel, and given Coughlin's current indigency, any
requirement that Coughlin pay up front for the transcript would make review prohibitive, and Coughlin
hereby requests of the Panel a fee waiver or deferment of such costs in that regard):
000505
Linda Shaw, Owner, Sunshine Reporting Services - Reno
1895 Plumas St,
Reno, NV 89509,
(775) 323-3411
Sunshine Reporting Services
Eric Nelson
CCR Longoni
(775) 323-3411
fax (775) 323-2749
151 Country Estates Circle
Reno, Nevada 89511
Carol Hummel
(775) 827-9120/
fax (775) 827-9120
chummel@charter.net
In her 3/12/12 Order in 11 TR 26800, a transmogrification of sorts appears to occur, turning a "simple
traffic citation trial" into a Disciplinary Hearing, albeit one of a summary nature, with an absent
Respondent. That Order read, in relevant part:
"Based upon the total circumstances of this case, the in-court performance of the
defendant, as observed by this court, the written documents faxed to the court for filing by
000506
this defendant, the statements and behavior of this defendant and his overall conduct herein,
this court finds, by clear and convincing evidence, that Zachary Barker Coughlin, an attorney
licensed to practice law in the State of Nevada, has committed numerous acts of attorney
misconduct, including, but not limited to, violating the following Rules of Professional
Conduct:
8.4(c}-engaging in dishonesty, fraud, deceit or misrepresentation;
8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
3 .l-defending in a proceeding by asserting or controverting an issue without a basis in
fact and with matters that are known to be frivolous;
3.2-failure to make reasonable efforts to expedite litigation. and, in fact, taking
extreme measures to delay litigation;
3.4(c)-being unfair to opposing counsel by continually alluding to matters the lawyer
does not reasonably believe are relevant or supported by admissible evidence;
1.3-failing to act with reasonable diligence and promptness; and
1. I-lack of competence in his practice and appearances before this court.
In addition, Zachary Barker Coughlin, likely also violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011, by surreptitiously recording
the traffic citation trial of February 27,2012 without the advance permission of this court and
then lying to this court when questioned about it and denying that he had done so.
Whether or not there are medical reasons to explain Mr. Coughlin's actions is not for
this court to decide. He has become nothing less than a vexatious litigant to Reno Municipal
Court due to his unorthodox, disruptive, bizarre and irrational methods and practices that go
beyond the pale of anything that is civil, ethical. professional or competent. Good cause
appearing therefore, the court orders as follows:
000507
IT IS ORDERED that this matter is continued, and all proceedings relating thereto are
tolled, until further order of this court, while the matter of attorney Zachary Barker Coughlin
is referred to the State Bar of Nevada;
IT IS ORDERED that no further action shall be taken by the Reno City Attorney's
Office, or the clerks or staff of Reno Municipal Court, in the above-entitled case, pending
further order of this court;
IT IS ORDERED that Zachary Barker Coughlin is barred and forbidden from faxing,
emailing, delivering. having delivered, serving. presenting for filing. personally or otherwise,
any motion or document to Reno Municipal Court, in the above-entitled case, pending further
order of this court."
One, Coughlin is not emailing this correspondence in that "above titled case (11 TR 26800) but in
connection with matters outside that case. Three, it is really not at all clear how Judge Nash Holmes
could make all those rulings, and only after having done that, decide to suspend the proceedings for a
Competency Evaluation, given the import of NRS 178.405:
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
defendant; notice of suspension to be provided to other departments.
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial,
when upon conviction the defendant is brought up for judgment or when a defendant who has been placed on
probation or whose sentence has been suspended is brought before the court, if doubt arises as to the
competence of the defendant, the court shall suspend the proceedings, the trial or the pronouncing of the
judgment, as the case may be, until the question of competence is determined.
000508
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any
other departments of the court of the suspension in writing. Upon receiving such notice, the other departments
of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to
be competent.
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court.
1. The justice shall, within 10 days after the notice of appeal is filed, transmit to the clerk of the district court
the transcript of the case, all other papers relating to the case and a certified copy of the docket.
2. The justice shall give notice to the appellant or the appellants attorney that the transcript and all other
papers relating to the case have been filed with the clerk of the district court.
3. If the district judge so requests, before or after receiving the record, the justice of the peace shall transmit
to the district judge the sound recording of the case.
NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary from
court to court according to the number and kind of cases customarily heard and whether the court is
designated as a court of record pursuant to NRS 5.010.
000509
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether
the citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right
at it and given what she said in court. Also, the whispering with Marshal Harley, and the bits about
Coughlin reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's
responses thereto on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording
anything or whether he possessed a "recording device" until AFTER the one and only restroom break Judge
Nash Holmes mentions on the audio record. Judge Nash Holmes did ask Coughlin if he had any proof that City
Attorney's Wong and Ormaas failed, in some way, to received or follow up on some offer by Coughlin to
provide materials related to Coughlin's contentions respecting the statement madAnd that sua sponte
interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH
HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED
AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S
EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME
OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME
WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd,
considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630
and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors
and public defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12
status conference between young and dogan that neither YOung nor Dogan wish to testify about...but which
seems to have been held anyways after a written communication of its being reset was transmitted to Coughlin
by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group
meetings amongst Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the
record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for
Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately
11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was
duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab makes
his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That,
and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive
document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on
2/27/12...never mind Young tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin
competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in
RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010)
here in Northern nevada..
000510
Coughlin didn't received the 2/28/12 Contempt Order in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash Holmes
continues to refuse to follow NRS 189.010-050
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily
by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a
contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For
we held in the Oliver case that a person charged with contempt before a "one-man grand jury" could not be
summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his
immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin
violated in both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being known
how to comply with, not sufficient warning, violat Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe
she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate,
particulary where she not only purports to issue a "summary criminal contempt" conviction against an
attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic
citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That
Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something
on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge
Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts
of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to
Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge
Nash HOlmes, Judge William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite
find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR
26405 (the appeal was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal
of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
was denied based upon a civil preparation of transcript down payment rule, in that criminal appeal, where the
RMC has a thing in place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the
audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the
transcript's preparation would absolutely not start until a down payment was made. Plus, even where Coughlin
caved to the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
communications (there may be an issue of the email Longoni holding out to the public issuing a
"bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon
information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf too...
000511
In her March 14th, 2012 grievance against Coughlin to the SBN Judge Nash Holmes details some concerns she
has with Coughlin's work as a self representing attorney defending a traffic citation (now NG12-0434, and
perhaps, NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in
King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need
to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King
now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009
Order was not filed by the RMC Judges?
AS to the application of the "courthouse sanctuary" doctrine to RMC Marshal Harley serving the Order to Show
Cause upon Coughlin at approximately 1:25 pm in one of the conference rooms right outside the interior of
Courtroom B at the RMC:
http://caselaw.findlaw.com/ny-district-court/1372465.html
"THE LAW
(COURTHOUSE SANCTUARY)
Despite antagonistic dicta to the contrary; most modern era precedent dealing with the issue of
Courthouse Sanctuary from service of process have held that New York State residents receive no such
immunity protections. Baumgartner v. Baumgartner, 273 A.D. 411, 77 N.Y.S.2d 668 (1st Dept.1948);
Department of Housing Preservation, City of New York v. Koenigsberg, 133 Misc.2d 893, 509 N.Y.S.2d 270
(N.Y. Civ.Ct.1986); Ford Motor Credit Co. v. Bobo, N.Y.L.J., 1 Misc.3d 901(A), 2003 WL 22928513 (Dec. 17,
2003, J. Miller, Nassau Co. Dist. Ct.) These cases hold that the Courthouse Sanctuary is only available to
foreign state residents who come into New York's Courts to contest jurisdiction. This doctrine has been
slightly expanded to include New York residents who enter the jurisdiction of a New York Court of limited
territorial jurisdiction to contest jurisdiction. See Palazzo v. Conforti, 50 N.Y.S.2d 706 (N.Y. Civ.Ct.1944);
Singer v. Reising, 154 Misc. 239, 276 N.Y.S. 714 (Queens County 1935).
The Baumgartner Appellate Division panel also acknowledges a limited Courthouse Sanctuary rule for
New York residents if such service would constitute a disturbance directly tending to interrupt the
proceedings of the Court or to impair the respect due its authority. This rule by itself would not be
applicable to the instant case as service of process was effected in the Courtroom but outside the Court's
presence and in between calendar calls.
STATE RESIDENCY IMMUNITY DISTINCTION?
The English Common Law made no New York State residency distinction. The doctrine of immunity from
arrest of a litigant attending a trial of an action to which he is a party found early recognition and dates back to
the book of 13 Henry IV, J.B. Sampson v. Graves, 208 A.D. 522, 203 N.Y.S. 729 (1st Dept.1924). This is for
the obvious reason that England had no sovereign states. The privilege is not a creature of statute, but was
created and deemed necessary for the due administration of justice. See Matthews v. Tufts, 87 N.Y. 568
(1882); citing to Van Lien v. Johnson (N.Y. Ct. Appeals, unreported 1871).
The logical question now arises, exactly when did New York's Appellate Court's recognize a residency distinction
for application of the Courthouse Sanctuary? The answer is that the Court of Appeals never
established such a rule. In contra point of fact, the Court of Appeals has opined that:
It is the policy of the law to protect suitors and witnesses from arrests upon civil process while coming to
000512
and attending the court and while returning home. Upon principle as well as upon authority their
immunity from the service of process for the commencement of civil actions against them is absolute eundo,
morando et redeundo. Person v. Grier, 66 N.Y. 124 (1876). Emphasis Added.
In this unanimous opinion, the Court of Appeals expressly addressed the New York State resident immunity
distinction and established in its dicta that whether any distinction should or does in fact exist, is at least
doubtful. This immunity is one of the necessities of the Administration of Justice, and Court's would often
be embarrassed if suitors or witnesses, while attending Court, could be molested with process. It is noted
that Person involved a foreign state resident. In establishing the sanctuary doctrine, the Court stated that
this rule is especially applicable in all its foreign suitors . By direct implication, the Court of
Appeals is also applying the protective rule to New York residents.
The basis of the Courthouse Sanctuary rule is that parties should be allowed to contest jurisdiction
without submitting to it. Allowing Re-service makes a mockery of the traverse hearing and
essentially allows the plaintiff to use a defective default judgment as a weapon to compel the defendant to
submit to the service of process. Ford Motor Credit Co. v. Bobo; cite supra. The location of an
individual's residence does little to legitimize such a mockery. Absent the compulsion of clear controlling
precedent; this Court will not condone such a situation..."
NRS 266.595 Appeals. Appeals to the district court may be taken from any final judgment of the municipal
court in accordance with the provisions of NRS 5.073.
NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary from
court to court according to the number and kind of cases customarily heard and whether the court is
designated as a court of record pursuant to NRS 5.010.
000513
NRS 5.010 General requirements for court; designation as court of record. There must be in each
city a municipal court presided over by a municipal judge. The municipal court:
1.Must be held at such place in the city within which it is established as the governing body of that city
may by ordinance direct.
2.May by ordinance be designated as a court of record.
The personal service by Marshal Harley of the Order to Show Cause in the appeal of the summary eviction
matter from Coughlin's former home law office at 121 River Rock St, with Richard G. Hill, Esq. as opposing
counsel in CV11-03628, occurred while Coughlin was speaking to RCA Ormaas in attempts to resolve the matter
(11 TR 26800 a traffic citation matter wherein RPD Sargent Tarter and other officers responded to Richard G.
Hill, Esq.'s office on 11/15/12 (its possible both Hill and Coughlin called the police and or 911...can't remember)
when Coughlin appeared there after being released from 3 days in jail incident to the 11/13/12 criminal
trespass arrest (now a conviction and discussed in that attached materials, some of which appear on the
Nevada Supreme Court's site under case 61901, the conviction stemming from 11 CR 26405 before RMC
Administrative Judge W. Gardner, the brother of District Court Judge Linda Gardner whose April 2009 Order
sanctioning Coughlin was cited by Washoe Legal Services at the cause for his firing, and led to 60302, now on
appeal...
I would really just like to move on from all of this, but this is a time of exigent circumstances, and if the RMC
and the City of Reno Marshals do not take affirmative steps to disavow the unsworn hearsay Judge Nash
Holmes attributed in her supposedly sworn testimony at Coughlin's 11/14/12 Disciplinary Hearing, it may be
that a negligent hiring, training, or supervision cause of action may acrue against various Marshals, even
personally (and its not so clear Mr. Christensen and the City of Reno would extend any purported
representation to such personal liability, for, say, slander or libel).
NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in judicial duties
at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or in its immediate vicinity,
tending to interrupt the due course of the trial or other judicial proceeding.
3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
4. Disobedience of a subpoena duly served, or refusing to be sworn or answer as a witness.
5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge at
chambers.
6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the presence of a
juror concerning an action in which the juror has been impaneled to determine, or in any manner approaching or interfering with such juror
with the intent to influence the verdict.
000514
7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or process of the
court.
[1911 CPA 452; RL 5394; NCL 8941](NRS A 1983, 843)
NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court; affidavit or
statement to be filed when contempt committed outside immediate view and presence of court; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may be
punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection, the court or judge shall
enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
(b) Finds the person guilty of the contempt; and
(c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit must be
presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters or arbitrators.
3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence of the
court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the contempt over the objection of
the person. The provisions of this subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was entered in such
court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings for the violation of the judgment or
decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been established in the judicial
district.
NRS 22.100 Penalty for contempt.

1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall determine whether the person
proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be imposed on the person
not exceeding $500 or the person may be imprisoned not exceeding 25 days, or both.
3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt pursuant to subsection 3
of NRS 22.010, the court may require the person to pay to the party seeking to enforce the writ, order, rule or process the reasonable
expenses, including, without limitation, attorneys fees, incurred by the party as a result of the contempt.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one of the following kinds shall be
guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its immediate view and presence,
and directly tending to interrupt its proceedings or to impair the respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or hearing pursuant to an order of
court, or in the presence of a jury while actually sitting in the trial of a cause or upon an inquest or other proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or referee;
4. Willful disobedience to the lawful process or mandate of a court;
5. Resistance, willfully offered, to its lawful process or mandate;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer any legal and proper
interrogatory;
7. Publication of a false or grossly inaccurate report of its proceedings; or
000515
8. Assuming to be an attorney or officer of a court or acting as such without authority.
ARTICLE IV - Judicial Department

Sec.4.010Municipal Court. The Municipal Court must include one department and may include
additional departments in the discretion of the City Council. If the City Council determines to create additional
departments, it shall do so by resolution and may appoint additional municipal judges to serve until the next
election.
(Ch. 662, Stats. 1971 p. 1976; ACh. 553, Stats. 1973 p. 881; Ch. 373, Stats. 1979 p. 645; Ch. 208, Stats. 1985
p. 675; Ch. 9, Stats. 1993 p. 21)
Sec.4.020Municipal Court: Qualifications of Municipal Judge; salary.
1.A Municipal Judge must be:
(a)An attorney licensed to practice law in the State of Nevada.
(b)A qualified elector within the City.
2.A Municipal Judge shall not engage in the private practice of law.
3.The salary of a Municipal Judge must be:
(a)Fixed by resolution of the City Council.
(b)Uniform for all judges in the Municipal Court.
(Ch. 662, Stats. 1971 p. 1976; ACh. 343, Stats. 1973 p. 422; Ch. 553, Stats. 1973 p. 881; Ch. 98, Stats. 1977
p. 211; Ch. 561, Stats. 1977 p. 1395; Ch. 208, Stats. 1985 p. 675; Ch. 599, Stats. 1993 p. 2501; Ch. 327, Stats.
1999 p. 1369)
Sec.4.030Disposition of fines. All fines and forfeitures for the violation of ordinances shall be
paid to the City Clerk in the manner to be prescribed by ordinance.
(Ch. 662, Stats. 1971 p. 1977)
Sec.4.040Procedure, additional judges. The practice and proceedings in the Court must conform
as nearly as practicable to that of justices courts in similar cases. Upon the written request of the City
Manager an additional temporary Municipal Judge may be provided for so long as the City Council authorizes
additional compensation for such a Judge. Whenever a person is sentenced to pay a fine, the Court may
adjudge and enter upon the docket a supplemental order that the offender may, if he or she desires, work on
the streets or public works of the City at the rate of $25 for each day. The money so earned must be applied
against the fine until it is satisfied.
CONTEMPT
000516
Acts or omissions constituting, generally, 22.010

Affidavit of facts constituting, 22.030
Affidavits presented in bad faith, NRCP 56(g), JCRCP 56(g)
Appearance, failure of defendant to make, 22.130

Arrest
Bond, 22.070
Excuses for not bringing arrested person before court, 22.140
Illness of defendant, effect, 22.140
Attorneys at law
Bar examination, early release of results, SCR 68
Discharged, failure to deliver certain materials to client, 7.055
Bail
Violation of conditions deemed contempt, 178.484
Commercial premises, violations of writ of restitution, 118C.210
Commission in presence of court or judge, 22.030
Compelling performance, imprisonment, 22.110
Court order, violation, 1.250, 22.010
Court reporters, 656.240
Criminal, 193.110, 193.300, 199.340
Custodial parent, failure to comply with visitation orders, 125C.030, 125C.040
Discharge from arrest, 22.070
Disqualification of judge or justice, making of charge not punished as contempt, 1.225, 1.230
Documents, refusal to permit inspection, NRCP 37(b)(2), JCRCP 37(b)(2)
Failure to perform specific acts directed by judgment, 22.010, NRCP 70, JCRCP 70
Imprisonment, 22.100, 22.110
000517
Indictment for contemptuous conduct, 22.120
Justice courts, civil proceedings, 74.040
Material witness granted immunity, failure to testify, 178.576
Misconduct by defendant during criminal trial, 175.387
Municipal court may punish for, 266.570
Punishment, 22.030, 22.100, 22.120
Reentry on real property after ejectment, 22.020
Refusal to answer or be sworn, 22.010, 50.195, NRCP 37(b)(1), JCRCP 37(b)(1)
Sheriffs duties, 22.060, 50.205
Subpoenas, failure to obey
Deemed contempt, 22.010, 174.385
Witnesses, forfeitures and damages, 50.195
Summary punishment, 22.030
Trials for contempt
By court or jury, 22.100
Disqualification of judge, 22.030
Investigating charge, 22.090
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and WalMart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
all the information necessary to issue a citation" explanations (including Crawfords
lying under oath that Coughlin didn't provide his driver's license to him on September
9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests000518tribal
by
officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
chance to explain how she prosecutes cases based upon arrests by tribal officers for
misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12
Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of

Indian Affairs or a person employed as a police officer by an Indian tribe may make an
arrest in obedience to a warrant delivered to him or her, or may, without a warrant,
arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not
in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or
agent has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross
misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or
described person for a public offense, and the officer or agent has reasonable cause to
believe that the person arrested is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested
has committed a battery upon that persons spouse and the peace officer finds
evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense
000519
committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or
agent is in fresh pursuit of a person who is reasonably believed by the officer or agent
to have committed a felony within the boundaries of the reservation or colony or has
committed, or attempted to commit, any criminal offense within those boundaries in
the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to
it in NRS 171.156.
Please see the photograph in the attached materials of the RSIC Officer taking
Coughlin's driver's license from him, thereby vitiating his assertion that an arrest was
an available option due to Couglin not providing his driver's license to the Officers.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 1 of 2.pdf
11TR26800 031412 RMC continuation of trial Nash Ormaas Hill traffic citation 031412_201203121033_01cd003b8f0851d0.mp3
11TR26800 RMC 022712 part 2 of 2 from 2 27 12 031412_20120227-1621_01ccf56bce224540.mp3

11TR26800 RMC 022712 part 1 of 2 from 2 27 12 031412_20120227-1507_01ccf5618f76c460 (2).mp3
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
NG12-0204.pdf
CR12-1262 appeal.pdf
11 2 12 file stamped complete notice of errata and revised supplemental 26405 1708 0204.pdf
11 15 11 rpd tarter redacted 0204 0434 26800 police report ormaas retaliation.pdf
000520
Download all
Elcano's testimony at Disciplinary Hearing FW: Opposition

Sent: Fri 11/23/12 7:22 AM
To: skent@skentlaw.com (skent@skentlaw.com); je@eloreno.com (je@eloreno.com); patrickk@nvbar.org
(patrickk@nvbar.org); eifert.nta@att.net (eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com);
jgarin@lipsonneilson.com (jgarin@lipsonneilson.com); pelcano@washoelegalservices.org
(pelcano@washoelegalservices.org); linda.gardner@washoecounty.us (linda.gardner@washoecounty.us)
10 attachments
emergency motion filed october 17 2011 merliss.pdf (127.4 KB) , 10 27 12 Order Denying Legal
Defender RMC Judge Howard 11 cr 22176 60838 despite Aigersinger mandatory authority.pdf (558.7
KB) , 10 26 12 Coughlin's Motion for Continuance in 22176 60838 denied though RMC grants one to
RCA for Hill to go on vacation.pdf (1145.7 KB) , 03018 to 03041 Judge Linda Gardner listed by SBN
King as greivant in ng12-0435 fyi prosecutorial misconduct blog smaller size b.pdf (2.5 MB) , 10 27
12 Order Denying Legal Defender RMC Judge Howard 11 cr 22176 60838 despite Aigersinger
mandatory authority.pdf (558.7 KB) , 10 17 12 Coughlin's Emergenc Motion commercial tenant no
cause forbidden 0204 1708 60331 61383 0204-3.pdf (620.6 KB) , 10 17 11 email and attached
Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order to Baker 1708 0204.pdf (146.3
KB) , wls gardner emails siragusa and non profit property tax email collection 0204 60302.pdf (4.4
MB) , 8 16 11 Judge Linda Gardner Order of Recusal from Coughlin case FV11-02864-2379391 so
why didn't her brother in 26405 1708 60331.pdf (51.9 KB) , fv08-03380 shortened TPO Santiago v
Vaxevanis Master Linda Gardner Coughlin WLS 26405 54844 60302 sjpr.pdf (542.4 KB)
Dear Panel,
Despite Mr. Hill's repeated assertions that I never raised the issue of being a commercial tenant (law office and or
mattress business) in the "Trial" court (or "lower court") in Hill's sworn testimony at the 6/18/12 criminal trespass
Trial at which I was convicted of trespassing in 11 CR 26405 (due to Richard's false police report, which is a
crime itself), and again at the Disciplinary Hearing on 11/14/12 wherein Hill again made the allegations that I did
not raise the issue of it being impermissible to utilize the summary eviction proceedings incident to NRS 40.253
against a commercial tenant unless pursued under a non-payment of rent basis. At the time of Hill's
serving/posting the 30 Day No Cause Notice of Unlawful Detainer, I was clearly practicing law out of my former
home law office at 121 River Rock St., Reno, NV (consider the double helpful Recusal Order by Judge Linda
Gardner (and Bar Counsel's bate stamped "Formal Hearing File SBN v. Zachary B. Coughlin", at 03018 contains a
page purporting to identify Judge Linda Gardner as the grievant in NG12-0434, though the SBN King's has
previously been rather, typically, coy about just whom provided him that April 2009 Order and under what
circumstances it became a "grievance", and how it was run through the Screening Panel. What is more
curious is that, according to King's bate stamping, the only thing in that file that indicates G: Judge Gardner A:
Zachary Coughlin, Esq. is a printout of a blog page that concerns "prosecutorial misconduct"...and "someone"
stampe "FYI" on it...and there is a bate stamping separate from King and the SBN's (which is at the bottom of the
page) given the "Page 1 of 1094" atop the page on 03019 (according to King's bate stamping). Sure seems like
lifelong prosecutor's like Linda Gardner and her brother William Gardner, now both Judges, and the SBN's King
are awfully keen to snuff out anyone who even thinks a prosecutor might be held to the same rules of professional
conduct as nearly all other lawyers (King isn't much for taking public defender's to task either....ironically, Judge
Linda Gardner takes a particularly punitive tact with legal aid domestic violence attorneys like....well, like myself,
whom she got fired by Washoe Legal Services Paul Elcano in May 2009 incident to her April 13th, 2009 Order
000521
sanctioning Coughlin, which WLS's Elcano testified to. What Elcano did not mention, and which is proven
and detailed in the attachments herein, is that when he moved WLS to a bigger more expensive building, right
before the economy crashed for a period of time that is still ongoing, he entered a lease with a private landlord
which attempted to shift the burden of paying property taxes onto the non-profit legal aid organization, Washoe
Legal Services. With all that legal talent at his disposal, Elcano asked Coughlin to research and write the
Memorandum of Law addressing the issue of whether WLS would be able to avoid such tax liability. The
attachments show that Coughlin was pressed to prepare as completely for the April 12th, and April 17th, 2009
Trial dates in the Joshi divorce case that became a Petition for Mandamaus and a wrongful termination suit in
54844 and 60302...but the attached materials also clearly disprove Judge Gardner's contention that Coughlin had
done no research and or lacked any basis to support the positions he took at trial in that matter. Further,
Coughlin's paralegal, Deb Pringle (who normally did good work) is indicated therein, as she was unable to retrieve
the ALR article that Coughlin mentioned to Judge Gardner at the Trial (contrary to Judge L. Gardner's written
Order's contentions), and Coughlin, upon retrieving it himself inbetween addressing the non-profit property tax
burden scenario for Elcano and WLS, sent Pringle an email demonstrating to her what it was he was asking her to
collect. And ED Elcano was at least somewhat accurate in his testimony at the 11/14/12 Disciplinary Hearing
when he indicated the he "stood by his employee" following a late January 2012 incident with Rhonda Harrison
or whatever it was...though that and the CAAW/TWS matters added up, and whether they contributed to what
transpired at the April 12th and 17th Joshi Trial or not (very possibly, though I got a bit too involved in the non
profit property tax issue because I had and have gratitude towards Paul Elcano for hiring me in September 2007
when no one else would and wanted to do a good job on it...and didn't give myself enough time to pull together
the research that I did, in fact do, for the Joshi Trial...but it is relevant to note that I followed ED Elcano's
directions to bounce ideas off of Todd Torvinen, and I did call Mr. Torvinen and also ran into him in the
courthouse prior to the Trial, and distinctly recall his approving, at least in theory, of the position I took at Trial.
I would bet it would have been better received with more specific citations to authority and a more polished
presentation of exhibits to Judge L. Gardner...but I was a very inexperienced attorney at that point and, frankly,
take issue with the extent to which all these prosecutors get all this "in court" experience...then become judges,
then want to fire anyone whom they are "hard pressed to explain to how to put on your case" which is a direct
quote from Judge Linda Gardner to me during that Trial...and I did mention the ALR articles that I researched to
her on the record...and I object to the extent to which Judge Gardner's Order on m Motion for Reconsideration
seeks to characterize the position I set out as somehow "devious". Mr. Joshi, to borrow from the domestic
violene literature, wanted the "power and control" (a la the Duluth Model) associated with having the credit cards
in his own name, and apparently largely used for his sisters to come over for trips and other expenses fairly
attenuated from those expended for the community. But, that is the funny thing...I was working hard on a a
Memorandum of Law to help ED Elcano and WLS's in an attempt to retain the freedom from property taxes often
enjoyed by non-profits...perhaps if Judge Linda Gardner was aware of that or the fact that I did do a fair amount of
preparation and research prior to that Joshi Trial, should would have a different view of the work I did
therein. But, I would do it again, because Paul's time was better spent out with the movers and shakers he had
developed relationships with in the community throughout a career spanning over thirty years, and that moves
along with interests of WLS a more significant way than I imagine only a very few others could approach.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000522
To: cdbaker@richardhillaw.com
Subject: RE: Opposition
Date: Mon, 17 Oct 2011 10:42:25 -0700
Just go ahead and review the laws directed to when and how often the property tax
information must be provided to renters.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
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Formal request for names of those on my Screening Panel`

Sent: Thu 11/22/12 12:39 PM
To: tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org);
patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net
(eifert.nta@att.net); skent@skentlaw.com (skent@skentlaw.com); davidc@nvbar.org
(davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com)
I am writing to formally request the names of those who were on the Screening Panel
incident to the current SCR 105 SBN v. Coughlin Complaint in ng12-0204, etc.
000523
Rule 105. Procedure on receipt of complaint.

1. Investigation.
(a)
Investigation and screening panel review. Investigations shall be initiated and conducted by bar counsel or
bar counsel's staff or other investigative personnel at bar counsel's direction prior or pursuant to the
opening of a grievance file. At the conclusion of an investigation of a grievance file, bar counselshall
recommend in writing dismissal with or without prejudice, referral to diversion or mentoring pursuant to
Rule 105.5, a letter of caution, a private reprimand, or the filing of a written complaint for formal hearing.
The recommendation shall be promptly reviewed by a screening panel. A screening panel shall consist of
three members of the disciplinary board, appointed by the chair in accordance with Rule 103(6). Two of the
three reviewers must be members of the bar. By majority vote they shall approve, reject, or modify the
recommendation, or continue the matter for review by another screening panel
Given the Board's inclusion of numerous individuals with patent conflicts (DDA Kandaras (intimately
involved in the opposition's causes in a number of matters, including the apparent search and seizure of my
smart phone and micro sd card incident to summary "misdemeanor of criminal contempt" Order (that
cited to a non summary civil contempt statue in NRS 22.010, yet attempted to utilized the summary nature
of NRS 22.030 (only without complying with the Affidavit requirement for conduct not in the "immediate
presence" of Judge Nash Holmes, all while purporting to be a criminal misdemeanor charge a la NRS
199.340 (very creative, and very, very duplicitous to boot coming from a Judge...and add to that an attempt
to further Bar Counsels SCR 111(5) aims by including the "find by clear and convincing evidence" burden
of proof standard necessary to prove an ethical violations of the RPD in a disciplinary hearing setting....
Then there is Richard Hill's best friend, David Hamilton being on the Board (and SBN King has curiously
redacted nearly any mention of Hill in his 8/23/12 Complaint (for which there remains no return of service
filed in the Disciplinary File (and any attempt by the SBN to assert that the certified mailing of 8/23/12 is
sufficient is fraudulent, see Coughlin's recent sworn Affidavit or Declaration under penalty of perjury as to
the SBN, Panel, and NNDB's representations in that regard, especially in light of SCR 105(4). Further is
is fraudulent and displays a lack of candor to assert that SCR 106 provides insulation from subpoena where
it speaks merely to causes of action, and any immunity therein surely has its limits, otherwise Pat King
would probably go biting Respondent's in their jugular's like the vampire he is.
Also, please formally provide me a copy of any rules of procedure or other applicable policies, practices,
rules, procedures, or dictates adopted by the Panel and or the NNDB or SBN that attach to these
disciplinary proceedings, such as the one of 11/14/12 (and the 45 days from the Panel's designation will run
real soon, so to get a non-void for lack of jurisdiction Disciplinary Hearing set and noticed, the SBN, Panel,
and NNDB is hereby advised to take note of that fact and proceed accordingly. Further, Coughlin objects
to the SBN, Panel, and Board's depriving him of his Sixth Amendment right to confront his accuser in this
quasi-criminal setting, particularly where the SBN still refuses to divulge the complainant in the NG12-0435
grievance, or which Clerk of Court or whoever it was that forwarded that April 2009 Order to the SBN.
And to the extent the Complaint has been curiously disinfected to redact mention of Richard G. Hill, Esq.,
000524
allegations in Hill's 1/14/12 unsigned grievance letter to the SBN (while they waited to hear back on their
Milsner v Carstarphen case from the Nevada Supreme Court) attached to the SBN's 2/14/12 letter to
Coughlin (which King fraudulently attempted to assert at the 11/14/12 Hearing that Coughlin somehow
failed to respond to, or to respond timely, particularly where the bate stamped Disciplinary File as late
provided by King on 11/8/12 (in violation of SCR 105(2)(c)) is a textbook case of fraudulent ommission and
obfuscation....see the "Folders" for each grievance (the folder listing Linda Gardner as the grievance filer is
particularly interesting considering is consists only of a online blog entry about prosecutorial misconduct,
and given that Linda Gardner and her brother, the one who refused to recuse himself from the criminal
trespass matter where Richard G. Hill signed the Complaint and the RPD has admitted to fraud incident
thereto on tape, 11 CR 26405, are both lifelong prosecutors.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Judge Howard and Cassandra Jackson want to explain

Sent: Thu 11/22/12 12:56 AM
To: je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
(eifert.nta@att.net); mike@tahoelawyer.com (mike@tahoelawyer.com); patrickk@nvbar.org
(patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); skauc@reno.gov (skauc@reno.gov);
robertsp@reno.gov (robertsp@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov);
wongd@reno.gov (wongd@reno.gov)
6 attachments
DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) , 12 16 11 email to
plongoni@charter.net longoni and 12 21 11 email to ballardd@reno.gov regarding longoni 22176
26800 0204 0435.pdf (22.7 KB) , 10 9 12 Affidavit of Laura Peters 0204 never sent to Coughlin no
proof of service, yet file stamped.pdf (1516.8 KB) , 12 15 11 22176 2064 Order by Howard on
transcript costs.pdf (92.8 KB) , 12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
(110.8 KB) , 11 16 12 skau grievance materials combined 0204 063341.pdf (1943.8 KB)
How RMC handouts and agreements with Pam Longoni are not violating NRS 189.030
and NRS 4.14(a)
RCA Skau wants to explain his lies about the judge authorize service by email for an
unnoticed hearing where Skau sought to argue email service was insufficient when it
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came to his people...Then RCA Hazlett-Stevens want to explain his mysterious claims
to have not received the Notice of Appeal in cr12-1262 or why he puts on perjured
testimony by Richard G. Hill, Esq., RCA Pam Roberts would like to explain the same
for 11 cr 22176. RCA Allison Ormaas wants to explain what she was whispering in
RMC Marshal Harley's ears on 2/27/12 and whether it was about the same failure to
chart follow up on, or report RPD Chris Carter's admission that "Richard Hill pays me a
lot of money, so I arrest who he says to and do what he says to do...", just like Reno
City Attorney Chief Criminal Deputy Dan Wong explained he was surely not going to
do to when Coughlin made the same report to him on 1/19/12....
SBN Clerk of Court Laura Peters wants to explain how she approved fax filing for
Coughlin on 9/11/12, and how her Affidavit of 10/9/12 wound up in the Disciplinary
file only made available to Coughlin 5 days before the hearing (with thousands of pages
of filler and duplicates to hide the little it contained...which in the case of Linda
Gardner's grievance, was a mysterious printout from a blog and no more...no cover
letter, no nothing...and Kings email where he purports that the "Clerk of Court" sent
him the Order still has not been clarified, though Joey Orduna Hastings, Clerk of Court
of the Second Judicial District Court wants to indicate whether she sent it to the SBN,
or, more likely, the Clerk of Court of one of the Muni Court Departments (probably
Judge Nash Holmes' in D3, considering her 3/23/12 email to the SBN about Coughlin's
clothing choices to check on a traffic citation at a munic court filing office window...)
who got ahold of District Court Judge Linda Gardners April 2009 Order when Judge
L. Gardner passed it to her brother, RMC William Gardner, who refused to recuse
himself from Coughlin's criminal trespass case based upon Richard Hill's Complaint,
but did manage to pass his sister's Order around to his fellow Judges and hold meetings
with them about how to get back at Coughlin for pointing out things they do that violate
due process rights and other laws. Like those requiring a stay of proceedings when a
defendants competency is brought into question. DDA Young is great at violating
those laws, and bossing Judge Sferrazza around in court, demanding he take into
custody anyone who doesn't do just exactly what DDA Young wants and or give just
exactly the answer he is looking for....
Pat King, Laura Peters and David Clark want to explain how their statements and
corresponence with Coughlin respecting his right to issue subpoenas and waiver of
witness fees of fees for subpoena duces tecums departed remarkably from the sudden
about face on that issue when the Motions to Quash started coming in, though the
Disciplinary Hearing of 11/14/12 went on just they same, right....
000526
Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper,
and Marshal Joel Harley,
Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment
violation if the person was guilty of the crime you suspected him of committing when
you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy
Sleazy, WCPD Jim Leslie by muscling over indigent criminal defendants for him when
Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to
Jimmy's rescue and tells Coughlin, Leslie at his side, that "I'm going to put my foot up
your ass..." Reyes watches defendants get put in jail for months day in day out for doing
less than that....
Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for
information on the transmission of the Eviction Order in rjc 2011-001708 to the
Washoe County Sheriff's Office.
Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits
of service he files, and Maureen and Roxy's assertions that the "receipt" of the eviction
Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must
effect the lockout "within 24 hours of receipt of the Order"...and Casey Baker, Esq.
wants to explain his testimony of 6/18/12 when he explained what he did with the
Sheriff's Office on October 28th, 2011...and Reno Carson Messenger service want to
explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple
minutes to 5 pm, and definitely not sooner than 4:48 pm, despite Machens 11/1/11
Affidavit of Service (that his supervisor Stuchell had to admit was false in that it alleged
"personal service" where the WCSO admits no one was home (and the locksmith totally
refutes Hill's testimony of 6/18/12 "they tried to serve it to you but you ran away..."
(really, Rich, becaue Casey didn't testify to that, but he did say that you weren't even
there that day, so what do you base that sworn allegations on Rich, besides your desire
to mitigate your liability for all your misdeeds there?).
Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash
Holmes got "confused" on in her "sworn testimony"...which is shaping up to look at lot
like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash
Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways. The
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attached audio from the Hearing and Judges Nash Holmes various Orders (which reveal
a disturbing attempt to mix and match various civil and criminal contempt statutes,
some plenary, some summary, and add the transmogrification of a "simple traffic
citation Trial" into some sort of Summary Disciplinary Hearing...which SBN Bar
Counsel Pat King is only too happy to sign on to, eager to kick back and rely on SCR
111(5) after having fed Judge Nash Holmes the instruction to make sure to copy and
paste as many sections of the Rules of Professional Conduct into an "Order" that is sure
to point out the burden of proof necessary for a "ethical violation" finding in a
Disciplinary Hearing setting. The only thing less transparent than this awkward attempt
by Bar Counsel and Judge Nash Holmes to get 'r done was the brother and sister act by
Judge William Gardner and his sister Judge Linda Gardner, complimented, of course,
by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge L.
Gardner's April 2009 Order sanctioning Coughlin, which Washoe Legal Services's Paul
Elcano cited as the sole reason for Coughlin's firing (and which begat the Mandamus
Petition against L. Gardner in 54844, the wrongful termination suit against WLS in
60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner refused
to recuse himself from, etc., etc.
WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS
178.405 and the communications with RMC Judge Nash Holmes regarding the 2/27/12
Order for Competency Evaluation that should have prevented her from even holding the
Trial (the one that occurred right after RMC Marshal Harley served a civil eviction
appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve
Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received
in connection with his being the attorney of record and an e-filer on that matter...see
Caplow).
RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about
their misconduct in 11 CR 26405 and the extent to which Richard Hill and his client,
Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405
and 61901.
Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v.
Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on that too..
RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who
was working that night of the 8/20/11 arrest that started a year in which Coughlin was
000528
arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one
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index to exhibits:
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1. exhibit 1: various relevant materials (also see the audio fo all the hearings Coughlin has previously provide on cd/dvd
and via electronic digitally verifiable transmission, especially the RMC cases and teh April 2009 Joshi Trail from which
3
ng12-0435 stems). 3,083 pages (3,083 pages, and pat king has been sending his exhbiit in illegible blurry form, printed on
both sides of the paper)
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2. Exhibit 2: another bate stamped collection of relevant documents

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3.exhibit 3: from the "big box" form Sierra Document certified mailing by SBN delivered to Coguhlin on first attempt on
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11/6/12 from "Fromal Hearing File SBN v. Zachary B Coughlin" collection in rubber band.
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000265
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IN THE RENO JUSTICE COURT OF THE STATE OF NEVADA
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PARK TERRACE
TOWNHOMES ASSOClA TION,
v.
Landlord,
ZACHARY COUGHLIN,
Tenant.
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CASE NO.:
REV2012-000374
DEPT. NO.: 3
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ORDER DENYING ZACHARY COUGHLIN'S NOTICE OF CLERK'S OFFICE AND
COURT'S FAILURE TO FILE COUGHLIN'S NOTICE OF APPEAL, REQUEST
THAT IT DO SO NOW"AND MOTION FOR RELIEF FROM JUDGMENT OF
3/15112 AND ORDER OF 5/15/12 IN LIGHT OF NEWLY DISCOVERED EVIDENCE
AND FRAUD AND NRCP 60(B)(4) AND WAIVING THE REQUIREMENT FOR
PARK TERRACE TOWNHOMES ASSOCIATION TO FILE AN OPPOSITION TO
ZACHARY COUGHLIN'S NOTICE
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On or about November 5, 2012, Pro Se Attorney Litigantffenant, Zach Coughlin
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("Coughlin") filed a Notice of Clerk's Office and Court's Failure to File Coughlin's Notice of
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Appeal, Request That itDo So Now, and Motion for Relief from Judgment 00/15112 and Order
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of 5115112 in Light of Newly Discovered Evidence and Fraud and NRCP 60(B)(4)
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("NoticelMotion").
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Townhomes' management company and attorney were served, the Court has discovered that, in
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fact, neither was served.
25.
Although Coughlin's Proof of Service indicates that Park Terrace
The Court has reviewed Coughlin's NoticeIMotion. The Court has further considered the
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papers and pleadings on file herein, together with any attached exhibits, and the applicable law.
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Based upon its review, the Court finds that there is no legal or factual basis for Coughlin's
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Notice/Motion.
000266
GOOD CAUSE APPEARING THEREFORE,

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IT IS HEREBY ORDERED that Coughlin's NoticelMotion is DENIED.
IT IS FURTHER ORDERED that Park Terrace Townhomes Association is released from
any requirement to respond to Coughlin's NoticelMotion.

DATED this
l+
day of November, 2012.
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Nov 19 2012 12:34 p.m.
Tracie K. Lindeman
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ZACH COUGHLIN;
Appellant.
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vs.
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) District Court No: CV11-03628
MATT MERLISS, MD; MATTHEW J.

MERLISS LIVING TRUST;
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Respondents
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NOTICE OF APPEARANCE AND 11 15 12 61383 Notice of Improper Dismissal of

Appeal, Motion for Reconsideration or to Reinstate Appeal, or Alter or Amend Judgement
of Court Clerk; Rule 103(7) challenges for cause and SCR 105(2)(a) Motion to remove
Panel Chair Echeverria and Panel Member Kent; Post-Hearing Brief, or, alternatively,
Motion for Leave to File Post-Hearing Brief; Motion to proceed in forma pauperis and for
immediate release of recordings of 11/14/12 HEARING AND WHATEVER
TRANSCRIPT MATERIALS CURRENTLY EXISTS TO BE RELEASED TO
COUGHLIN ABSENT AN PAYMENT UP FRONT WHATSOEVER; MOTION FOR
MISTRIAL; MOTION FOR RECONSIDERATION OF ORDER QUASHING
SUBPOENAS, AND ORDER DENYING MOTION TO BIFURCATE; request to
combine or consolidate appeals where legally tenable this appeal with 60331 and
amendment to case appeal statmeent and clarification of notice of appeal incident thereto
to indicate that D7's 3/30/12 Order in included amongst those appealed.
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http://sdrv.ms/Tt4dYf
- 1/71 -
Notice of Improper Dismissal of Appeal, Motion for Reconsideration or to Reinstate

Appeal, or Alter or Amend Judgement of Court Clerk
000278
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http://sdrv.ms/XmRkVL
coughlin apologizes for the formatting and length and is doing his best but this is a natural
byproduct of bar counsel bathing in scr 106 immunity and completely destroying any notions of fair play
incident to the 11/14/12 Disciplinary Hearing, justiyin SCR 119(3) contempt snactions against bar counsel
for all the attendant due proceed, notice, and service violations arising therin.
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included herein is an excusable neglect basis or good cause for reinstating the appeal beyond the fact that the
$250 filing fee was paid and the receipt and or docket show it was paid for this case...and an ifp is pending in
the associate 60331.
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Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's
conviction to true nature of facts, in order to determine whether underlying circumstances of
conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada
v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39
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2. Indictment
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Where the only relevant factual allegation contained in Disciplinary Board's affidavit, filed in support of its
petition for attorney's temporary suspension from the practice of law, was that a criminal indictment had
been filed against the attorney, this sole allegation, without more, was insufficient to justify summary
suspension and the immediate imposition of temporary restrictions. Sup.Ct.Rules, Rules 102, subd. 4(a),
111, subd. 1. Matter of Monteiro, 1984, 684 P.2d 506, 100 Nev. 440. Attorney And Client 48
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3. Serious crime
Attorney was not convicted of serious crime within meaning of rule regarding attorney suspension where
attorney did not engage in any criminal conduct whatsoever, did not engage in a conspiracy, and actually
entered plea of nolo contendere to nonexistent offense. Sup.Ct.Rules, Rule 111, subd. 2. Sloan v. State Bar
of Nevada, 1986, 726 P.2d 330, 102 Nev.
436. Attorney And Client 39
request to combine or consolidate appeals where legally tenable this appeal with 60331
and amendment to case appeal statmeent and clarification of notice of appeal incident
thereto to indicate that D7's 3/30/12 Order in included amongst those appealed.
couglin hereby reserves all defense under nrcp 12 g:(h) Waiver or Preservation of Certain Defenses.
(1) A defense of lack of jurisdiction over the person, insufficiency of process, or insufficiency of service of
process is waived (A) if omitted from a motion in the circumstances described in subdivision (g), or (B) if it
is neither made by motion under this rule nor included in a responsive pleading or an amendment thereof
permitted by Rule 15(a) to be made as a matter of course.
(2) A defense of failure to state a claim upon which relief can be granted, a defense of failure to join a party
indispensable under Rule 19, and an objection of failure to state a legal defense to a claim may be made in
any pleading permitted or ordered under Rule 7(a), or by motion for judgment on the pleadings, or at the trial
on the merits.
(3) Whenever it appears by suggestion of the parties or otherwise that the court lacks jurisdiction of the
subject matter, the court shall dismiss the action.
- 2/71 -

000279
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Time to add some more Richard G. Hill, Esq. chestnuts to the lie pile, especially
considering Hill's testimony under oath at Coughlin's 11/14/12 Disciplinary Hearing and
the follow sworn testimony by Hill from the 6/18/12 Trial, viewed in conjunction with the
statements Hill made to the RPD Officer Chris Carter and Sargent Marcia Lopez just prior
to and at the time of the 11/13/11 custodial arrest of Coughlin at his former home law
office for trespassing:
THE COURT: When Mr. Hill is here to ask some questions that I think
you've explored the possibilities, and I don't know what else you can offer
the Court in terms of this case via cross-examination.
MR. COUGHLIN: Yes, sir, Your Honor. I'll wrap this up quickly. BY
MR. COUGHLIN: Q Mr. Hill, at any time on that day, November 13th,
did the owner of the premises warn the arrestee to leave the property?
A
I think the message was communicated.
Q
Via what medium?
A
The fact that you were handcuffed and arrested. Didn't
you get the picture?
Q Okay, prior to the handcuffing and the arresting, did anybody say, "You
need to leave the premises?" A I didn't hear that. Q Nobody said that? A I
did not hear that, sir. Q Did you say it? A No. Q Did Dr. Merliss? A Not
that I heard. Q Did the police? A No, not that I heard. Q So, nobody that
you heard of warned the person
arrested for trespassing?
Page -1 1 0Copperfretti v. Shephard, 271 N.Y.S. 284 N.Y.App.Div.2.Dept.,1934
Tenant held entitled to set aside default judgment in summary proceedings
on showing that landlord acquired title under void judgment, irrespective
of tenant's excuse for default or defense upon merits.
I, Zach Coughlin, declare under penalty of perjury, pursuant to NRS
54.045 that the following numbered statements are true and correct to the
best of my knowledge:
1. The locksmith who did the lockout on 1/11/11 is named Sean
Cheathum of All American Lock & Safe P.O. Box 51869 Sparks, Nevada
89435-1869 (775) 626-5397. Mr. Cheathum indicated to mer personally
that he arrived to do the lockout that day at, 11/1/11 at 121 River Rock St.
Reno, NV 89501 just about the time the Sheriff's two Deputies and the
two landlord's agents did and that it was getting very close to 5 pm. 5 pm
represented an urgent deadline to the landlord's agents and the Sheriff's
- 3/71 -

000280
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Deputies, by which the lockout must be done, recalled Mr. Cheatum. Mr.
Cheathum indicated that the lockout occurred no earlier than 4:48 pm and
was fairly sure that it came down to the wire in terms of effecting the
lockout prior to 5 pm. Cheathum indicated that he postulated at the time
that the urgent 5 pm deadline was due to a wish by the landlord's agents
and the Sheriff to avoid running into the tenant should the tenant be
coming home from work after a typical 9 am to 5 pm schedule.
Cheathum's memories of that day are strong enough to specifically recal
the types of locks, the uniqueness of the location (mentioning how it was
near the Harrah's Auto Musuem, the Section 8 Housing to the South of
Court Street, and the Truckee River) and that the back door lock was very
easy to gain entrance through given that a key was broken off in it, which
enable him to open or pick the lock by merely turning a screw driver
pressed to it.
2. I spoke with Maureen and Roxy Silva of the Washoe County Sheriff's
Office on numerous occassions. On more than one occasions Ms. Silva
slammed the phone down on me in anger. However, on other occasions
she spoke at length about the way the WCSO carries out evictions,
particularly wit respect to the "within 24 hours of receipt of the Order"
language in NRS 40.253. Roxy Silva, Maureen, and Civil Division
Supervisor Liz Stuchell indicated that the WCSO received the "Eviction
Order" on 11/1/11 at 8:05 am, and that the data entered in there computer
system confirms this. Silva, "Maureen" and Stuchell also indicated that
the WCSO does not keep any records of when it receives Eviction Orders
beyond manually inputting the time that the Orders are taken from the fax
machine to which the Reno Justice Court sends such Orders (and RJC
Chief Civil Division Clerk Karen Stancil has indicated to Coughlin that it
is the usual custom and practice of the RJC to fax Eviction Orders over to
the WCSO the day the are entered or the next day. There is some
confusion over whether the 10/25/11 "Eviction Decision and Order"
signed by Judge Sferrazza on file stamped on that date is an "Order" and it
does appear that Ms. Stancil and Bonnie Cooper are correct in their
assertion that the typical RJC "form' eviction order is on a different "form"
or "template" than that 10/25/12 "Eviction Decision and Order". Whether
that means that 10/25/12 Order was not faxed to the Sheriff in accordance
with the "usual custom and practice" of the RJC does not seem clear, nor
has anyone with the RJC responded to requests for documentation or
information in that regard. Former IT employee Curtis Harvey may have
some information in that regard. Additionally, the RJC fax appears to
bare an incorrect time stamping fairly regularly. Further, Chief Civil
Clerk Stancil's apparently correct assertion that the WCSO does not file
anything along with their typical one page Affidavit of Service (which
bares a time stamping of sorts representing, apparently, when the lockout
was conducted...and WCSO's Deputy John Machen's Affidavit of Service
file stamped 11/7/11 indicates a time of 4:30 pm for "personally serving"
- 4/71 -

000281
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Coughlin. Locksmith Cheathum disputes Richard Hill's trial testimony in

11 CR 26405, where Hill indicates the WCSO attempted to "personally
serve" Coughlin the Eviction Order, but that Coughlin "ran away".
Cheathum indicates there was no indication any tenant was at the 121
River Rock location, nor was their any discussion by anyone there,
includign the two Sheriff's Deputies and two landlord's agents to that
effect. Hill admits to not having even been there for the lockout. Casey
Baker, Esq. testified on 6/18/12 that he and Sheri Hill were present and
waited with the Sheriff's deputies until "the locksmith finally arrived".
NOTE, Baker's Order of 10/27/12 is void in that it fails to included the
specific language called for in NRS 40.253(5), as the "within 24 hours"
language is not there, and Bakers testified as to this in 11 CR 26405, when
he also testified that he did somethign with the WCSO on October 28th,
2011 in connection with the lockout.
NOTE: COUGHLIN FILES T HIS WITH THE CAVEAT THAT, WHILE SOME SECTIONS
MAY BE A DECLARATION OR SAY SOMEYHIGN ABOUT PERJURY, COUGHLIN NEEDS MORE
TIME TO CLEAN THIS DOCUMENT UP, YET THE IMMINENT THREAT OF ATTACK AND OR
RETALIATION BY THE SBN, LOCAL PROSECUTORS, OR LAW ENFORCEMENT DICTATES
SUBMITTING THIS FILING NOW, DUE TO THE EXIGENCIES INVOLVED, WHICH EXISTS
SOLELY DUE TO THEIR MISCONDUCT AND IN NO WAY STEM FROM ANY FAILURE ON
COUGHLIN'S PART TO UNDERTAKE DUE DILIGENCE IN EVERY WAY.
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Docket entry for the trial court matter this case was appealed from, cv11-03628 (a Notice of Appeal was
filed, it appears on 7/30/12, though Coughlin may have filed one in jail, where Judge Linda Gardner's
brother (see Mandamus Petition by Coughlin against Linda Gardner in 54844 and the attached 8/17/11
recusal Order by Linda Gardner where she cites to the "I just outright hae a bias against you" judicial canon
in 2.11(a) in explianing her recusal...and that case proves, amongst other proof that the address Coughlin was
evicted from was indeed being used as and held out as the location for Coughlin's law practice (as was the
case on the www.nvbar.org contact information at the time for Coughlin, for over one year prior to the
unlawful summary eviction the subject of this appeal, along with the record setting attorney's fees by Judge
Patrick Flanagan, who refused to recuse himself despite he and Coughlin being former co-workers at Hale
Lane (now Holland & Hart) and there existing a multitude of basis incident thereto for a finding that recusal
was mandatory) shows the impropriety of the Clerk of Court dismissing the appeal for lack of paying a filing
- 5/71 -

000282
fee. Couglhin was provided a receipt showing that he had paid the filing fee for 61383, and Coughlin has an
IFP pending in 60331. The docket confirms this in the trial court matter from which both of these appeals
stem:
06-SEP-2012 04:55 PM $Notice/Appeal Supreme Court COUGHLIN, ZACHARY
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Entry: APPEAL FEE PAID FOR THE 7-30-12 NOTICE OF APPEAL - IMAGE ATTACHED TO JULY
FILING
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http://www.ccwashoe.com/public/ck_public_qry_doct.cp_dktrpt_frames?
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backto=P&case_id=CV11-03628&begin_date=&end_date=
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06-SEP2012
04:55 PM
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Entry:
$Notice/Appeal Supreme Court
COUGHLIN, ZACHARY
APPEAL FEE PAID FOR THE 7-30-12 NOTICE OF APPEAL - IMAGE ATTACHED
TO JULY FILING
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22
23
24
25
The Nevada Supreme Court Docket seems to miss the part where Coughlin paid the filing fee in
61383 and one has to wonder, given Richard G. Hill, Esq. testifying before the NNDB that he is a member
of at Coughlin's 11/14/12 Dsiciplinary Hearing (largely predicated upon arrests that Hill directed the RPD to
make) given the appeal in 61383 was dismissed (without a signature by an actual Justice....) just days prior
thereto. 07/31/2012Filing Fee - Filing Fee dueFiling Fee due for Appeal.07/31/2012Notice of Appeal
Documents - Notice of Appeal/Proper Person Pilot ProgramFiled Notice of Appeal/Proper Person Pilot
Program. Filed certified copy of proper person notice of appeal.12-24129
07/31/2012Notice/Outgoing - Notice to Pay Supreme Court Filing FeeIssued Notice to Pay Supreme Court
Filing Fee. No action will be taken on this matter until filing fee is paid. Due Date: 10 days.12-24133
11/07/2012Order/Dispositional - Order Dismissing AppealFiled Order Dismissing Appeal. To date,
appellant has not paid the filing fee or otherwise responded to this court's notice. Accordingly, cause
appearing, this appeal is dimissed.12-35194
26
27
Zach Coughlin, plaintiff, submits this filing (notice/ motion /objection) on his own behalf. Judge
28
Dorothy Nash Holmes just lied and lied under oath at Coughlin's 11/14/12 Disciplinary Hearing, especially
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000283
with regard to her assertion that she, in the traffic citation trial in 11 TR 26800 that she held on February
27th, 2012 from 3:30pm to 4:45 pm, despite she and or the RMC being aware that Coughlin had been
ordered to have a competency evaluation by RJC Judge Clifton's Order of 2/27/12, baring a file stampe of
1:31 pm...which is just about the time that Judge Nash Holme's judicial assistant announced on the record in
open court that nobody with the RMC could seem to find Judge Nash Holmes, and how weird that
was....which was just about the time DDA Young and Biray Dogan held their "clandestine status
conference" in rcr2012-065630 case where DDA Young persists in his retaliatory prosecution of Coughlin
for calling 911 to report police misconduct causing Coughlin to perceive an emergency being present and a
danger to his safety...) Anyways, NRS 178.405 and NRS 5.010 require Judge Nash Holmes to "stay all
10
proceedings" when such competency issues or Orders arise...not to do what she did, which is plunge
11
headlong into a retaliatory intent to find something to convict Coughlin for (Judge Nash Holmes
12
transmogrified a traffic citation matter, for a "Boulevard Stop", ie, a "California Roll" into a full blown
13
Disciplinary Hearing before the NNDB and State Bar of Nevada after she was coached up by Bar Counsel
14
Pat King to make sure to find "by clear and convincing evidence" that Coughlin had violated some Rule of
15
Professional Conduct or other (Nash Holmes decided to copy and past the whole lot of RPC's, and then
16
proceeded to muse aloud in her 3/12/12 continuation of the traffic ticket trial in 11 tr 26800 that Coughlin
17
had "probably" violated this or that rule...but when it came time to sign an Order, Judge Holmes remixed that
18
and decided that Coughlin had done so by "clear and convicing evidence".. This traffic citation trial stems
19
from Coughlin going to opposing counsel in the summary eviction from Coughlin's former home law office
20
(Richard G. Hill, Esq. and Casey Baker, Esq) after he was released from 3 days in jail incident to Richard G.
21
Hill's signing a criminal trespass complaint in 11 cr 26405 against Coughlin, after Hill and his neurologist
22
client, Dr. Matthew Joel Merliss were able to lie to and with the Reno Police Department's Officer Chris
23
Carter, Jr. and Sargent Marcia Lopez about whether anyone issued Coughlin a trespass warning, whether the
24
police identified themselves as law enforcement prior to the landlord kicking the door to the basement down
25
(the police apparently did not feel strongly enough in their cause or right to be undertaking the actions they
26
did to kick the door down themselves...though, RPD Officer Carter to Coughlin later that day that "Richard
27
Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do" may need some
28
more consternation....though don't hold your breath waiting for Bar Counsel Patrick O. King, Esq. to
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000284
undertake any, or Reno City Attorne's John Kadlic, Esq., Daniel Wong, Esq., or the prosecutor who
suborned all that perjury by Richard G. Hill, Esq. on the stand, Christopher Hazlett-Stevens, Esq.(Hazlett-
Steven's was provided indisputable video evidence showing that Hill's testiony was lies, at the 6/18/12
criminal trespass trial presided over by RMC Judge William Gardner, whom refused to recuse himself
despite Coughlin suing his sister, Judge Linda Gardner in 54844, and Judge Linda Gardner filing a grievance
against Coughlin in ng12-0435 (the SBN and NNDB held a disciplinary hearing on 11/14/12 despite the
panel not even being chosen until 10/30/12...don't worry though, Chair John Echeverria was able to step in
so quickly, that before Chair Susich's Order announcing Echeverria as Panel Chair could be staped to the
proof of service, much less mailed, Chair Echeverria had denied every Motion Coughlin filed and granted
10
everything Bar Counsel King could ask for...with the added plus that they (Bar Counsel Patrick O. King and
11
NNDB Chair J. Thomas Susich and, perhaps, some others) cooked up a Panel (despite the Complaint and
12
List set out fully in 61901...if the Office of the Clerk will file what Coughlin submitted for filing...which it
13
did not on May 24th, 2012 in 60838....
14
Why Bar Counsel Patrick O. King, Esq. and J. Thomas Susich, Esq. of the NVDETR (conflicted
15
out, or should have been via the matter of Maureen Cole, Esq. incident to her attempts to prevent Coughlin
16
from suing Washoe Legal Services in 2009...and its kind of hard to object to propsed Panel members when
17
the SBN does not serve the Complaint under SCR 109, then submits fraudulent materials to indicate the SBN
18
has done so, just as Laura Peters and Patrick O. King, Esq. did with the 10/9/12 file stamped Notice of Intent
19
to Take Default (which Coughlin hereby swears under penalty of perjury that the USPS downtown Reno,
20
Vassar Station would not give to Coughlin in light of it only having $1.25 worth of postage printed out on it
21
in the red "Pitney Bowes" SBN style typical of all SBN mailings (and where, and this is verfied by the
22
SBN's Peter's certificate of mailing attached to that 10/9/12 Notice of Intent To Take Default, the SBN only
23
sent that 10/9/12 file stamped NOITD via one method, certified mail,
24
25
26
27
Some might call it the "McGeorge Mafia" but...that is a bit much, no? However, that law school,
which is renown for long failing out over two thirds of its class (despite glady taking their money while the
relationship lasted) may, to some, seem to produce a certian type of lawyer or judge....the good points?
Teamwork demonstrated in spades....the bad points? Well, some might say the teamwork is mostly directed
28
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000285
to retaliation, zero sum game playing, and "failing out" anyone who dares to cross them. Some might say
that....Coughlin is not saying that.
-more cooking up a fine Panel and Disciplinary Hearing by King, Susich, the Washoe County Sheriff's
Office and the Second Judicial District Court, Reno City Attorney's Office, and Washoe County District
Attorney's Office, and SBN: Judge Linda Gardner's bailiff (and she was present for both days of trial in the
divorce matter wherein Coughlin, on behalf of Washoe Legal Services represented a domestic violance
victim, and took a position supported by the majority viewpoint in American law (though WLS Executive
Director Paul Elcano claims Coughlin's performance in the hearing justified and was the "sole reason" for
Coughlin being fired from WLS- which makes convenient (maybe that "big favor Linda Gardner owes"
10
him?) the fact that Coughlin was really fired for a variety of reasons, and under the typical comparator
11
analysis in employment law, whistleblower retaliation laws, hostile work environment, discrimination, and
12
other laws...the way Elcano ran WLS (involved lots of "old boys and girls network" style intimidation and
13
influence rather than any actual managerial or executive skill or rolling up of one's sleaves...and Thursdays
14
always competely devoted to the skeet shooting range, and practially daily trips from the pharmacy to his
15
mother's home to deliver medications (despite most pharmacy's offering that service for free in Reno...and
16
even one instance shortly before Coughlin's firing where Elcano had Coughlin ghost write a 20 page or so
17
memorandum to the Nevada Department of Taxation that may well have managed to get WLS out of the
18
bind attendant to it entering a lease where the non-profit 503(c), WLS, would be required to pay the property
19
taxes on behalf of the private for profit, landlord...and lots of comparing Coughlin to Seabiscuit, constant
20
critiques of and enforcements of a "dress code" that applied only to Coughlin, etc., etc.)...Anyways, finally,
21
after over 8 months of Coughlin requesting the materials, the SBN King's arranged to have Coughlin's SCR
22
105(2)(c) rights raped a little less than the have been, in getting Chair Echeverria (whom works remarkably
23
fast in disposing of all of Coughlin's motion with a denial and granting all of Kings, and don't be fooled...the
24
Chair was appointed on October 30th, 2012, by October 31st, 2012 he was signing orders disposing of all of
25
Coughlin's Motions (though upon a cross examination of Chair Echeverria it became quite clear he had not
26
read practically anything of what Coughlin worked hard on and submitted to the SBN and the Chair (and the
27
Chair's ruling an a motion that he was not sent by any means other then electronic service is even more
28
evidence of the acceptance of such service by the SBN and the Panel...though now the Panel and SBN are
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000286
attempting to "have it both ways" and alternately claim that King has forwarded all of Coughlin's filing on to
the Panel Members (but King got caught lying about that at the Hearing, to which Panel Member McGeorge
SOL class of 1980 Stephen Kent brazenly gave King a pass and indicated he wouldn't review the exhibits
attached to Coughlin filings anyway, including those containing "tape don't lie" excuplatory video and audio
evidence (and even where the Panel seeks to lazily rest on the language in SCR 111 about a "conviction is
conclusive proof" despite being presented with Claiborne and other authority (including 37 CFR 11.25(3)(a),
(c), which will likely result in the SBN and various local judges work being dissected in fine detail in a
federal setting given Coughlin's being licensed to practice patent law before the United States Patent and
Trademark Office (USPTO).
10
11
12
13
14
15
16
17
Also grounds for a mistrail in that SBN v Coughlin Disciplinary Matter are apparent where Reno
City Attorney Crieg Skau, Esq. appears to have lied about Judge Sferrazza ordering that an Emergency Ex
Parte Motion to Quash Coughlin's Subpoenas (seen both in the disciplinary proceeding and in the petty
larceny of an iPhone that Nicole Watson was videotaped admitting some guy found on the ground in
downtown Reno, and held aloft, (and this started off this whole ordeal with local law enforcement on
8/20/11) offered it up, then announced, loudly that he was going to "throw it in the river" if someone did not
claim it....
18
19
20
21
22
23
24
25
26
27
Any assertion by the SBN that Respondent has actual notice of this the NOITD, the DoWSoe, or
any Supplemental to the Designation of Witnesses, and knowledge of such somehow excuses proper service
or process, misses the point. The Nevada Supreme Court has long acknowledged that notice of a litigation is
not a substitute for proper service of process. C.H.A Venture v. G.C. Wallace Consulting Engineers, Inc.,
794 P.2d 707, 709 (Nev. 1990). Similarly, Defendant's notice of this litigation does not excuse Plaintiff's
insufficient service and insufficent process process. As such the SBN's (and Hill just testified at the
11/14/12 Disciplinary Hearing and about matters related to this appeal even therein) holding the 11/14/12 in
such a matter as to unduly prejuedice or provide excusable neglect or good cause basis for any failure on
Coughlin's part to move this appeal along. But the thing is, is that the Clerk's Office rejected a filing of
28
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000287
Coughlin's just last week that spoke to the appeal bond (in short, Richard Hill, Esq. has it, by way of his
failing to comply with Nevada law respectign tenant's deposits.
So Judge Linda Gardner's April 2009 Order sanctioning attorney Coughlin personally, under NRS
7.085 (despite there being no service by McGeorge SOL Class of 1985 opposing counsel John Springgate,
Esq. of a filing ready 21 day safe harbor NRCP 11 Motion for Sanctions....but rather an impromptu Motion
by Springgate during closing argument about facts not in evidence in support of his Motion for Sanctions....
(and the Order for sanctions by Judge Linda Gardner took the biggest issue with Coughlin's saying, upon
being asked if he had one of the over 10 exhibits that were not bound or previously marked that Springgate
sought to introduce at trial. Coughlin hereby incorproates by reference (an nifty trick Bar Counsel King
10
manages to do in avoiding doing any actual work, Mirch style, by just attaching extremely suspect
11
convictions ("conclusive proof of guilt" according to King, Claiborne and Burleigh be damned), and,
12
though King did not actually make or reserve this argument or cite to any authority like the Mirch case to
13
support what he probably now wishes he had, therefore, seek to find support to rebut the objections Coughlin
14
preserved for the record as to the lack of notice, specificity, factual support for contentions or allegations,
15
service, service of process, sufficiency of either service of process (see Garin's argument in 60302...okay,
16
now apply those to King's blurry exhibits, which were often printed on both sides of the page and contained
17
fraudulent certificates of mailing). The thing is Judge Linda Gardner's Pre-Trial Order itself ruled that either
18
attorney in that trial, who sought to introduce more than 10 exhibits, would be required to have them bound
19
and marked with an index prior to trial and a copy thereof provided to oppsoing counsel. Yet, upon
20
Coughlin voicing concerns that are directly related to and in support of the rationale behind such an Order...
21
(Coughlin is quoted in the Order as saying, in response to whether he has some document that Springgate
22
sought to introduce as about his 12th or 13th Exhibit where Judge Linda Gardner's April 2009 Order reads :
23
"The Court notes that at one point, after an exhibit had been admitted, Mr. Coughlin could not find the copy
24
provided by Mr. Springgate in discovery. Mr. Coughlin demanded a copy be provided at trial, stating: "am I
25
supposed to be rifling through my papers? My understanding is that you are supposed to provide a copy."
26
When asked if he had the copy of the document, Mr. Coughlin stated, "I do not know. I could spend my time
27
and mental energy looking around for Mr. Springgate 's document like I am his assistant, or we could ask
28
Mr. Springgate to provide a copy at the time he is seeking admission like I believe the rule states ." Again it
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000288
would seem the nothing in the following ALR suggests that making an objection once every ten minutes or
so is sanctionable. Conduct of attorney in connection with making objections or taking exceptions as
contempt of court, 68 A.L.R.3d 314. Further, the District Court' s statement regarding factual issues (such as
a rate of success arguing objections) is exaggerated.
Another basis for a mistrial here is all the lies and nonsense from the SBN and various local
governmental offices about the Subpoenas Coughlin issued and had served in the manner he was provided
authority to do so by the SBN and Panel. Also, Reno City Attorney Creig Skau fraudulently secured
Coughlin's attendnat at in improperly notice ex parte hearing the day before the 11/14/12 Disciplinary
Hearing in the iphone case set for 11/19/12 Trial (how conveniently terribly prejudicial to deny Coughlin a
10
continuance either in the Disciplinary Hearing or that iphone RJC case...). Witness the followign fraudulent
11
manner in which Skau secured Coughlin's attendance at an improperly noticed hearing before Judge
12
Sferrazza (who was also the Judge on the summary eviction proceeding/"Trial" that represents such a serious
13
liability to the RJC and arguably should require Judge Sferrazza recusing himself. Speaking of, former
14
WCSO Deputy Peter Eastman, aside from breaking an entering into Coughlin's rental from Jeff Nichols of
15
Cobblestone Masonry, and assiting Nichols in improperly evicting Coughlin through violenet "self help"
16
(despite NRS 118A.160 an the attached work Coughlin did for Nichols in exchange for the rental, required
17
by the fraudulently procurred summary eviction in RJC REv2012-000374 (another reason the RJC should
18
not be hearing cases with Coughlin as a criminal defendant...but Peter Eastman claims to have formerly been
19
Judge Sferrazza's court room deputy in tribal court and that "friends in the court house" indicate that Judge
20
Sferrazza "has it out" for Coughlin or otherwise "has a problem with" Coughlin. Eastman also admits that
21
he and his wife received communicatiosn from SBN Bar Counsel Patrick King, Esq. that violated SCR 121
22
and which also slandered Coughlin, given Eastman's admission that Bar Counsel King told the Eastman's
23
that NVB Judge Beesley had entered an Order, as of May 7th, 2012, barring Coughlin from practicing in the
24
NVB (which is patently untrue...and further evidence of the lengths to which Pat King will go to show his
25
masters he is a good little attack dog for the rich and powerful in Northern Nevada, McGeorge Mafia
26
included, Richard G. Hill, Esq. included, etc., etc.). But, back to Skau's misconduct: From: "Creighton C.
27
Skau" <skauc@reno.gov> To: zachcoughlin@hotmail,com Cc: "Jeannie Homer" <HomerJ@reno.gov>
28
Date: 11/09/2012 11:45 AM Subject: Fwd: FW: Case No. RCR2011-063341 Dear Mr. Coughlin, Please be
- 12/71 -

000289
advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized
service has already been effected.
Also, Coughlin hereby states under NRS 53.045 penalty of perjury that the following exchange
occurred between Coughlin and SBN's Laura Peters on September 11th, 2012 at 4:51 pm wherein SBN's
Laura Peters, whom has and has been by King and Clark repeatedly held out as the "Clerk of Court for the
State Bar of Nevada" and in charge of matters relating to the filing of documents (though Pat King seems to
manage to control every aspect of these proceedings, from directing around NNDB Chairman Susich, to
putting Chair Echeverria where he needs him (they got a real routine goin') to directing Clerk of Court Peters
to effect personal service of the Compalint on Coughlin on 9/25/12 when Coughlin showed up for the
10
Hearing required by the Court's 6/7/12 Order and SCR 111(7)-(8) and SCR 102(4)(d) incident to 60838's
11
6/7/12 Order and the 8/13/12 Petition Coughin filed in 61426, which was served upon the SBN, both the
12
North and South versions, on August 17th, 2012...the same date that Peters noticed Coughlin in writing of
13
the hearing she calendared for Coughlin, admitting it was to be for the "sole purpose" of addressing the
14
conviction in 60838.. King also failed to tell the Court in his SCR 111 Petition that Coughlin complied with
15
SCR 111(2) in self reporting the conviction resulting in his supsension in 60838. Anyways, here is what was
16
communicated between Coughlin and Peters on 9/11/12, contrary to the file stamped Affidavit of Peters in
17
the SBN's filed that was not served upon Coughlin....Coughlin swears under penalty of perjury that the
18
following communciations were made between he and Peters (done in a rush due to Bar Counsel and Panel
19
Chair coercion and flauting of SCR 105(2)(c):
20
21
22
23
24
"Coughlin: Now if I did get a Complaint and I need to serve an Answer, can I
serve it just by faxing it to you?
Clerk Peters: Um...yeah you can.
Coughlin: I have read the rules, they seem to say you go by NRCP except for
( See SCR 105(4))
Peters: ...you can... but it has got to be stamped.
Coughlin: By who? The filing office? The State Bar?
25
Peters: By me, I am a Court Clerk
26
Coughlin: Will you stamp a faxed document if I fax it in?
27
28
Peters: I can, but I need to know how I can get it back to you.
Coughlin: I have a fax, its the one listed on the Bar's website 949 667 7402"
...
- 13/71 -

000290
1
2
3
Coughlin: ...what day is it measured from if you guys filed a Complaint?

Peters (one the effect of certified mailings of the Complaints under SCR 109)
Okay i go 20 days from when I get that green card back, I go 20 days from after
when I get that little green card, so if you picked it up, say last Thursday, then I
go 20 days from last Friday...
Coughlin: Its not 20 days from the file stamped date on the Complaint or
something?
Peters: No, I go 20 days from that certified receipt, I want you to receive the
Complaint before the time starts ticking. That's the way I do it?
Coughlin: and if somebody doesn't pick up that letter, though, they'll will send it
back like after 15 days, and then what, you guys will go 20 days from then? Or
I imagine you guys might even push it a little more and say "no, its 20 days
from when we mailed it"
Peters: I do it from the receipt of the certified copy, so if you received it

yesterday it would be 20 days from today?
10
Coughlin: from my receipt of the certified copy as evinced by my signature on

the card?
11
12
Peters: right, as soon as you sign it and that shows when you got it, that's when
the time starts..I don't starting the counting until I get the green card back with
your signature saying you received it."
13
...
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Peters: Tom Susich's only involvement is setting the panel really....once a

Complaint has been filed we have 20 days or whenever until we receive the
Answer and then once we receive the Answer then we set a Panel...I have the
unclaimed Complaint I got it back September 10th, 2012...you haven't
technically received teh Complaint, even if you may hae received the first class
mail version we sent...
Coughlin: are you sure that at some point somebody with the SBN isn't going to
say "you know what, Zach, by now you have constructive notice of the
Complaint..." and they will try to hold me to that?
Peters: Nobdy is going to do that.
Coughlin: Are you sure? Typically we playin' prison rules in bar hearings...
Peters: Nobody is going to do that. I am the one that controls that, and as far as
I know you didn't receive the Compliant, because I have that certified mail
package right here as it was returned to me...as the Clerk of the Court of the Bar
I am telling you that you did not recieve this Complaint, because it came back
to me unclaimed... and so I am going to send it back out, send it back to you,
and if you pick this up and sign the green card...I will not attempt to do a Notice
of Intent to Take Default before I sent this Complaint back out via certified
mailing again, and I will send this back out and stamp it tomorrow and then
when you get it in the mail and sign the green card, that is when the 20 days to
file
Peters trips up and says Susich sets the Panel, but then says the SBN sets the
Panel (which occurred here pretty mcuh given the SBN purports to have mailed
at the Notice of Hearing and Designation of Witnesses and Summary of
Evidnece on 10/12/12 (SCR 105(2)(c) requires the Panel send those essential
filings, yet King and Peters did in this matter a ful 18 days before Susich's order
setting the panel was even signed and stamped."
- 14/71 -

000291
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
And Patty Ice, aka Pat King, there is more of this coming, guy...more about what you said and what you
said Chief Bar Counsel Clark said about Coughlin's right to issue subpoenas and waiever of witness or
subpoena fees and the manner of service, etc., etc. More to come, boys, more to come....And Chair
Echeverria will want to ask Theresa about that person calling themselves an "attorney" when answering the
phone for his office...which has a name plate that sounds and looks more like a venture captial firm...'The
Echeverria Group"....so coughlin preserver and continues to preserve his objetion to having his case in
chief or defense unnecessrily cut short and not being able to call witnesses or enforce the subpoenas given
the sudden and fraudulent flipping of the script by the panel and or sban obc clerk of court regarding the
rules attached thereto.
Further there is new supplmental evidenc eot and witnesses to support Coguhlin's contention that the
eviction lockout was based upon a void order and fraud is connecte thereto, with the wcso refusing to
comply with records requests and or subpoenas, as well as the RJC., which had jammed coughlin into the
iphone trial today in rcr2011-063341, which is overly prjejducing a variety of cases and Coguhlin's health...
Further, in light of the declaration made by the SBN and Peters upon, upon which Coughlin
reasonably relied, the established pattern and practice of the SBN not starting the running of deadlines
pursuant to the service of items under SCR 109 until the SBN gets back the signed green certified mail slip
must be accord to the October 27th, 2012 certified mailing return receipt slip that, while, it is signed by
Coughlin, it is signed by Coughlin's then housemate "Juliano" as "received by". See, Pat King...that's
called credibility....ie, not sittin' there wasting the Hearing Panel's time arguing that the audio transcripts
the RMC provided you and that you had copied for the Screening Panel are "irrelevant" or "not certified" or
"worthless becuase there is not an prohibitably expensive certified transcript of that Hearing to provide
"context"...(and this after Pat King was caught lying about whether the April 2009 Order he sought to
introduce of Jduge Linda Gardners (resulting Coughlin's firing from WLS...which Chair Echeverria saw no
issue having WLS's ED Elcano provide certification of the Order entered some two weeks after the trial
that, contrary to Echeverria's remixign, Elcano did not "attend" but merely watch the tape of (and under
King's analysis, despite paying $35 for the Second Judicial's tape of that Trial, it still would not be a
"certified copy". The fact that anyone lying about the tape could be cross examined provides plenty of
"certification", doesn't it?
17
20
Also, so cute how Pat King, in the bate stamped copy of the "Disciplinary File" (which Coughlin
should in no way be billed for given the deprivation of his SCR 105(2)(c) rights herein, nor should Couglin
have to pay for any of this Disciplinary Hearing, particulary given all the notice, service, and process
deficiencies attendant to Pat King's impermissible attempts to cheat Coughlin out of his due process and
therefore obtain a result King and the SBN do not deserve.
21
So, its really cute how in the Disciplinary File at 02954 there is the Affidavit of Mailing from the
23rd of August 2012, wherein Laura Peters swears, under penalty of perjury that
18
19
22
23
24
25
26
27
28
Also, Pat King brought his dog to work and let it wander around the halls of the SBN the day of the
hearing, and he wore cargo pants along with a horrific tie, then he sauntered up to Coughlin at a urinal and
salivated over the "pretty good grub, huh, Zach?" Patty Ice wasn't feelin' so chipper a day or so later when
Coughlin was interrogating him about the fraud King committed in the bate stamped copy of the
Disciplinary file, especially vis a vis the fact that curiously, all the SBN filings except for the two most key,
the Complaint and First Designation of Hearing Panel Members (would have been nice to have actually been
served that in accord with the rules and the policies held out by the SBN and justiably relied upon...as a
peremptory challenge would have definitely been issued for both Stephen Kent, as well as Chair Echeverria
(however, nice a men they may be outside the impermissible conflicts of interest they had which should have
prevented them from ever sitting on this Panel. So, where Coughlin now files and affidavit (to whatever
extent he did not so file one or a declaration or verificaton previously, which is not clear) contesting the
August 23rd, 2012 Affidavit of Mailing filed by Peters...which may be undone somewhat by the October
9th, 2012 Affidavit by Peters that is included in the file and filestamped but for which Coughlin was never
- 15/71 -

000292
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3
4
5
6
7
8
9
10
sent a copy or otherwsie served (and the big box copy of the NOITD of 10/9/12's certifcate of mailing does
not indicate that any such affidavit was included therein, so...the Disciplinary Hearing contains a filing that
is file stamped, yet was not sent to Coughlin (and if it was sent to Chair Echeverria or Chairman Susich,
that's misconduct. So King and Peters and the SBN have gotten all cute with this here bate stampe "copy of
the Disciplinary File" consolation prize for the SBN and Panel defenestrating Coughlin's right under SCR
105(2)c)...Peers therein swears she is "employed as a paralegl for the SBN. That in such capactity Affidant is
Cutodian of Records for the Discipline Department of the State Bar of Nevada...." Then Peters goes on to
swear that the "Complaint and First Designation of Hearin Panel Members were served on the following by
placy a copy in an envelope which was then seald and postage fully prepaid for ....despostted in the US. mail
at Rreno...."...Its odd because every other certifeid mail filing in that file bate stamped and copied to
coughlin by the SBN a scant 6 days prior to the Hearing proudly displays the green certified mailing card
(well, there is a distinction between the return receipt requested" card stock card and the more squarish,
certified mailing square slip with a tracking number (which does not involved getting a signature from the
addressee...So when the SBn sent Couglin on 10/12/12 the Notice of Hearing (which SCR 109 requires be
served in the same manner as Complaint (which entails and adoption of the rules Peters set out to Coughlin,
including in their September 21st, 2012 conversation....so, somehow, in that bate staped file for page 02954
is that Affidavit of Mailing by Peters on 8/23/12 wherein she swears that the " "Complaint and First
Designation of Hearin Panel Members were served on the following by placy a copy in an envelope which
was then seald and postage fully prepaid for"...which is clearly not true and or in accord with Peters
statements to and representatiosn and agreements with Coughlin on September 11th, 2012 at 4:41pm.
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"LAURA PETERS, under penalty of perjury, being first duly sworn, deposes and says as follows: That
Affiant is employed as a paralegal for the discipline department of the State Bar of Nevada and in such
capacity is the custodian of records for the State Bar of Nevada; , That on September 11, 2012, at
approximately 4:45 p.m., Zachary Coughlin called Affiant to confirm that a hearing was still scheduled to
take place on September 25, 2012. Affiant explained that the hearing would not take place on September
25th and that date had been scheduled prior to the filing of a formal Complaint. Mr. Coughlin reacted as if he
had no knowledge of a Complaint. Affiant then explained that, in fact, a copy of the Complaint, sent via
certified mail on August 23, 2012, from the Reno office of the State Bar, had been returned and marked
"unclaimed". Affiant further explained that since service had not been affected, a new certified copy would
go out the next day. Affiant requested that when Mr. Coughlin received said copy, he should return the
postcard attached to the mailing and his twenty (20) day period in which to answer the Complaint would
start running at that point. However, in speaking to Assistant Bar Counsel Patrick King, it was determined
that personal service should be affected upon Mr. Coughlin. Reno Carson messenger service was engaged to
attempt personal service despite Mr. Coughlin not providing the State Bar with a physical address. On
September 25, 2012, Mr. Coughlin arrived at the Reno office of the State Bar allegedly expecting a hearing
to take place. At that time, Mr. Coughlin was again told, both by Affiant and Assistant Bar Counsel Patrick
King, that no hearing would be taking place that day and that an answer to the State Bar's Complaint had not
been received. Affiant personally served Mr. Coughlin with a copy of the Complaint on his visit to the Bar
office on September 25th as witnessed by Paula Campbell, an employee of the State Bar. Mr. Coughlin
insisted that the hearing which had been previously scheduled for that day should be taking place because he
needed to be removed from temporary suspension. Mr. Coughlin has also been instructed by Assistant Bar
Counsel Patrick King that he cannot file pleadings with the State Bar via e-mail, which he continues to
attempt. The Motion to Dismiss, which Mr. Coughlin now insists should be granted as it has gone
unopposed by the State Bar, was never presented to Affiant for filing but was rather emailed prior to
Affiant's conversation with Mr. Coughlin on September 11th when Mr. Coughlin under no uncertain terms
told Affiant that he had not yet received the Complaint. FURTHER YOUR AFFIANT SAYETH NOT.
Dated this 91h day of October, 2012. "
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SCR 103: 7. Hearing panel members shall not participate in any proceeding in which a judge similarly
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situated would be required to abstain. Any member whose term expires while the member's
panel is considering a complaint shall remain a member until its disposition.

8. The chairs of the hearing panels and screening panels shall deliver reprimands and sign
all
documents on behalf of the panel to carry out the provisions of Rules 102(6), 102(7), and
103(6).
9. A grievance received against a member of a disciplinary board and processed in
accordance
with Rule 105(1) shall be referred to the other disciplinary board.
So, the policy announced by SBN PetersAs to that "received by" signature on October 27th, 2012
by "J. Juliano", under the established policies of the SBN as set forthe by the SBN and Clerk of Court
Peters during the September 27th, 2012 conversation with Coughlin wherein Peters established and
confirms that deadlines incident to service via certified mailing do not begin running until she or the SBN
receives back the green certified mail return receipt requested slip that, and or until two attempts at
such certified mailing service have gone unclaimed, whereupon, a Notice of Intent to Take Default
would be sent via certified mail (and Peters indicated all such certified mailings are sent in duplicate
via first class mail as well (though, strangely, the 10/9/12 Notice of Intent to Take Default's certificate
of mailing indicates that it was sent via only one method, certified mail (ie, not also by first class
mail) and, curiosly, despite every other SBN filing in the bate stamped Discipinary File in SBN v.
Coughlin having the certified mail slip included therein, the NOITD fails to (and this is likely due to
Pat King realizing (and SCR 109 requires that the Notice of Hearing and DoWSoE of
evidence.Coughlin could probably pull a Pat King and refuse to acknowedge that the cd's Pat King
he and the SBN had a problem in that upon doing a USPS Track and Confirmlf received from the
RMC were "certified" or otherwise appropriate for admitting into evidence (as to whether they are certified,
that depends who is doing to "defining" of what is certified...but it also begs the question, why would the
SBN be putting to a Screening Panel audio transcripts that are not certified? Also, the bit from the 2/27/12
trial in 11 TR 26800 about where Coughlin tells Judge Nash Holmes "that's quite a sound byte, Your
Honor" in response to her stating "I don't care about bribery, I don't care about corruption, I don't care
about retaliation...all I care about is the Boulevard Stop" (need to listen really closing to that Trial, or
somehow get the RMC and Longoni (whose Sunshien Reports should have never been allowed to do this
Hearing, no disrespect to Ms. Hummel, though, but a conflict clearly exists, particulary where Coughlin's
appeal in the conviction resulting in his current suspension was denied due to the failur of Longoni and the
RMC to prepare the transcript even though Nevada law required they do so upon Coughlin filign his Notice
of Appeal instant to NRS 189.010-.050... that statute is not advisory...is is the law, and D10 Judge Elliot's
mentioning a civil statute's stance on the prepareation of appeals and down payments thereto does not
change that. It is fraud by Longoni and the RMC So, if something is missing from the RMC's $35 audio
transcript that Coughlin was only able to obtain after drafting his own mother, Mary Barker, into the
pursuit (the RMC made up excuse after excuse for refusing to fill Coughlin's audio transcript request and
evne had its Marhals start manufacturing grievances against Couglin with the RMC (see their ridiculous
"greivance" or letters to the RMC and their even more ridiculous "Incident Reports". (even for the limited
purposed of demonstrating what King and Peters gave to Coughlin purporting them to be "leftovers" from
the Screening Panel on October 10th, 2012 that RMC Judge William Gardner obnoxiously claimed to know
so much about to Coughlin in court on 4/10/12, shortly after Judge Gardner announced that he and
McGeorge Mafia, class of 2006 member Reno City Attorney Hazlett-Steven's and Coughlin's McGeorge
Mafia SOL court appointed counsel Keith Loomis, Esq. had a secret meeting that morning prior to trial in
some backroom of the RMC where they all had a great time, uh, practicing their lines. And what a forced
lifeless performance it ultimately was when that troupe presented to indigent criminal defendant Coughlin
and attempted to navigate their way through the murky waters of violating NRS 178.405 (in light of the
2/27/12 Order for Competency Evaluation in RCR2012-065630 that the RMC Judges were well aware of,
incident to their "at least one meeting" when they brainstormed how to get Coughlin and the
communications between Judge Nash Holmes and the Washoe County Public Defender and or Biray
Dogan, Esq., counsel of record for Coughlin in that rcr2012-065630, whom can tell you all about how
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DDA Young violated NRS 178.405 in filing at 2:55pm a fugitive document in seeking to oppose
Coughlin's Motion to Appear as Co-Counsel, despite the OR
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First, despite Peters Affidavit of October 9th, 2011 (here is no proof of service of that Peters Affidavit on
Coughlin, and it it was served on the Panel or Chair, unbeknownst to Couglhin, that is an impermissible ex
parte communication) being filestamped an included in the materials that were only finally provide to
Coughlin on November 8th, 2011:08:55:54
further, Coughlin one hundred percent categorically denies Pat King's unsupported allegation of Coughlin
attempting to dodge service. One, the hearsay of Johhno Lazetich is in the form of a bill, not a sworn
affidavit, and further, it clearly contains mere conjecture on Lazetich's part. Further, Coughlin setn
Lazetich and his father's company Reno Carson Messenger Service an email and a voice mail asking what
he could do for them, along with emails and a fax to the SBN offering to meet a process server somewhere
or otherwise assist in having the Complaint appropriately served, however, King and the SBN chose to lied
to Coughlin instead, and go back on what Peters definitively declared during the September 11, 2012
conversation on the telphone with Coughlin that her unserved, yet file stamped, October 9th, 2012
Affidavit asserts. It is interesting that King and Peters say nothing about faxing motions...consdiering that
Peters clearly gave Coughlin permission to fax file motions (and in accord with other such forms of
electronic filing, Coughlin's fax filed motions, and arguably email filed Motions (including the skydrive
link files atached thereto should be made a part of the record and the file and the Panel should be provided
with them and reminded that they have a duty to review them. This is true, especially for anything prior to
the September 25th, 2012 email by King purporting to refuse email filing (and arguably, at that point, it
was too late for King to change the rules of procedure set forth by Laura Peters and or Susich's or the
Panel's failure to oppose such filings by Coughlin. REgardless, the file as King had it bate stamped and
provided to Coughlin at such a very late stage (November 8th, 2012 upon the first attempt to deliver it from
Sierra Document Processing Coughlin received it an signed for it, and thereby his SCR 105(2)(c) right to
inspeact "up to 3 days prior to the hearing" was violated, especially considering Coughlin was continually
refused the opportunity to inspect such records as the SBN at every stage since Pat King's phony offers to
allow such in March 2012...Further, the bate stamped Formal Hearing File SBN v. Zachary B. Coughlin is
missing a number of cd/dvd exhibits that Coughlin submitted for filing. Pat King admits to just choosing to
remove them from the file and or fail to copy the committee on them, while at the same time maintaining
he and the SBN and Peters have demonstrated Fidelity in their stated practice of providing everything
Coughlin files to the Panel. Additionaly, Peters Affidavit is quite fraudulent. One. clearly a Motion to
Dismiss dated September 17th, 2012 that Coughlin has a fax confirmation of and also email to Bar Counsel
and Susich was not "created prior
The Motion to Dismiss fax filed on September 17th, 2011 should be file stamped an included in the
file. Why else would Laura Peters Affidavit not indicate someting contrary to Coughlin's sworn assertion
that he was given permission to fax file by the SBN? Regardless, Coughlin's hadn delivered Motion to
Dismiss of Cctober 15th, 2012 (or it may have been October 16th, 2012, given Coughlin missed his self
imposed deadline of delivering to the SBN a Motion to Dismiss by midnight of some night, and sent Clerk
PEters and email the next day indicating the proof of service should be adjusted in that regard. Further the
Chairs assessment that Coughli nfailed to file a "verified response or answer" or that such "may not contain
anything stated upon infromation and belief" is contested and just flat out wrong. Coughlin's signature on
page 61/62 on the Motion for ORder to Show Cause may be a bit high above the signature line (though
the /s/ is operative in electronic filing, which the SBN gave Coughlin permission to do.
Judge Linda Gardner is a lifelong prosecutor turned Judge, like her brother RMC Judge William
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Gardner, like his fellow RMC Judge whom he admitted passed the April 2009 Order sanctioning Coughlin
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resulting in Coughlin's firing from WLS in 60302 (and a Mandamus filed against Linda Garnder by
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Coughlin in 54844, and a grievance filed by both Judge Linda Gardner and Judge Dorothy Nash Holmes
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000295
(also a lifelong prosecutor turned Judge...like Judge Kenneth Howard too) (on behalf of all of the RMC
Judges) against Coughlin in both NG12-0434 and NG12-0435...which along with the Richard G. Hill, Esq.
grievance (Rich was just fulfilling his RPC 8.3 duty, y'all...don't hate) in NG12-0204, SBN Bar Counsel of
the North Pat King whipped up in a SBN v. Coughlin Complaint, that he purports to have served under SCR
109 via a certified mailin of 8/23/12 that was returned to the SBN, and to which SBN Clerk of Court Laura
Peters indicated to Coughlin would absolutely, under no circumstances, ever be used as a return of or proof
of service of the Complaint against Coughlin given the fact that she herself received it as returned to send on
9/10/12, and especially where she told Coughlin he coudl rely upon her then indication that she would, in
accord with the SBN's pattern and practice and established policies, resend it once again the following day
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via certified mail, and only upon that mailing not being met with a signed certifed mail signature of
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Coughlin's would the SBN send out a Notice of Intent to Take Default, served in the same manner as that
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which was attempted with the Complaint itself. Of course, Pat King attempted to cheat the system by
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turning all those SBN-Coughlin agreements into lies, because if there is one thing Pat King will not stand for
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it is competition or a level playing field. King recoils from such like a vampire from a coming sunrise.
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SCR Rule 110. Subpoena power, production of documents, witnesses, and pretrial
proceedings.
1. Issuance of subpoenas by hearing panels and bar counsel. Bar counsel and a member
of
a hearing panel who is also a state bar member, in matters under investigation by either,
may
administer oaths and affirmations and issue and compel by subpoena the attendance of
witnesses
and the production of pertinent books, papers, and documents. The attorney may also
compel by subpoena the attendance of witnesses and the production of pertinent books,
papers,
and other documents before a hearing panel. Subpoena and witness fees and mileage
shall be the same as in a district court.
2. Confidentiality stated on subpoena. Subject to the provisions of Rule 121, subpoenas
shall clearly indicate on their face that they are issued in connection with a confidential
investigation
under these rules and that it is regarded as contempt of the supreme court or
grounds for discipline under these rules for a person subpoenaed to in any way breach
the confidentiality
of the investigation. It shall not be regarded as a breach of confidentiality for a
person subpoenaed to consult with counsel or to answer questions asked by bar counsel
or the
attorney to determine the facts known by the witness.
3. Attachment of person for failure to obey subpoena or produce documents. Whenever
any person subpoenaed to appear and give testimony or to produce books, papers, or
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documents as required by subpoena, or requested to provide documents pursuant to

Rule
78.5(1)(b), refuses to appear or testify before a hearing panel, or to answer any pertinent
or
proper questions, or to provide the requested documents, that person shall be deemed in
contempt
of the disciplinary board, and the chair of the disciplinary board shall report the fact to a
district judge of the county in which the hearing is being held or the investigation
conducted.
The district court shall promptly issue an attachment in the form usual in the court,
directed to
the sheriff of the county, commanding the sheriff to attach such person and bring such
person
forthwith before the court. On the return of the attachment, and the production of the
person
attached, the district court shall have jurisdiction of the matter; and the person charged
may
purge himself or herself of the contempt in the same way, and the same proceedings
shall be
had, and the same penalties may be imposed, and the same punishment inflicted as in
the case
of a witness subpoenaed to appear and give evidence on the trial of a civil cause before
a district
court of the State of Nevada.
4. Contest of subpoena. A contest of a subpoena shall be heard and determined by the
chair
of the appropriate disciplinary board.
5. Restriction on discovery. Discovery by the attorney, other than under Rule 105(2)(c),
is
not permitted prior to hearing, except by the order of the chair for good cause upon
motion under
Rule 103(5) or Rule 103(6).
6. Prehearing conference. At the discretion of the chair, a prehearing conference may be
ordered for the purpose of obtaining admissions or otherwise narrowing the issues
presented
by the pleadings. The conference may be held before the chair or the chair's designee.
7. Deposition in lieu of appearance. With the approval of the chair, testimony may be
taken
by deposition or by commission if the witness is not subject to subpoena or is unable to
attend
or testify at the hearing because of age, illness, or other infirmity.
8. Confidentiality of deposition. Depositions are subject to the protective requirements
and
confidentiality provided in Rule 121.
CREDIT(S)
Added, eff. Feb. 15, 1979. As amended, eff. Jan. 2, 1996; Mar. 1, 2007.
LIBRARY REFERENCES
Attorney and Client 47.1.
Westlaw Topic No. 45.
C.J.S. Attorney and Client 73, 89.
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-Judge Beesley's testimony on 11/14/12 is curious in light of the solid thumbs up he gave the no temporary
suspension getting Stephen R. Harris, in 57507, and the fact that Judge Beesley was hard pressed to provide
a single detail in support of his strong contentions that Coughlin's work and filings before him in the NVB
indicated Coughlin not competent to practice there. Coughlin is a National Merit Finalist who was ranked
10th in his class at a top 80 law school, has been a licensed Patent Attorney, and passed the July 2001 State
Bar of Nevada's Bar Examination a year before those matriculating as full time students with him to UNLV's
Boyd School of Law in August 2001 would even take that examination, meaning he passed it after his
second year of law school. Further, the attached filings by Coughlin before Judge Beesley in the NVB
clearly demonstrate a skill level beyond the baseline competency required to practice therein, something all
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the more impressive given they represent the very first two or three bankruptcy cases Coughlin ever took on.
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It is literally a textbook example of a solo attorney starting out and not taking on too many cases, sufficient
12
to be able to extricate himself and his client's from even the most unexpected calamities and circumstances
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foisted upon them by the misconduct of others (including having Judge Beelsey's McGeorge SOL 1977
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classmate RMC Judge Nash Holmes (who was sued for wiretapping attorney Martin Weiner or Crowley,
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Esq.), whom unlawfully and, apparently in conjunction with her former coworkers at the WCDA Office (and
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NNDB Panel Member Mary Kandaras was intimately involved in the process...in fact WCSO Deputy
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Madeline refused to return the smart phone and sd card to Coughlin even after Judge Nash Holmes' Order
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required the WCSO do so...with Madeline indicating she needed to get Mary Kandaras' permission first
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before complying with Judge Nash Holmes order (funny, didn't see Madeline getting hemmed up with an
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instant incarceration and summary criminal contempt charge there...)...shortly after (and Pam Wilmore, Esq.
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was there and heard all of this, though her partnership or sharing of an office with McGeorge SOL 1985
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John Springgate, Esq (opposing consel in 54844 April 2009 Judge Linda Gardner sanction order getting
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Coughlin fired in 60302 from WLS) may prevent too clear a recounting...Then WCSO Deputy Hodge got
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caught in a, uh, story, about whether the micro sd card was included in the materials booked and then in the
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materials released to Coughlin's friend, whom picke them up on 2/28/12 (interestingly...Coughlin's smart
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phone and micro sd card were booked into Coughlin's property upon intake at the jail...but a full day later the
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RMC Marshals returned (and Marshal Scott Coppa seemed to communicate and intent to do so to WCSO
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Deputy Cheung when he pulled him aside into a back room in the sally bay during the conclusion of the
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RMC Marshals transporting Coughlin to the WCDC o 2/27/12....Then Marshals Coppa and Marshal
Townsend retaliated against Coughlin's valid complaints thereto (and other criticisms of the extent to whih
the RMC is a monument to a lack of transparency or separation between the court's Departments and the
Court's filing office) by filing a nonsensical criticism of Coughlin's clothin choices when visiting a muni
court filing office counter to check on a traffic citation with the SBN...which King promptly mentioned to
Coughlin in a deliberately misleading way, via King's 3/23/12 email to Coughlin (King plays little games
with the moniker "Clerk of Court"....King, Marilyn Tognoni is not a "Clerk of Court"...neither is Cassandra
Jackson...and neither King nor Second Judicial District Clerk of Court Joey Orduna that likely wound up in
Judge Flanagan issuing a rash ruling on 3/30/12 disposing of Coughlin's appeal in the Richard G. Hill, Esq.
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appeal of the summary conviction from Coughlin's former hom
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(so as for cooking up a Panel...Susich and King got Panel Chair John Echeverria, whom had to admit he and
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WLS's Paul Elcano were boyhood chums and that both went to Stanford University in 1966 (add to that the
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fact that Echeverria went to Hastings Law School along with WLS's Caryn Sternlicht (whom Coughlin is
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suing, along with Elcano in 60302) and Reno City Attorney Pamela Roberts, Esq (whose prosecutorial
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misconduct in putting on perjured testiomny by Wal-Mart's Thomas Frontino and the Reno Sparks Indian
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Colony's Kameron Crawford (asserting that a custodial arrest and search incident thereto was permissible,
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despite NRS 171.1255 on some assertion that Coughlin failed to provide his driver's license...even where
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Roberts herself was given the "Interrogation Room" videos by Wal-Mart showing Coughlin giving his
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driver's license to Officer Crawford, whereupon Crawford copies down the information therefrom onto the
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Arrest Report and Probable Cause sheet and radios into his dispatch Coughlin's Nevada driver's license
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number...add to that the fact that Coughlin's detention intake property sheet lists that he was booked into jail
22
with his Nevada driver's license...and Officer Crawford and Thomas Frontino's lies are clearly exposed,
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which Pamela Robert's purposefully allowed them to tell in her retaliatory rush to get a conviction shortly
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after she back out of a written agreement to a continuance...and where Judge Howard specifically based his
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refusual to grant Coughlin a continuance upon his mistaken/incorrect belief that it was Coughlin whom was
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responsible for the 11/14/12 Trial date being continued. Judge Howard had to admit, later, on the record,
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that he was mistaken in that regard (so instead of declaring a mistrial, Judge Howard just admitted his
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mistake and proceeded with putting Coughlin in jail for 3 days for NRS 22.030 "summary contempt" despite
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000299
Judge Howard having failed to grant Coughlin's motion for counsel, even though the Nevada Courts of
Limited Jurisdiction Bench Book points out that Aigersinger is mandatory authority, and therefore,
appointed counsel is required where even the possibility of jail time exits. In his pre-trial Order denying
Coughlin's Sixth Amendment Right, Howard ruled that Coughlin was not entitled to counsel, even where he
had established he was indigent (and evicted just days prior thereto) because "jail time is not the typical
sentence" for first offense shoplifting of a de minimis amount of food. However, it is important to note that
Judge Howard did not rule out the possibility of jail time, and therefore Aignersinger applies. Further, Judge
Howard, who had been occupying the RMC Bench for 14 years at that point, announced during the rendition
of his conviction order that, not only was the summary contempt conviction not appealable (and, of course
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no stay would be availalbe...the RMC having a perogative to expedite matters before it an all (so much so
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that Judge Howard kept a supposedly financially strapped City of Reno Staff of RMC Marshals and RMC
12
Court Staff in court on overtime pay until 9:00 pm at night in his mad rush to conclude the petty larceny
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trial, first offense, of a de minimis amount of food, from a megaconglomerate corporation, where the arrest
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was made in violation of NRS 171.1255, by tribal police, on land that police force's employers (the Reno
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Sparks Indian Colony) rent to Wal-Mart. Judge Howard refused Coughlin (then a licensed attorney whose
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property right, his law license, under the Fourteenth Amendment, would necessarily be imperiled upon an
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SCR 111(6) "serious offense" conviction (stealing a grape would invoked that rule according to Pat
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King...though Stephen R. Harris stealing $740,000 from his clients and using it on hookers and designer
19
luxury products did not, nor did it result in a temporary suspension either...and it didn't prevent Judge
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Beesley from singing the praises of Stephen R. Harris, Esq. in 57507 even where an improperly noticed
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phoned in testiony by Judge Beesley at Coughlin's Discipilinary Hearing saw Judge Beesely (who had to
22
admit that he had a longtime long partnership relationship with someone Coughlin is suing, Washoe Legal
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Service's Karen Sabo, Esq., whom admitted to Paul Elcano that she could never, and would never work with
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Caryn Sternlicht, Esq., finding her personality so odious and detestable...though Ms. Sabo had no issues
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expecting Coughlin to cheerfully bare the brunt of such while he worked as a domestic violence attorney at
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WLS...Also Judge Beesley is a close friend of Paul Elcano's, attending a very intimate West Fourth Street
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Bistro invite only WLS party in 2008 at Elcano's invitation. Upon Coughlin cross examing Judge Beesley as
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to just what he was basing his sudden (and never before had Judge Beesley actually made and ruling or
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000300
otherwise voiced any consternation whatsoever to Coughlin about his work respresenting client's before the
NVB...so it was a zero to trash Coughlin as a Disciplinary Hearing approach by the measured, impartial
jurist Beesley, who graduate from McGeorge SOL in 1979, right between two other witnesses at Coughlin's
11/14/12 Disciplinary Hearing cook-off thrown by Chair Echeverria and Pat King (whom wore cargo pants
to work that day, whereupon he asked the Panel to disbar Coughlin based upon a petty larceny conviction of
a candy bar, a criminal trespass convction that only saw a SCR 111(4) Petition (ie, King had to admit it did
not qualify as a "serious offense" despite his trying to find leverage by threateing to file an SCR 111(6) for
months) even where opposing counsel in this summary eviction from Coughlin's former home law office
was applying an unlawful rent distraint under NRS 118A.520 to exculpatory videos and materials that would
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demonstrate Coughlin's innosence and the fact that on occasions previous to the 9/9/12 arrest, including on
11
July 7th, 2011, West 7th St Wal-Mart Assistant Store Manager John Ellis and an as yet to be indentified AP
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Associate specificaly told Coughlin that they would retaliate against him via an abuse of process (of course
13
Judge Howard ruled that, even if they did, that was not relevant) (supplemented to King's Designation of
14
Witnesses 4 days before the Hearing of 11/14/12, along with Judge Beesley, despite neither having anything
15
to testify to that Pat King did not know about for over six months...its just that, Pat King got real worried
16
about the fact that he violated SCR 121 by communicating to Coughlin's then client and or his wife, Peter
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Eastman and Pam Eastman that Judge Beesley (McGeorge SOL, class of 1979) had issued an order
18
prohibiting Coughlin from practicing in the Nevada Bankruptcy Court for the District of Nevada (which is
19
absolutely not true...and even if Judge Beesley had actually wanted to at that time...he would not have the
20
authority to...but there is plenty of evidence that Judge Beesley had no such intention towards any such
21
Order at the time of the May 7th, 2012 communication by Peter Eastman to Coughlin that revealed that Bar
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Counsel Patrick O. King has told the Eastman's that their then attorney, Zachary B. Coughlin, Esq., had been
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"suspended from practicing in the Bankruptcy Court" in light of Judge Beesley entering an Order so
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preventing Coughlin from doing so. King, during a meeting with Coughlin and King's boss, Chief Bar
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Counsel David Clark on August 17th, 2012 (a three hour meeting) grew flustered upon Coughlin querying
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him on his quizzical stated intent to have Coughlin disbarred...whence Coughlin asked King just what sins
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supported such a motive...amongst the first two things King mentioned to Coughlin and Clark was the fact
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that the NVB Judge Beesley had entered an Order prohibiting Coughlin from practicing in Bankruptcy
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000301
Court....This was "news" to Coughlin, whom had never been served any such Order, and had never heard
any such thing besides from his former clients (the Eastman's, whom were extremely late in making a
number of payments to Coughlin in exchange for his hard work and respresentation of Peter
Eastman)...Shortly after Coughlin was told of Bar Counsel's violation of SCR 121. Incident to Judge
Beesley (McGeorge School of Law, class of 1979) presiding over the Cadle Company v. Robert Keller
adversary proceedig in NVB (10-05104) Coughlin filed a Motion For Continuance wherein he attached
materials revealing that Judge Beesley's McGeorge School of Law classmate, Reno Municipal Court Judge
Dorothy Nash Holmes (McGeorge School of Law 1977) had violated Nevada law in purporting to rule that
NRS 22.010 was "the misdemeanor of criminal contempt" (actually, criminal contempt in Nevada is found at
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NRS 199.340...but that statute doesns't specifically allow for a "summary" finding of guilt, so, instead, Judge
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Nash Holmes too the bits she liked out of it, then renamed it NRS 22.010
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NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be
deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court,
or engaged in judicial duties at chambers, or toward masters or arbitrators while sitting on a
reference or arbitration, or other judicial proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or
in its immediate vicinity, tending to interrupt the due course of the trial or other judicial
proceeding.
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3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge
at chambers.
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5. Rescuing any person or property in the custody of an officer by virtue of an order or process of
such court or judge at chambers.
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6. Disobedience of the order or direction of the court made pending the trial of an action, in
speaking to or in the presence of a juror concerning an action in which the juror has been
impaneled to determine, or in any manner approaching or interfering with such juror with the intent
to influence the verdict.
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7. Abusing the process or proceedings of the court or falsely pretending to act under the authority
of an order or process of the court.
NRS 22.030 Summary punishment of contempt committed in immediate view and presence of
court; affidavit or statement to be filed when contempt committed outside immediate view and
presence of court; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at
chambers, the contempt may be punished summarily. If the court or judge summarily punishes a
person for a contempt pursuant to this subsection, the court or judge shall enter an order that:
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000302
(a) Recites the facts constituting the contempt in the immediate view and presence of the court or
judge;
chambers, an affidavit must be presented to the court or judge of the facts constituting the
contempt, or a statement of the facts by the masters or arbitrators.
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3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate
view and presence of the court, the judge of the court in whose contempt the person is alleged to be
shall not preside at the trial of the contempt over the objection of the person. The provisions of this
subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment
or decree was entered in such court by a predecessor judge thereof 10 years or more preceding the
bringing of contempt proceedings for the violation of the judgment or decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been
established in the judicial district.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one
of the following kinds shall be guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its
immediate view and presence, and directly tending to interrupt its proceedings or to impair the
respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or
hearing pursuant to an order of court, or in the presence of a jury while actually sitting in the trial
of a cause or upon an inquest or other proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of
a court, jury or referee;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer
any legal and proper interrogatory;
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But, actually, contrary to Judge Beesley's sworn testimony at the 11/14/12 Disciplinary Hearing,
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Judge Beesley could have somehow ruled in a manner seeking to regulate Coughlin's appearances before his
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Court, or providing, in any manner whatsoever, some indication to Coughlin as to any sort of displeasure
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with Coughlin's performances therein (which Judge Beesley absolutely never did) prior to Judge Beesley
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(upon being supplemented to the Designation of Witnesses list four days prior to the 11/14/12 Disciplinary
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Hearing related to Coughlin's lawsuit against WLS and Paul Elcano (McGeorge SOL, Class of 1978, and
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therefore a classmate of both Judge Beesley and Judge Nash Holmes, in addition to a class mate of Panel
Member Stephen Smiley (McGeorge SOL, Class of 1980, whom., therfore, was necessarily a class mate of
RMC Judge Kenneth Howard (McGeorge SOL, class of 1981....and speaking of Panel Member Kent...he
glared at Coughlin continuously throughout the 11/14/12 Disciplinary Hearing and upon Pat King being
caught in several lies that day (King told the panel an Order , the one that got Coughlin fired from Washoe
Legal Services over three years ago but which suddenly became a grievance when teh RMC Judges decided
to do their hit piece on Coughlin's life and law license because they got scared that their Court and the
Municipality that owns it, and the police force and Marshals that is leverages against the citizenry to collect
a tax disguised as justice (and the RMC had $700K or so turn up missin' in 2011, and explained that away by
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saying the shortfall was do to data entry errors and stuff) was a certified copy when it was not....no matter,
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Elcano's boyhood chum and fellow Stanford '66 alumni Panel Chair Echeverria allowed Elcano to provide
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certification of the Order in light of Elcano claiming to have "reviewed the video tape of the Trial" (which
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Echeverria tried to remix into "having attended the Trial" that led to Coughlin filing a Mandamus Petition
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against Judge Linda Gardner in 54844... Which was odd considering that Chair Echeverria refused to admit
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into evidence the certified copy of the audio of the 11 TR 26800 traffic citation trial on 2/27/12 Couglin
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offered into evidence (Chair Echeverria refused to allow Coughlin to testifyin to it being a certified copy or
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otherwise even look at the cd itself which Coughlin had to have his mother buy from the Reno Muncipal
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Court after months of the RMC and Judge Nash Holmes refusing to let Coughlin purchase a copy of it. That
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certified copy was to be used to impeach the lies by Judge Nash Holmes in the traffic citation trial Holmes
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held despite her admitting (see the 3/14/12 grievance against Coughlin Judge Nash Holmes sent to the SBN
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"on behalf of all the RMC Judges"...which is odd because one of those Judges William Gardner tried to
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pretend he wasn't aware of that, and just barely contained himself from holding the trespass trial on
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4/10/12....though he did manage to violate NRS 178.405 numerous other times himself (including the 3/8/12
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trial setting, and teh March 8th, 2012 Trial Setting the matter for 6/18/12 despite the Order on the
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Competency Evaluation not having been signed and entered until 5/9/12....yet Judge Nash Holmes
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constantly seeks to play hype man to some alleged "authority" and profound knowledge she feels she
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possesses with respect to mental health care and competency issues in general. Tell that to her 3/14/12
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grievance to the SBN, wherein she manages to write:

- 27/71 -

000304
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"This letter constitutes a fonnal complaint of attorney misconduct and/or

disability against Zachary Barker Coughlin. The accompanying box of materials
demonstrates some of the problems with the practice of this attorney being
experienced by myself and the other three judges in Reno Municipal Court. My
two most recent Orders in what should be a simple traffic citation case are selfexplanatory and are included, together with copies of massive documents Mr.
Coughlin has fax-filed to our court in this case. Audio recordings of two of my
hearings in this matter are also included. He failed to appear for the second one
this past Monday. I have another traffic case pending trial with him that was reassigned to me based on our Department 1 judge being out for surgery. We have
multiple addresses for Mr. Coughlin and can't seem to locate him between cases
very easily. We are setting that case for trial and attempting to serve him at
the most recent address we have (1422 E. 9th St #2, Reno NY 89512),
although I heard today he may be living in his vehicle somewhere. We do
have an address for his mother, however, as she recently posted part of a fine
for him. Judge Ken Howard Department 4 had case on Mr. Coughlin late last year
that is now on appeal to the Second Judicial District Court Judge Linda Gardner,
Department 2, also has a matter currently pending in his court with Mr. Coughlin
as the defendant. I have enclosed some copies of documents from those matters,
in chronological order, simply because they appear to demonstrate that he is
quickly decompensating in his mental status. Our staff also made you some audio
tapes of Coughlin hearings in Departments 2 and 4 so you can hear for yourself
how this attorney acts in court. You can see his behavior in my traffic citation
case does not appear to be an isolated incident.
You will the full cooperation of myself the other judges, and the staff of
Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned
himself as a vexatious litigant in our court, antagonizing the staff and even our pro
temp judges on the most simple traffic and misdemeanor matters. I do think this is
a case of some urgency and I apologize for taking two days to get this package to
you; our IT person was ill and could not make the copies of the audios of Mr.
Coughlin's hearings until today, and I felt it was important that the audios be
included in the materials to be considered by the State Bar. On February 27, 201
Mr. Coughlin told me he was actively practicing law and had appointments with
clients. I do not know if that was true, but if so, he could be causing serious harm
to the practice of law in Northern Nevada and could be jeopardizing someone's
freedom or property interests. Please contact me if you need any other
information. My direct line is 775-334-3823 and my cell phone is 775-250-0330"
And regardless of whether the materials the RMC's Nash Holmes provided King
are certified (good gawd they should be considering what it is she is trying to do with
them!, Coughlin was entitled to have them admitted for the purpose of showing what King
was provided by Nash Holmes with "the full cooperation of" her and "the ohter three RMC
Judges"
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AT the 11/14/12 Hearing Judge Nash Holmes lied when she testified that she
"started asking Coughlin questions about whether he was recording the proceeding or
whether he had a recordign device and he immediately go all sneakity and then said no, he
was not and didn't have a recording device, then he switched up his story and said that
was, get this, a "Fifth Amendment" thing...then he immediately asked to go to the
restroom, and I let him, but ORder RMC Marshal Harley to go with him, and refused to
allow Coughlin to take anything with him, even his yellow legal pad, and Marshal Harley
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reported to me that Coughlin disassembled a smart phone or recording device in the

restroom and hid parts of it there, which the Marshals later discovered after Coughlin was
handcuffed and arrested, and I think Coughlin probably lied about whether he was
recording the proceeding, so I found by "clear and convincing" evidence that Coughlin
violated all these rules of professional conduct that I conversed with Bar Counsel about,
and I am not trying to take Bar Counsel's place or nothin', but I am just tryin' a chip in an
do my part to make the public safe from this "attorney" whose writing is the most
frightening and unorthdox display of immense, immense talent that I have ever had the
misfortune of having been subjected to..." (Chair Echeverria was terrified of the prosepct
of the cook off, er, Disciplinary Hearing being recorded, and refused to allow Coughlin to
do so, lying that it was being record by the court reporter, though now Sunshine
Reporting, whose reporte Carol Hummel did the trancribing, is saying no recording was
made, and that, yes RMC "exclusive"transcritpinist Pam Longoni is amongst there
employees and that (and this combines with Judge Linda Gardner's current and then
deputy on the April 2009 trial being the deputy assigned the the 11/14/12 Discipinary
Hearing (what did I tell you? Can Patty Ice stacks a deck for hisself or what?
Tommy Susich, too. You just don't mess with the NV DETR or Maureen Cole, right
Tommy?). See attached materials related to the RMC and Longonis continuously
violating Nevada law in NRS 189.010-050 regarding the preparation of criminal
indigents transcripts on appeal.
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TRANSCRIPTS ON APPEAL/OTHERS CASSANDRA JACKSON Interim Court

Adminisu-ator J'USTJi'i ROPEI{ Chief Marshal - Depanmcnt of Alternative Sentenc
ing If you wish to order a transcript of your proceedings in the Reno Municipal
Court, you may do so by contacting Pam Longoni at (775) 530-5251. The following
information is provided to assist you in placing an order for a transcript: I. Orders
will require the date of the court appearance, type of proceeding, (trial, arraignment,
etc.), department number in which the proceeding was held, and also include the
appropriate deposit as indicated below. Payment may be made by check or money
order. No transcript will be prepared until the required deposit is received. ---~
7..,eost. Appeal transeripts are billed at $4.10 per page, which includes an original (to
be filed willi District Court), one copy for the appeilant, and one copy for the
opposing counsel. Transcripts ordered for purposes other than appeal, where only
one copy and original transcript is required, are billed at $3.00 per page. 3. Deposits.
Deposits required are as follows: $75.00 for arraignment/sentencing; a minimum
deposit of$200.00 for any trial transcript; and a minimum deposit of$500.00 for very
lengthy trials (those lasting more than three hours). NO TRANSCRIPT IS
CONSIDERED TO BE OFFICIALLY ORDERED, AND COMMENCEMENT OF
TRANSCRIPTION WILL NOT BEGIN, UNTIL RECEIPT OF THE REQUIRED
DEPOSIT. 4. Follow-up on Transcript Preparation. You will be notified when your
transcript has been prepared. If the actual cost of the transcript is less than the
amount of the deposit paid, a iefund will he issued with the transcript. And, likewise,
any outstanding balance due after completion of the transcript must be paid before
the Original is filed with District Court or any copies released. 0 refunds of deposits
will be given for transcripts once they have been prepared and no responsibility will
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be taken for the dismissal of any -appeal by District Court because no Original was
filed due to non payment of an out~ !and ing balance due. 5. Questions. Pam Longoni
will be happy to answer any qustions you may have"
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Panel Chair flat out refused to let a single piece of evidence be admitted that would in any way call
into legitimacy the convictions at issue in that Disciplinary Hearing. Supreme Court has obligation in
disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd.
3. State Bar of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39 2.
Indictment Where the only relevant factual allegation contained in Disciplinary Board's affidavit, filed in
support of its petition for attorney's temporary suspension from the practice of law, was that a criminal
indictment had been filed against the attorney, this sole allegation, without more, was insufficient to justify
summary suspension and the immediate imposition of temporary restrictions. Sup.Ct.Rules, Rules 102, subd.
4(a), 111, subd. 1. Matter of Monteiro, 1984, 684 P.2d 506, 100 Nev. 440. Attorney And Client 48 3. Serious
crime Attorney was not convicted of serious crime within meaning of rule regarding attorney suspension
where attorney did not engage in any criminal conduct whatsoever, did not engage in a conspiracy, and
actually entered plea of nolo contendere to nonexistent offense Sup.Ct.Rules, Rule 111, subd. 2. Sloan v.
State Bar of Nevada, 1986, 726 P.2d 330, 102 Nev. 436. Attorney And Client 39 4. Suspension of rule In
interest of justice, Supreme Court suspended court rule requiring it to order suspension of attorney upon
receipt of certificate of his conviction where attorney was impeached federal judge, who was arguably
beyond Supreme Court's jurisdiction, and attorney had voluntarily refrained from practice of law after his
release from incarceration, pending resolution of disciplinary proceeding. Sup.Ct.Rules, Rule 111. State Bar
of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39
Further, SBN Bar Counsel King lied continuously to Coughlin, every step along the way, in the
disciplinary matter. King's lies are too numerous to fully detail here, but, one was with regard to the
following, where King wrote to Coughlin about two grievances and an "Order" he had received: "The
grievances include supporting evidence in the form of: audio of your conduct in court proceedings. I am
enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order
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from District Court Please respond to allegations pertaining to your conduct. I will make available for your
review and inspection the supporting documents and audio recordings." King lied for months about this
purported offer to "make available for your review and inspection the supporting documents and audio
recordings". Simply put, Pat King is a cheap cheater. He cheats constantly in his role as Bar Counsel,
perverting and descreatign SCR 105(2)(c) at every turn, lying constantly to opposing counsel and
Respondent's (King told Coughlin that David Clark had given Coughlin permission to issue subpoenas for
the Disciplinary Hearing, suspended attorney or not, only to then file Ex Parte Motions to Quash the
Subpoenas based upon their not being issued by a licensed attorney...and Chair Echeverria grants King's Ex
Parte Motions the day they are filed...but admits to having not even bothered to read those filed by Coughlin.
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Clearly, stogie smokin' Boss Hog Echeverri had failed to review the multitude of materials Coughlin
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provided him. And clearly King had lied (and in fact, once caught doing so at the hearing, was reduced to
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back peddling furiously) to Coughlin (as did Peters) when they asserted that everything Coughlin filed with
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the SBN was copied and provided to all the Panel Members (whose addresses the SBN refused to provide to
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Coughlin, as did the SBN refuse to provide any set of rules of procedure that the Panel had adopted under
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SCR 105. King was caught at the Hearing upon cross examination by Coughlin, having to admit that he did
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not provide the CD/DVD's that Coughlin attached to his various filings. Panel Member Stephen Kent
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responded by announcing that he did not care that King lied about copying the Panel members on the
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cd/dvds attached as exhibits to Coughlin's filing and that, even if King had so attached those cd/dvds, Kent
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wouldn't have review them anywas. However, 1980 graduate of McGeorge School of Law Stephen Smiley
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Kent, Esq. (a perfect choice by King and Susich for the Panel given the apparent connection to Mike Smiley
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Rowe, Esq (whom Coughlin named in a grievance related to the fraudulent conduct by the SBN incident to
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his application for admission) and the act that, a McGeorge SOL 1980 graduate would necessarily have
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strong ties to Judge Howard (McGeorge '81), Keith Loomis (McGeorge '82, and for whom the grievance
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Coughlin filed against King disposed of with great quickness and shallow rationale), as well as Judge Nash
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Holmes, McGeorge '77, Judge Beesley, McGeorge '79, WLS's Paul Elcano, McGeorge '78, etc., etc.. Kent,
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besides glaring at Couglhin throughout the Disciplinary Hearing also attempted to take the spotlight off the
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lie that Coughlin had just caught Bar Counsel King and Clerk Peters in when the Panel members and King
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admitted that King and the SBN had failed to provide copies of the exhibits Coughlin attached to his filings,
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000308
despite the SBN having agreed to do so and represented to Coughlin that it would. Kent announced,
brazenly, that he didn't care if King copied him or the panel on the attachments to Coughlin's filings or that
King has indicated to the Panel that he was so copying the Panel on the entirety of Coughlin's filings, yet did
not point out that he actuall, was not, choosing to excise the dvd/cd attachments to those filings (and it does
not seem clear that King even did in fact have teh SBN copy the Panel member on all of Coughlin's filings,
particulary where Laura Peters had previously told Coughlin he could file by email or fax, and that the SBN
would never attempt to assert that the 8/23/12 certified mailing would be proof of or return of service. Once
the SBN makes a representation, SCR 109 goes out the window, and it is shameful that Pat King was fully
aware of that representation, and co-signed by his September 25th, 2012 attempts to get Coughlin to show
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up the the SBN for a hearing that was noticed and calendared to Coughlin and Susich for 9/25/12...only for
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King to refuse to hold the hearing, and instead seek to jam a bunch of other matters into a "combo-hearing"
12
including pending criminal charges in violation of Monteiro. Furhter Burleigh was violated in ever way due
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process wise, and the Panel outright flouted Nevada Law by refusing to recognize Claiborned. And so
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curious how the dismissal of this appeal is not signed by a Justice, and occurs just in time for the
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Disciplinary Hearing. (to go along with Michael Johnson apparently checking his twitter or facebook
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acount on his smartphone for most of the day....the only Panel members who displayed any professionalism
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at all were Clark Vellis, Esq. and laymember Karen Pearl, though it was entirely inappropriate for any of
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them to agree to sit for the hearing at all given the per se violations of SCR 105(2)(c), and thus, the total lack
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of jurisdiction to hold such a hearing. He is literally the cheapest, sleaziest attorney I have ever come across
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in my life...and I have dealt with Richard G. Hill, Esq. and Casey Baker, Esq. Pat King is literally more
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chicanerous than anyone I have every witnessed in my life. He has this Disciplinary Hearing thing sewn up
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to the point where he revels in SCR 106 immunity so much so that he brazenly lies at every turn, and
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encourages, and often forces "Clerk of Court/Investigator" Laura Peters to lie as well, which she does readily
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and often (telling Coughlin that she had the authority to and di so grant Coughlin the right to issue and have
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served subpoenas without paying witness fees, and further, that Respondent's never pay witness fees in these
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Disciplinary Hearings (good luck figuring out which rules apply, as clearly the NRCP do not, given Chair
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Echeverrias utter disregard for the NRCP and all of SCR 105(2)(c), typically done while Echeverria cackles
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and smiles menacingly at the Respondent, plays grab ass with his boyhood chum Elcano, and smokes a big
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000309
old stogie, Boss Hog style during the numerous "breaks" he insisted were a better use of the time for a
Hearing than affording Couglin an opportunity to, say, ask Judge Nash Holmes question about her
participation in the "clandestine status conference" on 2/27/12 wherein the Order for Competency Evaluation
was directed to Coughlin in rcr2012-065630 or the "strategy sessions" and "meetings" the RMC Judges and
court appointed defenders (like Loomis and City Attorney Hazlett-Stevens,Esq admit to having with Judge
William Gardner in the morning, secret to Coughlin prior to the 4/10/12 Trial date in the trespass matter
(which was set for Trial by Loomis and the RMC on 3/8/12 at a time when both tyhe RMC, Judge W.
Garnder, Loomis, and City Attorney Hazlett-Stevens knew full well that there was the 2/27/12 Order for
Competency Evaluation pending against Coughlin in RCR2012-065630 (and NRS 178.405 vis a vis NRS
10
5.010, in combination with Judge Nash Holmes accustation "on behalf of all RMC Judges" in her 3/14/12
11
greivannce against Coughlin (and Judge W. Gardner lied on the record during the April 10th, 2012 "Trial"
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and Motion Hearing in 11 CR 26405 when he alleged that none of Judge Nash Holmes Orders or her
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grievance letter the the SBN mentioned any "competency" issues related to Coughlin. Perhaps what is so
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distrubing is the extent to which these Judges lies are so easily disproven, indicating they have very little
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regard for the idea that this judicial system will ever take them to task for so doing. (and he refused to allow
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Coughlin more than and hour and a half to put on his case, most of which was, of course, wasted listening to
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Echeverria rule as irrelevant or inadmissible every single piece of evidence Coughlin sought to introduce,
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even a certified copy of the audio of the Trial n 11 TR 26800 that would prove that Judge Dorothy Nash
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Holmes lied and lied during her testimony. Not only did Coughlin have the audio cd that King finally gave
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to him
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SCR Rule 105. Procedure on receipt of complaint.
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2. Commencement of formal proceedings. Formal

disciplinary proceedings are commenced by bar counsel
filing a written complaint in the name of the state bar. The
complaint shall be sufficiently clear and specific to inform
the attorney of the charges against him or her and the
underlying conduct supporting the charges. A copy of the
complaint shall be served on the attorney and it shall direct
that a verified response or answer be served on bar counsel
within 20 days of service; the original shall be filed with
bar counsel's office. The time to respond may be
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extended once by the chair for not more than 20 days

for good cause or upon stipulation of the parties. In the
event the attorney fails to plead, the charges shall be
deemed admitted; provided, however, that an attorney who
fails to respond within the time provided may thereafter
obtain permission of the appropriate disciplinary board
chair to do so, if failure to file is attributable to mistake,
inadvertence, surprise, or excusable neglect.
(a) Challenges to and ad hoc appointments of panel
members. The complaint shall be served with the list of
members of the appropriate disciplinary board. The
attorney, or each if more than one, and bar counsel may
exercise five peremptory challenges each to the people on
the list by delivering such in writing to bar counsel on or
before the date a response to the complaint is due. "
(COUGHLIN HEREBY EXCERCISE HIS RIGHT TO
PEREMPTORILY REMOVE PANEL CHAIR
ECHEVERRIA AND McGeorge SOL Class of 1980
Stephen Smiley Kent (and anyone who went to McGeorge
for that matter, or even applied there) (whose classmates at
McGeorge include RMC Judge Kenneth Howard, who
denied Coughlin even one continuance in the first offense
petty larceny of a de minimis amount of food from a WalMart at a time when Coughlin was besieged with an
unlawful summary eviction from his former home law
office, and had an impermissible NRS 40.253(6) violating
"rent escrow" deposit of $2,275 required by the RJC just to
preserve Coughlin's right to litigate at the 10/25/12 "Trial"
Date (the RJC, noticed in writing the parties on the fact that
that was a "Trial" date in light of Judge Sferrazza's ruling at
the 10/13/11 summary eviction proceeding based upon a
No Cause Notice only (ie, non payment of rent was not
pled, making Hill and Baker's use of the summary eviction
process violative of nevada law against commercial tenant
Coughlin, particularly where Coughlin held the address out
to the public under SCR 79 as his law office, where filings
such as the one on 8/10/11 by Coughlin on behalf of then
client Robert Bell (in the matter that Judge Linda Gardner
recused herself from citing judicial cannon 2.11(a) (just
admitting a flat out bias against Coughlin) as the basis for
doing so) in fv11-02864 and the associated TPO
demonstrate via the 121 River Rock address in the caption
for then attorney Coughlin that the location was Coughlin's
law office, and that Coughlin was a commercial tenat, who
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000311
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possessed a law license at the time and where it is not clear

the "home office" exception to any requirement to have a
City or STate business license, particulary where Coughlin
was making less than $28,500 per year, attach in any way...
Coughlin objections to Panel Chair Echeverria's
participation go beyond the evident impartiality
demonstrated in all his various quick fire approvals of
King's Motions (including Motions to Quash Subpoenas
that fail to recongize the lies King and the SBN told
Coughlin with Respect to Chief Bar Counsel Clarks, Kings
and Clerk of Court Peters representations to and
agreements with Couglin vis a vis the application and
interpreation of SCR 110. "Subpoena power, production so
documents, witnesses, and pre-trial proceedings"...
Challenges to any member for cause under Rule 103(7)
shall be made as soon as possible after receiving either
actual or constructive notice of the grounds for
disqualification, and shall be made by motion to the chair
in accordance with these rules. In no event will a motion
seeking the disqualification of a member be timely if the
member has already heard, considered or
ruled upon any contested matter, except as to grounds
based on fraud or like illegal conduct of which the
challenging party had no notice until after the contested
matter was considered. Any challenge that is not raised in a
timely manner shall be deemed waived.
The chair may make ad hoc appointments to replace
designated panel members in the event challenges or
disqualification reduce the number to less than the number
required for the hearing panel. Ad hoc appointees shall be
subject to disqualification under Rule 103(7) and any
remaining peremptory challenges unexercised by either
the attorney(s) or bar counsel. A hearing panel as finally
constituted shall include a non-lawyer.
"(b) Assignment for hearing; venue. Following service of a
responsive pleading, or upon failure to plead, the
matter shall be assigned by the chair of the disciplinary
board to a hearing panel...."
There has not even been service of the complaint yet!!!!
Peters 10/9/12 Affidavit and Coughlin's various filings
and 11/19/12 Affidavit establish that conclusively.
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(c) Time to conduct hearing; notice of hearing;

discovery of evidence against attorney. The hearing
panel shall conduct a hearing within 45 days of
assignment and give the attorney at least 30 days'
written notice of its time and place. The notice shall be
served in the same manner as the complaint, and shall
inform the attorney that he or she is entitled to be
represented by counsel, to cross-examine witnesses, and
to present evidence. The notice shall be accompanied by
a summary prepared by bar counsel of the evidence
against the attorney, and the names of the witnesses bar
counsel intends to call for other than impeachment,
together with a brief statement of the facts to which
each will testify, all of which may be inspected up to 3
days prior to the hearing. Witnesses or evidence, other
than for impeachment, which became known to bar
counsel thereafter, and which bar counsel intends to use
at the hearing, shall be promptly disclosed to the
attorney. For good cause shown, the chair may allow
additional time, not to exceed 90 days, to conduct the
hearing.
(d) Quorum; time for decision of panel; votes required to
impose discipline. Any five members of the panel shall be a
quorum. The hearing panel shall render a written
decision within 30 days of the conclusion of the hearing,
unless post-hearing briefs are requested by either bar
counsel or the attorney and allowed by the panel or
requested by the chair, in which event the decision shall
be rendered within 60 days of the conclusion of the
hearing. The decision shall be served pursuant to Rule
109(1), accompanied by the panel's findings and
recommendation, all of which shall be filed with bar
counsel's office. A decision to impose or recommend
discipline requires the concurrence of four members of the
panel.
COUGHLIN REQUESTS A LEGITIMATE
OPPORTUNITY TO PUT A MORE APPROPRIATE
VERIFIED ANSWER OR RESPONSE ON FILE IN THIS
MATTER...FURTHER, COUGHLIN HEREBY
REQUEST AN OPPORUTNITY TO SUBMIT A POST
HEARING BRIEF...EVEN THOUGH THE HEARING
HE STILL REQUESTS BE STRIKEN OR VIEW MORE
AS A INTRODUCTORY MEETING...AND COUGHLIN
REMIND THE COMMITTEE THAT UPON THE
HEARING DATE OF 11/14/12 BEING RULE AS VOID
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FOR LACK OF DUE PROCESS, NOTICE, SERVICE,

PROCESS, JURISDICTION, ETC...THE PANEL WILL
SOON RUN UP AGAINST THE "WITHIN 45 DAYS OF
ASSIGNMENT" DICTATE
(e) Rules of evidence; support of panel's decision. The rules
applicable to the admission of evidence in the district
courts of Nevada govern admission of evidence before a
hearing panel.
Evidentiary rulings shall be made by the chair of the panel,
if one has been designated, or by the chair of the
appropriate disciplinary board prior to such a designation.
The findings of the panel must be supported by clear
and convincing evidence. And under SCR 104(3) and
SCR 103(7) Coughlin seeks to have SBN King removed
or conflicted out of this case for all the greivance
drumming up, for his impermissible communications
with Coughlin's then client's the Eastman's in early
may 2012, for feeding Judge Nash Holmes the "by clear
and convincing evidence" standard inserted into her
3/12/12 Order transmogrifying the trafficat case to a a
summary disciplinary hearing (and her testimony on
11/14/12, you could tell, was already anticipating the
jeers and offering mea culpas in that regard, or at least
caveats to spare...
(f) Court reporter. All formal hearings shall be reported by
a certified court reporter, which cost may be assessed
against the attorney pursuant to Rule 120. Any party
desiring to have any other disciplinary proceedings
reported must arrange in advance for a certified court
reporter at the party's own expense.
Zach Coughlin, J.D.
Patent Agent, USPTO
1471 E. 9th St.
Reno, NV 89512
Tele and Fax: 949-667-7402
November 17th, 2012,
RE: LITIGATION HOLD NOTICE REGARDING EVERY RECORDING,
DOCUMENT, DRAFT OF ANY SORT, OR PIECE OF DATA COLLECTED WITH
RESPECT TO THE ILLEGALLY HELD DISCIPLINARY HEARING OF 11/14/12 AT
THE STATE BAR OF NEVADA, AT WHICH CAROL HUMMEL WAS THE COURT
REPORTER OF RECORD AND FOR WHICH IT HAS BECOME KNOWN THAT PAT
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KING HAS A COPY OF THE RECORD OF THE PROCEEDING ALREADY AND

THEREFORE HAS BEEN GIVEN YET ANOTHER IMPERMISSIBLE ADVANTAGE
REQUIRING ANY RECORDINGS, ROUGH DRAFTS, WRITTEN TRANSCRIPTS,
OR AUDIO TRANSCRIPTS BE IMMEDIATELY TURNED OVER TO COUGHLIN
NOTICE OF CONFLICT BETWEEN ZACH COUGHLIN AND SUNSHINE
REPORTING SERVICES GIVEN SUNSHINE'S ADMISSION THAT PAM LONGONI
IS ON ITS STAFF AND MS. LONGONI'S DIRELECTION OF HER DUTIES IN 11 CR
22176, WHICH RESULTING IN A DISMISSAL OF COUGHLIN'S APPEAL IN CR112064 AND THE CURRENT TEMPORARY SUSPENSION OF COUGHLIN'S LICENSE
TO PRACTICE LAW IN 60838
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John Peter Echeverria, Esq., Panel Chair

Echeverria Law Office/Echeverria Group
9432 Double R Blvd.
Reno , NV 89521
Tel: 7757864800 Fax : 7757864808 JE@ELORENO.com
State Bar of Nevada, Office of Bar Cousnel
David Clark, Esq., Chief Bar Counsel
Las Vegas: 600 E. Charleston Blvd
Las Vegas, NV 89104 Phone: 702-382-2200 Fax: 702-385-2878
Patrick O. King, Assistant Bar Counsel
9456 Double R Blvd, Suite B
Reno, NV 89521 Tel: 775-329-4100 Fax: 775-329-0522

Dear Chair Echeverria, Panel Members, and SBN Office of Bar Counsel,
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Please provide to me immediately all materials (including the sound recording) of

the 11/14/12 Disciplinary Hearing that Pam Longoni coworker and Sunshine Reproting
Services employee, CCR Carol Hummel was the CCR on at the State Bar of Nevada from
approximately 8:30 am to approximately 6 pm. As you are aware, I have a conflict with
Pam Longoni that likely will entail substantial litigation, to whatever extent there is not
already litigation ongoing. Please review the attached materials for more explication in
that regard. However, while I am not purporting to give you legal advice, I believe it was
wrong for that firm to work the 11/14/12 Disciplinary Hearing. I am writing to request to
be given immediately, and absent any sort of payment or agreement whatsoever, all
materials recording, transcribed, reported, or otherwise collected in any way by Sunshine
Reporting Services and or Carol Hummel at that 11/14/12 Hearing and any other materials
connected thereto, including correspondence or agreements with the State Bar of Nevada,
the Northern Nevada Disciplinary Board, and the Panel (including Panel Chari John
Echeverria, Esq. and the Echeverria Group) in addition to the materials Pat King himself
has.
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DUE TO MR. KING'S AND LAURA PETERS THREATS OF ABUSE OF

PROCESS (INCLUDING CALLING THE POLICE FOR SPURIOUS REASONS OR
PURSUING A PROTECTION ORDER, I AM HEREBY SERVING THE SBN, KING,
PETERS, AND PANEL CHAIR ECHEVERRIA A STAY AWAY ORDER OF MY
OWN. ANY ENTREATIES ONTO MY PROPERTY, WHICH IS MARKED WITH A
LARGE "NO TRESPASSING" SIGN, MUST BE APPROVED IN ADVANCE AND
REQUIRE A PHONE CALL PRIOR THERETO AND EXPRESS APPROVALY BY
ZACH COUGHLIN AND ONLY ZACH COUGHLIN. FURTHER, COUGHLIN
HERERBY DEMANDS THAT ALL OF HIS FAX FILINGS BE FILESTAMPED AND
THAT A COMPLETE COPY OF THE RECORD AND DISCIPLINARY FILE BE
PROVIDED TO COUGHLIN, INCLUDING HIS OWN FILINGS, AND THAT THE
SBN COMPLY WITH THE STATES RULES AND POLICIES IT ARTICULATED TO
COUGHLIN ON ITS OWN BEHALF AND ON BEHALF OF THE PANEL AND
BOARD AND PANEL CHAIR, BY PROVIDING COMPLETE COPIES OF
EVERYTHING COUGHLIN HAS SUBMITTED (INCLUDING THE CD/DVDS
ATTACHED AS EXHIBITS) TO ALL PANEL MEMBERS.
I am indigent, severly so, and the State Bar of Nevada and Chair Echeverria, some
might say, are fraudulently attempting to take away my Fourteenth Amendment property
right, my law license, chiefly through their numerous violations of SCR 105(2)(c) and and
any other due process rules, law, or concepts they can desecrate. There simply was no
colorable basis for ruling that I was not permitted to record the proceedings...although,
neither the DCR nor NRCP appear to have any rules either prohibiting the recording of
Disciplinary Proceedings (made applicable via SCR 105(4), unless the Panel has enacted
some unpublished rules that it has so far refused to give me, as is the case with the SBN.
FURTHER, THE SBN AND NNDB PANEL AND ITS CHAIR, AND HIS LAW
OFFICE AND ECHEVERRIA GROUP ARE HEREBY PLACED ON A LITIGATION
HOLD NOTICE. PAT KING MAKES CUTE JOKES LIKE "WHAT'S A LITIGATION
HOLD NOTICE"...ITS SOMETHING THAT WILL SUBJECT YOU TO CONTEMPT,
PAT, NEVERMIND YOUR ILLUSIONS RESPECTING SCR 106 AND YOUR
"UNLIMITED IMMUNITY"...MR. KING, I AM HEREBY ONCE AGAIN PLACING
YOU ON NOTICE THAT LITIGATION IS LIKELY TO ARISE REQUIRING YOU TO
MAINTAIN AND TURN OVER AT SOME POINT THE MANILA ENVELOPE THAT
THE SBN PLACED INSUFFICIENT POSTAGE ON IN MAILING OUT ON 10/9/12
(OR AT LEAST PRINTING THE RED PITNEY BOWES POSTAGE THEREON ON
THAT DATE...AND PLEASE REALIZE, THE SBN DID NOT SEND THAT NOITD
BY FIRST CLASS MAIL IN ADDITION TO A CERTIFIED MAILING...PROBABLY
SOME TACTICAL DECISION BY KING TO GAIN AN ADVANTAGE, CHECK THE
CERTIFICATE OF MAILING...THE LITIGATION HOLD NOTICE EXTENDS TO
ALL CALL RECORDS BETWEEN THE SBN IN ANY WAY WITH CHAIR
ECHEVERRIA OR OTHER MEMBERS OF THE PANEL, INCLUDING ACTIVITIES
INVOLVING LAURA PETERS. CHAIR ECHEVERRIA'S STAFF LEFT COUGHLIN
A PHONE CALL IN RESPONSE TO HIS INQUIRY REGARDING A MUNDANE,
NON-SUBSTANTIVE MATTER (DEENA, NOT TERESA, AND YOU WILL WANT
TO REVIEW NRS 199.340(7) REGARDING SOME RECENT DEVELOPMENTS),
AND DEENE COMMUNICATE IN NO UNCERTAIN TERMS THE CHAIR WOULD
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NOT SPEAK TO COUGHLIN, EVEN THOUGH HE IS PROCEEDING WITH SELF

REPRESENTATION AND IT IS MORE THAN COMMON FOR RESPONDENT'S
COUNSEL TO REGULARLY COMMUNICATE WITH THE CHAIR. I HAVE READ
ALL THE DECISIONS AND GRABBED THE RECORDS ON APPEAL. PLEASE
IMMEDIATELY PROVIDE ME A COPY OF ANY PROCEDURAL RULES THE
BOARD HAS ADOPTED INCIDENT TO SCR 105 AND EXPLAING WHY THE
10/9/12 AFFIDAVIT OF LAURA PETERS IS FILE STAMPED, YET WAS NEVER
SENT TO COUGHLIN. PLEASE FURTHER EXPLAIN WHY THE "DISCIPLINARY
FILE" HAS BEEN DOCTORED TO EXCLUDE THE GREEN CERTIFIED MAIL
TAGS FOR THE COMPLAINT (WHICH USPS TRACK & CONFIRM REVEALS WAS
NEVER SIGNED FOR BY COUGHLIN, AND IN FACT, JUST AS CLERK PETERS
ADMITTED ON SEPTEMBER 11TH, 2012 AT 4:55 PM, WAS RETURNED TO SEND
AND SIGNED FOR BY THE SBN ON 9/10/11. PLEASE HAVE CLERK PETERS
FILL OUT A NON FRAUDULENT RETURN OF SERVICE OR PROOF OF SERVICE
OF THE COMPLAINT REFLECTING HER DECLARATION OF SBN AND PANEL
RULES AND POLICY TO THE EFFECT THAT THE 8/23/12 CERTIFIED MAILING
WOULD NEVER BE PUT FORTH AS PROOF OF SERVICE OF THE
COMPLAINT....WHICH LEAVES THE SBN AND PANEL TO EXPLAIN WHY KING
UNILATERALLY ALTERED THE DECLARATIONS MADE BY PETERS TO
COUGHLIN RESPECTING THE PROCEDURAL POLICIES AND ADOPTED RULES
AND PRACTICES OF THE BOARD, SBN, AND PANEL IN THESE DISCIPLINARY
PROCEEDINGS, INCLUDING HER ATTESTATION THAT SHE HAD AUTHORITY
TO REPRESENT TO COUGHLIN THAT NO TIME DEADLINES WOULD RUN FOR
ANY EVENT WHOSE SERVICE REQUIRED COMPLIANCE WITH SCR 109
(MEANING ALL MATTERS MENTIONED IN SCR 105(2)(C), MEANING THE
NOTICE OF THE HEARING WAS DEFICIENT, GIVEN COUGHLIN'S SIGNATURE
INDICATES A DATE OF 10/27/12, IE, FAR LESS THAN THE "AT LEAST 30 DAYS"
BEFORE THE HEARING MAY TAKE PLACE (17 DAYS IS NOT EVEN CLOSE),
AND THE Designation of Witnesses and Summary of Evidence is not listed in the
certificate of mailing, nor is it file stamped upon a review of the bate stamped filed box
that somehow took 7 days to copy (because Pat King needed to go back through it and
remove the certified mailing slips for which the SBN had not secured a signature from
Coughlin, including the NOITD (because the SBN placed insufficient postage thereon, and
Tim, counter attendant at the Downtown Reno Station would not release that 10/9/11
NOITD unless Coughlin paid the SBN's postage, which he clearly is not required to
do...Further, the Supplemental DoWSoE was not served in accord with SCR 109
considering the policies, rules, and practices the SBN, NNDB, and Panel held out to
Coughlin and upon which he justifiably relied. Basically, the entire hearing must be
thrown out, mistrial, recusal of Echeverria and Kent, and King is conflicted out too.
My issues with Ms. Longoni related primarily to her hanging up on me on more
than one occasion in December 2011 when I was attempting to comply with the dictates
she and the Reno Municipal Court put forth to criminal appellant's, including ones like me
who were indigent at that time.
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I need the materials I am requesting above immediately, TIME IS OF THE

ESSENCE with respect to a number of actions I must take to preserve my rights, and even
the roughest draft of the transcript and the audio recordings made that day are completely
vital to my protecting my rights. I believe you would be substantially mitigating your
potential liability by having these emailed to me immediately, though you should consider
getting counsel from your own attorney in that regard.
Further, I believe your firm and or Ms. Longoni may still be required to prepare
and provide to me the transcript for 11 CR 22176, (I am providing you via a cd/dvd in the
mail and a link to a SkyDrive contaning the audio therefor) as well as the transcript for 11
TR 26800 (a notice of appeal was filed on 3/7/12 and again sometime thereafter, and
during that time the RCM continued its illegal practice of holding Ms. Longoni out as the
only court reporter it would release the audio recordings to (certified or not), and further,
as demonstrated by the attached handout given to all criminal defendant appellants by the
RMC, Ms. Longoni and the RMC maintained a practice that was violative of NRS
189.030:
NRS 189.030 Transmission of transcript, other papers, sound
recording and copy of docket to district court.
1. The justice shall, within 10 days after the notice of
appeal is filed, transmit to the clerk of the district court the
transcript of the case, all other papers relating to the case and
a certified copy of the docket.
2. The justice shall give notice to the appellant or the
appellant's attorney that the transcript and all other papers
relating to the case have been filed with the clerk of the district
court.
3. If the district judge so requests, before or after receiving the
record, the justice of the peace shall transmit to the district
judge the sound recording of the case.
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I am prepared to move forward with respect to pursuing whatever lawful action I

may take in connection with this impermissible conflict of interest (which I believe I can
prove you knew full well about) in addition to the misconduct by Ms. Longoni in
connection with RMC 11 CR 22176. Nice touch having Judge Linda Gardner's courtroom
deputy work the hearing.
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Coughlin hereby demands that the SBN comply with the agreement and rules
requiring the SBN reveal the names of the Screening Panel members from the hearing on
or about 4/10/12. Pat doesn't get around to saying he meant the "Clerk of Court" of a
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Department in the RMC, even though the Order is from D14 of the Second Judicial
District Court (whose courtroom deputy worked the 11/14/12 Disciplinary Hearing along
with one of Pam Longoni's co-workers...Carol Hummel (no offense to Ms. Hummel...I
blame Pat King and or Susich here, as King is now backing out of an agreement to
indicate who was on the Screening Panel and the Panel for the Hearing was obviously
hand picked to arrive at the most biased crowd available or possible.
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3. Review by supreme court.

(a) Time and manner of appeal. A decision of a hearing
panel shall be served on the attorney, and service shall be
deemed Notice of Entry of Decision for appeal purposes.
Except as provided in Rule 105(3)(b) a decision is final and
effective 30 days from service, unless an appeal, is taken
within that time. To the extent not inconsistent with these
rules, an appeal from a decision of a hearing panel shall be
treated as would an appeal from a civil judgment of a
district court and is governed by the Nevada Rules of
Appellate Procedure.
(b) De novo review of public discipline. Except for
disbarments by consent pursuant to Rule 112 or a public
reprimand agreed to in writing by the attorney pursuant to
Rule 113, a decision recommending a public reprimand,
suspension or disbarment shall be automatically reviewed
by the supreme court. Review under this paragraph shall be
commenced by bar counsel forwarding the record of the
hearing panel proceedings to the court within 30 days of
entry of the decision. Receipt of the record in such cases
shall be acknowledged in writing by the clerk of the
supreme court.
The attorney and bar counsel shall have 30 days from the
date the supreme court acknowledges receipt of the record
within which to file an opening brief or otherwise advise
the court of any intent to contest the hearing panel's
findings and recommendations. If an opening brief is filed,
briefing shall thereafter proceed in accordance with NRAP
31(a). Extensions of time to file briefs are disfavored and
will only be granted upon a showing of good cause. The
parties shall not be required to prepare an appendix, but
rather shall cite to the record of the disciplinary
proceedings. If no opening brief is filed, the matter will be
submitted for decision on the record without briefing or
oral argument.
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000319
4. Rules of procedure. The chairs, after consulting with

their respective disciplinary boards, may adopt rules of
procedure, subject to approval by the board of governors.
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1. In general
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Violations of professional conduct rules not charged in attorney disciplinary complaint

could not be considered by Supreme Court. In re Discipline of Schaefer, 2001, 25 P.3d
191, 117 Nev. 496, modified on denial of rehearing 31 P.3d 365, certiorari denied 122
S.Ct. 1072, 534
U.S. 1131, 151 L.Ed.2d 974. Attorney And Client 52 SO COUGHLIN OBJECTS TO
KING AND ECHEVERRIA'S ATTEMPTS TO TURN THE 11/14/12 HEARING IN
TO SOME SUMMARY DISCIPLINARY PROCEEDIGN FOR DECLARATION
MAKING IN THEIR PRESENCE, WHETHER LEVERAGING PAST FILINGS
REBRANDED OR NOT...
2. Due process
Procedure in which Board of Governors, the body responsible for finances of bar
association, functioned as factfinder in disciplinary proceeding against attorneys,
involving costs which were substantial and which were recoverable by state bar only
upon finding of misconduct, violated due process. Sup.Ct.Rules, Rules 85, 85, subd. 2,
86, subds. (1-4, 7, 12), 104, subd. 7 (1978); U.S.C.A. Const.Amend. 14. Matter of Ross,
1983, 656 P.2d 832, 99 Nev. 1, rehearing denied 668 P.2d 1089, 99 Nev. 657. Attorney
And Client 54; Constitutional Law 4273(3)
Individual members of disciplinary board had no personal financial stake in outcome of
their deliberations and no executive responsibilities for finances of state bar which
would be inconsistent with due process requirements for disciplinary proceedings,
despite potential for recovery by bar of fines and costs. Sup.Ct.Rules, Rules 86, 103,
subds. 1, 3; U.S.C.A.Const.Amend.
14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d 1201, 98 Nev. 140. Constitutional
Law 4273(3)
State cannot exclude person from practice of law without due process of law.
U.S.C.A.Const.Amend. 14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d 1201, 98
Nev.
140. Constitutional Law 4273(1)
Practice of a profession is valuable property right, of which one cannot be arbitrarily
deprived. U.S.C.A.Const.Amend. 14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d
1201, 98 Nev.
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4. Degree of proof
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Ethical violations by attorney must be proven by clear and convincing evidence. In re

Discipline of Schaefer, 2001, 25 P.3d 191, 117 Nev. 496, modified on denial of
rehearing 31 P.3d 365, certiorari denied 122 S.Ct. 1072, 534 U.S. 1131, 151 L.Ed.2d
974. Attorney And Client 53(2)
In bar disciplinary matters, higher degree of proof is required than in ordinary civil
proceedings; clear and convincing evidence must support any findings of misconduct.
Sup.Ct.Rules, Rule 105, subd. 2(e). In re Discipline of Drakulich, 1995, 908 P.2d 709,
111 Nev. 1556. Attorney And Client 53(2)
In determining questions of fact, higher degree of proof is required in disciplinary
matters han in ordinary civil proceedings; standard is whether findings are supported by
clear and convincing evidence. Sup.Ct.Rules, Rule 105, subd. 2(e). In re Discipline of
Stuhff, 1992, 837 P.2d 853, 108 Nev. 629. Attorney And Client 53(2)
To determine questions of fact, higher degree of proof is required in attorney
disciplinary matters, than in ordinary civil matters; standard is whether findings are
supported by clear and convincing evidence. Sup.Ct.Rules, Rule 105, subd. 2(e). Gentile
v. State Bar of Nevada, 1990, 787 P.2d 386, 106 Nev. 60, certiorari granted 111 S.Ct.
669, 498 U.S. 1023, 112 L.Ed.2d 662, reversed 111 S.Ct. 2720, 501 U.S. 1030, 115
L.Ed.2d 888. Attorney And Client 53(2)
5. Recommendation of board
Although recommendations of disciplinary panel are persuasive, Supreme Court is not
bound by panel's findings and recommendation, and must examine record anew and
exercise independent judgment, in attorney disciplinary proceeding. In re Discipline of
Schaefer, 2001, 25 P.3d 191, 117 Nev. 496, modified on denial of rehearing 31 P.3d
365, certiorari denied 122 S.Ct. 1072, 534 U.S. 1131, 151 L.Ed.2d 974. Attorney And
Client 57
Disciplinary board's recommendation is not final and binding upon Supreme Court, even
though attorney has consented in writing to Board's decision. Sup.Ct.Rules, Rule 105,
subd. 3(b). Matter of Kenick, 1984, 680 P.2d 972, 100 Nev. 273. Attorney And Client 57
6. Continuances
Attorney was not entitled to continuance of second hearing date in attorney disciplinary
proceedings to obtain counsel, on basis that second hearing was reset for January 4, not
later in the month, and attorney not able to find new counsel because no one wanted to
work on his case over the holidays, where attorney stated on the record that he needed no
more than one week's notice of the continued hearing, and was aware from November 17
that he needed to find counsel immediately, attorney was notified no later than
December 6 of new hearing date, and even from December 6, attorney had four weeks to
obtain new counsel and to prepare for the continued hearing. In re Discipline of
Client 54
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000321
ASSUMING THERE HAS BEEN SERVICE OF THE COMPLAINT,

WHICH HAS NOT BEEN SHOW, COUGHLIN REQUEST HIS FIRST
CONTINUANCE...
Sup. Ct. Rules, RULE 105, NV ST S CT RULE 105
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NRCP RULE 12. DEFENSES AND OBJECTIONS

WHEN AND HOW PRESENTEDBY PLEADING OR
MOTIONMOTION FOR JUDGMENT ON
PLEADINGS
(a) When Presented.
(1) A defendant shall serve an answer within 20 days after
being served with the summons and complaint, unless
otherwise provided by statute when service of process is
made pursuant to Rule 4(e)(3).
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Coughlin was never served with the Summons and

Complaints under SCR 109, and Bar Counsel cited no
authority to support its apparent contention that merely
mailing a certified mailing purporting to included the
Complaint is sufficient, especially where, as here, Bar
Counsel and the SBN made representations Coughlin was
permitted to reply upon to the effec that the 8/23/12
certified mailing Bar Counsel asserts would never be
offered as proof of or return of service.
(2) A party served with a pleading stating a cross-claim
against that party shall serve an answer thereto within 20
days after being served. The plaintiff shall serve a reply to
a counterclaim in the answer within 20 days after service of
the answer or, if a reply is ordered by the court, within 20
days after service of the order, unless the order otherwise
directs.
(3) The State of Nevada or any political subdivision
thereof, and any officer, employee, board or commission
member of the State of Nevada or political subdivision, and
any state legislator shall file an answer or other responsive
pleading within 45 days after their respective dates of
service.
(4) The service of a motion permitted under this rule alters
these periods of time as follows, unless a different time is
fixed by order of the court:
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(A) if the court denies the motion or postpones its

disposition until the trial on the merits, a responsive
pleading shall be served within 10 days after notice of
the courts action;
Chair Echeverria's Order purporting to require
Couglin file averified Response in less time than allotted
upon any purported ruling on Coughlin's Motion to
Dismiss, makes holding the Hearing on 11/14/12 and
and Order connected thereto void (even whether Bar
Counsel has perpetrated a fraud in standing behind a
certificate of mailing that is knows is not true as to the
October 9th, 2012 certified mailing only (in contrast to
practically everything else the SBN mailed, according to
its certificate's of mailing, the SBN sent the 10 9 12
Notice of Intent to Take Default by certified mial only,
ie, it was not sent via first class mail as well).
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(B) if the court grants a motion for a more definite

statement, a responsive pleading shall be served within 10
days after service of the more definite statement.
(b) How Presented. Every defense, in law or fact, to a
claim for relief in any pleading, whether a claim,
counterclaim, cross-claim, or third-party claim, shall be
asserted in the responsive pleading thereto if one is
required, except that the following defenses may at the
option of the pleader be made by motion: (1) lack of
jurisdiction over the subject matter, (2) lack of
jurisdiction over the person, (3) insufficiency of process,
(4) insufficiency of service of process, (5) failure to state
a claim upon which relief can be granted, (6) failure to
join a party under Rule 19. A motion making any of these
defenses shall be made before pleading if a further pleading
is permitted. No defense or objection is waived by being
joined with one or more other defenses or objections in a
responsive pleading or motion. If a pleading sets forth a
claim for relief to which the adverse party is not required to
serve a responsive pleading, the adverse party may assert at
the trial any defense in law or fact to that claim for relief.
If, on a motion asserting the defense numbered (5) to
dismiss for failure of the pleading to state a claim upon
which relief can be granted, matters outside the pleading
are presented to and not excluded by the court, the motion
shall be treated as one for summary judgment and disposed
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of as provided in Rule 56, and all parties shall be given

reasonable opportunity to present all material made
pertinent to such a motion by Rule 56.
Couglin presented all the above bolded defense and

Chair Echeverria did not dispose of all such Motions made
by Coughlin.
...
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(d) Preliminary Hearings. The defenses specifically

enumerated (1)-(6) in subdivision (b) of this rule, whether
made in a pleading or by motion, and the motion for
judgment mentioned in subdivision (c) of this rule shall be
heard and determined before trial on application of any
party, unless the court orders that the hearing and
determination thereof be deferred until the trial.
(e) Motion for More Definite Statement. If a pleading to
which a responsive pleading is permitted is so vague or
ambiguous that a party cannot reasonably be required
to frame a responsive pleading, the party may move for
a more definite statement before interposing a
responsive pleading. The motion shall point out the
defects complained of and the details desired. If the motion
is granted and the order of the court is not obeyed within 10
days after notice of the order or within such other time as
the court may fix, the court may strike the pleading to
which the motion was directed or make such order as it
deems just.
(f) Motion to Strike. Upon motion made by a party before
responding to a pleading or, if no responsive pleading is
permitted by these rules, upon motion made by a party
within 20 days after the service of the pleading upon the
party or upon the courts own initiative at any time, the
court may order stricken from any pleading any insufficient
defense or any redundant, immaterial, impertinent, or
scandalous matter.
(g) Consolidation of Defenses in Motion. A party who
makes a motion under this rule may join with it any other
motions herein provided for and then available to the party.
If a party makes a motion under this rule but omits
therefrom any defense or objection then available to the
party which this rule permits to be raised by motion, the
party shall not thereafter make a motion based on the
defense or objection so omitted, except a motion as
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provided in subdivision (h)(2) hereof on any of the grounds

there stated.
(h) Waiver or Preservation of Certain Defenses.
(1) A defense of lack of jurisdiction over the person,

insufficiency of process, or insufficiency of service of
process is waived (A) if omitted from a motion in the
circumstances described in subdivision (g), or (B) if it is
neither made by motion under this rule nor included in a
responsive pleading or an amendment thereof permitted by
Rule 15(a) to be made as a matter of course.
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(2) A defense of failure to state a claim upon which relief

can be granted, a defense of failure to join a party
indispensable under Rule 19, and an objection of failure to
state a legal defense to a claim may be made in any
pleading permitted or ordered under Rule 7(a), or by
motion for judgment on the pleadings, or at the trial on the
merits.
(3) Whenever it appears by suggestion of the parties or
otherwise that the court lacks jurisdiction of the subject
matter, the court shall dismiss the action.
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Also available at that link is the transcript from the criminal trespass Trial on 6/18/12
where HIll and Baker testify, before Judge L. Gardner's (whom recused herself from a
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case Coughlin represented Robert Bell in, filed August 11, 2011, which further proves that
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Coughlin was a commercial tenant practicing law at the 121 River Rock address,
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something pled in Coughlin's Tenant's Affidavit and set forth repeatedly ad nausuem
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throughout the trial court case, which Hill mistakenly alleges, in his lie filled testimony at
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the criminal trespass trial, that Coughlin "did not plead" that he was a "commercial tenant"
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in the trial court eviction case. Wrong, Mr. Hill. The record is quite clear that Coughlin
did. And Judge L. Gardner's recusal (and Judge Flanagan's Presidency of the SBN during
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000325
a period of time in which Coughlin now has pending grievances against members of the
Character and Fitness Committe further complicates matters and augured for a recusal,
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beyond the apparent bad mouthing of Coughlin by Judge Flanagan and Coughlin's former
firm, where they were both a part of at the same time in 2005, to the CBX (unless the CBX
is lying or bluffing, which is entirely possible, as anyone who has ever met a bar counsel
could tell you) is just another reason why recusal was appropriate. Additionally, the
lockout pursuant to the eviction Order, whether the Eviction Decision and ORder of
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October 25th, 2011 or the Findings of Fact, Conclusions of Lw....of 10/27/11 (depending
on how one view NRS 40.253's "within 24 hours" dictate) was either performed to early or
too later, and therefore the Order was stale or
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void at time WCSO Machen and Baker conduted the lockout. (too early under the analysis
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respecting the application, via nrs 40.400 of NRCP 5 and NRCP 6 requiring 3 days for
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mailing for "constructive service" of such and Order, and beyond that the Second Judicial
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District Court appears to have refused for filing from Couglin a filing that may have
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operated as a MOtion to STay under NRAP 8 sometime between October 26th, 2011 and
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November 2nd 2011 in CV11-03051 or CV11-03126, in violation of Whitman, Sullivan,
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Donoho and NRCP 5(e)'s dictate against clerk's rejecting filings regardles of what a local
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rule says) or the lockout was conduct too late in light of the testimony by Baker
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concerning how and when the wCSO received the lockout order or either of the eviction
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orders (Baker indicated his office relied upon the usual practice of the RJC to transmit it to
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the wCSO, but curiously the RJC seems to now assert is has no record of such a
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transmission, and the WCSO is lawyering up when it comes to such information.
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Herman v. Style Line Greetings, Inc., 289 So.2d 876
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000326
La.App.4.Cir.,1974Where eviction proceeding was taken under advisement and judgment
of eviction was rendered on following day and out of presence of counsel, statute
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providing that if court finds

lessor or owner entitled to relief sought, court shall render immediately a judgment of
eviction
ordering delivery of possession of premises to lessor or owner had not been complied with
and judgment was invalid. LSA-C.C.P. art. 4732.
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Richard G. Hill, Esq. and Casey Baker, Esq. (who has now conveniently absconded back to
Kentucky now that his lies have imperiled Coughlin's law license (see Coughlin's recent filing in 61901 and
60838 for more explication thereof) failed to comply with Nevada law respecting the return of Coughlin's
security/damage/cleaning deposit ($500 for security/damage, $200 for "cleaning" deposit, with the Standard
Rental Agreement giving Coughlin certain options thereto). Coughlin is indigent (largely due to the fraud of
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Baker, Hill, and their client, Dr. Matt Merliss, MD) and asks this Court to recognize that the failure of the
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landlord to comply with Nevada law vis a vis the itemization or return within 30 days of the deposits should
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fulfill any $500 bond on appeal, and then some. Further, the Reno Justice Court is still refusing to return the
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$250 Coughlin deposited with it in compliance with NRS 118A.380 and 118A.385 (further, it is not clear
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how NJCRCP 72 or 73 could apply to summary eviction (even ones like this one that were notice, in writing,
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by the RJC, as a "Trial" after Judge Sferrazza had ruled that Coughlin had met his NRS 40.253 burden to
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prove there was a "genuine issue of material fact", both at and following the 10/13/11 "summary eviction
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proceeding" and during the first part, at least, of the "Trial" which curiously transmogrified into, apparently,
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something other than a Trial when Baker managed to point out, the consequences thereof. Regardless,
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Coughlin filed a Notice of Appeal on October 18th, 2011 (and see also the appeal and associated general
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civil Complaint in the District Court). Also, court clerk's Michelle Purdee and or Lori Matheus seemed to
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refuse to file in a document from Coughlin sometime between October 17th to November 1st, 2011 that may
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have arguably operated as a NRAP 8 Motion to Stay, in violation of the dictates in Nevada law against court
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clerk's unilaterally refusing to file things, like in Whitman, Sullivan, Dohono, Barnes, and their progeny.
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Further,
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Now the SBN intends to hold a hearing on November 14th, 2012 pursuant to its SCR 105
Complaint against Coughlin wherein all subpoena by Coughlin are sought quashed, even where the SBN
states that Judge Dorothy Nash Holmes will appear by phone to answer question (but apparently not testify,
and she hasn't recused herself from the two matters she has Coughlin as a criminal defendant before her in)
(Coughlin totally objects ot Judge Nash Holmes phoning it in, especially where her 3/14/12 grievance to the
SBN in ng12-0434 and the possible ghost-grievancing done in ng12-0435 (in concert with RMC jUdge W.
Gardner and his sister WDC Family Court Judge LInda Gardner and SBN's Pat King and Laura Peters in
attempts to allow RMC W. Gardner to avoid recusing himself from the richard hill signed criminal trespass
complaint in 11 cr 26405...It may be necessary to check up on rmc judge w. gardner's 2/27/12 order
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transferring jurisdiction of the richard hill incuced january 12th, 2012 custodial arrest of coughlin for
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jaywalking in RMC 12 cr 00696 (and consider all the copying and or erasing of Coughlin's laptops,
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smartphones, and data cards incident to all this arrests under State v. Diaz, including the in court arrest on 11
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30 11 with rmc judge howard in RMC 11 cr 22176 (which resulted in this Court's 6/7/12 temporary
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suspension of Coughlin's law license) (summary contempt for saying "wow"...and the 2/27/12 arrest by reno
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marshals (marshal harley lied during the SITA and issued directive to another marshal to go repeat his lie to
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Judge Nash Holmes....finding a smartphone during a SITA does not entitle Harley to bark out "got tell judge
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nash holmes Coughlin lied! He was recording!....or for judge Nash Holmes to later, in the tape from the
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3/12/12 hearing in 11 tr 26800 to indicate some marshall told her he saw Couglin dissessmbling a smart
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phone in the bathroom stall (this would have been before Judge Nash Holmes even asked Coughlin any
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questions regarding recording or recording devices...whatever she means by "recording device" (wouldn't
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every laptop brought with any defendant or lawyer be a "recording device" under Judge Holme's apparent
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analysis?) to testify with regard to Respondent's conduct in connection with Case No. 11-TR-26800 12 in
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Reno Municipal Court.
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Incident to Judge Nash Holmes "summary criminal

contempt" Order against Coughlin within the traffic
citations issued to Coughlin outside Richard Hill's law
office after Coughlin showed up to get his Marshal harley
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violating the courthouse sanctuary rule, on behalf of wcso
deputy machen, whom hill sent to the 2/27/12 trial
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regarding the richard hill traffic citations of 11/15/11 to

serve coughlin the ORder to show cause for the 3/23/12
Hearing in the richard hill eviction appeal in cv11-03628,
based upon a fraudulent motion to show cause and
declaration filed by Hill, his associate Casey Baker, and
Hill's trusy licensed contractor, NBI's Phil Stewart
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to having been informed by the Washoe County Public Defender's Office of the Order for
Comptency Evaluation directed to Cogulin in RCR2012-065630 (the retaliatory "misuse of 911" custodial
arrest and prosecution incident to an arrest made by the same RPD Sargent Sifre, on 1/14/12, who ordered
Couglin arrested by then trainee Officer Wesley Leedy (whom applied excessive force to Coughlin, out of
the blue and prior to any sort of warning, along with another dishonorable and shameful RPD Officer Travis
Look, all captured on video tape as well (though Panel Chair ruled all of that inadmissible as well...though
that pending jaywalking prosecution was not ruled irrelevant or dismissed form King's Complaint.
Somehow, Chair Echeverria accepted Kings argument that video taping of events did not provide reliable
evidence of what happened...rather, having Richard Hill and the McGeorge Mafia come in an wrech shop on
a career of Coughlin's that was many years in the making (and all in Nevada mine you, from kingdergarten
through law school) (in February 2009 Elcano had admitted to Coughlin that he asked several judges,
including Master Edmonson and Judge Linda Gardner what they thought of Coughlin's work before them
and that both of those judges gave Coughlin a positive review....and at that time Elcano also stated that "and
Judge Linda Gardner owes me because I did a big, big favor for her a long time ago...so if she say's your all
right, then...". Elcano has also finally managed to get WLS's fingers in the pie that is the ECR program that
is partners with the Washoe County District Attorney's Office with in denying indigent criminal defendants
their Sixth Amendment Rights (an RMC Court appointed defender, Lew Taitel, was originally Coughlin's
appointed counsel in the Donnie and Marie conflict yet no recusal criminal trespass complaint signed by
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Richard Hill (whom also got Coughlin subject to a custodial arrest for "jaywalking" on January 12th, 2012,
incident to Hill lying to RPD Officers that Coughlin "has lost his appeal" (though the appeal was not decided
until 3/30/12...Further, Hill filed a Declaration on 1/20/12 in that appeal CV11-03628 which clearly contains
numerous lies when reviewing the video tape of that incident....and 61901 further provides video evidence of
the extent to which Richard G. Hill, Esq. is allowed to terrorize the citizenry of Washoe County with his lies
and Rambo litigation tactis, all with more than a little enabling by a cadre of local judges) and the court
appointed defender for Couglin (Keith Loomis, Esq., McGeorge SOL, Class of 1982) who has managed to
collect a paycheck while twice refusing to advocate on Coughlin's behalf (garnering two Orders granting his
withdrawal by RMC Judges, one, in the criminal trespass cases (61901) that Judge William Gardner refused
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to recuse himself on, stemming from Richard G. Hill, Esq. lying to and with the police in 11 CR 26405, even
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where Judge Gardner then had a pending grievance against Coughlin (NG12-0435, wherein Judge Nash
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Holmes filed one on "behalf of all the RMC Judges, from whom you will have our full cooperation" and
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assitance in carrying out a scheme to discredit and destroy Coughlin that they "planned out" "very carefully"
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(Judge Nash Holmes lied during Coughlin's 11/14/12 Disciplinary Hearing when she testified under oath that
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she had (because of some unattributed hearsay that Panel Chair Echeverria would not let Coughlin ask
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follow up questions on) "heard Coughlin likes to record things" and that upon her questioning about whether
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he was recording the proceedings and or had a recording device Coughlin during that traffic ticket trial,
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Holmes testified that Coughlin immediately grew very shitfy and uncomfortable and asked to be allowed to
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use the restroom, whereupon Holmes ordered RMC Marshal Joel Harley to follow Coughlin into the
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bathroom, whereupon Judge Nash Holmes testified that Marshal Harley witnessed Couglin disassembling a
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recording device in the bathroom and leaving a portion of it in the bathroom, which the RMC Marshal
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discovered later). One, that is a god damn lie. Coughlin did not disassemble anything in the bathroom.
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Two, Judge Nash Holmes lied under oath when she testified that she asked Coughlin any questions
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whatsoever about recording devices or recording the proceedings prior to the ONE restroom break that Judge
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Nash Holmes allowed before she had Coughlin arrested for the "misdemeanor of criminal contempt...NRS
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22.010" . Judge Nash Holmes lied during her sworn testimony in saying that the one restroom break came
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AFTER she interrogated Coughlin about whether he had an recording devices or was recording . The
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certified audio of the Trial clearly reveals there was one, and only one restroom break and that, clearly,
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Judge Nash Holmes asked Coughlin questions related to recording or having recording devices only AFTER
that one restroom break. Judge Nash Holmes clearly lied during her testimony in that regard, seeking to
rewrite the orders of events in an attempt to suggest that she interrogated Coughlin (sua sponte, of course, as
is her wont, wherein she mixes in her experiences as a prison warden type with her lifelong devotion to
being a prosecutor, wiretapping attorneys, etc., etc....ask Henry Sotelo, Esq., the RMC defender that says he
left the law for awhile completely given what a terrible taste was left in his mouth after working under her
while she was the Washoe County District Attorney in 1993-1996 or so...or ask the Washoe County Deputy
whom Coughlin overhead, during one of his several trips to the Courthouse (it wasn't Cummings, and it
wasn't the Hawaiian one, but it was the other one) reveal the extent to which he felt Judge Nash Holmes was
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completely out of her mind and inordinately punitive, sentencing a youth whom she had the week previous
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"put in some hug a thug program" to six months in jail following his reappearring before her one week later
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after having bee arrested for "jaywalking". (As to her 2/28/12 and 3/12/12 Orders speaking to the
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"contempt conviction" actually, Judge Nash Holmes just chose the most penal aspects of a variety of
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criminal and civil contempts statutes, along with making a pastiche of theose sanctions requiring the least
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due process attendant thereto, and also managaed to transmogrify the "simple traffic citation trial" into a full
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blow Disciplinary Hearing, whereupon on February 12th, 2012, she took another bite at the apple (not
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satisfied with her 2/28/12 Contempt Finding and Order of Sanctions or the fact that she and her Court
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promised Coughlin's mother that her payng $100.00 would get Coughlin released one day early on the
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unfathomable 5 day jail sentence she ordered to start immediately after Coughlin testified that "RPD Sargent
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Tarter lied when he..." (BOOM...Coughlin didn't even get to finish his sentence...Judge Nash Holmes
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immediately found Coughlin in contempt and had him cuffed, and laughed at the idea of granting any sort of
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stay to allow Coughlin, then a licensed attorney, and opportunity to make arrangements for his client's
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interests to avoid being prejudiced. Judge Kenneth Howard, (McGeorge SOL, '81), while noting that it
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"saddened him" to think of the 3 day contempt incarceration that he himself ordered upon Coughlin to start
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immediately following the 11/30/11 rendition of the conviction of petty larceny of a "candy bar and some
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coughlin drops" (at the Wal-Mart that is on land rented from the Indian Colony, in an arrest made by tribal
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police for a misdemeanor-Wal-Mart's Thomas Frontino testified that neither he nor anyone with Wal-Mart
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made a citizens arrest on 9/9/11 of Coughlin) that violated the law in that NRS 171.1255 forbids tribal police
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000331
from making arrests other than those for gross misdemeanors and felonies.
Michael Smily Rowe, Esq, a person whom Coughlin had indicated would invoked a conflict upon a showing
of sufficient connection thereto...)
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SBN cLERK OF cOURT Laura Peters (the SBN has filed not proof of service of the
summons and complaint sufficient to satisfy SCR 109 in view of the representations made
by the State Bar of Nevada, including those by Laura Peters on the phone and in writing
to Coughlin and found in Peters Affidavit on file in this matter. The first alleged certified
mailing of 8/23/12 is not sufficient to show service where Peters herself (and this is
spoken to in her affidavit) represented that the SBN would not be attempting to use it to
proof service of any sort of the Complaint, but rather, Peters would send, soon after
September 11th, 2012 a certified mailing copy of the SCR 105 SBN v zach Coughlin
complaint to Coughlins SCR 79 address, and that the complaint would not be deemed
served or by the SBN, nor would the SBN attempt to represent in any way that it had
been served, until zach coughlin had signed the return receipt requested and or certified
letter signature card and it had been received by the SBN.
2. 11/14/12 hearing go forward, which it clearly should not, at least not in its current
unbifurcated, due process violating, unnoticed, no service of the 10/9/12 NOtice of INtent
to Take Default, no "at least 30 days" service of the Designation of Witness and Summary
of Evidence BY THE PANEL, NOT BY THE SBN, BAR COUNSEL, OR THE CLERK
OF THE SBN, under SCR 105(2)(c)
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whom appears to be related to
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eviction
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Dear Bar Counsel and Panel Members,

Please find attached my Emergency Ex Parte Motion (perhaps not "ex parte" given Bar Counsel was
provided it). Also, please note, the October 9th, 2012 certificate of mailing by the SBN for the Notice of
Intent to Take Default was never served on me in any way shape or form until I received the copy of the
"entire" file form Sierra Legal Duplicating. The State Bar of Nevada knows this. They put the wrong postage
on the certified mail envelope containing the Notice of Intent to Take Default. When I went to pick it up
"Tim" USPS counter attendant at the Vassar Postal Station here in downtown Reno refused to allow me to
pick up that certified mailing given that is was about $5.00 deficient in postage. I did not have $5.00 and it is
not be responsibility to pay it, as far as I know. In fact, I have asked the Bar and this Panel to allow me to
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proceed in forma pauperis in this matter, and am doing so again here (I am flat broke, I have a 1996 Honda
Accord, rent a room for $300 a month, have less than $200 in my bank account, no stocks, no bonds).
I have been mislead or lied to by the SBN in numerous ways in this proceeding. I was told I could issue
subpoenas despite being a suspended attorney (and there is case law that says even when suspended, one is
still an "attorney"). I was told I would not be required to pay subpoena fees. I was told the August 23rd, 2012
certified mailing would absolutely not be used to prove proof of service of the Complaint in this matter, SBN
v. Coughlin. Yet a review of the files reveals that the SBN and Panels only Return of Service (and see SBN
Ethics Committee Member Joseph Garin's recent Brief in 60302 seeking to dismiss my entire wrongful
termination lawsuit against Washoe Legal Services) for a real ironic example of just why the hearing on
November 14th, 2012 must not go forward. It is fraudulent for the State Bar of Nevada to stipulate with me
that the August 23rrd, 2012 certified mailing of the Complaint is alleges was sent and that Clerk of Court
Peters admits to having received back on September 10th, 2012 would never be cited to as effecting service
of the Complaint upon me or otherwise put forward as proof of return of service etc. Now the SBN seeks to
get around the inconvenient fact that, instead of holding my hearing on September 25th, 2012 (Clerk Peters
told me it was on the calendar, I was noticed of it in writing, I agreed to that date for the Hearing amongst a
choice of dates, etc..) Bar Counsel King attempted to shove a document he alleges was the Complaint in my
suit jacket, then persisted in ordering Clerk of Court Peters (whom King alternately claims to have
separation from and no authority over with ordering her not to file my Motion to Dismiss, attempting to
reneg on stipluations and representations made by the SBN, etc). Further, it is wrong for Clerk of Court
Peters to be signing the certificates of mailing for both the SBN and for the Panel Chair. Additionally, under
SCR 105(2)(c), it is the Panel that must send the Respondent the Notice of Hearing "at least 30 days" prior to
the Hearing date, and that Notice must include with it the Designation of Witnesses and Summary of
Evidence, and it must be served in the same manner as the Complaint. It is impermissible for Pat King to
attempt to mail out the Notice of the Hearing and Designation of Witnesses weeks before the Panel is even
announced (how can you possibly be pretending to take your duty as a Panel member seriously when you are
essentially showing up the day of the first game, skipping all the practices and pre-season games....we all
saw how that turned out for Bret Farve in his last season. It is appalling to me that you intend to hold this
hearing given these blatant violations of SCR 105(2)(c), but when you add to that the fraudulent conduct of
Pat King, in failing to amend his and or Clerk of Court Peters certificate of mailiing or return of service for
the purported certified mailing (and, contrary to the SBN's established practice detailed in the certificates of
mailing I have review upon finally being granted a copy of the "file", though, the rule says I get to go to the
SBN's offices and review certain things "up to three days"...not have Pat King and Laura Peters manufacture
some nonsense about why I am not allowed at the building or otherwise violating my rights (which is
something King and Peters do everytime they get caught violating the rules.) Further, I have been (and some
might say this was largely by design) jammed into having this Disciplinary Hearing on November 14th,
2012 in impermissible proximity to the petty larceny trial in rcr2011-063341 (see Montiero for why it is not
even appropriate for King to be seeking to force me to prejudice my defense in that matter) on November
19th, 2012, in Department 2, before Judge Sferrazza, whom presided over the summary eviction/unlawful
detainer "Trial" from my former home law office that the criminal trespass arrest, jaywalking arrest (King's
Complaint doesn't manage to specify that the January 12th, 2012 arrest was for jaywalking outside my
former home law office shortly after my collecting video evidence revealed the fraud attendant to Hill's
contractor havig used my own plywood to board up the back porch of the property....Hill, also, at that time,
went and got a TPO that was based largely upon an outright lie, ie, that I "climbed up on" the contractor Phil
Stewart's truck). I believe this Panel should review (I cannot affor the $35 to $70 for the video of the two
hearings on Hill's Motion for Order to Show Cause of January 20th, 2012 (the Order to Show Cause was
served by RMC Marsm hal Harley, despite what WCSO Deputy Machen said he personally served in his
affidavit (Machen also lied about personally serving the eviction lockout order for HIll, and HIll lied at the
trespass trial when he testified that Machen "posted it on the door becaues you ran away", Hill also lied at
trial when he alleged the Reno PD announced themselves as law enforcement and issued a lawful order to
emerge form the basement prior to the landlord kicking in the door, and Hill also lied about whether anyone
that day warned Coughlin to leave the property prior to Hill's signing the criminal complaint to affect a
custodial arrest for criminal trespass).
Additionally. I moved recently, and updated my SCR 79 address in compliance with that Supreme Court
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Rule well within the 30 days of my moving. Further, I filed an official Change of Address with the USPS,
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and that caused delays in receiving my mail incident to the typical forwarding procedures of the USPS, and I
have the yellow stickers on the envelopes to prove it. Further, besides submitting an official Change of
Address form to the Vassar Station on October 5th, 2012, Coughlin wrote the SBN on October 14th, 2012,
and provided his new 1471 E. 9th St. mailing and physical address, in addition to updating the online portal
and the NV CLE Board even prior to that, all in compliance with SCR 79.
"We nevertheless conclude that discipline orders appearing in the Nevada Lawyer may
be cited to this court for the limited purpose of providing examples of the discipline
imposed in similar fact situations. This approach has also been taken by several other
courts. n22
n22 See. e.g., Berman v. City of Daly City, 21 Cal. App. 4th 276, 26 Cal. Rptr, 2d 493,
496 n.5 (Ct. App. 1993); Marez v. Dairyland Ins. Co., 638 P.2d 286, 289 n.2 (Colo. 1981);
Manderfeld v. Krovitz, 539 N.W.2d 802, 807 n.3 (Minn. Ct. App. 1995): Leisure Hills of
Grand Rapids v. DHS, 480 N.W.2d 149, 151 n.3 (Minn. Ct. App. 1992)." LAUB.
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Then there is Judge Hardesty being a one of the three Justices signing the 6/7/12 Order that
temporarily suspended Coughlin's law license over a conviction for petty theft of "a candy bar and some
cough drops" (despite the recently reinstated Stephen R. Harris, Esq. not having a temporary suspension
even where he admitted to, upon being forced to by his wife law partner, misappropriating some $740,000
and using it on...(NVD Judge Beesley's, a Bankruptcy Judge in Federal Court who has a specialization in
"Creditor's Rights" listed on his contact page at www.nvbar.org, (McGeorge Law School class of 1979,
meaning he attended with Reno Municipal Court Judge Dorothy Nash Holmes name was supplmeneted to
the Designation of Witness by a November 7th, 2012 filing by Bar Counsel King...which means Couglhin
did not have much notice at all that Beesley would testify. Neither did, apparently, Judge Beesley, as, for
one testifying as to whether a man shoudl retain his law license and the Judge being willing to so weigh in
with definitive opinions (even where a multitude of conlficts of interests where present that should have
arguably precluded him from so doing under the canons of his profession....Nash Holmes/McGeorge
connection, Karen Sabo/Beesley Peck/Coughlin suing Washoe Legal Services/ Beesley close personal friend
of Elcano's angle) Judge Beesley sure didn't have much in the way of specifics to support his strong
opinions. IN fact, he seemed to trip up on things rather easily and wish to vague it all way when Coughlin
pressed for specifics. One thing that seems particularly untoward is the extent to which Judge Beelsey failed
to, in any way, mention the extremely noticeable filing (made accesible to all via the RECAP plugin on
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Firefox for those using Pacer, wherein Judge Beesley's McGeorge Class mate (they were one year apart and
are almost exactly the same age) Dorothy Nash Holmes illegally confiscating an pro se attorney defendant's
smart phone and micro sd data card, well after any period for her Marshals to conduct a "search incident to
arrest" and without any warrant or Order made available to Coughlin was mentioned and extensive
supporting documentation was provided for in the adversary proceeding 10-05104 Cadle Company v. Keller.
Further, Coughlin dispalyed a profound level of professionalism in connection with the John Gessin
adversary proceedings, particulary where Coughlin owned up to the extent to which the rules of court as
currently applied in the NVD make one attorney or record regardless of whether the agreement between
attorney and client is of an "unbundled services" nature, and regardless of Gessin himself telling Coughlin he
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was monitoring the case on Pacer, did not want Coughlin to work any further on the case, etc.... Gessin soon
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became Panel Member Shelly O'Neill's client.
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Regardless, a review of Coughlin's filing in the three NVB cases wherein Coughlin practice before
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Judge Beesley will reveal extremely comptenet work. Perhaps what Judge Beesley was unable to elucidate
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specifically in support of his contentions (which, again, sought to accomplish through a leveraging of the
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Coe Swobe/mental health care apparatus that which is not supportable through more straighforward means)
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is that Judge Beesley's McGeorge SOL Class of 1977 class mate, RMC Judge Dorothy Nash Holmes'
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extremely questionable conduct and rulings in RMC 11 TR 26800 on 2/27/12, 2/28/12, and 3/12/12
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(resumption of Trial in spite of NRS 178.405 and NRS 5.010 and Holmes' own assessment of Coughlin's
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"mental health" issues in both her 2/28/12 Order and here 3/12/12 ruminations rendered and subsequent
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contradictory Order signed, in addition to the), 3/13/12 (various other orders by Judge Nash HOlmes, and
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3/14/12 (grievance letter to SBN), and 10/4/12 (again, Judge Nash Holmes refuses to follow NRS 189.010-
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050 in striking another attempt by Coughlin to have the fact that a summary contempt order is a final
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appealable order, and therefore the RMC and Judge Nash Holmes, once again, are permitted to skirt the law
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with respect to the Court, under NRS 189.030 being required to order the preparation of the criminal
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appellant's transcript (and certainly, if Judge Nash Holmes wishes to issue a "misdemeanor of criminal
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contempt" conviction in a summary fashion (based upon unattributed hearsay by "some Marshal" whom,
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contrary to the dictates of NRS 22.030 did not have to sign an affidavit to have a contempt finding for
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conduct allegedly occurring outside the presence of the court be consiered (good thing for Marshal Joel
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Harley...because either he is lying or Judge Nash Holmes is lying some more, specifically with respect to
this categorically false non-sense about Coughlin "disassembling a smart phone" or recording device in the
restroom and leaving part of it there (the implication being, given Judge Nash Holmes lies about the order of
her sua sponte interrogation of Coughlin regarding recording issues and Coughlin needing to use the
restroom-ie, Judge Nash Holmes lied, under oath, on 11/14/12 when she said Coughlin's request to use the
restroom came only AFTER she began her interrogation about recording or recording device...which, if
Chair Echeverria would have allowed Coughlin to enter the certified copy he had to have his mother buy for
him (becuase the RMC thrice rejected Coughlin's attempts to buy one himself, and in fact, Judge Nash
Holmes attempted to levy some unfathomable sanction or sua sponte disbarment about some piddly
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nonsense related to Coughlin's filing of an in forma pauperis application (truly a low, even here...especially
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where Judge Nash Holmes alternately writes bar counsel on 3/14/12 a greivance directed to Coughlin where
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she mentions, via some unattributed hearsay (which seems to be a common theme running through Judge
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Nash Holmes work) that ) using an Affidavit that was from November 22, 2011 in a March 2012 filing (IFP
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Orders typically last 6 months, so....? And to whatever extent Judge Nash Holmes seeks to make Coughlin's
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interlineating a different case number on that notarized IFP or Coughlin's adding "Request for Audio
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Recording of Trial in 11 TR 26800" onto that IFP as tantamount to conduct supporting her desire to sua
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sponte disbar Coughlin...welll...Coughlin wonders why that Hug-a-Thug program was not given more of a
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chance before Judge Nash Holmes went all "six months in County for jaywalking" on him. Coughlin's
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friend Geof Giles, Esq. (big ups to the Masjid here in Reno, including Rafik Beekun, a member of the
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Muslim centers board of directors and everyone there who was so kind in giving Coughlin a place to go for
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food and pleasant company, during their celebration of Ramadan, no less, incident to Coughlin attempting to
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recover from the Leviathan wrath of the Reno Municipal Court and the McGeorge Mafia's, some might say,
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"approach") may have said it best when he mentioned something about "the community college professors of
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the legal landscape..."
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Also Panel Chair Echeverria is running the Panel like a thug, basically. See WLS's attorney Joe
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Garin's argument respecting Coughlin's right to insist on technical compliance with service rules....NOw
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what that mean? It mean that the SBN and King and Peters do not get to put on testimony by Judge Beesley
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and Elcano (even though lots of stuff was said by both that damages the SBN's case and only further drives
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home the McGeorge Mafia meme, and the extent to which King and Echeverria cheerfuly defile any
conception of due process that might attache to a Dsiciplinary Hearing (to which they seem to drag along
Clerk Peters...what is she supposed to do? Get fired like Coughlin at WLS? See Caryn Sternlicht's approach
at the hearing on the Objection to Master Linda Gardner's Recommendations in the the Santiago v.
Vaxevanis TPO deal FV08-03380, where she filled in for Coughlin, whom took issue with then Master
Linda Gardner making Orders in TPO's where opposing counsel was Richard Molezzo, Esq., that purported
to rule on the title to vehicles...despite NRS 33.018 seeming to clearly lack any jurisdictional basis for her to
do so, particularly where the vehicle was being given to the accused abuser, and further where that Order
was seemingly later recharacterized as an "agreement"....uh, no. See a similar "this ORder is an agreement
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so no appeals will be allowed from it, even the 12/26/12 one you filed, Coughlin" this summary eviction
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"Trial" appeal (from which this 61383 atty fees of $42, 050 appeals stems...) incident to the 12/20/11
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Hearing (six weeks late because Hill (but what about Casey Baker, Esq., who has absconded to Kentucky
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and left Rich to face the music?) had to go on a six week vacation, a fact about which he claimed to be able
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to control the RJC into not complying with NRS 40.253(7)-(8). Coughlin hereby asks this court to stop the
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trial of 11/19/12 in rcr2011-063341 (the iphone case presided over by judge sferrazza, whom managed to
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confiscate all of Coughlin's subpoenas on the auspices that Skau's fraudulently noticed ex part motion
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provided sufficient grounds too...but then failed to return any of them to Coughlin in time to have them
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served for the 11/19/12 hearing...and entered an Order that purports to take away from Coughlin the right to
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have served subpoenas issued propertly under a reading that doesn't include the rendered order by Judge
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SFerrazza of 10-/22/12 in 063341)...So, while Coughlin likes and respects Judge Sferrazza, he must recuse
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himself from that continuation of Trial in 063341 on 11/19/12.
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Also, both Echeverria and Pat King are seeking to take a page out of the Judge Nash Holmes
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"Contempt Statute Pastiche Cookbook" to accomplish their nefarious aims, includign disobeying the
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following authority by trying to "preserve for the record" and "admitting for the limited purpose of establish
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Coughlin's "altering" a previously filed document, where Coughlin, in complete exasperation at Echeverria
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demonstrating the highest possible level of evident impartiality in ruling irrelevant or not properly
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authenticated every single thing Coughlin offered into evidence
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As for Coughlin's inability to get Echeverria to admit anything into evidence for any purpose other than in
support of some Summary Disciplinary Hearing violation of the RPC that Echeverria sought to enter in an
Order in violation of Schaeffer (when Echeverria was not grimacing noticeably and telegraphing displeasure
to Coughlin at Coughlin mere mention of the mitigating quality of local law enforcement misconduct or that
of members of the judiciary or prosecution team...much less Echeverrias verbally suggest that Coughlin
forget about the permission to do so found in Laub and instead cease comparing his case to Stephen R.
Harris, Esq.'s (despite the ripe ground to consiering Judge Beesley's improprly notice (no signed green car
certifie dmailin in compliance with the requirements of SCR 109 considering Laura Peter's announcing of
the rules on September 11th, 2012 and subsequent indications of assent to electronic service by the nndb,
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sbn, and panel, and declaration of the rules attendnat to the running of time vis a vis materials required
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served under scr 109, incident to a certified mailing (ie, Peters announced the SBN and Panel would only
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begin the running of such time periods upon the date on which Coughlin's signature was made on one of the
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green certified mailin return receipt requested cards...and given the SBN can't show as much for the
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Supplemental notice announcing the Designation fo Witnesses of Judge Beesley or WLS's Elcano
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(Echeverria seemed to indicate he did not understand what Coughlin was referring to when Coughlin
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suggested that given he was suing wls and elcano in 60302, and garin was elcano and wls's attorney of
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record there, that questioning elcano may be tantamount to communications with represented parties (dollars
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to donuts elcano has not told garin about this, and Coughlin didn't have the time to given the "jUdge
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sferrazza auhtorize me to serve you notice of the ex parte emergency hearing to quash your subpoenas on
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basis that judge sferrazzas himself seemed to approve your using in connection with utilizing such
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subpoenas on 10/22/12 in rcr2011-063341" by Reno City Attorney Creig Skau (who, ironically sought to ex
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part quash Coughlin's subpoenas based upon insufficiency of procedural rules compliance grounds even
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where he was apparently lying about Jduge SFerrazza granting him the authority to serve Coughlin notice of
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the hearing by email....and or of the 11/7/12 order by Judge sferazzaa. Local government really doesn't like
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complying with subpoenas...just ask the SEcond Judicial District Court and WCDA's Office, whom
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waitinged until 11/13/12 at 4:46 to even fax Coughlin notice of its intent to fail to appear at the 11/14/12
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Disciplinary Hearing (despite the fact that the basis for such objections by Watts-Vial (and thats another
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thing...is that the Watts-Vial whom is a 2nd Judicial judges staff member? Is the Judicial Assistant
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Townsend in the RMC connected to the Marshal Townshend? Is Sargent AVansino of the RSIC connected
to Dena Avansino? We know ecomm 911 dispatcher jessica duralde is married to rpd Nick Duralde, the
officer who effected the wrongful, admittedly retaliating "how's that?" arrest on 8/20/11 in rcr2011-063341
that started all this off....and that jessica duralde was on duty that day and that wcda jim leslie failed to
provide the materials or response from kelley odom and ecomm incident to the 10/3/12 subpoena he sent her
(Judge Sferrazzaoffering the scant time Coughlin's case in chief was accorded, which amount to 1/8th of the
total running time of the on the record portion of the proceedings (and the stoagie breaks "Boss Hog"
Echeverria (and his med mal background provides yet another specious connection to Elcano via the
"panopay" case Elcano constantly reminsces about...) grew more and more frequent once the Hearing turned
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to the time allotted to Coughlin's case in chief...), a couple people name Cummings in the WCSO/WCDC,
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ec., etc.
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But as to King and Echeverria's attempt to make the Discipinary Hearing one where some summary
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profssional conduct ORder may be issued (an allegation that coughlin "altered a previously filed document"
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is so laughable from Echeverria where Coughlin is alleged to have scratch out and or notated his doing so a
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file stamp on the 10/31/12 Pre Hearing Memorandum of Law, and interlineated that the document was now
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being titled a "Declaration" or something similar in an exasperated attemtp to get somethign, anything, into
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the record in that ng12-0204 case...Violations of professional conduct rules not charged in attorney
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disciplinary complaint could not be considered by Supreme Court. In re Discipline of Schaefer, 2001, 25
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P.3d 191, 117 Nev. 496, modified on denial of rehearing 31 P.3d 365, certiorari denied 122 S.Ct. 1072, 534
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U.S. 1131, 151 L.Ed.2d 974. So, if the SBN and Echeverria want to charge coughlin with some violation
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there, it will require due process, and they must refrain from a Nash Holmsian transmogrification of one type
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of proceeding into another type wholly unsupportable under the law (judge Nash Holmes sought to make a
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traffic citation trial a full blown "Summary Disciplinary Proceeding" in 11 tr 26800, whereas Echeverria and
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King seek to turn a Disciplinary Proceeding that they have rigged to cheat Coughlin out of every single due
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process protection possible into a "Summary Disciplinary Proceeding"...which doesn't even exist in Nevada
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law. a SCR 102(5)? maybe....but not a Summary Disciplinary Proceeding Order Finding Coughlin to have
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"Altered" a Previously Filed Document just because Chair Echeverria was flummoxed by the ingenuity of
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Coughlin in getting into the record all that stuff on the cd/dvd's and in the two different "Declarations" or
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similarly titled submissions into evidence that had those cd/dvd's attached to them....(and the panel and nndb
and sbn's assent to electronic service makes required that the materials in the SkyDrive and via email
attachments, as well as the cd/dvd's Coughlin provided be included in the record on appeal).
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Plus, it was wrong for Chair Echeverria to deny Coughlin the right to record the
11/14/12 Disciplinary Hearing and Couglin HEREBY PLACES THE STATE BAR OF
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NEVADA, SUNSHINE REPORTING SERVICES, CAROL HUMMEL, LINDA SHAW,
PAT KING, LAURA PETERS, THE NORTHERN NEVADA DISCIPLINARY BOARD
AND ITS PANEL ON NG12-0205 ET AL ON A LITIGATION HOLD NOTICE.
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Also, kind of odd that NVB Judge Beesley didn't mention the 3/30/12 (hey, thats the same date Judge
Flanagan dismissed Coughlin's appeal of the summary eviction /"Trial" from his former home law office...."
filing by Couglin in Cadle Company v. Keller wherein Coughlin attached as exhibits that pesky filing of a
notice of appeal by coughlin against the RMC and City ATtorney and Judge Nash HOlmes following his
release from 5 ays summary incarceration, no stay (though Judge Nash HOolmes sure does care about those
clients, to be sure, right? she wouldn't, nor would Jduge Howard, be seeking to get back at Coughlin more by
attempting to arrange greater damage theml;kjasdfl;
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/It is categorically false for Judge Nash Holmes to assert, in the audio record on
3/12/12 the order of events and when she asked Coughlin her questions about
recording, considering when a restroom break took place an exactly what it is she
asked Couglin and when, and what his responses were, and when some allegations by
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"the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the
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audio transcript reads 7 minutes into the audio record the RMC provided the SBN:
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Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from
some extreme form of mental illness. during the trial I asked the defendant attorney
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then he quote took the fifth a few other times and then he requested to be excused to go to the
bathroom and the Marshal later reported to me that while the gentleman was in the
and that was retrieved and it was put into his possession at the Sheriff's office and when they
booked him into jail for the contempt charge that was booked into evidence and I asked the
Sheriff's office to hold that into evidence. I believe he has violated Supreme Court Rule
229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of
unattributed hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN)
above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her
statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering
from some extreme form of mental illness." Further, that which Judge Nash Holmes had
communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to
under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her mental
processes" loophole, as he has done.
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City Attorney Ormaas sure could be made to explain her statements on the record regarding
whether the citation or report in 11 tr 26800 contained any mention of retaliation, given she was
looking right at it and given what she said in court. Also, the whispering with Marshal Harley, and
the bits about Coughlin reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901,
and Ormaas's responses thereto on 2/27/12, and Dan Wong, ditto at an earlier hearing on that
matter...
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Nash Holmes mentions on the audio record. And that sua sponte interrogation of Couglin occured
IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES
REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH
OCCURED AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE
WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND
MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE QUESTIONS
COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF
TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF
THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found,
and how odd that was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr
00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and
indications that local law enforcement and prosecutors and public defenders were non too happy with
Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan
that neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time
Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about
Coughlin that RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405?
Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of
2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately 11/28/12,
which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was
duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab
makes his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty,
apparently. That, and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of
2:55pm a fugitive document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as
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CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order
finding Coughlin competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial
seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405
(including within NRs 5.010) here in Northern nevada..
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Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge
Nash HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the
recording is entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash
Holmes, maybe she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an
inappropriate, particulary where she not only purports to issue a "summary criminal contempt" conviction
against an attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a
simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel
and the Panel...That Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to
have to put something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat
King wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn
testimony, but rather just some musings by Judge Nash Holmes purporting to make "rulings" finding "by
clear and convincing evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King,
SBN Bar Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge Gardners
Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin faxed to her
(allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was dismissed under an
NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction
resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based upon a
civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in
place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the
trial for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's
preparation would absolutely not start until a down payment was made. Plus, even where Coughlin caved to
the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf
too...
26
27
28
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps,
NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in King's
3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
- 65/71 -

000342
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2
3
4
5
6
7
8
9
10
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12
13
14
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3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would
need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King
for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's
April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have
anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473

Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against
Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the problems
with the practice of this attorney being experienced by myself and the other three judges in Reno
Municipal Court. My two most recent Orders in what should be a simple traffic citation case are
self-explanatory and are included, together with copies of massive documents Me. Coughlin has
faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also
included. He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our
Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't
seem to locate him between cases very easily. We are setting that case for trial and attempting to
th
serve him at the most recent address we have (1422 E. 9 St. #2 Reno NY 89512), although I
heard today he may be living in his vehicle somewhere. We do have an address for his mother,
however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now
on appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a
matter currently pending in his court with Mr. Coughlin as the defendant. I have enclosed some
copies of documents from those matters, in chronological order, simply because they appear to
demonstrate that he is quickly decompensating in his mental status. Our staff also made you some
audio tapes of Coughlin in the him and him and him and him and him and him and him him and I
will him and him and him and him and him in Departments 2 and 4 so you can hear for yourself
how this attorney acts in court. You can see his behavior in my traffic citation case does not
appear to be an isolated incident.
21
22
23
24
It is my understanding that Reno Justice Court also has a matter pending on this attorney.
My Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr.
Coughlin jailed for Contempt of Court and they stated that they represent him in a Gross
Misdemeanor matter in RJC. I have no other information on that.
25
26
27
28
You will have the full cooperation of myself, the other judges, and the staff of Reno
Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious
litigant in our court, antagonizing the staff and even our pro temp judges on the most simple
traffic and misdemeanor matters. I do think this is a case of some urgency, and I apologize for
- 66/71 -

000343
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2
3
4
5
6
7
8
9
10
11
taking two days to get this package to you; our IT person was ill and could not make the copies of
the audios of Mr. Coughlin's hearings until today, and I felt it was important that the audios be
included in the materials to be considered by the State Bar. On February 27, 2012, Mr. Coughlin
told me he was actively practicing law and had appointments with clients. [ do not know if that
was true, but if so, he could be causing serious harm to the practice of law in Northern Nevada
and could be jeopardizing someone's freedom or property interests. "
/Rule 120. Costs; bar counsel conflict or disqualification.

1.
An attorney subjected to discipline or seeking reinstatement under these rules may be assessed the costs, in
full or in part, of the proceeding, including, but not limited to, reporter's fees, investigation fees, bar counsel
and staff's salaries, witness expenses, service costs, publication costs, and any other fees or costs deemed
reasonable by the panel and allocable to the proceeding.
2.
If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of
governors shall appoint an attorney, ad hoc, to act in the place of bar counsel.
12
13
14
Coughlin is truly severly indigent at this point and requests, to whatever
15
extent and IFP has not already been granted herein, and Order allowing him to
16
proceed In Forma Pauperis
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18
19
20
Docket entry for the trial court matter this case was appealed form shows the impropriety of the Clerk of
Court dismissing the appeal for lack of paying a filing fee:
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FILING
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25
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28
06-SEP2012
04:55 PM
COUGHLIN, ZACHARY
- 67/71 -

000344
APPEAL FEE PAID FOR THE 7-30-12 NOTICE OF APPEAL - IMAGE ATTACHED TO
JULY FILING
Entry:
2
3
4
5
06-SEP-2012
04:56 PM
**Payment Receipted
Entry:
A Payment of -$34.00 was made on receipt DCDC375290.
7
8
9
conclusion
please reinstate the appeal and or grant ifp status or provide time to submit a proper ifp as
10
bar counsel clearly is gunning for a Panel Order that entails Coughlin paying back this unconcionable
11
attorney fee award prior to reinstatement, and that is if Bar Counsel Pat King doesn't get his stated
12
wish to have Coughlin disbarred. Further, the District Court's 3/30/12 Order should be added to this
13
appeal given the circumstances, to whatever extent Coughlin failed to file a timely notice of appeal
14
thereto, as should the notice of appeal of the justice court's 12/21/11 Order Resolving Coughlin's
15
November 17th, 2011 Motion to Contest Personal Property Lien consdiering the RJC failed to file
16
stamp in Coughlin's timely 12/26/11 notice of appeal thereto in rjc rev2011-001708, as the rjc did in
17
another summary eviction from a commercial lease involving coughlin's former home law office in rjc
18
rev2012-000374...further RMC Judge Nash Holmes has similarly refused to follow the rules on
19
transmitting appeals in 11 TR 26800 ( a case whee Richard Hill had RMC Marshal Joel Harley violate
20
courthouse sanctuary doctrine where Harley personally served Coughlin notice of the 3/23/12 order to
21
show cause hearing in the district court appeal of this matter (and really, on October 19th, 2011,
22
Coughlin alreaqdy had a District court appeal in this matter in cv11-03126 or cv11-03051...thus
23
making void the entire appeal in cv11-03628, perhaps).
24
25
26
27
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- 68/71 -

000345
1
2
The undersigned does hereby affirm that the preceding document does not contain the
3
4
social security number of any person. The assertions herein are made, pursuant to NRS
53.045 under penalty of perjry and based upon my first hand knowledge of these matters,
except to perhaps a very, very few aspects of a a very few assertions which are made upon
information and belief.
8
9
Dated this November 17th, 2012,
10
11
12

electronically
Zach Coughlin, Esq.
13
Appellant
14
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16
17
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24
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- 69/71 -

000346
Proof of Service:
1
2
3
foregoing document to all registered efilers, and to those whom are not I placed a true and
correct copy of the foregoing document in the usps mail on this date:
4
5
6
7
Richard G. Hill, Esq.

Casey Baker, Esq.
Richard G. Hill, CHTD.
Attorneys for Respondent Merliss
652 Forrest St.
Reno, NV 89509
10
11
12
DATED THIS: Dated this November 17th, 2012

/s/ Zach Coughlin
13
Zach Coughlin
14
Appellant
15
16
17
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19
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23
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000347
INDEX TO EXHIBITS:
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3
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8
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- 71/71 -

000348
000349
000350
000351
temporary address change and instr uction to

pursue a continuance
Sent: Mon 11/21/11 4:06 PM
To: howardk@reno.gov; robertsp@reno.gov
Dear Judge Howard Deputy City Attorney Roberts,

I have been evicted and perhaps subject to an illegal lockout and unlawful rent
distraint by an attorney representing my Beverly Hills High School graduate
California Neurosurgeon landlord, who has spent approx $30,000 in attorneys
fees pursuing a summary eviction, and whose attorney is withholding my state
issued indentification, wallet, and all materials necessary to my law practice
all in an unlawful rent distraint prohibited by NRS 40.460 and 40.520. I am
pursuing a continuance of the upcoming hearing/trial, I cannot even access
when that hearing is. I have informed opposing counsel Roberts of some of
the issues which will require extensive discovery, a jury trial, and more time
to afford myself a legitimate opportunity to defend this case. I have not been
served any Order responding to my request for appointment of counsel, as I
believe it is required even if the State does not "intend" to seek jail time,
where any incarceration is a possibility, the Sixth Amendment guarantees it.
Please note that my temporary address for now is:
Zach Coughlin, Esq.
c/o Silver Dollar Motel
817 N. Virginia St., Unit # 2
Reno, NV 89501
The opposing counsel in the summary eviction matter is withholding my
phone as well and refusing to allow me to access any mail that may remain at
the property from those times when the USPS was processing my official
Change of Address. Email is the best way to get in contact with me during
this transition period.
000352
For instance, I am unware whether my Motion for Appointment of Counsel

was granted or not. I called Judge Howard's assistant and requested that she
email me the docket in this case and any pleadings or orders filed, including
any order that may have stemmed form any of my previous motions, as I am
not sure how those were ruled on. I believe my internet based fax service will
allow me to receive those materials at my number 949 667 7402, though I
would prefer email, but I know many governmental entities prefer to fax such
items. I am requesting a jury trial, a substantial continuance, and the
appointment of counsel. I object to the RMC's practice of refusing to tell
litigants who the 4 "house" appointed defenders are upon questioning.
Further, it has become clear that some of these "former prosecutors" who are
now the gang of four "house" defenders, do not even announce to accused
arraignees that they are, in fact, the defender or an attorney or that they may be
representing the arraignees. I am hereby filing a motion in limine regarding
any materials or information gleaned from the unlawful search by the RSIC
Officer, who clearly announced that they would base their probable cause to
arrest and conduct a search incident to arrest upon any failure to consent to a
search by the accused. Further, the alleged conduct did not occur in the
Officer's presence, and I believe there exists authority preventing a minor
misdemeanor arrest and transport under those circumstances. Additionally,
more time is needed to conduct discovery in this matter, especially in light of
allegations that Walmart had previously threatened individuals, including,
perhaps, the accused, with retaliatory action, including illicit abuse of process,
for the purported attempts by someone to have the Walmart Return Policy
enforced, and to hold accountable all Walmart employees and managers, some
of whom have over a decade experience in their positions, who curiously
"forget" they Return Policy Walmart holds out to the public when it is
convenient to do so, the same Return Policy that Walmart used to drive out of
business so many competitors. Further, this case is likely to get extremely
complicated given the apparent conflict of interest stemming from the fact that
the Walmart in question is on land owned by the RSIC, which may own or
employ the RSIC police, and which is rented or owned in part by Walmart.
I know Opposing Counsel Roberts may appreciate a continuance as well and
the opportunity it would afford her to fulfill her NRCP 11 duty and other
prosecutorial duties to conduct a reasonably diligent inquiry into these
matters.
000353
Sincerely,
Zach Coughlin
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
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Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or
other applicable privilege.
000354
3/5/13
Chief Marshal Roper and Marshal Harley on

setting the record str aight in NG12-0435
Sent: Fri 11/23/12 4:09 PM
To: roperj@reno.gov (roperj@reno.gov); harleyj@reno.gov
(harleyj@reno.gov); je@eloreno.com (je@eloreno.com);
skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com
(cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
patrickk@nvbar.org (patrickk@nvbar.org); christensend@reno.gov
(christensend@reno.gov); mike@tahoelawyer.com
(mike@tahoelawyer.com); davidc@nvbar.org (davidc@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com);
stuttle@washoecounty.us (stuttle@washoecounty.us); wongd@reno.gov
(wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov);
mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us);
jleslie@washoecounty.us (jleslie@washoecounty.us);
holmesd@reno.gov (holmesd@reno.gov)
Dear Panel, Judge Nash Holmes, Chief Roper, Marshal Harley, Bar Counsel,
et al,
I apologize for using email to communicate here, but my current indigency
and time constraints so require it. Further, I in no way wish to violate any
Orders by any of the RMC Judges respecting emailing or contacting the RMC
in connection with specific cases, and submit this limited correspondence in
the hopes that my interpretation of any such Orders is in line with reality and
will forgive at least this limited use of email outside of any attempt to file
anything in any of the matters in which I am a party before the RMC. The
exigency involved here relates primarily to the enormous deference that will
be given to the Panel's decision in the SBN v. Coughlin disciplinary matter,
000355
https://bay002.mail.live.com/mail/PrintMessages.aspx?cpids=4c008190-615c-46cd-baf8-83d24e1a434b,m&isSafe=false&FolderID=66666666-6666-6666-6666-
1/26
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and my desire to have the Panel afforded every opportunity to have all
essential information necessary to arrive at a just decision at its disposal.
What follows is in part a request and in part a recognition of the extent to
which Judge Nash Holmes's action during the 2/27/12 Trial in 11 TR 26800
may likely have been the best thing to have had done, owing to her vast
experience in these and a great deal many other matters, and, hopefully, will
have an upbeat result stemming therefrom.
At the Double R Blvd. Northern Office of the State Bar of Nevada, RMC
Judge Nash Holmes, on 11/14/12, testified under oath and indicated
something along the lines of the following:
During the 11 TR 26800 "simple traffic citation Trial" on 2/27/12, starting at
about 3 pm, Judge Holmes interrogated Coughlin as various points
throughout the Trial as to whether he was recording the proceedings (without
permission), and or whether he had a "recording device" (whether every laptop
anyone brings to Court would be considered a "recording device" to Judge
Holmes is not exactly clear).
Judge Holmes then testified that after an initial round of interrogation of
Coughlin as to whether he was recording the proceedings and or had a
"recording device" that Coughlin got "all sneakity" and said he was not, but
then "quote, 'took the Fifth' then immediately asked to be allowed to use the
restroom...and I ordered Marshal Joel Harley to accompany him there...and it
was reported to me that while in the restroom Coughlin disassembled a
recording device and hid some part of it in the restroom..." (Coughlin
recounts this testimony from memory, and admittedly, it is far from
verbatim).
It is cate gor ically false (though not necessar ily maliciously so)
for Ju dge Nash Holmes to asser t, in the audio r ecor d on
3/12/12 the or der of events and when she asked Coughlin her
questions about r ecor ding, consider ing when a r estr oom br eak
took place and exactly what i t is she asked Coughlin and when,
000356
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3/5/13
and what h is r esponses wer e, and when some allegati ons by

" the Mar shal" wer e made, what th ey consisted of, etc.. on
3/12/12 in 11 tr 26800 the audio tr anscr ipt r eads 7 minutes into
the audio r ecor d the RMC pr ovided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the
defendant is suffering from some extreme form of mental
illness. during the trial I asked the defendant attorney
repeatedly if he was recording the proceedings he denied that
vehemently a few times and then he quote took the fifth a few
other times and then he requested to be excused to go to the
bathroom and the Marshal later reported to me that while the
gentleman was in the bathroom he disassembled a recording
device in his pocket and took the memory out of it and it was
later found in that, uh, by the Marshal no one else had gone into
the bathroom and that was retrieved and it was put into his
possession at the Sheriff's office and when they booked him
into jail for the contempt charge that was booked into evidence
and I asked the Sheriff's office to hold that into evidence. I
believe he has violated Supreme Court Rule 229(2)(B) which was
amended by ADKT 440, August 1st, 2011...."
above.
Perhaps NRS 178.405 in the context of NRS 5.073 should have some baring on anything said or
done or Ordered by Judge Nash Holmes following her statement at the 7 minute mark that "It
appears to me in this case that the defendant is suffering from some extreme form of mental
illness." To the extent any question of Coughlin's competency was communicated to or brought to
Judge Nash Holmes attention prior to the 2/27/12 3:00pm start of the Trial in 11 TR 26800, that
proceeding should have been stayed or suspended, especially if the WCPD's Office made such
communnications in close temporal proximity to the 1:31 pm 2/27/12 Order for Competency
000357
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3/5/13
Evaluation by Judge Clifton in RCR2011-065630. And arguably, given the same office (in a broad
sense) in which DDA Z. Young and DDA Kandaras work, it is arguably a basis for conflicting out the
WCDA's Office from any one of the three prosecutions is has maintained against Coughlin this year
(especially considering the issues related to whether the WCSO's timely effected the lockout of
11/1/11 in the eviction from Coughlin's former home law office, which, given the recent admissions
by the locksmith there that day, and the Reno Carson Messenger receipt from the day prior, and
Casey Baker, Esq's testimony related to his interactions with the WCSO on October 28th, 2012
during his sworn testimony at the criminal trespass trial before RMC Judge Garder on 6/18/12, and
the RJC's failure to even move to Quash Coughlin's subpoenaing records related to the fax logs and
confrimation of transmission or receipt incident to the RJC's "usual custom and practice" of faxing
eviction Orders to the WCSO for service (like those in the Richard Hill/Casey Baker Summary
Eviction "Trial" involving Coughlin's former home law office, and the "within 24 hours of receipt"
language found within NRS 40.253 (the Order is void or invalid after that point, in which case, it
would mean Hill and or Baker were the trespassers, not Coughlin, regardless, its inappropriate for
RMC court appointed defender Loomis to categorically refuse to assert any claim of right defense
that such a criminal trespass defendant may wish to assert for, say, Richard Hill admits to charging
the same rent under a "storage of personal property" that was previously charged for "full use and
occupancy". Nonetheless, posting an Eviction Order that does not contain stay away language
(much less the fact that is does not have the required "within 24 hours" language called for by the
statute) is not tantamount to posting a no trespassing sign, further, Hazlett-Stevens making
arguments in his closing as to matters not in evidence (allegations of living in the residence) is
reversible error, and for Judge Gardner to do as Judge Howard did, an prevent the City Attorney
from even having to Oppose Coughlin's Motion for New Trial, is further indication of the extent to
which Coughlin's reactions during the 2/27/12 Trial, however offputting, are not totally unfounded.
Further, that which Judge Nash Holmes had communicated to her prior to the start of Trial on
2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert to
half baked "can't ask the judge about her mental processes" loophole, as he has done. But,
actually, a review of the Hardesty/Mirch dynamic may dictate that Coughlin would have been fairly
limited in that regard anyways, nonetheless, Judge Nash Holmes appeared, to her credit, and
answered some questions. The answers revealed an opportunity put forward now to clear some
things up, though the constraints of the Disciplinary Hearing format, some disagreements over
what the SBN communicated to Coughlin with respect to the rules that would be applied to him vis
a vis NRCP 45 subpoenas (whether, he, as a suspended attorney could issues a subpoena
(Coughlin maintains the Bar/Panel/Board did give him such authority) and whether any witness fee
or subpoena decus tecum fee must be paid by Coughlin (Coughlin maintains he was provided
indications upon which he reasonably relied that he would not be so required in additions to the
rules or practicies attached to the service thereof), and other factors severely limited the extent to
which the opportunity created by Judge Nash Holmes testimony was realized to its full potential.
That necessitated this correspondence. Coughlin recalls the first time he saw opposing counsel
allege he was lying in a filing, it was one of the early one's by Richard Hill's former associate
Casey Baker, alleging "outright lies". It was upsetting, especially considering how unfair and
baseless the allegations seemed...and Coughlin nows wishes he would have done and said some
things differently incident to his testimony relative to RPD Sargent Tarter and Judge Nash Holmes's
own testimony, and intends to address the extent to which objectionable conduct by opposing
counsel can often times become a sort of learned characteristic perpetuating a race to, if not the
ethical gutter, at least a preponderance of Rambo litigating. To some extent the incidents with
Marshal Harley and RCA Ormaas may be fallout from that. Important too, however, is to consider
whether the "courthouse sanctuary" doctrine has some application, however confusing it may be,
000358
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3/5/13
where the WCSO may be hired by private parties to conduct service, and the Marshals are only
extending intra-governmental courtesies in assisting in the manner in which Marshal Harley did on
2/27/12. Richard Hill gets the "oopsies" a lot. Oppsie, I asked for $20K in attorney's fee incident
to a summary eviction at the trial court level, despite that not being supportable under NRS 69.020,
Hill says. Oopsie, I left the window unit air conditioner in the exposed to the street by the Lakemill
lodge window at your former home law office, which was then robbed, but for which I still managed
to charge you full rental value at full use and occupancy rates, though I had you subject to an
arrest for custodial trespass anyways, Hill and Baker say.
(at the 9 minute 48 second mark of the first audio file attached from 2/27/12)
"Judge: Sir, I would like you to raise your hand to be sworn, because its my experience that people
who represent themselves tend to testify a whole lot when they are asking other people questions,
so let's just start that way and then we won't have to do it later, so swear him in and then we'll get
going
Marshal: Testimony (inaudible)...you are about to (inaudible) understand (inaudible) truth, whole
truth, nothing but truth, solemnly?
Coughlin: Yes, Sir?"
However, from there, throughout the Trial Judge Nash Holmes interrupts Coughlin during his
questioning of Tarter to indicate to Coughlin that he is asking questions and not testifying, or that
he will have an opportunity to make some point when its his turn to testify, if he chooses to testify,
etc., etc, and eventually Judge Nash Holmes asks Coughlin, after the restroom break, if he intends
to testify on his own behalf..."Nor does the trial judge's speculation that Appellant might use his
closing argument to present unsworn testimony." Soto, 139 S.W.3d at 857.
The transcript from the 2/27/12 certified audio recording of the traffic citation Trial
at the 1 hour and 6 minute 18 second mark of the running time (yes the certified audio transcript is
provided in a FTR format that necessitates installing TheRecord Player, but for the ease of the
receipients of this correspondnece, Coughlin convereted the audio therein exactly as it was into a
more workable format, .mp3 files, split into two files for 2/27/12 (before and after the one
restroom break) and one file for the continuation fo the trial on 3/12/12) of file one:
Judge Nash Holmes (Judge): Sir, Mr. Coughln, sit down, I am done with you.
Coughlin: Just to preserve for the record, Your Honor.
Judge: Sit down, sit down, your're done. For the record the defendant is looking in his pockets and
behind his back and turning around and clowning around and showing utter disprespect for this
000359
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court and if you say another word or do another little antic like that you are going out of this Court
in handcuffs. Do you have any other witnesses? Prosecutor?
Prosecutor Ormaas: No, Your Honor, the City rests.
Judge: Sir, do you wish to testify?
Coughlin: Can I call Officer Tarter as my own witness?
Judge: you can call anyone you wish to testify.
Coughlin: I am sorry, Your Honor, but I really need to use the restroom.
Judge: You have two minutes. Marshal (Harley), you will escort him to the restroom, don't take
anything with you, Sir...
Coughlin: Can I take my notes with me?
Judge:No, turn them upside down.
Coughlin: Can I take the one page?
Judge: No, turn them upside down.
Coughlin: Really?
Judge: Turn them upside down. Marshal you will go with him to the restroom.
Coughlin: Will I be able to go into the stall alone? Just checking.
Judge: You have two minutes. You have two minutes.
Coughlin: Okay.
(that ends the first audio file attached for 2/27/12, which represents the entirety of the proceeding
prior to the ONLY restroom break during that Trial)
(Start of the second audio file of 2/27/12, which represents the entirety of the proceedings of that
day following the ONLY restroom break of the day).
Coughlin: (re-enters courtroom): Thank you, Your Honor.
Judge: Okay, we are back on the record in 11 TR 26800. Mr. Coughlin, are you recording these
proceedings?
Coughlin: No, Your Honor.
Judge: Do you have any sort of devices in your pocket?
000360
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Coughlin: I believe what is in my pocket is private, Your Honor.

Judge: I want to know if you have any sort of recording devices in your pocket!
Coughlin: I believe that is a Fourth Amendment issue, Your Honor.
Judge: I am asking you, are you are recording anything from these proceedings in your pocket
without Court permission?
Coughlin: I believe that is a Fourth Amendment issue.
Judge: Sir?
Coughlin: And, no, I'm not.
Judge: Okay, proceed, do you have any questions for this witness (RPD Sargent John Tarter) that
are different from the area that we gave gone over already.
Coughlin: Well, I would like to ask a follow up on the rolling stop citation..." (thereafter Judge Nash
Holmes does not ask any other questions of Coughlin in any way related to recording or recording
devices, nor did Judge Nash Holmes ask any questions of anyone related to recording or recording
devices besides. Judge Nash Holmes did ask, before the restroom break, of Coughlin, if Coughlin
had any evidence or proof to support his contention that he attempted to provide to either Reno
City Attorney Wong or Ormaas discovery or information related to the statement to Coughlin,
incident to the November 13th, 2011 custodial criminal trespass arrest of Coughlin at his former
law office incident to an impermissible summary eviction of a commercial tenant not based on the
non-payment of rent (ie, a No Cause Eviction Notice was posted and a Landlord's Affidavit alleged
a No Cause basis for proceeding).
On the second audio file from 2/27/12, at the 5 minute mark, the follow occurs on the record:
"Coughlin: was I there? Do I remember the name of the other officer who was there with him who
went into Richard Hill's law office for twenty minutes with him and hung out?
Judge: If you mention the name Richard Hill again I am going to hold you in contempt because I
have told you repeatedly to stick to the relevant issues about the boulevard stop."
(At the 11:17 minute mark of the second audio from 2/27/12 the following occurs on the record):
Judge: Officer (RPD Sargent Tarter), you are excused. Sir, do you intend to testify?
Coughlin: Yes, Your Honor.
Judge: Then testify, you don't need to take the stand, you can testify right there, you don't have to
ask yourself questions, just give me a short narrative version of what happened, and don't refer to
yourself in the third person, he was sworn in at the beginning of the case, don't refer to yourself in
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the third person, just tell me what happened.

Coughlin: Yes, your honor, I reported a bribe to Sargent Tarter, then he retaliated against me.
Judge: Sir! Sir! Keep it relevant!
Reno City Attorney Ormaas: Objection, move to strike!
Judge: Keep it relevant about whether or not the boulevard stop occurred and what happened:
Coughlin: Sargent Tarter perjured his testimony today
Judge: Sir, Sir, answer about the boulevard stop.
Coughlin: Yes, Your Honor, this incident occurred when I went over to Richard Hill's office.
Judge: Sir.
Coughlin: I can't get into that? Okay.
Judge: Sir, boulevard stop.
Coughlin: Sargent Tarter lied today when he...
Judge: All right, Sir!
Coughlin: about the boulevard stop, I am saying...I disagree
Judge: take him into custody, you are in contempt of court, you will spend the next five days in jail,
this court is finished, this matter is continued
Coughlin: Your Honor I move for a stay, I have a trial..and I have clients who need me
Judge: that is your problem, Sir. For the record you are in contempt of court because you have been
insubordinate, you have disregarded all of my requests, directions, orders, cajoling, my efforts to
get you to follow the instructions of the court, to act like a lawyer, or even to act like a defendant
representing himself in this court, you have made faces, belittled, you have argued, you have
played, you have been ridiculous in this courtroom and brought up issues that are irrelevant and
immaterial and to disrupt this proceeding, and there are only five or six people here that you could
disrupt, you have done everything you can to divert from the matter at question and to keep us
from resolving the issue of whether or not you have committed the traffic violation of the boulevard
stop, and you are in utter contempt of this court and have done nothing to deal with the facts of
this case...you are being an obstinate jackass, I am having a hard time believing you are a lawyer,
you obviously missed the class on on evidence, courtroom decorum and on criminal law..."
Coughlin was taken into custody whereupon a search incident to arrest was performed in the
holding area/back room of the RMC by Marshal Joel Harley with Marshal Scott Coppa assisting,
and Marshal Coppa was one of two Marshals transporting Coughlin to the Washoe County
Detention Facility where he served the 5 days in jail Judge Nash Holmes ordered (and the RMC
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refused to return the $100 that Coughlin's mother paid into the RMC when counter clerk "Tom"
promised her the Court would issue an Order resulting in Coughlin being released from jail one day
early...however, aside from the WCDC walking Coughlin down in handcuffs from his cell to the
booking desk and back, there was no release from custody and Coughlin's mother was not returned
her $100 payment in exchange for an early release by either the RMC or the WCDC.
While conducting the search incident to arrest, RMC Marshal Harley went through Coughlin's
pockets and took out a simple flip style cell phone, a smart phone, a micro sd card, and an
electronic shaver. Upon taking possession of the micro sd card Marshal Harley immediately began
interrogating Coughlin as to whether it would work with the smartphone, then directed another
Marshal to "go tell the Judge that Coughlin was recording!" without any other support for such an
accusation. None of this occurred in the restroom and Chief Marshal Roper has indicated to
Coughlin that Marshal Harley, in carrying out Judge Nash Holmes Order to escort Coughlin to the
restroom, did not actually go in the restroom, but rather waited outside its door.
I ask that Chief Marshal Roper, Marshal Harley, and Marshal Coppa correct the misrepresentations
made by Judge Nash Holmes (whether or not they were purposeful or where something was lost in
translation and the affidavit requirement of NRS 22.030 for "contempt not in the immediate
presence of the Court" was not followed by Judge Nash Holmes incident to her 2/28/12 Order,
wherein Judge Nash Holmes writes, on page 2 of her 2/28/12 Order Finding the Defendnat in
Contempt of Court and Imposing Sanctions: "The matter was called at apprxoimately 3:00p.m. and
concluded withoua verdict about 4:30 p.m. after the court held the defendnat in criminal contempt
of court for his behavior and activites committed in the direct presence of this court during the
trial. The court finds that defendant's contemptuous conduct conside of his ....deceitful...behavior
during trial, all of which appeard to be done to vex an annoy the court, the witness, and the
opposing party, and to disrupt the trial process. The court finds that the following occurred, and
constitute contempt...."9) defendant's lying to the court in response to direct questions posed by
the court with regard to his recording the proceedings...(page 3)...The court finds that the
defendnat's actions were intentional and done in utter disregard and contempt for the court, an in
the presence of the cour, for purposes of disrupting and delaying the proceedins and dishonoring
the rule of law and this court, and constitute the misdemeanor of criminal contempt, a violation of
NRS 22.010. Good cause appearing therefore, the following sanctions are imposed: IT IS
ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at the Wahoe County
Regional Detnetion Facility for the term of five (5) days, from the time he was taken into custody
on this court's order on February 27, 2012, and that sentence shall not be reduced for any
reason..." The time stamping on that 2/28/12 Order Finding the Defendant in Contempt of Court
and Imposing Sanctions indicate "3:47". Washoe County Sheriff's Office personnel Deputy Hodge,
Patricia Beckman, RMC
Somehow, in her 2/28/12 Order (and during the Trial) Judge Nash Holmes found it relevant that,
allegedly, the RPD "gave Coughlin a break" over his driver's license being expired (actually,
Coughlin's then valid, current, driver's license was being withheld by Richard G. Hill, Esq., as
Coughlin reported to Sargent Tarter...and it was likely an old DL that the RPD is referring to 000363
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"expired" when mentioning the "break", which, again, was somehow relevant enough to find its
way into the Order, but the withholding of Coughlin's then current, valid DL by Hill was sustained
as irrelevant during the Trial (and in fact seems to have been one of a myriad of vague basis for
issuing a summary criminal contempt Order requiring then licensed attorney with client's
depending upon him, Coughlin, immediately being taken to the WCDC for 5 days in jail...).
Coughlin hereby requests the RMC, WCDA, and WCDC to indicate the extent to which his property
was booked into his personal property at the WCDC, only to have the WCDC and or WCDA release
the property to the City of Reno Marshals the following day, well after any timeframe to conduct a
search incident to arrest (NNDB Member Mary Kandaras was involved in this matter, and in fact,
despite Judge Nash Holmes ordering the property released on 3/30/12, it took until 4/7/12 and
approval by Mary Kandaras before the property was so released. wcso12-1805 c-47951.
With local attorney Pam Wilmore standing, watching, and or hearing/participating in the
conversations, on or about March 21st, 2012 WCSO's P. Beckman handed Coughlin a note that read
"Per Judges Orders, call Marshal Deighton" and provided a phone number for Coughlin to seek
further explanation as to the admission that the City of Reno Marshals had returned to the jail on
2/28/12 and retrieved items of Coughlin's personal property, including his "flip" phone, his smart
phone, and his micro sd card. Deputy Hodge's admission that, contrary to the indications by WCSO
Cummings and Campbell that the micro sd card was released to Coughlin's agent on 2/29/12, but
rather, was not so release, combined with his statement that the smartphone, micro sd card, etc.
were released to the Marshals because it would be easier for Coughlin to get his property back
through them, reveal that a search not incident to arrest occurred here by the RMC on 2/28/12 and
or the City of Reno Marshals, or, to be fair, at least some sort of "seizure" did (especially
considering that upon the smartphone and micro sd card finally being returned to Coughlin on or
about 4/7/12 by WCSO Deputy Iver, Brandi Berriman, and Patricia Beckman (and only after
"Maddy" got approval from DDA Kandaras, and after Coughlin was threatened with abuse of
process by Deputy Beatson). The RMC's Marilyn Tognoni also made some indications respecting
the smartphone and micro sd card to Coughlin. Perhaps, the allusion to wcso12-1805 c-47951 in
Judge Nash Holmes 3/30/12 Order Releasing Coughlin's property indicates whether a warrant or
some other lawful Order allowed for the Marshals to retrieve those items a day after they were
booked into Coughlin's personal property at the jail...but Coughlin has not been provided any such
Warrant or Order and hereby requests that he be so provided a copy of it now, and that, given
important data was lost to Coughlin upon his discovery the micro sd card and smartphone had been
wiped, that any copies of the data then stored therein be provided to Coughlin (the Diaz case in the
Ninth Circuit seems to provided a great deal of latitude to law enforcement to search digital data
within the reach of one whom is subject to a custodial arrest, and perhaps even copy it...in which
case....is would be appreciate if a copy thereof could be provided to Coughlin, and some
compensation for the extent to which his 32 GB micro sd card was rendered useless upon its
return, as was his HTC G2 cell phone (which never quite worked the same from then on and was
rendered totally inoperative a short time thereafter...the 32 GB micro sd card having an
approximate value of $85 and the HTC G2 smartphone a used value of around $175.00).
000364
https://bay002.mail.live.com/mail/PrintMessages.aspx?cpids=4c008190-615c-46cd-baf8-83d24e1a434b,m&isSafe=false&FolderID=66666666-6666-6666-6666 10/26
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I know I write in the third person sometimes (its tough representing yourself, especially when time
requires lots of copying and pasting, etc., etc) and that it can appear awkward.
I would appreciate the parties receiving this correspondence who have any knowledge of the
events detailed herein (especially with respect to the false accusations related to recordings,
disassembling, and hiding component parts of devices in the RMC restroom as detailed on the
record on 3/12/12 in 11 TR 26800 and again in Judge Nash Holmes testimony at the 11/14/12
Disciplinary Hearing for NG12-0434 (and NG12-0204, and NG12-0435) to set the record straight.
For a verbatim or close to it transcription of what Judge Nash Holmes testified to at the Disciplinary
Hearing on 11/14/12 (including those matters she purported to repeat details related to what
variosu RMC Marshals told her regarding Coughlin, on would likely need get the transcript or any
recordings from the CCR assigned to that Hearing, Carol Hummel, and given Coughlin's current
indigency, any requirement that Coughlin pay up front for the transcript would make review
prohibitive, and Coughlin hereby requests of the Panel a fee waiver or deferment of such costs in
that regard):
Linda Shaw, Owner, Sunshine Reporting Services - Reno

1895 Plumas St,
Reno, NV 89509,
(775) 323-3411
Sunshine Reporting Services
Eric Nelson
CCR Longoni
(775) 323-3411
fax (775) 323-2749
151 Country Estates Circle
Reno, Nevada 89511

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Carol Hummel
(775) 827-9120/
fax (775) 827-9120
chummel@charter.net
In her 3/12/12 Order in 11 TR 26800, a transmogrification of sorts appears to occur, turning a

"simple traffic citation trial" into a Disciplinary Hearing, albeit one of a summary nature, with an
absent Respondent. That Order read, in relevant part:
"Based upon the total circumstances of this case, the in-court performance of the
defendant, as observed by this court, the written documents faxed to the court for filing by
this defendant, the statements and behavior of this defendant and his overall conduct herein,
this court finds, by clear and convincing evidence, that Zachary Barker Coughlin, an attorney
licensed to practice law in the State of Nevada, has committed numerous acts of attorney
misconduct, including, but not limited to, violating the following Rules of Professional
Conduct:
8.4(c}-engaging in dishonesty, fraud, deceit or misrepresentation;
8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
3 .l-defending in a proceeding by asserting or controverting an issue without a basis in
fact and with matters that are known to be frivolous;
3.2-failure to make reasonable efforts to expedite litigation. and, in fact, taking
extreme measures to delay litigation;
3.4(c)-being unfair to opposing counsel by continually alluding to matters the lawyer
does not reasonably believe are relevant or supported by admissible evidence;
1.3-failing to act with reasonable diligence and promptness; and
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1. I-lack of competence in his practice and appearances before this court.
In addition, Zachary Barker Coughlin, likely also violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011, by surreptitiously recording
the traffic citation trial of February 27,2012 without the advance permission of this court and
then lying to this court when questioned about it and denying that he had done so.
Whether or not there are medical reasons to explain Mr. Coughlin's actions is not for
this court to decide. He has become nothing less than a vexatious litigant to Reno Municipal
Court due to his unorthodox, disruptive, bizarre and irrational methods and practices that go
beyond the pale of anything that is civil, ethical. professional or competent. Good cause
appearing therefore, the court orders as follows:
IT IS ORDERED that this matter is continued, and all proceedings relating thereto are
tolled, until further order of this court, while the matter of attorney Zachary Barker Coughlin
is referred to the State Bar of Nevada;
IT IS ORDERED that no further action shall be taken by the Reno City Attorney's
Office, or the clerks or staff of Reno Municipal Court, in the above-entitled case, pending
further order of this court;
IT IS ORDERED that Zachary Barker Coughlin is barred and forbidden from faxing,
emailing, delivering. having delivered, serving. presenting for filing. personally or otherwise,
any motion or document to Reno Municipal Court, in the above-entitled case, pending further
order of this court."
One, Coughlin is not emailing this correspondence in that "above titled case (11 TR 26800) but in
connection with matters outside that case. Three, it is really not at all clear how Judge Nash
Holmes could make all those rulings, and only after having done that, decide to suspend the
proceedings for a Competency Evaluation, given the import of NRS 178.405:
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NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to

competence of defendant; notice of suspension to be provided to other departments.
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to

competence of defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial,
during trial, when upon conviction the defendant is brought up for judgment or when a defendant
who has been placed on probation or whose sentence has been suspended is brought before the
court, if doubt arises as to the competence of the defendant, the court shall suspend the
proceedings, the trial or the pronouncing of the judgment, as the case may be, until the question of
competence is determined.
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must
notify any other departments of the court of the suspension in writing. Upon receiving such notice,
the other departments of the court shall suspend any other proceedings relating to the defendant
until the defendant is determined to be competent.
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to
district court.
1. The justice shall, within 10 days after the notice of appeal is filed, transmit to the clerk of the
district court the transcript of the case, all other papers relating to the case and a certified copy of
the docket.
2. The justice shall give notice to the appellant or the appellants attorney that the transcript and
all other papers relating to the case have been filed with the clerk of the district court.
3. If the district judge so requests, before or after receiving the record, the justice of the peace
shall transmit to the district judge the sound recording of the case.
NRS5.073Conformity of practice and proceedings to those of justice courts; exception;

imposition and collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to
the practice and proceedings of justice courts in similar cases. An appeal perfected transfers the
action to the district court for trial anew, unless the municipal court is designated as a court of
record as provided in NRS 5.010. The municipal court must be treated and considered as a justice
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court whenever the proceedings thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are
within the jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS5.075Form of docket and records.The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary
from court to court according to the number and kind of cases customarily heard and whether the
court is designated as a court of record pursuant to NRS 5.010.
matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was
recording anything or whether he possessed a "recording device" until AFTER the one and only
restroom break Judge Nash Holmes mentions on the audio record. Judge Nash Holmes did ask
Coughlin if he had any proof that City Attorney's Wong and Ormaas failed, in some way, to
received or follow up on some offer by Coughlin to provide materials related to Coughlin's
contentions respecting the statement madAnd that sua sponte interrogation of Couglin occured
IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED
TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER
COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH
OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT
UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE
TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON
THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes
just couldn't be found, and how odd that was...which is odd, considering what was going on in 11
cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the
time (lots of reasons for and indications that local law enforcement and prosecutors and public
defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the
2/27/12 status conference between young and dogan that neither YOung nor Dogan wish to testify
about...but which seems to have been held anyways after a written communication of its being
reset was transmitted to Coughlin by Dogan, wherein, during the time Judge Nash Holmes couldn't
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be found (maybe she was at one of the group meetings amongst Judges about Coughlin that RMC
Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the
Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's
filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately
11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a
charge that was duplicative, even where YOung failure to allege theft or possessing/receiving
"from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8 violation,
which is YOung's specialty, apparently. That, and violating NRs 178.405, which YOung did by filing
in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to
Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12...never mind Young tried to
hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in cr12-0376
didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr
26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010)
here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt Order in 11 tr 26800 until July 2012...but did file a
Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order,
Judge Nash Holmes continues to refuse to follow NRS 189.010-050
It is true that contempt committed in a trial courtroom can under some circumstances be punished
summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a
trial judge of a contempt committed in his immediate presence in open court cannot be likened to
the proceedings here. For we held in the Oliver case that a person charged with contempt before a
"one-man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge
to punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S.
257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800,
also orders no sufficiently detailed or capable of being known how to comply with, not sufficient
warning, violat Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur
" in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have
misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash
HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again,
maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on
unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to
issue a "summary criminal contempt" conviction against an attorney, but also where Judge Nash
Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full
blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal
needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put
something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King
wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn
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testimony, but rather just some musings by Judge Nash Holmes purporting to make "rulings"
finding "by clear and convincing evidence" all sorts of things outside her jurisdiction) on 11/14/12,
on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the Subpoenas Coughlin
attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge
William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the
NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11
CR 26405 (the appeal was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got
Coughlin appeal of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary
suspension Order in cr11-2064, which was denied based upon a civil preparation of transcript down
payment rule, in that criminal appeal, where the RMC has a thing in place with this Pam Longoni
that violates Nevada law in that it refused to give Coughlin the audio cd of the trial for some time,
insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation would
absolutely not start until a down payment was made. Plus, even where Coughlin caved to the
payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
"bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list,
and upon information and belief, Coughlin faxed his request to the number the RMC held out for
her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN Judge Nash Holmes details some
concerns she has with Coughlin's work as a self representing attorney defending a traffic citation
(now NG12-0434, and perhaps, NG12-0435, depending upon whom you ask and what King means
by "Clerk of Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms.
Marilyn Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second Judicial
District Court Clerk of Court Joey Orduna Hastings that would need to send Family Court Judge
Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent
contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009 Order
was not filed by the RMC Judges?
AS to the application of the "courthouse sanctuary" doctrine to RMC Marshal Harley serving the
Order to Show Cause upon Coughlin at approximately 1:25 pm in one of the conference rooms right
outside the interior of Courtroom B at the RMC:
http://caselaw.findlaw.com/ny-district-court/1372465.html
"THE LAW
(COURTHOUSE SANCTUARY)
Despite antagonistic dicta to the contrary; most modern era precedent dealing with the issue of
Courthouse Sanctuary from service of process have held that New York State residents receive no
such immunity protections. Baumgartner v. Baumgartner, 273 A.D. 411, 77 N.Y.S.2d 668 (1st
Dept.1948); Department of Housing Preservation, City of New York v. Koenigsberg, 133 Misc.2d
893, 509 N.Y.S.2d 270 (N.Y. Civ.Ct.1986); Ford Motor Credit Co. v. Bobo, N.Y.L.J., 1 Misc.3d 901(A),
2003 WL 22928513 (Dec. 17, 2003, J. Miller, Nassau Co. Dist. Ct.) These cases hold that the
Courthouse Sanctuary is only available to foreign state residents who come into New York's Courts
to contest jurisdiction. This doctrine has been slightly expanded to include New York residents
who enter the jurisdiction of a New York Court of limited territorial jurisdiction to contest
jurisdiction. See Palazzo v. Conforti, 50 N.Y.S.2d 706 (N.Y. Civ.Ct.1944); Singer v. Reising, 154
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Misc. 239, 276 N.Y.S. 714 (Queens County 1935).

The Baumgartner Appellate Division panel also acknowledges a limited Courthouse Sanctuary
rule for New York residents if such service would constitute a disturbance directly tending to
interrupt the proceedings of the Court or to impair the respect due its authority. This rule
by itself would not be applicable to the instant case as service of process was effected in the
Courtroom but outside the Court's presence and in between calendar calls.
STATE RESIDENCY IMMUNITY DISTINCTION?
The English Common Law made no New York State residency distinction. The doctrine of
immunity from arrest of a litigant attending a trial of an action to which he is a party found early
recognition and dates back to the book of 13 Henry IV, J.B. Sampson v. Graves, 208 A.D. 522, 203
N.Y.S. 729 (1st Dept.1924). This is for the obvious reason that England had no sovereign states.
The privilege is not a creature of statute, but was created and deemed necessary for the due
administration of justice. See Matthews v. Tufts, 87 N.Y. 568 (1882); citing to Van Lien v. Johnson
(N.Y. Ct. Appeals, unreported 1871).
The logical question now arises, exactly when did New York's Appellate Court's recognize a
residency distinction for application of the Courthouse Sanctuary? The answer is that the Court
of Appeals never established such a rule. In contra point of fact, the Court of Appeals has opined
that:
It is the policy of the law to protect suitors and witnesses from arrests upon civil process
while coming to and attending the court and while returning home. Upon principle as well
as upon authority their immunity from the service of process for the commencement of civil
actions against them is absolute eundo, morando et redeundo. Person v. Grier, 66 N.Y. 124
(1876). Emphasis Added.
In this unanimous opinion, the Court of Appeals expressly addressed the New York State resident
immunity distinction and established in its dicta that whether any distinction should or does in
fact exist, is at least doubtful. This immunity is one of the necessities of the Administration of
Justice, and Court's would often be embarrassed if suitors or witnesses, while attending Court,
could be molested with process. It is noted that Person involved a foreign state resident. In
establishing the sanctuary doctrine, the Court stated that this rule is especially applicable in all
its foreign suitors . By direct implication, the Court of Appeals is also applying the protective
rule to New York residents.
The basis of the Courthouse Sanctuary rule is that parties should be allowed to contest
jurisdiction without submitting to it. Allowing Re-service makes a mockery of the traverse
hearing and essentially allows the plaintiff to use a defective default judgment as a weapon to
compel the defendant to submit to the service of process. Ford Motor Credit Co. v. Bobo; cite
supra. The location of an individual's residence does little to legitimize such a mockery. Absent
the compulsion of clear controlling precedent; this Court will not condone such a situation..."
NRS 266.595 Appeals. Appeals to the district court may be taken from any final judgment of the
municipal court in accordance with the provisions of NRS 5.073.
NRS5.073Conformity of practice and proceedings to those of justice courts; exception;

imposition and collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to
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3/5/13
the practice and proceedings of justice courts in similar cases. An appeal perfected transfers the
action to the district court for trial anew, unless the municipal court is designated as a court of
record as provided in NRS 5.010. The municipal court must be treated and considered as a justice
court whenever the proceedings thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are
within the jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS5.075Form of docket and records.The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary
from court to court according to the number and kind of cases customarily heard and whether the
court is designated as a court of record pursuant to NRS 5.010.
NRS5.010General requirements for court; designation as court of record.There must be in

each city a municipal court presided over by a municipal judge. The municipal court:
1.Must be held at such place in the city within which it is established as the governing body of
that city may by ordinance direct.
2.May by ordinance be designated as a court of record.
The personal service by Marshal Harley of the Order to Show Cause in the appeal of the summary
eviction matter from Coughlin's former home law office at 121 River Rock St, with Richard G. Hill,
Esq. as opposing counsel in CV11-03628, occurred while Coughlin was speaking to RCA Ormaas in
attempts to resolve the matter (11 TR 26800 a traffic citation matter wherein RPD Sargent Tarter
and other officers responded to Richard G. Hill, Esq.'s office on 11/15/12 (its possible both Hill and
Coughlin called the police and or 911...can't remember) when Coughlin appeared there after being
released from 3 days in jail incident to the 11/13/12 criminal trespass arrest (now a conviction and
discussed in that attached materials, some of which appear on the Nevada Supreme Court's site
under case 61901, the conviction stemming from 11 CR 26405 before RMC Administrative Judge W.
Gardner, the brother of District Court Judge Linda Gardner whose April 2009 Order sanctioning
Coughlin was cited by Washoe Legal Services at the cause for his firing, and led to 60302, now on
appeal...
I would really just like to move on from all of this, but this is a time of exigent circumstances, and if
the RMC and the City of Reno Marshals do not take affirmative steps to disavow the unsworn
hearsay Judge Nash Holmes attributed in her supposedly sworn testimony at Coughlin's 11/14/12
000373
3/5/13
Disciplinary Hearing, it may be that a negligent hiring, training, or supervision cause of action may
acrue against various Marshals, even personally (and its not so clear Mr. Christensen and the City
of Reno would extend any purported representation to such personal liability, for, say, slander or
libel).
NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in
judicial duties at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial
proceeding.
2. A breach of the peace, boisterous cond uct or violent disturbance in the presence of the court, or in its immediate
vicinity, tending to interrupt the due course of the trial or other judicial proceeding.
3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge
at chambers.
6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the
presence of a juror concerning an action in which the juror has been impaneled to determine, or in any manner
approaching or interfering with such juror with the intent to influence the verdict.
7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or
process of the court.
[1911 CPA 452; RL 5394; NCL 8941](NRS A 1983, 843)
NRS 22.030 Summar y punishment of contempt committed in immediate view and pr esence of cour t; affidavit or
statement to be filed when contempt committed outside immediate view and pr esence of cour t; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may
be punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection,
the court or judge shall enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit
must be presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters
or arbitrators.
3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence
of the court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the
contempt over the objection of the person. The provisions of this subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was
entered in such court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings
for the violation of the judgment or decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been established in the
judicial district.
NRS 22.100 Penalty for contempt.

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1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall determine whether the
person proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be imposed on
the person not exceeding $500 or the person may be imprisoned not exceeding 25 days, or both.
3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt pursuant to
subsection 3 of NRS 22.010, the court may require the person to pay to the party seeking to enforce the writ, order,
rule or process the reasonable expenses, including, without limitation, attorneys fees, incurred by the party as a
result of the contempt.
NRS 199.340 Cr iminal contempt. Every person who shall commit a contempt of court of any one of the following kinds
shall be guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its immediate view and
presence, and directly tending to interrupt its proceedings or to impair the respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or hearing pursuant to an
order of court, or in the presence of a jury while actually sitting in the trial of a cause or upon an inquest or other
proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or
referee;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer any legal and proper
interrogatory;
ARTICLE IV - Judicial Department

Sec.4.010Municipal Court.The Municipal Court must include one department and may include
additional departments in the discretion of the City Council. If the City Council determines to create
additional departments, it shall do so by resolution and may appoint additional municipal judges to
serve until the next election.
(Ch. 662, Stats. 1971 p. 1976; ACh. 553, Stats. 1973 p. 881; Ch. 373, Stats. 1979 p. 645; Ch. 208,
Stats. 1985 p. 675; Ch. 9, Stats. 1993 p. 21)
Sec.4.020Municipal Court: Qualifications of Municipal Judge; salary.
1.A Municipal Judge must be:
(a)An attorney licensed to practice law in the State of Nevada.
(b)A qualified elector within the City.
2.A Municipal Judge shall not engage in the private practice of law.
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3.The salary of a Municipal Judge must be:

(a)Fixed by resolution of the City Council.
(b)Uniform for all judges in the Municipal Court.
(Ch. 662, Stats. 1971 p. 1976; ACh. 343, Stats. 1973 p. 422; Ch. 553, Stats. 1973 p. 881; Ch. 98,
Stats. 1977 p. 211; Ch. 561, Stats. 1977 p. 1395; Ch. 208, Stats. 1985 p. 675; Ch. 599, Stats. 1993 p.
2501; Ch. 327, Stats. 1999 p. 1369)
Sec.4.030Disposition of fines.All fines and forfeitures for the violation of ordinances shall be
paid to the City Clerk in the manner to be prescribed by ordinance.
(Ch. 662, Stats. 1971 p. 1977)
Sec.4.040Procedure, additional judges.The practice and proceedings in the Court must
conform as nearly as practicable to that of justices courts in similar cases. Upon the written
request of the City Manager an additional temporary Municipal Judge may be provided for so long
as the City Council authorizes additional compensation for such a Judge. Whenever a person is
sentenced to pay a fine, the Court may adjudge and enter upon the docket a supplemental order
that the offender may, if he or she desires, work on the streets or public works of the City at the
rate of $25 for each day. The money so earned must be applied against the fine until it is satisfied.
CONTEMPT
Acts or omissions constituting, generally, 22.010
Affidavit of facts constituting, 22.030
Affidavits presented in bad faith, NRCP 56(g), JCRCP 56(g)
Appearance, failure of defendant to make, 22.130
Arrest
Bond, 22.070
Excuses for not bringing arrested person before court, 22.140
Illness of defendant, effect, 22.140
Attorneys at law
Bar examination, early release of results, SCR 68
Discharged, failure to deliver certain materials to client, 7.055
Bail
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Violation of conditions deemed contempt, 178.484

Commercial premises, violations of writ of restitution, 118C.210
Commission in presence of court or judge, 22.030
Compelling performance, imprisonment, 22.110
Court order, violation, 1.250, 22.010
Court reporters, 656.240
Criminal, 193.110, 193.300, 199.340
Custodial parent, failure to comply with visitation orders, 125C.030, 125C.040
Discharge from arrest, 22.070
Disqualification of judge or justice, making of charge not punished as contempt, 1.225, 1.230
Documents, refusal to permit inspection, NRCP 37(b)(2), JCRCP 37(b)(2)
Failure to perform specific acts directed by judgment, 22.010, NRCP 70, JCRCP 70
Imprisonment, 22.100, 22.110
Indictment for contemptuous conduct, 22.120
Justice courts, civil proceedings, 74.040
Material witness granted immunity, failure to testify, 178.576
Misconduct by defendant during criminal trial, 175.387
Municipal court may punish for, 266.570
Punishment, 22.030, 22.100, 22.120
Reentry on real property after ejectment, 22.020
Refusal to answer or be sworn, 22.010, 50.195, NRCP 37(b)(1), JCRCP 37(b)(1)
Sheriffs duties, 22.060, 50.205
Subpoenas, failure to obey
Deemed contempt, 22.010, 174.385
Witnesses, forfeitures and damages, 50.195
Summary punishment, 22.030
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Trials for contempt

By court or jury, 22.100
Disqualification of judge, 22.030
Investigating charge, 22.090
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC
and Wal-Mart are in a long term business partnership where the 2nd St. WalMart is on tribal land rented out by the RSIC and patrolled by its tribal
officers, who admit to routinely making misdemeanor petty theft/shoplifting
custodial arrest (Officer Kameron Crawford and Donnie Braunworth have
been trained in all the neato "he didn't give me all the information necessary to
issue a citation" explanations (including Crawfords lying under oath that
Coughlin didn't provide his driver's license to him on September 9th, 2011,
especially where Wal-Mart's Frontino admits he did not make a citizen's
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests
by tribal officers are forbidden under NRS 171.1255.. Reno City Attorney too
would like a chance to explain how she prosecutes cases based upon arrests
by tribal officers for misdemeanor where Nevada law expressly prevents
misdemeanor arrests by tribal officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the
11/14/12 Disciplinary Hearing, and the SBN and Panel's violations of SCR
105 contributed greatly to my failure to alert Mr. Garin prior to that. I think
out of fairness I and Mr. Garin/Ms. Nordstrom should be provided transcripts
from the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or
police officer employed by Indian tr ibe.
1. Except as otherwise provided in subsection 2, an officer or agent of the
Bureau of Indian Affairs or a person employed as a police officer by an Indian
tribe may make an arrest in obedience to a warrant delivered to him or her, or
may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents
presence.
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3/5/13
(b) When a person arrested has committed a felony or gross misdemeanor,

although not in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the
officer or agent has reasonable cause for believing the person arrested to have
committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony
or gross misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a
named or described person for a public offense, and the officer or agent has
reasonable cause to believe that the person arrested is the person so named or
described.
(f) When the peace officer has probable cause to believe that the person to be
arrested has committed a battery upon that persons spouse and the peace
officer finds evidence of bodily harm to the spouse.
(a) Within the boundaries of an Indian reservation or Indian colony for an
offense committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the
officer or agent is in fresh pursuit of a person who is reasonably believed by
the officer or agent to have committed a felony within the boundaries of the
reservation or colony or has committed, or attempted to commit, any criminal
offense within those boundaries in the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning
ascribed to it in NRS 171.156.
Please see the photograph in the attached materials of the RSIC Officer taking
Coughlin's driver's license from him, thereby vitiating his assertion that an
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3/5/13
arrest was an available option due to Couglin not providing his driver's
license to the Officers.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11TR26800 031412 RMC continuation of trial Nash Ormaas Hill traffic citation 031412_201203121033_01cd003b8f0851d0.mp3
11TR26800 RMC 022712 part 2 of 2 from 2 27 12 031412_20120227-1621_01ccf56bce224540.mp3
11TR26800 RMC 022712 part 1 of 2 from 2 27 12 031412_20120227-1507_01ccf5618f76c460 (2).mp3
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS
26406 1708 26800 NG12-0204.pdf
CR12-1262 appeal.pdf
11 2 12 file stamped complete notice of errata and revised supplemental 26405 1708 0204.pdf
11 15 11 rpd tarter redacted 0204 0434 26800 police report ormaas retaliation.pdf
Download all
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000396
for "misuse of 911" even though Coughlin received two protection orders in FV12
00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the
night upon his walking to his car after being released from jail on a 15 degree night on
1/13/12, where five other RPD Officers helped Officer Duralde with the pressing matter
of the sudden disappearance of Coughlin's license plate...), (all suspiciously close in
time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12 with the
RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying that
dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a
possible fight" thus supporting their reponse and the associated Terry Stop weapons
check frisk pat down and custodial arrest for a misdemeanor allegedly occuring outside
their presence after 7 pm:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another
alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is
committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the manner
provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued pursuant to NRS
33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and WalMart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
all the information necessary to issue a citation" explanations (including Crawfords
lying under oath that Coughlin didn't provide his driver's license to him on September
9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
000529
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
chance to explain how she prosecutes cases based upon arrests by tribal officers for
misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12
Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of

Indian Affairs or a person employed as a police officer by an Indian tribe may make an
arrest in obedience to a warrant delivered to him or her, or may, without a warrant,
arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not
in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or
agent has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross
misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or
described person for a public offense, and the officer or agent has reasonable cause to
believe that the person arrested is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested
has committed a battery upon that persons spouse and the peace officer finds
evidence of bodily harm to the spouse.
(a) Within the boundaries of an Indian reservation or Indian colony for an offense
000530
committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or
agent is in fresh pursuit of a person who is reasonably believed by the officer or agent
to have committed a felony within the boundaries of the reservation or colony or has
committed, or attempted to commit, any criminal offense within those boundaries in the
presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to
it in NRS 171.156.
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts
with my father, Palmer v. Pioneer, etc.
So, this is the Elcano approach...he gets an email on 4/19/12 that is a written
employment law centered complaint from an employee...and he has the employee
suspended within days thereafter...then claims to have not received the email, then
adopts some Duluth Model "Power and Control" wheel co-opting or leveraging of
"treatment" or armchair psychiatry...
Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79. Stephen
Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction resulting in 6/7/12
temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82 (twice
Coughlin's RMC court appointed counsel, allowed to withdraw with pay both times,
refused to advocate in any way). Gammick, McGeorge '82. Springgate, McGeorge '85
(opposing consel in ng12-0435 asking for sanctions in divorce case closing argument).
Kandaras, McGeorge '91 (Deputy District Attorney involved in warrantless seizure of
Coughlin's smart phone. DDA Z. Young, McGeorge '04. Hazlett-Stevens, McGeorge,
'06.
What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned
Coughlin about "recording devices" and or whether he was recording BEFORE the one
restroom break, purposefully changing the order of the questioning and the restroom
break to suggest some furtive activity on Coughlin's part, which Judge Nash Holmes
then further attempted to amplify in her assertion that Marshal Joel Harley was ordered
to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin
"disassembled a recording device" in the restroom and "hid a part or portion of it in the
000531
restroom"
Fraud on the court Conduct of counsel in omitting portion of deposition when

deposition is read into record, and giving impression that entire document is being
proffered, resulting in buttressing of his party's position is fraud on the court warranting
the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d). Sierra Glass &
Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119, rehearing denied.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events
and when she asked Coughlin her questions about recording, considering when a restroom break took place
an exactly what it is she asked Couglin and when, and what his responses were, and when some allegations
by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript
reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering
from some extreme form of mental illness. during the trial I asked the defendant
attorney repeatedly if he was recording the proceedings he denied that vehemently a few
times and then he quote took the fifth a few other times and then he requested to be
excused to go to the bathroom and the Marshal later reported to me that while the
gentleman was in the bathroom he disassembled a recording device in his pocket and
took the memory out of it and it was later found in that, uh, by the Marshal no one else
had gone into the bathroom and that was retrieved and it was put into his possession at
the Sheriff's office and when they booked him into jail for the contempt charge that was
booked into evidence and I asked the Sheriff's office to hold that into evidence. I believe
he has violated Supreme Court Rule 229(2)(B) which was amended by ADKT 440,
August 1st, 2011...."
unattributed hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the
SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following
her statement at the 7 minute mark that "It appears to me in this case that the defendant is
suffering from some extreme form of mental illness." Further, that which Judge Nash Holmes
had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be
testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the judge
about her mental processes" loophole, as he has done.
000532
Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12
"simple traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office
to get his driver's license, wallet, keys, and client's files following a custodial arrest for
trespass (see RPD Sargent Lopez and Officer Carter's explanations thereof in 11 CR 26405
and 61901) and three days spent in jail, upon being released therefrom on 11/15/12...and at the
Trial on that traffic citation issued by RPD Sargent John Tarter, RMC Marshal Joel Harley,
just before Trial (when Judge Nash Holmes couldn't be found and WCPD Biray Dogan and
DDA Zach Young were getting an Order for Competency Evaluation of Coughlin in rcr2012
065630 at 1:31 pm...and the 11 TR 26800 Trial starting late, not at 1 pm as noticed, but at 3
pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges
wherein they brainstormed ways of combating Coughlin's championing of due process rights
for the disenfranchised...
whether the citation or report in 11 tr 26800 contained any mention of retaliation, given she
was looking right at it and given what she said in court. Also, the whispering with Marshal
Harley, and the bits about Coughlin reporting to Ormaas what RPD OFficer Carter said to
Coughlin in 61901, and Ormaas's responses thereto on 2/27/12, and Dan Wong, ditto at an
earlier hearing on that matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was
recording anything or whether he possessed a "recording device" until AFTER the one and only
restroom break Judge Nash Holmes mentions on the audio record. And that sua sponte interrogation
of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH
JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL
PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL
PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY
CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT
UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY
BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S
ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that
was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr
26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that
local law enforcement and prosecutors and public defenders were non too happy with Coughlin...and
consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that
neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the
time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst
000533
Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the record in
11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation
for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin
of approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr2011
063341 to add a charge that was duplicative, even where YOung failure to allege theft or
possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case
a RPC 3.8 violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which
YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an
Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind
YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in
cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC
11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs
5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a
Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge
Nash HOlmes continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript,
yay....
It is true that contempt committed in a trial courtroom can under some circumstances be punished
summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a
trial judge of a contempt committed in his immediate presence in open court cannot be likened to the
proceedings here. For we held in the Oliver case that a person charged with contempt before a "one
man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge to
punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S. 257.
Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also
orders no sufficiently detailed or capable of being known how to comply with, not sufficient warning,
violate Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur
" in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have
misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash
HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again,
maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on
unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to issue a
"summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes
appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR
105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to sign an
affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record,
000534
under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash
HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing
evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar
Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge
Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin
faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was
dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11
cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
was denied based upon a civilpreparation of transcript down payment rule, in that criminal appeal,
where the RMC has a thing in place with this Pam Longoni that violates Nevada law in that it
refused to give Coughlin the audio cd of the trial for some time, insisting only Longoni would be
allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down
payment was made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly
hung up the phone on him and otherwise ignored his communications (there may be an issue of the
email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit as
to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his
request to the number the RMC held out for her on her behalf too...
NG12-0435 (stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed
Court (I'd bet its from the RMC Clerk of Court, whom King purported to have certified documents
from a Court she doesn't even work for at the 11/14/12 Disciplinary Hearing...but then again, Panel
Chair Echeverria allow WLS's Elcano to certify documents just because he claimed to have watched
a tape of a hearing, where Elcano is neither a licensed attorney, nor does he work for any Court....),
depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12
email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that
would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to
the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting
of Judge L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court
Orduna Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to
bar counsel reads:
"
Dear Mr. Clark:
000535
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker
Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this attorney being
experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what should be
a simple traffic citation case are self-explanatory and are included, together with copies of massive documents Me.
Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also included.
He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge
being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him between cases very
easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9th St. #2
Reno NY 89512), although I heard today he may be living in his vehicle somewhere. We do have an address for his
mother, however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr.Coughlin late last year that is now on appeal to the Second
Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in his court with Mr.
Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order, simply
because they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made you
some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him and
him and him and him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You
can see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant
was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed for Contempt of Court and
they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your
pursuit of this matter. Mr.Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff and
even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a caseof some urgency,
and I apologize for taking two days to get this package to you; our IT person was ill and could not make the copies of
the audios of Mr.Coughlin's hearings until today, and I felt it was important that the audios be included in the materials
to be considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of
law in Northern Nevada and could be jeopardizing someone's freedom or property interests. "
Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is
easily proven to be patently false at Disciplinary Hearings (to the extent one is allowed to offer
such proof, which Panel Chair Echeverria invariably rules is "not relevent" and King smugly
basks in his SCR 111(5) vacation with his "Clerk of Court" Laura Peters...whose lies about
000536
SCR 105(4) resulted in Panel Chair Echeverria quashing all subpoenas Coughlin issued,
including those to which SBN Bar Counsel Pat King filed on behalf of his former co-worker at
the AG's Office, Reno City Attorney Dan Wong...While the other Reno City Attorney, Creig
Skau, kept Coughlin busy with his lies about "the judge authorized me to serve you by
email"...
Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000537
F I LED
Case No. 11CR 22176

Dept. 4
:eM
DEC 1 5 2011
NI
Court
Dept 4
Deputy CIe!'I<
IN THE MUNICIPAL COURT OF THE CITY OF RENO

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COUNTY OF WASHOE, STATE OF NEVADA

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CITY OF RENO,
Plaintiff,
ORDER
vs.
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ZACHARY BARKER COUGHLIN,

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Defendant.
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--------/
On November 30, 2011, Defendant Coughlin was found guilty of the
offense of Petit Larceny, a violation of RMC 8.10.040. Thereafter, Appellant filed his
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Notice of Appeal on December 13, 2011. Additionally, Defendant Coughlin filed a
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Motion to Vacate and/or Set Aside, Motion for Reconsideration, Motion for Recusal
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and Motion for Publication of Transcript at Public Expense.
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Appellant Coughlin
requested that he be provided the trial transcript at public expense on the basis that
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he was indigent.
On November 14, 2011, Defendant Coughlin filed a Motion to
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Proceed In Forma Pauperis wherein he seeks a waiver of certain fees due to his
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asserted indigence.
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A. FAILURE TO PROPERLY SERVE CITY ATTORNEY
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Written motions are to be served upon each of the parties.
NRS
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178.582. Service upon the attorney or upon a party must be made in the manner
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provided in civil actions. NRS 178.584.

1
---_ ._--- -----
._-_.---...
. "'-'
"
000538

has chosen to serve the City Attorney with these various
Appellant
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pleadings via electronic mail. There is no provision in the Nevada Revised Statutes or
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the Rules of Court which denotes electronic mail as an appropriate means of service
of process. This alone is a basis for non-consideration/denial of Appellant's various
requests.
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B. MOTION FOR PUBLICATION OF TRANSCRIPT AT PUBLIC EXPENSE and

MOTION TO PROCEED IN FORMA PAUPERIS
Defendant Coughlin cites to NRS 12.015 as authority for allowing him to
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issue "any, necessary writ, process, pleading or paper without charge, with the
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exception of jury fees because I lack sufficient financial ability to proceed without this
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waiver".
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Appellant Coughlin's reference to NRS 12.015 is misplaced as that

provision refers to civil procedure. He cites no other authority for his request.
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This case has gone to verdict and the defendant was found guilty. It is
difficult to see what additional costs will be incurred by Appellant Coughlin other than
the trial transcript. This is not a complex case with numerous factual or legal issues.
Mr. Coughlin is a licensed attorney-at-law who implied during trial that
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his incarceration for contempt would adversely affect his clients. Yet, Mr. Coughlin, in
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his "affidavit of poverty" does not indicate any income from his practice of law. Of
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note, Mr. Coughlin posted cash bail during the litigation of the instant matter.
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This Court has not been provided sufficient information to determine Mr.
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Coughlin's indigency status and will not grant him carte blanche authority to continue
the fishing expedition he conducted during the trial of this matter. Appellant's motion
to further pursue this matter at public expense is denied.
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000539
C. MOTION TO VACATE AND/OR SET ASIDE, MOTION FOR
RECONSIDERA TION AND MOTION FOR RECUSAL
These motions will not be addressed as Defendant Coughlin has not
submitted a basis for their consideration.

5
IT IS HEREBY ORDERED that Defendant Coughlin's Motion to Proceed
In Forma Pauperis and Motion for Publication of Transcript at Public Expense is
DENIED.
IT IS FURTHER ORR DERED that the Motion to Vacate and/or Set
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Aside, Motion for Reconsideration and Motion for Recusal are presently DENIED.
DATED this
/5
'UI.
day of December, 201 .
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000540
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CERTIFICATE OF SERVICE
Pursuant to NRCP 5(b), I certify that I
am
an employee of the Reno MuniciIRI Court,
Reno, Nevada, and that on this date I served a true and correct copy of the foregoing document,
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ORDER on the party(ies) set forth below:
Placing said document in a sealed envelope placed for collecting and mailing in the
United States mail, at Reno, Nevada, postage prepaid, following ordinary business
practices.
Facsimile to :
Reno/Carson Messenger Service.
Federal Express or other overnight delivery.
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Inner-office mail following ordinary business practices.
Personal Delivery.
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City Attorney's Office
Zachary Coughlin
Post Office Box 1900
817 N. Virginia Street, #2
Reno, Nevada 89509
Reno, Nevada 89501
DA TED this
JlL day of Dec mber,
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000541
REPRINTED RECEIPT
RENO JUSTICE COURT 1 South Sierra Street Reno, NV 89501
Receipt No.
Payor
Coughlin, Zachary
817 N Virginia ST N
Reno, NV 89501
2012-00393
Transaction Date
12/22/2011
Amount Paid
Description
On Behalf Of Coughlin, Zachary
REV2011-001708
Matthew Merliss vs. Zachary Coughlin
Bond Account
Cash Bond
SUBTOTAL
250.00
250.00
PAYMENT TOTAL
1L-.
250.00
250.00
0.00
Total Tendered
Change
Cashier PSizemore
Station 266102
250...;:....; ....J
00
:...
____
Cash Tendered
03/0M2012
09:08 AM
Audit
4567694
REPRINTED RECEIPT
000542
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Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
tel and fax 949 667 7402
IN THE STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA
)
PLAINTIFF
)
NG12-0204, NG12-0434, NG12-0435
)
V.
ZACHARY B COUGHLIN
)
RESPONDENT
)
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)
Rule 103(7) challenges for cause and SCR 105(2)(a) Motion to remove
Panel Chair Echeverria and Panel Member Kent; Post-Hearing Brief, or, alternatively,
vs.
Motion for Leave to File Post-Hearing Brief; Motion to proceed in forma pauperis and for
immediate release of recordings of 11/14/12 HEARING AND WHATEVER
TRANSCRIPT MATERIALS CURRENTLY EXISTS TO BE RELEASED TO
COUGHLIN ABSENT AN PAYMENT UP FRONT WHATSOEVER; MOTION FOR
MISTRIAL; MOTION FOR RECONSIDERATION OF ORDER QUASHING
SUBPOENAS, AND ORDER DENYING MOTION TO BIFURCATE;
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000543
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http://sdrv.ms/XmRkVL
coughlin apologizes for the formatting and length and is doing his best but this is a natural
byproduct of bar counsel bathing in scr 106 immunity and completely destroying any notions of fair play
incident to the 11/14/12 Disciplinary Hearing, justiyin SCR 119(3) contempt snactions against bar counsel
for all the attendant due proceed, notice, and service violations arising therin.
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included herein is an excusable neglect basis or good cause for reinstating the appeal beyond the fact that the
$250 filing fee was paid and the receipt and or docket show it was paid for this case...and an ifp is pending in
the associate 60331.
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Supreme Court has obligation in disciplinary proceeding to look beyond label given to attorney's
conviction to true nature of facts, in order to determine whether underlying circumstances of
conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd. 3. State Bar of Nevada
v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39
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2. Indictment
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Where the only relevant factual allegation contained in Disciplinary Board's affidavit, filed in support of its
petition for attorney's temporary suspension from the practice of law, was that a criminal indictment had
been filed against the attorney, this sole allegation, without more, was insufficient to justify summary
suspension and the immediate imposition of temporary restrictions. Sup.Ct.Rules, Rules 102, subd. 4(a),
111, subd. 1. Matter of Monteiro, 1984, 684 P.2d 506, 100 Nev. 440. Attorney And Client 48
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3. Serious crime
Attorney was not convicted of serious crime within meaning of rule regarding attorney suspension where
attorney did not engage in any criminal conduct whatsoever, did not engage in a conspiracy, and actually
entered plea of nolo contendere to nonexistent offense. Sup.Ct.Rules, Rule 111, subd. 2. Sloan v. State Bar
of Nevada, 1986, 726 P.2d 330, 102 Nev.
436. Attorney And Client 39
request to combine or consolidate appeals where legally tenable this appeal with 60331
and amendment to case appeal statmeent and clarification of notice of appeal incident
thereto to indicate that D7's 3/30/12 Order in included amongst those appealed.
couglin hereby reserves all defense under nrcp 12 g:(h) Waiver or Preservation of Certain Defenses.
(1) A defense of lack of jurisdiction over the person, insufficiency of process, or insufficiency of service of
process is waived (A) if omitted from a motion in the circumstances described in subdivision (g), or (B) if it
is neither made by motion under this rule nor included in a responsive pleading or an amendment thereof
permitted by Rule 15(a) to be made as a matter of course.
(2) A defense of failure to state a claim upon which relief can be granted, a defense of failure to join a party
indispensable under Rule 19, and an objection of failure to state a legal defense to a claim may be made in
any pleading permitted or ordered under Rule 7(a), or by motion for judgment on the pleadings, or at the trial
on the merits.
(3) Whenever it appears by suggestion of the parties or otherwise that the court lacks jurisdiction of the
subject matter, the court shall dismiss the action.
- 2/71 -

000544
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Time to add some more Richard G. Hill, Esq. chestnuts to the lie pile, especially
considering Hill's testimony under oath at Coughlin's 11/14/12 Disciplinary Hearing and
the follow sworn testimony by Hill from the 6/18/12 Trial, viewed in conjunction with the
statements Hill made to the RPD Officer Chris Carter and Sargent Marcia Lopez just prior
to and at the time of the 11/13/11 custodial arrest of Coughlin at his former home law
office for trespassing:
THE COURT: When Mr. Hill is here to ask some questions that I think
you've explored the possibilities, and I don't know what else you can offer
the Court in terms of this case via cross-examination.
MR. COUGHLIN: Yes, sir, Your Honor. I'll wrap this up quickly. BY
MR. COUGHLIN: Q Mr. Hill, at any time on that day, November 13th,
did the owner of the premises warn the arrestee to leave the property?
A
I think the message was communicated.
Q
Via what medium?
A
The fact that you were handcuffed and arrested. Didn't
you get the picture?
Q Okay, prior to the handcuffing and the arresting, did anybody say, "You
need to leave the premises?" A I didn't hear that. Q Nobody said that? A I
did not hear that, sir. Q Did you say it? A No. Q Did Dr. Merliss? A Not
that I heard. Q Did the police? A No, not that I heard. Q So, nobody that
you heard of warned the person
arrested for trespassing?
Page -1 1 0Copperfretti v. Shephard, 271 N.Y.S. 284 N.Y.App.Div.2.Dept.,1934
Tenant held entitled to set aside default judgment in summary proceedings
on showing that landlord acquired title under void judgment, irrespective
of tenant's excuse for default or defense upon merits.
I, Zach Coughlin, declare under penalty of perjury, pursuant to NRS
54.045 that the following numbered statements are true and correct to the
best of my knowledge:
1. The locksmith who did the lockout on 1/11/11 is named Sean
Cheathum of All American Lock & Safe P.O. Box 51869 Sparks, Nevada
89435-1869 (775) 626-5397. Mr. Cheathum indicated to mer personally
that he arrived to do the lockout that day at, 11/1/11 at 121 River Rock St.
Reno, NV 89501 just about the time the Sheriff's two Deputies and the
two landlord's agents did and that it was getting very close to 5 pm. 5 pm
represented an urgent deadline to the landlord's agents and the Sheriff's
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000545
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Deputies, by which the lockout must be done, recalled Mr. Cheatum. Mr.
Cheathum indicated that the lockout occurred no earlier than 4:48 pm and
was fairly sure that it came down to the wire in terms of effecting the
lockout prior to 5 pm. Cheathum indicated that he postulated at the time
that the urgent 5 pm deadline was due to a wish by the landlord's agents
and the Sheriff to avoid running into the tenant should the tenant be
coming home from work after a typical 9 am to 5 pm schedule.
Cheathum's memories of that day are strong enough to specifically recal
the types of locks, the uniqueness of the location (mentioning how it was
near the Harrah's Auto Musuem, the Section 8 Housing to the South of
Court Street, and the Truckee River) and that the back door lock was very
easy to gain entrance through given that a key was broken off in it, which
enable him to open or pick the lock by merely turning a screw driver
pressed to it.
2. I spoke with Maureen and Roxy Silva of the Washoe County Sheriff's
Office on numerous occassions. On more than one occasions Ms. Silva
slammed the phone down on me in anger. However, on other occasions
she spoke at length about the way the WCSO carries out evictions,
particularly wit respect to the "within 24 hours of receipt of the Order"
language in NRS 40.253. Roxy Silva, Maureen, and Civil Division
Supervisor Liz Stuchell indicated that the WCSO received the "Eviction
Order" on 11/1/11 at 8:05 am, and that the data entered in there computer
system confirms this. Silva, "Maureen" and Stuchell also indicated that
the WCSO does not keep any records of when it receives Eviction Orders
beyond manually inputting the time that the Orders are taken from the fax
machine to which the Reno Justice Court sends such Orders (and RJC
Chief Civil Division Clerk Karen Stancil has indicated to Coughlin that it
is the usual custom and practice of the RJC to fax Eviction Orders over to
the WCSO the day the are entered or the next day. There is some
confusion over whether the 10/25/11 "Eviction Decision and Order"
signed by Judge Sferrazza on file stamped on that date is an "Order" and it
does appear that Ms. Stancil and Bonnie Cooper are correct in their
assertion that the typical RJC "form' eviction order is on a different "form"
or "template" than that 10/25/12 "Eviction Decision and Order". Whether
that means that 10/25/12 Order was not faxed to the Sheriff in accordance
with the "usual custom and practice" of the RJC does not seem clear, nor
has anyone with the RJC responded to requests for documentation or
information in that regard. Former IT employee Curtis Harvey may have
some information in that regard. Additionally, the RJC fax appears to
bare an incorrect time stamping fairly regularly. Further, Chief Civil
Clerk Stancil's apparently correct assertion that the WCSO does not file
anything along with their typical one page Affidavit of Service (which
bares a time stamping of sorts representing, apparently, when the lockout
was conducted...and WCSO's Deputy John Machen's Affidavit of Service
file stamped 11/7/11 indicates a time of 4:30 pm for "personally serving"
- 4/71 -

000546
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Coughlin. Locksmith Cheathum disputes Richard Hill's trial testimony in

11 CR 26405, where Hill indicates the WCSO attempted to "personally
serve" Coughlin the Eviction Order, but that Coughlin "ran away".
Cheathum indicates there was no indication any tenant was at the 121
River Rock location, nor was their any discussion by anyone there,
includign the two Sheriff's Deputies and two landlord's agents to that
effect. Hill admits to not having even been there for the lockout. Casey
Baker, Esq. testified on 6/18/12 that he and Sheri Hill were present and
waited with the Sheriff's deputies until "the locksmith finally arrived".
NOTE, Baker's Order of 10/27/12 is void in that it fails to included the
specific language called for in NRS 40.253(5), as the "within 24 hours"
language is not there, and Bakers testified as to this in 11 CR 26405, when
he also testified that he did somethign with the WCSO on October 28th,
2011 in connection with the lockout.
NOTE: COUGHLIN FILES T HIS WITH THE CAVEAT THAT, WHILE SOME SECTIONS
MAY BE A DECLARATION OR SAY SOMEYHIGN ABOUT PERJURY, COUGHLIN NEEDS MORE
TIME TO CLEAN THIS DOCUMENT UP, YET THE IMMINENT THREAT OF ATTACK AND OR
RETALIATION BY THE SBN, LOCAL PROSECUTORS, OR LAW ENFORCEMENT DICTATES
SUBMITTING THIS FILING NOW, DUE TO THE EXIGENCIES INVOLVED, WHICH EXISTS
SOLELY DUE TO THEIR MISCONDUCT AND IN NO WAY STEM FROM ANY FAILURE ON
COUGHLIN'S PART TO UNDERTAKE DUE DILIGENCE IN EVERY WAY.
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Docket entry for the trial court matter this case was appealed from, cv11-03628 (a Notice of Appeal was
filed, it appears on 7/30/12, though Coughlin may have filed one in jail, where Judge Linda Gardner's
brother (see Mandamus Petition by Coughlin against Linda Gardner in 54844 and the attached 8/17/11
recusal Order by Linda Gardner where she cites to the "I just outright hae a bias against you" judicial canon
in 2.11(a) in explianing her recusal...and that case proves, amongst other proof that the address Coughlin was
evicted from was indeed being used as and held out as the location for Coughlin's law practice (as was the
case on the www.nvbar.org contact information at the time for Coughlin, for over one year prior to the
unlawful summary eviction the subject of this appeal, along with the record setting attorney's fees by Judge
Patrick Flanagan, who refused to recuse himself despite he and Coughlin being former co-workers at Hale
Lane (now Holland & Hart) and there existing a multitude of basis incident thereto for a finding that recusal
000547
was mandatory) shows the impropriety of the Clerk of Court dismissing the appeal for lack of paying a filing
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fee. Couglhin was provided a receipt showing that he had paid the filing fee for 61383, and Coughlin has an
IFP pending in 60331. The docket confirms this in the trial court matter from which both of these appeals
stem:
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FILING
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06-SEP2012
04:55 PM
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Entry:
COUGHLIN, ZACHARY
APPEAL FEE PAID FOR THE 7-30-12 NOTICE OF APPEAL - IMAGE ATTACHED
TO JULY FILING
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The Nevada Supreme Court Docket seems to miss the part where Coughlin paid the filing fee in
61383 and one has to wonder, given Richard G. Hill, Esq. testifying before the NNDB that he is a member
of at Coughlin's 11/14/12 Dsiciplinary Hearing (largely predicated upon arrests that Hill directed the RPD to
make) given the appeal in 61383 was dismissed (without a signature by an actual Justice....) just days prior
thereto. 07/31/2012Filing Fee - Filing Fee dueFiling Fee due for Appeal.07/31/2012Notice of Appeal
Documents - Notice of Appeal/Proper Person Pilot ProgramFiled Notice of Appeal/Proper Person Pilot
Program. Filed certified copy of proper person notice of appeal.12-24129
07/31/2012Notice/Outgoing - Notice to Pay Supreme Court Filing FeeIssued Notice to Pay Supreme Court
Filing Fee. No action will be taken on this matter until filing fee is paid. Due Date: 10 days.12-24133
11/07/2012Order/Dispositional - Order Dismissing AppealFiled Order Dismissing Appeal. To date,
appellant has not paid the filing fee or otherwise responded to this court's notice. Accordingly, cause
appearing, this appeal is dimissed.12-35194
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Zach Coughlin, plaintiff, submits this filing (notice/ motion /objection) on his own behalf. Judge
000548
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Dorothy Nash Holmes just lied and lied under oath at Coughlin's 11/14/12 Disciplinary Hearing, especially
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with regard to her assertion that she, in the traffic citation trial in 11 TR 26800 that she held on February
27th, 2012 from 3:30pm to 4:45 pm, despite she and or the RMC being aware that Coughlin had been
ordered to have a competency evaluation by RJC Judge Clifton's Order of 2/27/12, baring a file stampe of
1:31 pm...which is just about the time that Judge Nash Holme's judicial assistant announced on the record in
open court that nobody with the RMC could seem to find Judge Nash Holmes, and how weird that
was....which was just about the time DDA Young and Biray Dogan held their "clandestine status
conference" in rcr2012-065630 case where DDA Young persists in his retaliatory prosecution of Coughlin
for calling 911 to report police misconduct causing Coughlin to perceive an emergency being present and a
danger to his safety...) Anyways, NRS 178.405 and NRS 5.010 require Judge Nash Holmes to "stay all
10
proceedings" when such competency issues or Orders arise...not to do what she did, which is plunge
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headlong into a retaliatory intent to find something to convict Coughlin for (Judge Nash Holmes
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transmogrified a traffic citation matter, for a "Boulevard Stop", ie, a "California Roll" into a full blown
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Disciplinary Hearing before the NNDB and State Bar of Nevada after she was coached up by Bar Counsel
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Pat King to make sure to find "by clear and convincing evidence" that Coughlin had violated some Rule of
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Professional Conduct or other (Nash Holmes decided to copy and past the whole lot of RPC's, and then
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proceeded to muse aloud in her 3/12/12 continuation of the traffic ticket trial in 11 tr 26800 that Coughlin
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had "probably" violated this or that rule...but when it came time to sign an Order, Judge Holmes remixed that
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and decided that Coughlin had done so by "clear and convicing evidence".. This traffic citation trial stems
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from Coughlin going to opposing counsel in the summary eviction from Coughlin's former home law office
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(Richard G. Hill, Esq. and Casey Baker, Esq) after he was released from 3 days in jail incident to Richard G.
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Hill's signing a criminal trespass complaint in 11 cr 26405 against Coughlin, after Hill and his neurologist
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client, Dr. Matthew Joel Merliss were able to lie to and with the Reno Police Department's Officer Chris
23
Carter, Jr. and Sargent Marcia Lopez about whether anyone issued Coughlin a trespass warning, whether the
24
police identified themselves as law enforcement prior to the landlord kicking the door to the basement down
25
(the police apparently did not feel strongly enough in their cause or right to be undertaking the actions they
26
did to kick the door down themselves...though, RPD Officer Carter to Coughlin later that day that "Richard
27
Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do" may need some
28
more consternation....though don't hold your breath waiting for Bar Counsel Patrick O. King, Esq. to
- 7/71 -

000549
undertake any, or Reno City Attorne's John Kadlic, Esq., Daniel Wong, Esq., or the prosecutor who
suborned all that perjury by Richard G. Hill, Esq. on the stand, Christopher Hazlett-Stevens, Esq.(Hazlett-
Steven's was provided indisputable video evidence showing that Hill's testiony was lies, at the 6/18/12
criminal trespass trial presided over by RMC Judge William Gardner, whom refused to recuse himself
despite Coughlin suing his sister, Judge Linda Gardner in 54844, and Judge Linda Gardner filing a grievance
against Coughlin in ng12-0435 (the SBN and NNDB held a disciplinary hearing on 11/14/12 despite the
panel not even being chosen until 10/30/12...don't worry though, Chair John Echeverria was able to step in
so quickly, that before Chair Susich's Order announcing Echeverria as Panel Chair could be staped to the
proof of service, much less mailed, Chair Echeverria had denied every Motion Coughlin filed and granted
10
everything Bar Counsel King could ask for...with the added plus that they (Bar Counsel Patrick O. King and
11
NNDB Chair J. Thomas Susich and, perhaps, some others) cooked up a Panel (despite the Complaint and
12
List set out fully in 61901...if the Office of the Clerk will file what Coughlin submitted for filing...which it
13
did not on May 24th, 2012 in 60838....
14
Why Bar Counsel Patrick O. King, Esq. and J. Thomas Susich, Esq. of the NVDETR (conflicted
15
out, or should have been via the matter of Maureen Cole, Esq. incident to her attempts to prevent Coughlin
16
from suing Washoe Legal Services in 2009...and its kind of hard to object to propsed Panel members when
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the SBN does not serve the Complaint under SCR 109, then submits fraudulent materials to indicate the SBN
18
has done so, just as Laura Peters and Patrick O. King, Esq. did with the 10/9/12 file stamped Notice of Intent
19
to Take Default (which Coughlin hereby swears under penalty of perjury that the USPS downtown Reno,
20
Vassar Station would not give to Coughlin in light of it only having $1.25 worth of postage printed out on it
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in the red "Pitney Bowes" SBN style typical of all SBN mailings (and where, and this is verfied by the
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SBN's Peter's certificate of mailing attached to that 10/9/12 Notice of Intent To Take Default, the SBN only
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sent that 10/9/12 file stamped NOITD via one method, certified mail,
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Some might call it the "McGeorge Mafia" but...that is a bit much, no? However, that law school,
which is renown for long failing out over two thirds of its class (despite glady taking their money while the
relationship lasted) may, to some, seem to produce a certian type of lawyer or judge....the good points?
Teamwork demonstrated in spades....the bad points? Well, some might say the teamwork is mostly directed
000550
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- 8/71 -

to retaliation, zero sum game playing, and "failing out" anyone who dares to cross them. Some might say
that....Coughlin is not saying that.
-more cooking up a fine Panel and Disciplinary Hearing by King, Susich, the Washoe County Sheriff's
Office and the Second Judicial District Court, Reno City Attorney's Office, and Washoe County District
Attorney's Office, and SBN: Judge Linda Gardner's bailiff (and she was present for both days of trial in the
divorce matter wherein Coughlin, on behalf of Washoe Legal Services represented a domestic violance
victim, and took a position supported by the majority viewpoint in American law (though WLS Executive
Director Paul Elcano claims Coughlin's performance in the hearing justified and was the "sole reason" for
Coughlin being fired from WLS- which makes convenient (maybe that "big favor Linda Gardner owes"
10
him?) the fact that Coughlin was really fired for a variety of reasons, and under the typical comparator
11
analysis in employment law, whistleblower retaliation laws, hostile work environment, discrimination, and
12
other laws...the way Elcano ran WLS (involved lots of "old boys and girls network" style intimidation and
13
influence rather than any actual managerial or executive skill or rolling up of one's sleaves...and Thursdays
14
always competely devoted to the skeet shooting range, and practially daily trips from the pharmacy to his
15
mother's home to deliver medications (despite most pharmacy's offering that service for free in Reno...and
16
even one instance shortly before Coughlin's firing where Elcano had Coughlin ghost write a 20 page or so
17
memorandum to the Nevada Department of Taxation that may well have managed to get WLS out of the
18
bind attendant to it entering a lease where the non-profit 503(c), WLS, would be required to pay the property
19
taxes on behalf of the private for profit, landlord...and lots of comparing Coughlin to Seabiscuit, constant
20
critiques of and enforcements of a "dress code" that applied only to Coughlin, etc., etc.)...Anyways, finally,
21
after over 8 months of Coughlin requesting the materials, the SBN King's arranged to have Coughlin's SCR
22
105(2)(c) rights raped a little less than the have been, in getting Chair Echeverria (whom works remarkably
23
fast in disposing of all of Coughlin's motion with a denial and granting all of Kings, and don't be fooled...the
24
Chair was appointed on October 30th, 2012, by October 31st, 2012 he was signing orders disposing of all of
25
Coughlin's Motions (though upon a cross examination of Chair Echeverria it became quite clear he had not
26
read practically anything of what Coughlin worked hard on and submitted to the SBN and the Chair (and the
27
Chair's ruling an a motion that he was not sent by any means other then electronic service is even more
28
evidence of the acceptance of such service by the SBN and the Panel...though now the Panel and SBN are
- 9/71 -
000551

attempting to "have it both ways" and alternately claim that King has forwarded all of Coughlin's filing on to
the Panel Members (but King got caught lying about that at the Hearing, to which Panel Member McGeorge
SOL class of 1980 Stephen Kent brazenly gave King a pass and indicated he wouldn't review the exhibits
attached to Coughlin filings anyway, including those containing "tape don't lie" excuplatory video and audio
evidence (and even where the Panel seeks to lazily rest on the language in SCR 111 about a "conviction is
conclusive proof" despite being presented with Claiborne and other authority (including 37 CFR 11.25(3)(a),
(c), which will likely result in the SBN and various local judges work being dissected in fine detail in a
federal setting given Coughlin's being licensed to practice patent law before the United States Patent and
Trademark Office (USPTO).
10
11
12
13
14
15
16
17
Also grounds for a mistrail in that SBN v Coughlin Disciplinary Matter are apparent where Reno
City Attorney Crieg Skau, Esq. appears to have lied about Judge Sferrazza ordering that an Emergency Ex
Parte Motion to Quash Coughlin's Subpoenas (seen both in the disciplinary proceeding and in the petty
larceny of an iPhone that Nicole Watson was videotaped admitting some guy found on the ground in
downtown Reno, and held aloft, (and this started off this whole ordeal with local law enforcement on
8/20/11) offered it up, then announced, loudly that he was going to "throw it in the river" if someone did not
claim it....
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Any assertion by the SBN that Respondent has actual notice of this the NOITD, the DoWSoe, or
any Supplemental to the Designation of Witnesses, and knowledge of such somehow excuses proper service
or process, misses the point. The Nevada Supreme Court has long acknowledged that notice of a litigation is
not a substitute for proper service of process. C.H.A Venture v. G.C. Wallace Consulting Engineers, Inc.,
794 P.2d 707, 709 (Nev. 1990). Similarly, Defendant's notice of this litigation does not excuse Plaintiff's
insufficient service and insufficent process process. As such the SBN's (and Hill just testified at the
11/14/12 Disciplinary Hearing and about matters related to this appeal even therein) holding the 11/14/12 in
such a matter as to unduly prejuedice or provide excusable neglect or good cause basis for any failure on
Coughlin's part to move this appeal along. But the thing is, is that the Clerk's Office rejected a filing of
000552
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- 10/71 -

Coughlin's just last week that spoke to the appeal bond (in short, Richard Hill, Esq. has it, by way of his
failing to comply with Nevada law respectign tenant's deposits.
So Judge Linda Gardner's April 2009 Order sanctioning attorney Coughlin personally, under NRS
7.085 (despite there being no service by McGeorge SOL Class of 1985 opposing counsel John Springgate,
Esq. of a filing ready 21 day safe harbor NRCP 11 Motion for Sanctions....but rather an impromptu Motion
by Springgate during closing argument about facts not in evidence in support of his Motion for Sanctions....
(and the Order for sanctions by Judge Linda Gardner took the biggest issue with Coughlin's saying, upon
being asked if he had one of the over 10 exhibits that were not bound or previously marked that Springgate
sought to introduce at trial. Coughlin hereby incorproates by reference (an nifty trick Bar Counsel King
10
manages to do in avoiding doing any actual work, Mirch style, by just attaching extremely suspect
11
convictions ("conclusive proof of guilt" according to King, Claiborne and Burleigh be damned), and,
12
though King did not actually make or reserve this argument or cite to any authority like the Mirch case to
13
support what he probably now wishes he had, therefore, seek to find support to rebut the objections Coughlin
14
preserved for the record as to the lack of notice, specificity, factual support for contentions or allegations,
15
service, service of process, sufficiency of either service of process (see Garin's argument in 60302...okay,
16
now apply those to King's blurry exhibits, which were often printed on both sides of the page and contained
17
fraudulent certificates of mailing). The thing is Judge Linda Gardner's Pre-Trial Order itself ruled that either
18
attorney in that trial, who sought to introduce more than 10 exhibits, would be required to have them bound
19
and marked with an index prior to trial and a copy thereof provided to oppsoing counsel. Yet, upon
20
Coughlin voicing concerns that are directly related to and in support of the rationale behind such an Order...
21
(Coughlin is quoted in the Order as saying, in response to whether he has some document that Springgate
22
sought to introduce as about his 12th or 13th Exhibit where Judge Linda Gardner's April 2009 Order reads :
23
"The Court notes that at one point, after an exhibit had been admitted, Mr. Coughlin could not find the copy
24
provided by Mr. Springgate in discovery. Mr. Coughlin demanded a copy be provided at trial, stating: "am I
25
supposed to be rifling through my papers? My understanding is that you are supposed to provide a copy."
26
When asked if he had the copy of the document, Mr. Coughlin stated, "I do not know. I could spend my time
27
and mental energy looking around for Mr. Springgate 's document like I am his assistant, or we could ask
28
Mr. Springgate to provide a copy at the time he is seeking admission like I believe the rule states ." Again it
- 11/71 -
000553

would seem the nothing in the following ALR suggests that making an objection once every ten minutes or
so is sanctionable. Conduct of attorney in connection with making objections or taking exceptions as
contempt of court, 68 A.L.R.3d 314. Further, the District Court' s statement regarding factual issues (such as
a rate of success arguing objections) is exaggerated.
Another basis for a mistrial here is all the lies and nonsense from the SBN and various local
governmental offices about the Subpoenas Coughlin issued and had served in the manner he was provided
authority to do so by the SBN and Panel. Also, Reno City Attorney Creig Skau fraudulently secured
Coughlin's attendnat at in improperly notice ex parte hearing the day before the 11/14/12 Disciplinary
Hearing in the iphone case set for 11/19/12 Trial (how conveniently terribly prejudicial to deny Coughlin a
10
continuance either in the Disciplinary Hearing or that iphone RJC case...). Witness the followign fraudulent
11
manner in which Skau secured Coughlin's attendance at an improperly noticed hearing before Judge
12
Sferrazza (who was also the Judge on the summary eviction proceeding/"Trial" that represents such a serious
13
liability to the RJC and arguably should require Judge Sferrazza recusing himself. Speaking of, former
14
WCSO Deputy Peter Eastman, aside from breaking an entering into Coughlin's rental from Jeff Nichols of
15
Cobblestone Masonry, and assiting Nichols in improperly evicting Coughlin through violenet "self help"
16
(despite NRS 118A.160 an the attached work Coughlin did for Nichols in exchange for the rental, required
17
by the fraudulently procurred summary eviction in RJC REv2012-000374 (another reason the RJC should
18
not be hearing cases with Coughlin as a criminal defendant...but Peter Eastman claims to have formerly been
19
Judge Sferrazza's court room deputy in tribal court and that "friends in the court house" indicate that Judge
20
Sferrazza "has it out" for Coughlin or otherwise "has a problem with" Coughlin. Eastman also admits that
21
he and his wife received communicatiosn from SBN Bar Counsel Patrick King, Esq. that violated SCR 121
22
and which also slandered Coughlin, given Eastman's admission that Bar Counsel King told the Eastman's
23
that NVB Judge Beesley had entered an Order, as of May 7th, 2012, barring Coughlin from practicing in the
24
NVB (which is patently untrue...and further evidence of the lengths to which Pat King will go to show his
25
masters he is a good little attack dog for the rich and powerful in Northern Nevada, McGeorge Mafia
26
included, Richard G. Hill, Esq. included, etc., etc.). But, back to Skau's misconduct: From: "Creighton C.
27
Skau" <skauc@reno.gov> To: zachcoughlin@hotmail,com Cc: "Jeannie Homer" <HomerJ@reno.gov>
28
Date: 11/09/2012 11:45 AM Subject: Fwd: FW: Case No. RCR2011-063341 Dear Mr. Coughlin, Please be
- 12/71 -
000554

advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized
service has already been effected.
Also, Coughlin hereby states under NRS 53.045 penalty of perjury that the following exchange
occurred between Coughlin and SBN's Laura Peters on September 11th, 2012 at 4:51 pm wherein SBN's
Laura Peters, whom has and has been by King and Clark repeatedly held out as the "Clerk of Court for the
State Bar of Nevada" and in charge of matters relating to the filing of documents (though Pat King seems to
manage to control every aspect of these proceedings, from directing around NNDB Chairman Susich, to
putting Chair Echeverria where he needs him (they got a real routine goin') to directing Clerk of Court Peters
to effect personal service of the Compalint on Coughlin on 9/25/12 when Coughlin showed up for the
10
Hearing required by the Court's 6/7/12 Order and SCR 111(7)-(8) and SCR 102(4)(d) incident to 60838's
11
6/7/12 Order and the 8/13/12 Petition Coughin filed in 61426, which was served upon the SBN, both the
12
North and South versions, on August 17th, 2012...the same date that Peters noticed Coughlin in writing of
13
the hearing she calendared for Coughlin, admitting it was to be for the "sole purpose" of addressing the
14
conviction in 60838.. King also failed to tell the Court in his SCR 111 Petition that Coughlin complied with
15
SCR 111(2) in self reporting the conviction resulting in his supsension in 60838. Anyways, here is what was
16
communicated between Coughlin and Peters on 9/11/12, contrary to the file stamped Affidavit of Peters in
17
the SBN's filed that was not served upon Coughlin....Coughlin swears under penalty of perjury that the
18
following communciations were made between he and Peters (done in a rush due to Bar Counsel and Panel
19
Chair coercion and flauting of SCR 105(2)(c):
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"Coughlin: Now if I did get a Complaint and I need to serve an Answer, can I
serve it just by faxing it to you?
Clerk Peters: Um...yeah you can.
Coughlin: I have read the rules, they seem to say you go by NRCP except for
( See SCR 105(4))
Peters: ...you can... but it has got to be stamped.
Coughlin: By who? The filing office? The State Bar?
25
Peters: By me, I am a Court Clerk
26
Coughlin: Will you stamp a faxed document if I fax it in?
27
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Peters: I can, but I need to know how I can get it back to you.
Coughlin: I have a fax, its the one listed on the Bar's website 949 667 7402"
...
- 13/71 -

000555
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Coughlin: ...what day is it measured from if you guys filed a Complaint?

Peters (one the effect of certified mailings of the Complaints under SCR 109)
Okay i go 20 days from when I get that green card back, I go 20 days from after
when I get that little green card, so if you picked it up, say last Thursday, then I
go 20 days from last Friday...
Coughlin: Its not 20 days from the file stamped date on the Complaint or
something?
Peters: No, I go 20 days from that certified receipt, I want you to receive the
Complaint before the time starts ticking. That's the way I do it?
Coughlin: and if somebody doesn't pick up that letter, though, they'll will send it
back like after 15 days, and then what, you guys will go 20 days from then? Or
I imagine you guys might even push it a little more and say "no, its 20 days
from when we mailed it"
Peters: I do it from the receipt of the certified copy, so if you received it

yesterday it would be 20 days from today?
10
Coughlin: from my receipt of the certified copy as evinced by my signature on

the card?
11
12
Peters: right, as soon as you sign it and that shows when you got it, that's when
the time starts..I don't starting the counting until I get the green card back with
your signature saying you received it."
13
...
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Peters: Tom Susich's only involvement is setting the panel really....once a

Complaint has been filed we have 20 days or whenever until we receive the
Answer and then once we receive the Answer then we set a Panel...I have the
unclaimed Complaint I got it back September 10th, 2012...you haven't
technically received teh Complaint, even if you may hae received the first class
mail version we sent...
Coughlin: are you sure that at some point somebody with the SBN isn't going to
say "you know what, Zach, by now you have constructive notice of the
Complaint..." and they will try to hold me to that?
Peters: Nobdy is going to do that.
Coughlin: Are you sure? Typically we playin' prison rules in bar hearings...
Peters: Nobody is going to do that. I am the one that controls that, and as far as
I know you didn't receive the Compliant, because I have that certified mail
package right here as it was returned to me...as the Clerk of the Court of the Bar
I am telling you that you did not recieve this Complaint, because it came back
to me unclaimed... and so I am going to send it back out, send it back to you,
and if you pick this up and sign the green card...I will not attempt to do a Notice
of Intent to Take Default before I sent this Complaint back out via certified
mailing again, and I will send this back out and stamp it tomorrow and then
when you get it in the mail and sign the green card, that is when the 20 days to
file
Peters trips up and says Susich sets the Panel, but then says the SBN sets the
Panel (which occurred here pretty mcuh given the SBN purports to have mailed
at the Notice of Hearing and Designation of Witnesses and Summary of
Evidnece on 10/12/12 (SCR 105(2)(c) requires the Panel send those essential
filings, yet King and Peters did in this matter a ful 18 days before Susich's order
000556
setting the panel was even signed and stamped."
- 14/71 -

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And Patty Ice, aka Pat King, there is more of this coming, guy...more about what you said and what you
said Chief Bar Counsel Clark said about Coughlin's right to issue subpoenas and waiever of witness or
subpoena fees and the manner of service, etc., etc. More to come, boys, more to come....And Chair
Echeverria will want to ask Theresa about that person calling themselves an "attorney" when answering the
phone for his office...which has a name plate that sounds and looks more like a venture captial firm...'The
Echeverria Group"....so coughlin preserver and continues to preserve his objetion to having his case in
chief or defense unnecessrily cut short and not being able to call witnesses or enforce the subpoenas given
the sudden and fraudulent flipping of the script by the panel and or sban obc clerk of court regarding the
rules attached thereto.
Further there is new supplmental evidenc eot and witnesses to support Coguhlin's contention that the
eviction lockout was based upon a void order and fraud is connecte thereto, with the wcso refusing to
comply with records requests and or subpoenas, as well as the RJC., which had jammed coughlin into the
iphone trial today in rcr2011-063341, which is overly prjejducing a variety of cases and Coguhlin's health...
Further, in light of the declaration made by the SBN and Peters upon, upon which Coughlin
reasonably relied, the established pattern and practice of the SBN not starting the running of deadlines
pursuant to the service of items under SCR 109 until the SBN gets back the signed green certified mail slip
must be accord to the October 27th, 2012 certified mailing return receipt slip that, while, it is signed by
Coughlin, it is signed by Coughlin's then housemate "Juliano" as "received by". See, Pat King...that's
called credibility....ie, not sittin' there wasting the Hearing Panel's time arguing that the audio transcripts
the RMC provided you and that you had copied for the Screening Panel are "irrelevant" or "not certified" or
"worthless becuase there is not an prohibitably expensive certified transcript of that Hearing to provide
"context"...(and this after Pat King was caught lying about whether the April 2009 Order he sought to
introduce of Jduge Linda Gardners (resulting Coughlin's firing from WLS...which Chair Echeverria saw no
issue having WLS's ED Elcano provide certification of the Order entered some two weeks after the trial
that, contrary to Echeverria's remixign, Elcano did not "attend" but merely watch the tape of (and under
King's analysis, despite paying $35 for the Second Judicial's tape of that Trial, it still would not be a
"certified copy". The fact that anyone lying about the tape could be cross examined provides plenty of
"certification", doesn't it?
17
20
Also, so cute how Pat King, in the bate stamped copy of the "Disciplinary File" (which Coughlin
should in no way be billed for given the deprivation of his SCR 105(2)(c) rights herein, nor should Couglin
have to pay for any of this Disciplinary Hearing, particulary given all the notice, service, and process
deficiencies attendant to Pat King's impermissible attempts to cheat Coughlin out of his due process and
therefore obtain a result King and the SBN do not deserve.
21
So, its really cute how in the Disciplinary File at 02954 there is the Affidavit of Mailing from the
23rd of August 2012, wherein Laura Peters swears, under penalty of perjury that
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Also, Pat King brought his dog to work and let it wander around the halls of the SBN the day of the
hearing, and he wore cargo pants along with a horrific tie, then he sauntered up to Coughlin at a urinal and
salivated over the "pretty good grub, huh, Zach?" Patty Ice wasn't feelin' so chipper a day or so later when
Coughlin was interrogating him about the fraud King committed in the bate stamped copy of the
Disciplinary file, especially vis a vis the fact that curiously, all the SBN filings except for the two most key,
the Complaint and First Designation of Hearing Panel Members (would have been nice to have actually been
served that in accord with the rules and the policies held out by the SBN and justiably relied upon...as a
peremptory challenge would have definitely been issued for both Stephen Kent, as well as Chair Echeverria
(however, nice a men they may be outside the impermissible conflicts of interest they had which should have
prevented them from ever sitting on this Panel. So, where Coughlin now files and affidavit (to whatever
extent he did not so file one or a declaration or verificaton previously, which is not clear) contesting the
August 23rd, 2012 Affidavit of Mailing filed by Peters...which may be undone somewhat by the October 000557
9th, 2012 Affidavit by Peters that is included in the file and filestamped but for which Coughlin was never
- 15/71 -

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sent a copy or otherwsie served (and the big box copy of the NOITD of 10/9/12's certifcate of mailing does
not indicate that any such affidavit was included therein, so...the Disciplinary Hearing contains a filing that
is file stamped, yet was not sent to Coughlin (and if it was sent to Chair Echeverria or Chairman Susich,
that's misconduct. So King and Peters and the SBN have gotten all cute with this here bate stampe "copy of
the Disciplinary File" consolation prize for the SBN and Panel defenestrating Coughlin's right under SCR
105(2)c)...Peers therein swears she is "employed as a paralegl for the SBN. That in such capactity Affidant is
Cutodian of Records for the Discipline Department of the State Bar of Nevada...." Then Peters goes on to
swear that the "Complaint and First Designation of Hearin Panel Members were served on the following by
placy a copy in an envelope which was then seald and postage fully prepaid for ....despostted in the US. mail
at Rreno...."...Its odd because every other certifeid mail filing in that file bate stamped and copied to
coughlin by the SBN a scant 6 days prior to the Hearing proudly displays the green certified mailing card
(well, there is a distinction between the return receipt requested" card stock card and the more squarish,
certified mailing square slip with a tracking number (which does not involved getting a signature from the
addressee...So when the SBn sent Couglin on 10/12/12 the Notice of Hearing (which SCR 109 requires be
served in the same manner as Complaint (which entails and adoption of the rules Peters set out to Coughlin,
including in their September 21st, 2012 conversation....so, somehow, in that bate staped file for page 02954
is that Affidavit of Mailing by Peters on 8/23/12 wherein she swears that the " "Complaint and First
Designation of Hearin Panel Members were served on the following by placy a copy in an envelope which
was then seald and postage fully prepaid for"...which is clearly not true and or in accord with Peters
statements to and representatiosn and agreements with Coughlin on September 11th, 2012 at 4:41pm.
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"LAURA PETERS, under penalty of perjury, being first duly sworn, deposes and says as follows: That
Affiant is employed as a paralegal for the discipline department of the State Bar of Nevada and in such
capacity is the custodian of records for the State Bar of Nevada; , That on September 11, 2012, at
approximately 4:45 p.m., Zachary Coughlin called Affiant to confirm that a hearing was still scheduled to
take place on September 25, 2012. Affiant explained that the hearing would not take place on September
25th and that date had been scheduled prior to the filing of a formal Complaint. Mr. Coughlin reacted as if he
had no knowledge of a Complaint. Affiant then explained that, in fact, a copy of the Complaint, sent via
certified mail on August 23, 2012, from the Reno office of the State Bar, had been returned and marked
"unclaimed". Affiant further explained that since service had not been affected, a new certified copy would
go out the next day. Affiant requested that when Mr. Coughlin received said copy, he should return the
postcard attached to the mailing and his twenty (20) day period in which to answer the Complaint would
start running at that point. However, in speaking to Assistant Bar Counsel Patrick King, it was determined
that personal service should be affected upon Mr. Coughlin. Reno Carson messenger service was engaged to
attempt personal service despite Mr. Coughlin not providing the State Bar with a physical address. On
September 25, 2012, Mr. Coughlin arrived at the Reno office of the State Bar allegedly expecting a hearing
to take place. At that time, Mr. Coughlin was again told, both by Affiant and Assistant Bar Counsel Patrick
King, that no hearing would be taking place that day and that an answer to the State Bar's Complaint had not
been received. Affiant personally served Mr. Coughlin with a copy of the Complaint on his visit to the Bar
office on September 25th as witnessed by Paula Campbell, an employee of the State Bar. Mr. Coughlin
insisted that the hearing which had been previously scheduled for that day should be taking place because he
needed to be removed from temporary suspension. Mr. Coughlin has also been instructed by Assistant Bar
Counsel Patrick King that he cannot file pleadings with the State Bar via e-mail, which he continues to
attempt. The Motion to Dismiss, which Mr. Coughlin now insists should be granted as it has gone
unopposed by the State Bar, was never presented to Affiant for filing but was rather emailed prior to
Affiant's conversation with Mr. Coughlin on September 11th when Mr. Coughlin under no uncertain terms
told Affiant that he had not yet received the Complaint. FURTHER YOUR AFFIANT SAYETH NOT.
Dated this 91h day of October, 2012. "
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SCR 103: 7. Hearing panel members shall not participate in any proceeding in which a judge similarly
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000558
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situated would be required to abstain. Any member whose term expires while the member's
panel is considering a complaint shall remain a member until its disposition.

8. The chairs of the hearing panels and screening panels shall deliver reprimands and sign
all
documents on behalf of the panel to carry out the provisions of Rules 102(6), 102(7), and
103(6).
9. A grievance received against a member of a disciplinary board and processed in
accordance
with Rule 105(1) shall be referred to the other disciplinary board.
So, the policy announced by SBN PetersAs to that "received by" signature on October 27th, 2012
by "J. Juliano", under the established policies of the SBN as set forthe by the SBN and Clerk of Court
Peters during the September 27th, 2012 conversation with Coughlin wherein Peters established and
confirms that deadlines incident to service via certified mailing do not begin running until she or the SBN
receives back the green certified mail return receipt requested slip that, and or until two attempts at
such certified mailing service have gone unclaimed, whereupon, a Notice of Intent to Take Default
would be sent via certified mail (and Peters indicated all such certified mailings are sent in duplicate
via first class mail as well (though, strangely, the 10/9/12 Notice of Intent to Take Default's certificate
of mailing indicates that it was sent via only one method, certified mail (ie, not also by first class
mail) and, curiosly, despite every other SBN filing in the bate stamped Discipinary File in SBN v.
Coughlin having the certified mail slip included therein, the NOITD fails to (and this is likely due to
Pat King realizing (and SCR 109 requires that the Notice of Hearing and DoWSoE of
evidence.Coughlin could probably pull a Pat King and refuse to acknowedge that the cd's Pat King
he and the SBN had a problem in that upon doing a USPS Track and Confirmlf received from the
RMC were "certified" or otherwise appropriate for admitting into evidence (as to whether they are certified,
that depends who is doing to "defining" of what is certified...but it also begs the question, why would the
SBN be putting to a Screening Panel audio transcripts that are not certified? Also, the bit from the 2/27/12
trial in 11 TR 26800 about where Coughlin tells Judge Nash Holmes "that's quite a sound byte, Your
Honor" in response to her stating "I don't care about bribery, I don't care about corruption, I don't care
about retaliation...all I care about is the Boulevard Stop" (need to listen really closing to that Trial, or
somehow get the RMC and Longoni (whose Sunshien Reports should have never been allowed to do this
Hearing, no disrespect to Ms. Hummel, though, but a conflict clearly exists, particulary where Coughlin's
appeal in the conviction resulting in his current suspension was denied due to the failur of Longoni and the
RMC to prepare the transcript even though Nevada law required they do so upon Coughlin filign his Notice
of Appeal instant to NRS 189.010-.050... that statute is not advisory...is is the law, and D10 Judge Elliot's
mentioning a civil statute's stance on the prepareation of appeals and down payments thereto does not
change that. It is fraud by Longoni and the RMC So, if something is missing from the RMC's $35 audio
transcript that Coughlin was only able to obtain after drafting his own mother, Mary Barker, into the
pursuit (the RMC made up excuse after excuse for refusing to fill Coughlin's audio transcript request and
evne had its Marhals start manufacturing grievances against Couglin with the RMC (see their ridiculous
"greivance" or letters to the RMC and their even more ridiculous "Incident Reports". (even for the limited
purposed of demonstrating what King and Peters gave to Coughlin purporting them to be "leftovers" from
the Screening Panel on October 10th, 2012 that RMC Judge William Gardner obnoxiously claimed to know
so much about to Coughlin in court on 4/10/12, shortly after Judge Gardner announced that he and
McGeorge Mafia, class of 2006 member Reno City Attorney Hazlett-Steven's and Coughlin's McGeorge
Mafia SOL court appointed counsel Keith Loomis, Esq. had a secret meeting that morning prior to trial in
some backroom of the RMC where they all had a great time, uh, practicing their lines. And what a forced
lifeless performance it ultimately was when that troupe presented to indigent criminal defendant Coughlin
and attempted to navigate their way through the murky waters of violating NRS 178.405 (in light of the
2/27/12 Order for Competency Evaluation in RCR2012-065630 that the RMC Judges were well aware of,
incident to their "at least one meeting" when they brainstormed how to get Coughlin and the
communications between Judge Nash Holmes and the Washoe County Public Defender and or Biray
000559
Dogan, Esq., counsel of record for Coughlin in that rcr2012-065630, whom can tell you all about how
- 17/71 -

DDA Young violated NRS 178.405 in filing at 2:55pm a fugitive document in seeking to oppose
Coughlin's Motion to Appear as Co-Counsel, despite the OR
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First, despite Peters Affidavit of October 9th, 2011 (here is no proof of service of that Peters Affidavit on
Coughlin, and it it was served on the Panel or Chair, unbeknownst to Couglhin, that is an impermissible ex
parte communication) being filestamped an included in the materials that were only finally provide to
Coughlin on November 8th, 2011:08:55:54
further, Coughlin one hundred percent categorically denies Pat King's unsupported allegation of Coughlin
attempting to dodge service. One, the hearsay of Johhno Lazetich is in the form of a bill, not a sworn
affidavit, and further, it clearly contains mere conjecture on Lazetich's part. Further, Coughlin setn
Lazetich and his father's company Reno Carson Messenger Service an email and a voice mail asking what
he could do for them, along with emails and a fax to the SBN offering to meet a process server somewhere
or otherwise assist in having the Complaint appropriately served, however, King and the SBN chose to lied
to Coughlin instead, and go back on what Peters definitively declared during the September 11, 2012
conversation on the telphone with Coughlin that her unserved, yet file stamped, October 9th, 2012
Affidavit asserts. It is interesting that King and Peters say nothing about faxing motions...consdiering that
Peters clearly gave Coughlin permission to fax file motions (and in accord with other such forms of
electronic filing, Coughlin's fax filed motions, and arguably email filed Motions (including the skydrive
link files atached thereto should be made a part of the record and the file and the Panel should be provided
with them and reminded that they have a duty to review them. This is true, especially for anything prior to
the September 25th, 2012 email by King purporting to refuse email filing (and arguably, at that point, it
was too late for King to change the rules of procedure set forth by Laura Peters and or Susich's or the
Panel's failure to oppose such filings by Coughlin. REgardless, the file as King had it bate stamped and
provided to Coughlin at such a very late stage (November 8th, 2012 upon the first attempt to deliver it from
Sierra Document Processing Coughlin received it an signed for it, and thereby his SCR 105(2)(c) right to
inspeact "up to 3 days prior to the hearing" was violated, especially considering Coughlin was continually
refused the opportunity to inspect such records as the SBN at every stage since Pat King's phony offers to
allow such in March 2012...Further, the bate stamped Formal Hearing File SBN v. Zachary B. Coughlin is
missing a number of cd/dvd exhibits that Coughlin submitted for filing. Pat King admits to just choosing to
remove them from the file and or fail to copy the committee on them, while at the same time maintaining
he and the SBN and Peters have demonstrated Fidelity in their stated practice of providing everything
Coughlin files to the Panel. Additionaly, Peters Affidavit is quite fraudulent. One. clearly a Motion to
Dismiss dated September 17th, 2012 that Coughlin has a fax confirmation of and also email to Bar Counsel
and Susich was not "created prior
The Motion to Dismiss fax filed on September 17th, 2011 should be file stamped an included in the
file. Why else would Laura Peters Affidavit not indicate someting contrary to Coughlin's sworn assertion
that he was given permission to fax file by the SBN? Regardless, Coughlin's hadn delivered Motion to
Dismiss of Cctober 15th, 2012 (or it may have been October 16th, 2012, given Coughlin missed his self
imposed deadline of delivering to the SBN a Motion to Dismiss by midnight of some night, and sent Clerk
PEters and email the next day indicating the proof of service should be adjusted in that regard. Further the
Chairs assessment that Coughli nfailed to file a "verified response or answer" or that such "may not contain
anything stated upon infromation and belief" is contested and just flat out wrong. Coughlin's signature on
page 61/62 on the Motion for ORder to Show Cause may be a bit high above the signature line (though
the /s/ is operative in electronic filing, which the SBN gave Coughlin permission to do.
Judge Linda Gardner is a lifelong prosecutor turned Judge, like her brother RMC Judge William
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Gardner, like his fellow RMC Judge whom he admitted passed the April 2009 Order sanctioning Coughlin
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resulting in Coughlin's firing from WLS in 60302 (and a Mandamus filed against Linda Garnder by
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Coughlin in 54844, and a grievance filed by both Judge Linda Gardner and Judge Dorothy Nash Holmes
- 18/71 -

000560
(also a lifelong prosecutor turned Judge...like Judge Kenneth Howard too) (on behalf of all of the RMC
Judges) against Coughlin in both NG12-0434 and NG12-0435...which along with the Richard G. Hill, Esq.
grievance (Rich was just fulfilling his RPC 8.3 duty, y'all...don't hate) in NG12-0204, SBN Bar Counsel of
the North Pat King whipped up in a SBN v. Coughlin Complaint, that he purports to have served under SCR
109 via a certified mailin of 8/23/12 that was returned to the SBN, and to which SBN Clerk of Court Laura
Peters indicated to Coughlin would absolutely, under no circumstances, ever be used as a return of or proof
of service of the Complaint against Coughlin given the fact that she herself received it as returned to send on
9/10/12, and especially where she told Coughlin he coudl rely upon her then indication that she would, in
accord with the SBN's pattern and practice and established policies, resend it once again the following day
10
via certified mail, and only upon that mailing not being met with a signed certifed mail signature of
11
Coughlin's would the SBN send out a Notice of Intent to Take Default, served in the same manner as that
12
which was attempted with the Complaint itself. Of course, Pat King attempted to cheat the system by
13
turning all those SBN-Coughlin agreements into lies, because if there is one thing Pat King will not stand for
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it is competition or a level playing field. King recoils from such like a vampire from a coming sunrise.
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SCR Rule 110. Subpoena power, production of documents, witnesses, and pretrial
proceedings.
1. Issuance of subpoenas by hearing panels and bar counsel. Bar counsel and a member
of
a hearing panel who is also a state bar member, in matters under investigation by either,
may
administer oaths and affirmations and issue and compel by subpoena the attendance of
witnesses
and the production of pertinent books, papers, and documents. The attorney may also
compel by subpoena the attendance of witnesses and the production of pertinent books,
papers,
and other documents before a hearing panel. Subpoena and witness fees and mileage
shall be the same as in a district court.
2. Confidentiality stated on subpoena. Subject to the provisions of Rule 121, subpoenas
shall clearly indicate on their face that they are issued in connection with a confidential
investigation
under these rules and that it is regarded as contempt of the supreme court or
grounds for discipline under these rules for a person subpoenaed to in any way breach
the confidentiality
of the investigation. It shall not be regarded as a breach of confidentiality for a
person subpoenaed to consult with counsel or to answer questions asked by bar counsel
or the
attorney to determine the facts known by the witness.
3. Attachment of person for failure to obey subpoena or produce documents. Whenever
any person subpoenaed to appear and give testimony or to produce books, papers, or
000561
other
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documents as required by subpoena, or requested to provide documents pursuant to

Rule
78.5(1)(b), refuses to appear or testify before a hearing panel, or to answer any pertinent
or
proper questions, or to provide the requested documents, that person shall be deemed in
contempt
of the disciplinary board, and the chair of the disciplinary board shall report the fact to a
district judge of the county in which the hearing is being held or the investigation
conducted.
The district court shall promptly issue an attachment in the form usual in the court,
directed to
the sheriff of the county, commanding the sheriff to attach such person and bring such
person
forthwith before the court. On the return of the attachment, and the production of the
person
attached, the district court shall have jurisdiction of the matter; and the person charged
may
purge himself or herself of the contempt in the same way, and the same proceedings
shall be
had, and the same penalties may be imposed, and the same punishment inflicted as in
the case
of a witness subpoenaed to appear and give evidence on the trial of a civil cause before
a district
court of the State of Nevada.
4. Contest of subpoena. A contest of a subpoena shall be heard and determined by the
chair
of the appropriate disciplinary board.
5. Restriction on discovery. Discovery by the attorney, other than under Rule 105(2)(c),
is
not permitted prior to hearing, except by the order of the chair for good cause upon
motion under
Rule 103(5) or Rule 103(6).
6. Prehearing conference. At the discretion of the chair, a prehearing conference may be
ordered for the purpose of obtaining admissions or otherwise narrowing the issues
presented
by the pleadings. The conference may be held before the chair or the chair's designee.
7. Deposition in lieu of appearance. With the approval of the chair, testimony may be
taken
by deposition or by commission if the witness is not subject to subpoena or is unable to
attend
or testify at the hearing because of age, illness, or other infirmity.
8. Confidentiality of deposition. Depositions are subject to the protective requirements
and
confidentiality provided in Rule 121.
CREDIT(S)
Added, eff. Feb. 15, 1979. As amended, eff. Jan. 2, 1996; Mar. 1, 2007.
LIBRARY REFERENCES
Attorney and Client 47.1.
Westlaw Topic No. 45.
C.J.S. Attorney and Client 73, 89.
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000562
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- 20/71 -

-Judge Beesley's testimony on 11/14/12 is curious in light of the solid thumbs up he gave the no temporary
suspension getting Stephen R. Harris, in 57507, and the fact that Judge Beesley was hard pressed to provide
a single detail in support of his strong contentions that Coughlin's work and filings before him in the NVB
indicated Coughlin not competent to practice there. Coughlin is a National Merit Finalist who was ranked
10th in his class at a top 80 law school, has been a licensed Patent Attorney, and passed the July 2001 State
Bar of Nevada's Bar Examination a year before those matriculating as full time students with him to UNLV's
Boyd School of Law in August 2001 would even take that examination, meaning he passed it after his
second year of law school. Further, the attached filings by Coughlin before Judge Beesley in the NVB
clearly demonstrate a skill level beyond the baseline competency required to practice therein, something all
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the more impressive given they represent the very first two or three bankruptcy cases Coughlin ever took on.
11
It is literally a textbook example of a solo attorney starting out and not taking on too many cases, sufficient
12
to be able to extricate himself and his client's from even the most unexpected calamities and circumstances
13
foisted upon them by the misconduct of others (including having Judge Beelsey's McGeorge SOL 1977
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classmate RMC Judge Nash Holmes (who was sued for wiretapping attorney Martin Weiner or Crowley,
15
Esq.), whom unlawfully and, apparently in conjunction with her former coworkers at the WCDA Office (and
16
NNDB Panel Member Mary Kandaras was intimately involved in the process...in fact WCSO Deputy
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Madeline refused to return the smart phone and sd card to Coughlin even after Judge Nash Holmes' Order
18
required the WCSO do so...with Madeline indicating she needed to get Mary Kandaras' permission first
19
before complying with Judge Nash Holmes order (funny, didn't see Madeline getting hemmed up with an
20
instant incarceration and summary criminal contempt charge there...)...shortly after (and Pam Wilmore, Esq.
21
was there and heard all of this, though her partnership or sharing of an office with McGeorge SOL 1985
22
John Springgate, Esq (opposing consel in 54844 April 2009 Judge Linda Gardner sanction order getting
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Coughlin fired in 60302 from WLS) may prevent too clear a recounting...Then WCSO Deputy Hodge got
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caught in a, uh, story, about whether the micro sd card was included in the materials booked and then in the
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materials released to Coughlin's friend, whom picke them up on 2/28/12 (interestingly...Coughlin's smart
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phone and micro sd card were booked into Coughlin's property upon intake at the jail...but a full day later the
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RMC Marshals returned (and Marshal Scott Coppa seemed to communicate and intent to do so to WCSO
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Deputy Cheung when he pulled him aside into a back room in the sally bay during the conclusion of the
- 21/71 -

000563
RMC Marshals transporting Coughlin to the WCDC o 2/27/12....Then Marshals Coppa and Marshal
Townsend retaliated against Coughlin's valid complaints thereto (and other criticisms of the extent to whih
the RMC is a monument to a lack of transparency or separation between the court's Departments and the
Court's filing office) by filing a nonsensical criticism of Coughlin's clothin choices when visiting a muni
court filing office counter to check on a traffic citation with the SBN...which King promptly mentioned to
Coughlin in a deliberately misleading way, via King's 3/23/12 email to Coughlin (King plays little games
with the moniker "Clerk of Court"....King, Marilyn Tognoni is not a "Clerk of Court"...neither is Cassandra
Jackson...and neither King nor Second Judicial District Clerk of Court Joey Orduna that likely wound up in
Judge Flanagan issuing a rash ruling on 3/30/12 disposing of Coughlin's appeal in the Richard G. Hill, Esq.
10
appeal of the summary conviction from Coughlin's former hom
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(so as for cooking up a Panel...Susich and King got Panel Chair John Echeverria, whom had to admit he and
12
WLS's Paul Elcano were boyhood chums and that both went to Stanford University in 1966 (add to that the
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fact that Echeverria went to Hastings Law School along with WLS's Caryn Sternlicht (whom Coughlin is
14
suing, along with Elcano in 60302) and Reno City Attorney Pamela Roberts, Esq (whose prosecutorial
15
misconduct in putting on perjured testiomny by Wal-Mart's Thomas Frontino and the Reno Sparks Indian
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Colony's Kameron Crawford (asserting that a custodial arrest and search incident thereto was permissible,
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despite NRS 171.1255 on some assertion that Coughlin failed to provide his driver's license...even where
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Roberts herself was given the "Interrogation Room" videos by Wal-Mart showing Coughlin giving his
19
driver's license to Officer Crawford, whereupon Crawford copies down the information therefrom onto the
20
Arrest Report and Probable Cause sheet and radios into his dispatch Coughlin's Nevada driver's license
21
number...add to that the fact that Coughlin's detention intake property sheet lists that he was booked into jail
22
with his Nevada driver's license...and Officer Crawford and Thomas Frontino's lies are clearly exposed,
23
which Pamela Robert's purposefully allowed them to tell in her retaliatory rush to get a conviction shortly
24
after she back out of a written agreement to a continuance...and where Judge Howard specifically based his
25
refusual to grant Coughlin a continuance upon his mistaken/incorrect belief that it was Coughlin whom was
26
responsible for the 11/14/12 Trial date being continued. Judge Howard had to admit, later, on the record,
27
that he was mistaken in that regard (so instead of declaring a mistrial, Judge Howard just admitted his
28
mistake and proceeded with putting Coughlin in jail for 3 days for NRS 22.030 "summary contempt" despite
- 22/71 -
000564

Judge Howard having failed to grant Coughlin's motion for counsel, even though the Nevada Courts of
Limited Jurisdiction Bench Book points out that Aigersinger is mandatory authority, and therefore,
appointed counsel is required where even the possibility of jail time exits. In his pre-trial Order denying
Coughlin's Sixth Amendment Right, Howard ruled that Coughlin was not entitled to counsel, even where he
had established he was indigent (and evicted just days prior thereto) because "jail time is not the typical
sentence" for first offense shoplifting of a de minimis amount of food. However, it is important to note that
Judge Howard did not rule out the possibility of jail time, and therefore Aignersinger applies. Further, Judge
Howard, who had been occupying the RMC Bench for 14 years at that point, announced during the rendition
of his conviction order that, not only was the summary contempt conviction not appealable (and, of course
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no stay would be availalbe...the RMC having a perogative to expedite matters before it an all (so much so
11
that Judge Howard kept a supposedly financially strapped City of Reno Staff of RMC Marshals and RMC
12
Court Staff in court on overtime pay until 9:00 pm at night in his mad rush to conclude the petty larceny
13
trial, first offense, of a de minimis amount of food, from a megaconglomerate corporation, where the arrest
14
was made in violation of NRS 171.1255, by tribal police, on land that police force's employers (the Reno
15
Sparks Indian Colony) rent to Wal-Mart. Judge Howard refused Coughlin (then a licensed attorney whose
16
property right, his law license, under the Fourteenth Amendment, would necessarily be imperiled upon an
17
SCR 111(6) "serious offense" conviction (stealing a grape would invoked that rule according to Pat
18
King...though Stephen R. Harris stealing $740,000 from his clients and using it on hookers and designer
19
luxury products did not, nor did it result in a temporary suspension either...and it didn't prevent Judge
20
Beesley from singing the praises of Stephen R. Harris, Esq. in 57507 even where an improperly noticed
21
phoned in testiony by Judge Beesley at Coughlin's Discipilinary Hearing saw Judge Beesely (who had to
22
admit that he had a longtime long partnership relationship with someone Coughlin is suing, Washoe Legal
23
Service's Karen Sabo, Esq., whom admitted to Paul Elcano that she could never, and would never work with
24
Caryn Sternlicht, Esq., finding her personality so odious and detestable...though Ms. Sabo had no issues
25
expecting Coughlin to cheerfully bare the brunt of such while he worked as a domestic violence attorney at
26
WLS...Also Judge Beesley is a close friend of Paul Elcano's, attending a very intimate West Fourth Street
27
Bistro invite only WLS party in 2008 at Elcano's invitation. Upon Coughlin cross examing Judge Beesley as
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to just what he was basing his sudden (and never before had Judge Beesley actually made and ruling or
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000565
otherwise voiced any consternation whatsoever to Coughlin about his work respresenting client's before the
NVB...so it was a zero to trash Coughlin as a Disciplinary Hearing approach by the measured, impartial
jurist Beesley, who graduate from McGeorge SOL in 1979, right between two other witnesses at Coughlin's
11/14/12 Disciplinary Hearing cook-off thrown by Chair Echeverria and Pat King (whom wore cargo pants
to work that day, whereupon he asked the Panel to disbar Coughlin based upon a petty larceny conviction of
a candy bar, a criminal trespass convction that only saw a SCR 111(4) Petition (ie, King had to admit it did
not qualify as a "serious offense" despite his trying to find leverage by threateing to file an SCR 111(6) for
months) even where opposing counsel in this summary eviction from Coughlin's former home law office
was applying an unlawful rent distraint under NRS 118A.520 to exculpatory videos and materials that would
10
demonstrate Coughlin's innosence and the fact that on occasions previous to the 9/9/12 arrest, including on
11
July 7th, 2011, West 7th St Wal-Mart Assistant Store Manager John Ellis and an as yet to be indentified AP
12
Associate specificaly told Coughlin that they would retaliate against him via an abuse of process (of course
13
Judge Howard ruled that, even if they did, that was not relevant) (supplemented to King's Designation of
14
Witnesses 4 days before the Hearing of 11/14/12, along with Judge Beesley, despite neither having anything
15
to testify to that Pat King did not know about for over six months...its just that, Pat King got real worried
16
about the fact that he violated SCR 121 by communicating to Coughlin's then client and or his wife, Peter
17
Eastman and Pam Eastman that Judge Beesley (McGeorge SOL, class of 1979) had issued an order
18
prohibiting Coughlin from practicing in the Nevada Bankruptcy Court for the District of Nevada (which is
19
absolutely not true...and even if Judge Beesley had actually wanted to at that time...he would not have the
20
authority to...but there is plenty of evidence that Judge Beesley had no such intention towards any such
21
Order at the time of the May 7th, 2012 communication by Peter Eastman to Coughlin that revealed that Bar
22
Counsel Patrick O. King has told the Eastman's that their then attorney, Zachary B. Coughlin, Esq., had been
23
"suspended from practicing in the Bankruptcy Court" in light of Judge Beesley entering an Order so
24
preventing Coughlin from doing so. King, during a meeting with Coughlin and King's boss, Chief Bar
25
Counsel David Clark on August 17th, 2012 (a three hour meeting) grew flustered upon Coughlin querying
26
him on his quizzical stated intent to have Coughlin disbarred...whence Coughlin asked King just what sins
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supported such a motive...amongst the first two things King mentioned to Coughlin and Clark was the fact
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that the NVB Judge Beesley had entered an Order prohibiting Coughlin from practicing in Bankruptcy
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000566
Court....This was "news" to Coughlin, whom had never been served any such Order, and had never heard
any such thing besides from his former clients (the Eastman's, whom were extremely late in making a
number of payments to Coughlin in exchange for his hard work and respresentation of Peter
Eastman)...Shortly after Coughlin was told of Bar Counsel's violation of SCR 121. Incident to Judge
Beesley (McGeorge School of Law, class of 1979) presiding over the Cadle Company v. Robert Keller
adversary proceedig in NVB (10-05104) Coughlin filed a Motion For Continuance wherein he attached
materials revealing that Judge Beesley's McGeorge School of Law classmate, Reno Municipal Court Judge
Dorothy Nash Holmes (McGeorge School of Law 1977) had violated Nevada law in purporting to rule that
NRS 22.010 was "the misdemeanor of criminal contempt" (actually, criminal contempt in Nevada is found at
10
NRS 199.340...but that statute doesns't specifically allow for a "summary" finding of guilt, so, instead, Judge
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Nash Holmes too the bits she liked out of it, then renamed it NRS 22.010
12
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NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be
deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court,
or engaged in judicial duties at chambers, or toward masters or arbitrators while sitting on a
reference or arbitration, or other judicial proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or
in its immediate vicinity, tending to interrupt the due course of the trial or other judicial
proceeding.
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3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge
at chambers.
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5. Rescuing any person or property in the custody of an officer by virtue of an order or process of
such court or judge at chambers.
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6. Disobedience of the order or direction of the court made pending the trial of an action, in
speaking to or in the presence of a juror concerning an action in which the juror has been
impaneled to determine, or in any manner approaching or interfering with such juror with the intent
to influence the verdict.
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25
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7. Abusing the process or proceedings of the court or falsely pretending to act under the authority
of an order or process of the court.
NRS 22.030 Summary punishment of contempt committed in immediate view and presence of
court; affidavit or statement to be filed when contempt committed outside immediate view and
presence of court; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at
chambers, the contempt may be punished summarily. If the court or judge summarily punishes a
person for a contempt pursuant to this subsection, the court or judge shall enter an order that:
000567
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(a) Recites the facts constituting the contempt in the immediate view and presence of the court or
judge;
chambers, an affidavit must be presented to the court or judge of the facts constituting the
contempt, or a statement of the facts by the masters or arbitrators.
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3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate
view and presence of the court, the judge of the court in whose contempt the person is alleged to be
shall not preside at the trial of the contempt over the objection of the person. The provisions of this
subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment
or decree was entered in such court by a predecessor judge thereof 10 years or more preceding the
bringing of contempt proceedings for the violation of the judgment or decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been
established in the judicial district.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one
of the following kinds shall be guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its
immediate view and presence, and directly tending to interrupt its proceedings or to impair the
respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or
hearing pursuant to an order of court, or in the presence of a jury while actually sitting in the trial
of a cause or upon an inquest or other proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of
a court, jury or referee;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer
any legal and proper interrogatory;
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But, actually, contrary to Judge Beesley's sworn testimony at the 11/14/12 Disciplinary Hearing,
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Judge Beesley could have somehow ruled in a manner seeking to regulate Coughlin's appearances before his
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Court, or providing, in any manner whatsoever, some indication to Coughlin as to any sort of displeasure
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with Coughlin's performances therein (which Judge Beesley absolutely never did) prior to Judge Beesley
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(upon being supplemented to the Designation of Witnesses list four days prior to the 11/14/12 Disciplinary
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Hearing related to Coughlin's lawsuit against WLS and Paul Elcano (McGeorge SOL, Class of 1978, and
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000568
therefore a classmate of both Judge Beesley and Judge Nash Holmes, in addition to a class mate of Panel
Member Stephen Smiley (McGeorge SOL, Class of 1980, whom., therfore, was necessarily a class mate of
RMC Judge Kenneth Howard (McGeorge SOL, class of 1981....and speaking of Panel Member Kent...he
glared at Coughlin continuously throughout the 11/14/12 Disciplinary Hearing and upon Pat King being
caught in several lies that day (King told the panel an Order , the one that got Coughlin fired from Washoe
Legal Services over three years ago but which suddenly became a grievance when teh RMC Judges decided
to do their hit piece on Coughlin's life and law license because they got scared that their Court and the
Municipality that owns it, and the police force and Marshals that is leverages against the citizenry to collect
a tax disguised as justice (and the RMC had $700K or so turn up missin' in 2011, and explained that away by
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saying the shortfall was do to data entry errors and stuff) was a certified copy when it was not....no matter,
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Elcano's boyhood chum and fellow Stanford '66 alumni Panel Chair Echeverria allowed Elcano to provide
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certification of the Order in light of Elcano claiming to have "reviewed the video tape of the Trial" (which
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Echeverria tried to remix into "having attended the Trial" that led to Coughlin filing a Mandamus Petition
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against Judge Linda Gardner in 54844... Which was odd considering that Chair Echeverria refused to admit
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into evidence the certified copy of the audio of the 11 TR 26800 traffic citation trial on 2/27/12 Couglin
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offered into evidence (Chair Echeverria refused to allow Coughlin to testifyin to it being a certified copy or
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otherwise even look at the cd itself which Coughlin had to have his mother buy from the Reno Muncipal
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Court after months of the RMC and Judge Nash Holmes refusing to let Coughlin purchase a copy of it. That
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certified copy was to be used to impeach the lies by Judge Nash Holmes in the traffic citation trial Holmes
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held despite her admitting (see the 3/14/12 grievance against Coughlin Judge Nash Holmes sent to the SBN
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"on behalf of all the RMC Judges"...which is odd because one of those Judges William Gardner tried to
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pretend he wasn't aware of that, and just barely contained himself from holding the trespass trial on
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4/10/12....though he did manage to violate NRS 178.405 numerous other times himself (including the 3/8/12
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trial setting, and teh March 8th, 2012 Trial Setting the matter for 6/18/12 despite the Order on the
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Competency Evaluation not having been signed and entered until 5/9/12....yet Judge Nash Holmes
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constantly seeks to play hype man to some alleged "authority" and profound knowledge she feels she
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possesses with respect to mental health care and competency issues in general. Tell that to her 3/14/12
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grievance to the SBN, wherein she manages to write:

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000569
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"This letter constitutes a fonnal complaint of attorney misconduct and/or

disability against Zachary Barker Coughlin. The accompanying box of materials
demonstrates some of the problems with the practice of this attorney being
experienced by myself and the other three judges in Reno Municipal Court. My
two most recent Orders in what should be a simple traffic citation case are selfexplanatory and are included, together with copies of massive documents Mr.
Coughlin has fax-filed to our court in this case. Audio recordings of two of my
hearings in this matter are also included. He failed to appear for the second one
this past Monday. I have another traffic case pending trial with him that was reassigned to me based on our Department 1 judge being out for surgery. We have
multiple addresses for Mr. Coughlin and can't seem to locate him between cases
very easily. We are setting that case for trial and attempting to serve him at
the most recent address we have (1422 E. 9th St #2, Reno NY 89512),
although I heard today he may be living in his vehicle somewhere. We do
have an address for his mother, however, as she recently posted part of a fine
for him. Judge Ken Howard Department 4 had case on Mr. Coughlin late last year
that is now on appeal to the Second Judicial District Court Judge Linda Gardner,
Department 2, also has a matter currently pending in his court with Mr. Coughlin
as the defendant. I have enclosed some copies of documents from those matters,
in chronological order, simply because they appear to demonstrate that he is
quickly decompensating in his mental status. Our staff also made you some audio
tapes of Coughlin hearings in Departments 2 and 4 so you can hear for yourself
how this attorney acts in court. You can see his behavior in my traffic citation
case does not appear to be an isolated incident.
You will the full cooperation of myself the other judges, and the staff of
Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned
himself as a vexatious litigant in our court, antagonizing the staff and even our pro
temp judges on the most simple traffic and misdemeanor matters. I do think this is
a case of some urgency and I apologize for taking two days to get this package to
you; our IT person was ill and could not make the copies of the audios of Mr.
Coughlin's hearings until today, and I felt it was important that the audios be
included in the materials to be considered by the State Bar. On February 27, 201
Mr. Coughlin told me he was actively practicing law and had appointments with
clients. I do not know if that was true, but if so, he could be causing serious harm
to the practice of law in Northern Nevada and could be jeopardizing someone's
freedom or property interests. Please contact me if you need any other
information. My direct line is 775-334-3823 and my cell phone is 775-250-0330"
And regardless of whether the materials the RMC's Nash Holmes provided King
are certified (good gawd they should be considering what it is she is trying to do with
them!, Coughlin was entitled to have them admitted for the purpose of showing what King
was provided by Nash Holmes with "the full cooperation of" her and "the ohter three RMC
Judges"
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AT the 11/14/12 Hearing Judge Nash Holmes lied when she testified that she
"started asking Coughlin questions about whether he was recording the proceeding or
whether he had a recordign device and he immediately go all sneakity and then said no, he
was not and didn't have a recording device, then he switched up his story and said that
was, get this, a "Fifth Amendment" thing...then he immediately asked to go to the
restroom, and I let him, but ORder RMC Marshal Harley to go with him, and refused to
allow Coughlin to take anything with him, even his yellow legal pad, and Marshal Harley000570
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reported to me that Coughlin disassembled a smart phone or recording device in the

restroom and hid parts of it there, which the Marshals later discovered after Coughlin was
handcuffed and arrested, and I think Coughlin probably lied about whether he was
recording the proceeding, so I found by "clear and convincing" evidence that Coughlin
violated all these rules of professional conduct that I conversed with Bar Counsel about,
and I am not trying to take Bar Counsel's place or nothin', but I am just tryin' a chip in an
do my part to make the public safe from this "attorney" whose writing is the most
frightening and unorthdox display of immense, immense talent that I have ever had the
misfortune of having been subjected to..." (Chair Echeverria was terrified of the prosepct
of the cook off, er, Disciplinary Hearing being recorded, and refused to allow Coughlin to
do so, lying that it was being record by the court reporter, though now Sunshine
Reporting, whose reporte Carol Hummel did the trancribing, is saying no recording was
made, and that, yes RMC "exclusive"transcritpinist Pam Longoni is amongst there
employees and that (and this combines with Judge Linda Gardner's current and then
deputy on the April 2009 trial being the deputy assigned the the 11/14/12 Discipinary
Hearing (what did I tell you? Can Patty Ice stacks a deck for hisself or what?
Tommy Susich, too. You just don't mess with the NV DETR or Maureen Cole, right
Tommy?). See attached materials related to the RMC and Longonis continuously
violating Nevada law in NRS 189.010-050 regarding the preparation of criminal
indigents transcripts on appeal.
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TRANSCRIPTS ON APPEAL/OTHERS CASSANDRA JACKSON Interim Court

Adminisu-ator J'USTJi'i ROPEI{ Chief Marshal - Depanmcnt of Alternative Sentenc
ing If you wish to order a transcript of your proceedings in the Reno Municipal
Court, you may do so by contacting Pam Longoni at (775) 530-5251. The following
information is provided to assist you in placing an order for a transcript: I. Orders
will require the date of the court appearance, type of proceeding, (trial, arraignment,
etc.), department number in which the proceeding was held, and also include the
appropriate deposit as indicated below. Payment may be made by check or money
order. No transcript will be prepared until the required deposit is received. ---~
7..,eost. Appeal transeripts are billed at $4.10 per page, which includes an original (to
be filed willi District Court), one copy for the appeilant, and one copy for the
opposing counsel. Transcripts ordered for purposes other than appeal, where only
one copy and original transcript is required, are billed at $3.00 per page. 3. Deposits.
Deposits required are as follows: $75.00 for arraignment/sentencing; a minimum
deposit of$200.00 for any trial transcript; and a minimum deposit of$500.00 for very
lengthy trials (those lasting more than three hours). NO TRANSCRIPT IS
CONSIDERED TO BE OFFICIALLY ORDERED, AND COMMENCEMENT OF
TRANSCRIPTION WILL NOT BEGIN, UNTIL RECEIPT OF THE REQUIRED
DEPOSIT. 4. Follow-up on Transcript Preparation. You will be notified when your
transcript has been prepared. If the actual cost of the transcript is less than the
amount of the deposit paid, a iefund will he issued with the transcript. And, likewise,
any outstanding balance due after completion of the transcript must be paid before
the Original is filed with District Court or any copies released. 0 refunds of deposits
will be given for transcripts once they have been prepared and no responsibility will000571
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be taken for the dismissal of any -appeal by District Court because no Original was
filed due to non payment of an out~ !and ing balance due. 5. Questions. Pam Longoni
will be happy to answer any qustions you may have"
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Panel Chair flat out refused to let a single piece of evidence be admitted that would in any way call
into legitimacy the convictions at issue in that Disciplinary Hearing. Supreme Court has obligation in
disciplinary proceeding to look beyond label given to attorney's conviction to true nature of facts, in order to
determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 111, subd.
3. State Bar of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39 2.
Indictment Where the only relevant factual allegation contained in Disciplinary Board's affidavit, filed in
support of its petition for attorney's temporary suspension from the practice of law, was that a criminal
indictment had been filed against the attorney, this sole allegation, without more, was insufficient to justify
summary suspension and the immediate imposition of temporary restrictions. Sup.Ct.Rules, Rules 102, subd.
4(a), 111, subd. 1. Matter of Monteiro, 1984, 684 P.2d 506, 100 Nev. 440. Attorney And Client 48 3. Serious
crime Attorney was not convicted of serious crime within meaning of rule regarding attorney suspension
where attorney did not engage in any criminal conduct whatsoever, did not engage in a conspiracy, and
actually entered plea of nolo contendere to nonexistent offense Sup.Ct.Rules, Rule 111, subd. 2. Sloan v.
State Bar of Nevada, 1986, 726 P.2d 330, 102 Nev. 436. Attorney And Client 39 4. Suspension of rule In
interest of justice, Supreme Court suspended court rule requiring it to order suspension of attorney upon
receipt of certificate of his conviction where attorney was impeached federal judge, who was arguably
beyond Supreme Court's jurisdiction, and attorney had voluntarily refrained from practice of law after his
release from incarceration, pending resolution of disciplinary proceeding. Sup.Ct.Rules, Rule 111. State Bar
of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 115. Attorney And Client 39
Further, SBN Bar Counsel King lied continuously to Coughlin, every step along the way, in the
disciplinary matter. King's lies are too numerous to fully detail here, but, one was with regard to the
following, where King wrote to Coughlin about two grievances and an "Order" he had received: "The
grievances include supporting evidence in the form of: audio of your conduct in court proceedings. I am
enclosing with this letter copies of a grievance letter, from the Municipal Court and a copy of an Order
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000572
from District Court Please respond to allegations pertaining to your conduct. I will make available for your
review and inspection the supporting documents and audio recordings." King lied for months about this
purported offer to "make available for your review and inspection the supporting documents and audio
recordings". Simply put, Pat King is a cheap cheater. He cheats constantly in his role as Bar Counsel,
perverting and descreatign SCR 105(2)(c) at every turn, lying constantly to opposing counsel and
Respondent's (King told Coughlin that David Clark had given Coughlin permission to issue subpoenas for
the Disciplinary Hearing, suspended attorney or not, only to then file Ex Parte Motions to Quash the
Subpoenas based upon their not being issued by a licensed attorney...and Chair Echeverria grants King's Ex
Parte Motions the day they are filed...but admits to having not even bothered to read those filed by Coughlin.
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Clearly, stogie smokin' Boss Hog Echeverri had failed to review the multitude of materials Coughlin
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provided him. And clearly King had lied (and in fact, once caught doing so at the hearing, was reduced to
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back peddling furiously) to Coughlin (as did Peters) when they asserted that everything Coughlin filed with
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the SBN was copied and provided to all the Panel Members (whose addresses the SBN refused to provide to
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Coughlin, as did the SBN refuse to provide any set of rules of procedure that the Panel had adopted under
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SCR 105. King was caught at the Hearing upon cross examination by Coughlin, having to admit that he did
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not provide the CD/DVD's that Coughlin attached to his various filings. Panel Member Stephen Kent
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responded by announcing that he did not care that King lied about copying the Panel members on the
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cd/dvds attached as exhibits to Coughlin's filing and that, even if King had so attached those cd/dvds, Kent
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wouldn't have review them anywas. However, 1980 graduate of McGeorge School of Law Stephen Smiley
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Kent, Esq. (a perfect choice by King and Susich for the Panel given the apparent connection to Mike Smiley
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Rowe, Esq (whom Coughlin named in a grievance related to the fraudulent conduct by the SBN incident to
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his application for admission) and the act that, a McGeorge SOL 1980 graduate would necessarily have
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strong ties to Judge Howard (McGeorge '81), Keith Loomis (McGeorge '82, and for whom the grievance
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Coughlin filed against King disposed of with great quickness and shallow rationale), as well as Judge Nash
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Holmes, McGeorge '77, Judge Beesley, McGeorge '79, WLS's Paul Elcano, McGeorge '78, etc., etc.. Kent,
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besides glaring at Couglhin throughout the Disciplinary Hearing also attempted to take the spotlight off the
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lie that Coughlin had just caught Bar Counsel King and Clerk Peters in when the Panel members and King
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admitted that King and the SBN had failed to provide copies of the exhibits Coughlin attached to his filings,
000573
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despite the SBN having agreed to do so and represented to Coughlin that it would. Kent announced,
brazenly, that he didn't care if King copied him or the panel on the attachments to Coughlin's filings or that
King has indicated to the Panel that he was so copying the Panel on the entirety of Coughlin's filings, yet did
not point out that he actuall, was not, choosing to excise the dvd/cd attachments to those filings (and it does
not seem clear that King even did in fact have teh SBN copy the Panel member on all of Coughlin's filings,
particulary where Laura Peters had previously told Coughlin he could file by email or fax, and that the SBN
would never attempt to assert that the 8/23/12 certified mailing would be proof of or return of service. Once
the SBN makes a representation, SCR 109 goes out the window, and it is shameful that Pat King was fully
aware of that representation, and co-signed by his September 25th, 2012 attempts to get Coughlin to show
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up the the SBN for a hearing that was noticed and calendared to Coughlin and Susich for 9/25/12...only for
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King to refuse to hold the hearing, and instead seek to jam a bunch of other matters into a "combo-hearing"
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including pending criminal charges in violation of Monteiro. Furhter Burleigh was violated in ever way due
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process wise, and the Panel outright flouted Nevada Law by refusing to recognize Claiborned. And so
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curious how the dismissal of this appeal is not signed by a Justice, and occurs just in time for the
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Disciplinary Hearing. (to go along with Michael Johnson apparently checking his twitter or facebook
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acount on his smartphone for most of the day....the only Panel members who displayed any professionalism
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at all were Clark Vellis, Esq. and laymember Karen Pearl, though it was entirely inappropriate for any of
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them to agree to sit for the hearing at all given the per se violations of SCR 105(2)(c), and thus, the total lack
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of jurisdiction to hold such a hearing. He is literally the cheapest, sleaziest attorney I have ever come across
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in my life...and I have dealt with Richard G. Hill, Esq. and Casey Baker, Esq. Pat King is literally more
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chicanerous than anyone I have every witnessed in my life. He has this Disciplinary Hearing thing sewn up
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to the point where he revels in SCR 106 immunity so much so that he brazenly lies at every turn, and
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encourages, and often forces "Clerk of Court/Investigator" Laura Peters to lie as well, which she does readily
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and often (telling Coughlin that she had the authority to and di so grant Coughlin the right to issue and have
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served subpoenas without paying witness fees, and further, that Respondent's never pay witness fees in these
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Disciplinary Hearings (good luck figuring out which rules apply, as clearly the NRCP do not, given Chair
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Echeverrias utter disregard for the NRCP and all of SCR 105(2)(c), typically done while Echeverria cackles
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and smiles menacingly at the Respondent, plays grab ass with his boyhood chum Elcano, and smokes a big
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000574
old stogie, Boss Hog style during the numerous "breaks" he insisted were a better use of the time for a
Hearing than affording Couglin an opportunity to, say, ask Judge Nash Holmes question about her
participation in the "clandestine status conference" on 2/27/12 wherein the Order for Competency Evaluation
was directed to Coughlin in rcr2012-065630 or the "strategy sessions" and "meetings" the RMC Judges and
court appointed defenders (like Loomis and City Attorney Hazlett-Stevens,Esq admit to having with Judge
William Gardner in the morning, secret to Coughlin prior to the 4/10/12 Trial date in the trespass matter
(which was set for Trial by Loomis and the RMC on 3/8/12 at a time when both tyhe RMC, Judge W.
Garnder, Loomis, and City Attorney Hazlett-Stevens knew full well that there was the 2/27/12 Order for
Competency Evaluation pending against Coughlin in RCR2012-065630 (and NRS 178.405 vis a vis NRS
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5.010, in combination with Judge Nash Holmes accustation "on behalf of all RMC Judges" in her 3/14/12
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greivannce against Coughlin (and Judge W. Gardner lied on the record during the April 10th, 2012 "Trial"
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and Motion Hearing in 11 CR 26405 when he alleged that none of Judge Nash Holmes Orders or her
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grievance letter the the SBN mentioned any "competency" issues related to Coughlin. Perhaps what is so
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distrubing is the extent to which these Judges lies are so easily disproven, indicating they have very little
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regard for the idea that this judicial system will ever take them to task for so doing. (and he refused to allow
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Coughlin more than and hour and a half to put on his case, most of which was, of course, wasted listening to
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Echeverria rule as irrelevant or inadmissible every single piece of evidence Coughlin sought to introduce,
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even a certified copy of the audio of the Trial n 11 TR 26800 that would prove that Judge Dorothy Nash
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Holmes lied and lied during her testimony. Not only did Coughlin have the audio cd that King finally gave
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to him
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SCR Rule 105. Procedure on receipt of complaint.
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2. Commencement of formal proceedings. Formal

disciplinary proceedings are commenced by bar counsel
filing a written complaint in the name of the state bar. The
complaint shall be sufficiently clear and specific to inform
the attorney of the charges against him or her and the
underlying conduct supporting the charges. A copy of the
complaint shall be served on the attorney and it shall direct
that a verified response or answer be served on bar counsel
within 20 days of service; the original shall be filed with
bar counsel's office. The time to respond may be
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extended once by the chair for not more than 20 days

for good cause or upon stipulation of the parties. In the
event the attorney fails to plead, the charges shall be
deemed admitted; provided, however, that an attorney who
fails to respond within the time provided may thereafter
obtain permission of the appropriate disciplinary board
chair to do so, if failure to file is attributable to mistake,
inadvertence, surprise, or excusable neglect.
(a) Challenges to and ad hoc appointments of panel
members. The complaint shall be served with the list of
members of the appropriate disciplinary board. The
attorney, or each if more than one, and bar counsel may
exercise five peremptory challenges each to the people on
the list by delivering such in writing to bar counsel on or
before the date a response to the complaint is due. "
(COUGHLIN HEREBY EXCERCISE HIS RIGHT TO
PEREMPTORILY REMOVE PANEL CHAIR
ECHEVERRIA AND McGeorge SOL Class of 1980
Stephen Smiley Kent (and anyone who went to McGeorge
for that matter, or even applied there) (whose classmates at
McGeorge include RMC Judge Kenneth Howard, who
denied Coughlin even one continuance in the first offense
petty larceny of a de minimis amount of food from a WalMart at a time when Coughlin was besieged with an
unlawful summary eviction from his former home law
office, and had an impermissible NRS 40.253(6) violating
"rent escrow" deposit of $2,275 required by the RJC just to
preserve Coughlin's right to litigate at the 10/25/12 "Trial"
Date (the RJC, noticed in writing the parties on the fact that
that was a "Trial" date in light of Judge Sferrazza's ruling at
the 10/13/11 summary eviction proceeding based upon a
No Cause Notice only (ie, non payment of rent was not
pled, making Hill and Baker's use of the summary eviction
process violative of nevada law against commercial tenant
Coughlin, particularly where Coughlin held the address out
to the public under SCR 79 as his law office, where filings
such as the one on 8/10/11 by Coughlin on behalf of then
client Robert Bell (in the matter that Judge Linda Gardner
recused herself from citing judicial cannon 2.11(a) (just
admitting a flat out bias against Coughlin) as the basis for
doing so) in fv11-02864 and the associated TPO
demonstrate via the 121 River Rock address in the caption
for then attorney Coughlin that the location was Coughlin's
law office, and that Coughlin was a commercial tenat, who
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possessed a law license at the time and where it is not clear

the "home office" exception to any requirement to have a
City or STate business license, particulary where Coughlin
was making less than $28,500 per year, attach in any way...
Coughlin objections to Panel Chair Echeverria's
participation go beyond the evident impartiality
demonstrated in all his various quick fire approvals of
King's Motions (including Motions to Quash Subpoenas
that fail to recongize the lies King and the SBN told
Coughlin with Respect to Chief Bar Counsel Clarks, Kings
and Clerk of Court Peters representations to and
agreements with Couglin vis a vis the application and
interpreation of SCR 110. "Subpoena power, production so
documents, witnesses, and pre-trial proceedings"...
Challenges to any member for cause under Rule 103(7)
shall be made as soon as possible after receiving either
actual or constructive notice of the grounds for
disqualification, and shall be made by motion to the chair
in accordance with these rules. In no event will a motion
seeking the disqualification of a member be timely if the
member has already heard, considered or
ruled upon any contested matter, except as to grounds
based on fraud or like illegal conduct of which the
challenging party had no notice until after the contested
matter was considered. Any challenge that is not raised in a
timely manner shall be deemed waived.
The chair may make ad hoc appointments to replace
designated panel members in the event challenges or
disqualification reduce the number to less than the number
required for the hearing panel. Ad hoc appointees shall be
subject to disqualification under Rule 103(7) and any
remaining peremptory challenges unexercised by either
the attorney(s) or bar counsel. A hearing panel as finally
constituted shall include a non-lawyer.
"(b) Assignment for hearing; venue. Following service of a
responsive pleading, or upon failure to plead, the
matter shall be assigned by the chair of the disciplinary
board to a hearing panel...."
There has not even been service of the complaint yet!!!!
Peters 10/9/12 Affidavit and Coughlin's various filings
and 11/19/12 Affidavit establish that conclusively.
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(c) Time to conduct hearing; notice of hearing;

discovery of evidence against attorney. The hearing
panel shall conduct a hearing within 45 days of
assignment and give the attorney at least 30 days'
written notice of its time and place. The notice shall be
served in the same manner as the complaint, and shall
inform the attorney that he or she is entitled to be
represented by counsel, to cross-examine witnesses, and
to present evidence. The notice shall be accompanied by
a summary prepared by bar counsel of the evidence
against the attorney, and the names of the witnesses bar
counsel intends to call for other than impeachment,
together with a brief statement of the facts to which
each will testify, all of which may be inspected up to 3
days prior to the hearing. Witnesses or evidence, other
than for impeachment, which became known to bar
counsel thereafter, and which bar counsel intends to use
at the hearing, shall be promptly disclosed to the
attorney. For good cause shown, the chair may allow
additional time, not to exceed 90 days, to conduct the
hearing.
(d) Quorum; time for decision of panel; votes required to
impose discipline. Any five members of the panel shall be a
quorum. The hearing panel shall render a written
decision within 30 days of the conclusion of the hearing,
unless post-hearing briefs are requested by either bar
counsel or the attorney and allowed by the panel or
requested by the chair, in which event the decision shall
be rendered within 60 days of the conclusion of the
hearing. The decision shall be served pursuant to Rule
109(1), accompanied by the panel's findings and
recommendation, all of which shall be filed with bar
counsel's office. A decision to impose or recommend
discipline requires the concurrence of four members of the
panel.
COUGHLIN REQUESTS A LEGITIMATE
OPPORTUNITY TO PUT A MORE APPROPRIATE
VERIFIED ANSWER OR RESPONSE ON FILE IN THIS
MATTER...FURTHER, COUGHLIN HEREBY
REQUEST AN OPPORUTNITY TO SUBMIT A POST
HEARING BRIEF...EVEN THOUGH THE HEARING
HE STILL REQUESTS BE STRIKEN OR VIEW MORE
AS A INTRODUCTORY MEETING...AND COUGHLIN
REMIND THE COMMITTEE THAT UPON THE
HEARING DATE OF 11/14/12 BEING RULE AS VOID
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000578
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FOR LACK OF DUE PROCESS, NOTICE, SERVICE,

PROCESS, JURISDICTION, ETC...THE PANEL WILL
SOON RUN UP AGAINST THE "WITHIN 45 DAYS OF
ASSIGNMENT" DICTATE
(e) Rules of evidence; support of panel's decision. The rules
applicable to the admission of evidence in the district
courts of Nevada govern admission of evidence before a
hearing panel.
Evidentiary rulings shall be made by the chair of the panel,
if one has been designated, or by the chair of the
appropriate disciplinary board prior to such a designation.
The findings of the panel must be supported by clear
and convincing evidence. And under SCR 104(3) and
SCR 103(7) Coughlin seeks to have SBN King removed
or conflicted out of this case for all the greivance
drumming up, for his impermissible communications
with Coughlin's then client's the Eastman's in early
may 2012, for feeding Judge Nash Holmes the "by clear
and convincing evidence" standard inserted into her
3/12/12 Order transmogrifying the trafficat case to a a
summary disciplinary hearing (and her testimony on
11/14/12, you could tell, was already anticipating the
jeers and offering mea culpas in that regard, or at least
caveats to spare...
(f) Court reporter. All formal hearings shall be reported by
a certified court reporter, which cost may be assessed
against the attorney pursuant to Rule 120. Any party
desiring to have any other disciplinary proceedings
reported must arrange in advance for a certified court
reporter at the party's own expense.
Zach Coughlin, J.D.
Patent Agent, USPTO
1471 E. 9th St.
Reno, NV 89512
Tele and Fax: 949-667-7402
November 17th, 2012,
RE: LITIGATION HOLD NOTICE REGARDING EVERY RECORDING,
DOCUMENT, DRAFT OF ANY SORT, OR PIECE OF DATA COLLECTED WITH
RESPECT TO THE ILLEGALLY HELD DISCIPLINARY HEARING OF 11/14/12 AT
THE STATE BAR OF NEVADA, AT WHICH CAROL HUMMEL WAS THE COURT000579
REPORTER OF RECORD AND FOR WHICH IT HAS BECOME KNOWN THAT PAT
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KING HAS A COPY OF THE RECORD OF THE PROCEEDING ALREADY AND

THEREFORE HAS BEEN GIVEN YET ANOTHER IMPERMISSIBLE ADVANTAGE
REQUIRING ANY RECORDINGS, ROUGH DRAFTS, WRITTEN TRANSCRIPTS,
OR AUDIO TRANSCRIPTS BE IMMEDIATELY TURNED OVER TO COUGHLIN
NOTICE OF CONFLICT BETWEEN ZACH COUGHLIN AND SUNSHINE
REPORTING SERVICES GIVEN SUNSHINE'S ADMISSION THAT PAM LONGONI
IS ON ITS STAFF AND MS. LONGONI'S DIRELECTION OF HER DUTIES IN 11 CR
22176, WHICH RESULTING IN A DISMISSAL OF COUGHLIN'S APPEAL IN CR112064 AND THE CURRENT TEMPORARY SUSPENSION OF COUGHLIN'S LICENSE
TO PRACTICE LAW IN 60838
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John Peter Echeverria, Esq., Panel Chair

Echeverria Law Office/Echeverria Group
9432 Double R Blvd.
Reno , NV 89521
Tel: 7757864800 Fax : 7757864808 JE@ELORENO.com
State Bar of Nevada, Office of Bar Cousnel
David Clark, Esq., Chief Bar Counsel
Las Vegas: 600 E. Charleston Blvd
Las Vegas, NV 89104 Phone: 702-382-2200 Fax: 702-385-2878
Patrick O. King, Assistant Bar Counsel
9456 Double R Blvd, Suite B
Reno, NV 89521 Tel: 775-329-4100 Fax: 775-329-0522

Dear Chair Echeverria, Panel Members, and SBN Office of Bar Counsel,
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Please provide to me immediately all materials (including the sound recording) of

the 11/14/12 Disciplinary Hearing that Pam Longoni coworker and Sunshine Reproting
Services employee, CCR Carol Hummel was the CCR on at the State Bar of Nevada from
approximately 8:30 am to approximately 6 pm. As you are aware, I have a conflict with
Pam Longoni that likely will entail substantial litigation, to whatever extent there is not
already litigation ongoing. Please review the attached materials for more explication in
that regard. However, while I am not purporting to give you legal advice, I believe it was
wrong for that firm to work the 11/14/12 Disciplinary Hearing. I am writing to request to
be given immediately, and absent any sort of payment or agreement whatsoever, all
materials recording, transcribed, reported, or otherwise collected in any way by Sunshine
Reporting Services and or Carol Hummel at that 11/14/12 Hearing and any other materials
connected thereto, including correspondence or agreements with the State Bar of Nevada,
the Northern Nevada Disciplinary Board, and the Panel (including Panel Chari John
Echeverria, Esq. and the Echeverria Group) in addition to the materials Pat King himself
has.
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DUE TO MR. KING'S AND LAURA PETERS THREATS OF ABUSE OF

PROCESS (INCLUDING CALLING THE POLICE FOR SPURIOUS REASONS OR
PURSUING A PROTECTION ORDER, I AM HEREBY SERVING THE SBN, KING,
PETERS, AND PANEL CHAIR ECHEVERRIA A STAY AWAY ORDER OF MY
OWN. ANY ENTREATIES ONTO MY PROPERTY, WHICH IS MARKED WITH A
LARGE "NO TRESPASSING" SIGN, MUST BE APPROVED IN ADVANCE AND
REQUIRE A PHONE CALL PRIOR THERETO AND EXPRESS APPROVALY BY
ZACH COUGHLIN AND ONLY ZACH COUGHLIN. FURTHER, COUGHLIN
HERERBY DEMANDS THAT ALL OF HIS FAX FILINGS BE FILESTAMPED AND
THAT A COMPLETE COPY OF THE RECORD AND DISCIPLINARY FILE BE
PROVIDED TO COUGHLIN, INCLUDING HIS OWN FILINGS, AND THAT THE
SBN COMPLY WITH THE STATES RULES AND POLICIES IT ARTICULATED TO
COUGHLIN ON ITS OWN BEHALF AND ON BEHALF OF THE PANEL AND
BOARD AND PANEL CHAIR, BY PROVIDING COMPLETE COPIES OF
EVERYTHING COUGHLIN HAS SUBMITTED (INCLUDING THE CD/DVDS
ATTACHED AS EXHIBITS) TO ALL PANEL MEMBERS.
I am indigent, severly so, and the State Bar of Nevada and Chair Echeverria, some
might say, are fraudulently attempting to take away my Fourteenth Amendment property
right, my law license, chiefly through their numerous violations of SCR 105(2)(c) and and
any other due process rules, law, or concepts they can desecrate. There simply was no
colorable basis for ruling that I was not permitted to record the proceedings...although,
neither the DCR nor NRCP appear to have any rules either prohibiting the recording of
Disciplinary Proceedings (made applicable via SCR 105(4), unless the Panel has enacted
some unpublished rules that it has so far refused to give me, as is the case with the SBN.
FURTHER, THE SBN AND NNDB PANEL AND ITS CHAIR, AND HIS LAW
OFFICE AND ECHEVERRIA GROUP ARE HEREBY PLACED ON A LITIGATION
HOLD NOTICE. PAT KING MAKES CUTE JOKES LIKE "WHAT'S A LITIGATION
HOLD NOTICE"...ITS SOMETHING THAT WILL SUBJECT YOU TO CONTEMPT,
PAT, NEVERMIND YOUR ILLUSIONS RESPECTING SCR 106 AND YOUR
"UNLIMITED IMMUNITY"...MR. KING, I AM HEREBY ONCE AGAIN PLACING
YOU ON NOTICE THAT LITIGATION IS LIKELY TO ARISE REQUIRING YOU TO
MAINTAIN AND TURN OVER AT SOME POINT THE MANILA ENVELOPE THAT
THE SBN PLACED INSUFFICIENT POSTAGE ON IN MAILING OUT ON 10/9/12
(OR AT LEAST PRINTING THE RED PITNEY BOWES POSTAGE THEREON ON
THAT DATE...AND PLEASE REALIZE, THE SBN DID NOT SEND THAT NOITD
BY FIRST CLASS MAIL IN ADDITION TO A CERTIFIED MAILING...PROBABLY
SOME TACTICAL DECISION BY KING TO GAIN AN ADVANTAGE, CHECK THE
CERTIFICATE OF MAILING...THE LITIGATION HOLD NOTICE EXTENDS TO
ALL CALL RECORDS BETWEEN THE SBN IN ANY WAY WITH CHAIR
ECHEVERRIA OR OTHER MEMBERS OF THE PANEL, INCLUDING ACTIVITIES
INVOLVING LAURA PETERS. CHAIR ECHEVERRIA'S STAFF LEFT COUGHLIN
A PHONE CALL IN RESPONSE TO HIS INQUIRY REGARDING A MUNDANE,
NON-SUBSTANTIVE MATTER (DEENA, NOT TERESA, AND YOU WILL WANT
TO REVIEW NRS 199.340(7) REGARDING SOME RECENT DEVELOPMENTS),
AND DEENE COMMUNICATE IN NO UNCERTAIN TERMS THE CHAIR WOULD 000581
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NOT SPEAK TO COUGHLIN, EVEN THOUGH HE IS PROCEEDING WITH SELF

REPRESENTATION AND IT IS MORE THAN COMMON FOR RESPONDENT'S
COUNSEL TO REGULARLY COMMUNICATE WITH THE CHAIR. I HAVE READ
ALL THE DECISIONS AND GRABBED THE RECORDS ON APPEAL. PLEASE
IMMEDIATELY PROVIDE ME A COPY OF ANY PROCEDURAL RULES THE
BOARD HAS ADOPTED INCIDENT TO SCR 105 AND EXPLAING WHY THE
10/9/12 AFFIDAVIT OF LAURA PETERS IS FILE STAMPED, YET WAS NEVER
SENT TO COUGHLIN. PLEASE FURTHER EXPLAIN WHY THE "DISCIPLINARY
FILE" HAS BEEN DOCTORED TO EXCLUDE THE GREEN CERTIFIED MAIL
TAGS FOR THE COMPLAINT (WHICH USPS TRACK & CONFIRM REVEALS WAS
NEVER SIGNED FOR BY COUGHLIN, AND IN FACT, JUST AS CLERK PETERS
ADMITTED ON SEPTEMBER 11TH, 2012 AT 4:55 PM, WAS RETURNED TO SEND
AND SIGNED FOR BY THE SBN ON 9/10/11. PLEASE HAVE CLERK PETERS
FILL OUT A NON FRAUDULENT RETURN OF SERVICE OR PROOF OF SERVICE
OF THE COMPLAINT REFLECTING HER DECLARATION OF SBN AND PANEL
RULES AND POLICY TO THE EFFECT THAT THE 8/23/12 CERTIFIED MAILING
WOULD NEVER BE PUT FORTH AS PROOF OF SERVICE OF THE
COMPLAINT....WHICH LEAVES THE SBN AND PANEL TO EXPLAIN WHY KING
UNILATERALLY ALTERED THE DECLARATIONS MADE BY PETERS TO
COUGHLIN RESPECTING THE PROCEDURAL POLICIES AND ADOPTED RULES
AND PRACTICES OF THE BOARD, SBN, AND PANEL IN THESE DISCIPLINARY
PROCEEDINGS, INCLUDING HER ATTESTATION THAT SHE HAD AUTHORITY
TO REPRESENT TO COUGHLIN THAT NO TIME DEADLINES WOULD RUN FOR
ANY EVENT WHOSE SERVICE REQUIRED COMPLIANCE WITH SCR 109
(MEANING ALL MATTERS MENTIONED IN SCR 105(2)(C), MEANING THE
NOTICE OF THE HEARING WAS DEFICIENT, GIVEN COUGHLIN'S SIGNATURE
INDICATES A DATE OF 10/27/12, IE, FAR LESS THAN THE "AT LEAST 30 DAYS"
BEFORE THE HEARING MAY TAKE PLACE (17 DAYS IS NOT EVEN CLOSE),
AND THE Designation of Witnesses and Summary of Evidence is not listed in the
certificate of mailing, nor is it file stamped upon a review of the bate stamped filed box
that somehow took 7 days to copy (because Pat King needed to go back through it and
remove the certified mailing slips for which the SBN had not secured a signature from
Coughlin, including the NOITD (because the SBN placed insufficient postage thereon, and
Tim, counter attendant at the Downtown Reno Station would not release that 10/9/11
NOITD unless Coughlin paid the SBN's postage, which he clearly is not required to
do...Further, the Supplemental DoWSoE was not served in accord with SCR 109
considering the policies, rules, and practices the SBN, NNDB, and Panel held out to
Coughlin and upon which he justifiably relied. Basically, the entire hearing must be
thrown out, mistrial, recusal of Echeverria and Kent, and King is conflicted out too.
My issues with Ms. Longoni related primarily to her hanging up on me on more
than one occasion in December 2011 when I was attempting to comply with the dictates
she and the Reno Municipal Court put forth to criminal appellant's, including ones like me
who were indigent at that time.
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I need the materials I am requesting above immediately, TIME IS OF THE

ESSENCE with respect to a number of actions I must take to preserve my rights, and even
the roughest draft of the transcript and the audio recordings made that day are completely
vital to my protecting my rights. I believe you would be substantially mitigating your
potential liability by having these emailed to me immediately, though you should consider
getting counsel from your own attorney in that regard.
Further, I believe your firm and or Ms. Longoni may still be required to prepare
and provide to me the transcript for 11 CR 22176, (I am providing you via a cd/dvd in the
mail and a link to a SkyDrive contaning the audio therefor) as well as the transcript for 11
TR 26800 (a notice of appeal was filed on 3/7/12 and again sometime thereafter, and
during that time the RCM continued its illegal practice of holding Ms. Longoni out as the
only court reporter it would release the audio recordings to (certified or not), and further,
as demonstrated by the attached handout given to all criminal defendant appellants by the
RMC, Ms. Longoni and the RMC maintained a practice that was violative of NRS
189.030:
NRS 189.030 Transmission of transcript, other papers, sound
recording and copy of docket to district court.
1. The justice shall, within 10 days after the notice of
appeal is filed, transmit to the clerk of the district court the
transcript of the case, all other papers relating to the case and
a certified copy of the docket.
2. The justice shall give notice to the appellant or the
appellant's attorney that the transcript and all other papers
relating to the case have been filed with the clerk of the district
court.
3. If the district judge so requests, before or after receiving the
record, the justice of the peace shall transmit to the district
judge the sound recording of the case.
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I am prepared to move forward with respect to pursuing whatever lawful action I

may take in connection with this impermissible conflict of interest (which I believe I can
prove you knew full well about) in addition to the misconduct by Ms. Longoni in
connection with RMC 11 CR 22176. Nice touch having Judge Linda Gardner's courtroom
deputy work the hearing.
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Coughlin hereby demands that the SBN comply with the agreement and rules
requiring the SBN reveal the names of the Screening Panel members from the hearing on
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Department in the RMC, even though the Order is from D14 of the Second Judicial
District Court (whose courtroom deputy worked the 11/14/12 Disciplinary Hearing along
with one of Pam Longoni's co-workers...Carol Hummel (no offense to Ms. Hummel...I
blame Pat King and or Susich here, as King is now backing out of an agreement to
indicate who was on the Screening Panel and the Panel for the Hearing was obviously
hand picked to arrive at the most biased crowd available or possible.
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3. Review by supreme court.

(a) Time and manner of appeal. A decision of a hearing
panel shall be served on the attorney, and service shall be
deemed Notice of Entry of Decision for appeal purposes.
Except as provided in Rule 105(3)(b) a decision is final and
effective 30 days from service, unless an appeal, is taken
within that time. To the extent not inconsistent with these
rules, an appeal from a decision of a hearing panel shall be
treated as would an appeal from a civil judgment of a
district court and is governed by the Nevada Rules of
Appellate Procedure.
(b) De novo review of public discipline. Except for
disbarments by consent pursuant to Rule 112 or a public
reprimand agreed to in writing by the attorney pursuant to
Rule 113, a decision recommending a public reprimand,
suspension or disbarment shall be automatically reviewed
by the supreme court. Review under this paragraph shall be
commenced by bar counsel forwarding the record of the
hearing panel proceedings to the court within 30 days of
entry of the decision. Receipt of the record in such cases
shall be acknowledged in writing by the clerk of the
supreme court.
The attorney and bar counsel shall have 30 days from the
date the supreme court acknowledges receipt of the record
within which to file an opening brief or otherwise advise
the court of any intent to contest the hearing panel's
findings and recommendations. If an opening brief is filed,
briefing shall thereafter proceed in accordance with NRAP
31(a). Extensions of time to file briefs are disfavored and
will only be granted upon a showing of good cause. The
parties shall not be required to prepare an appendix, but
rather shall cite to the record of the disciplinary
proceedings. If no opening brief is filed, the matter will be
submitted for decision on the record without briefing or
oral argument.
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4. Rules of procedure. The chairs, after consulting with

their respective disciplinary boards, may adopt rules of
procedure, subject to approval by the board of governors.
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1. In general
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Violations of professional conduct rules not charged in attorney disciplinary complaint

could not be considered by Supreme Court. In re Discipline of Schaefer, 2001, 25 P.3d
191, 117 Nev. 496, modified on denial of rehearing 31 P.3d 365, certiorari denied 122
S.Ct. 1072, 534
U.S. 1131, 151 L.Ed.2d 974. Attorney And Client 52 SO COUGHLIN OBJECTS TO
KING AND ECHEVERRIA'S ATTEMPTS TO TURN THE 11/14/12 HEARING IN
TO SOME SUMMARY DISCIPLINARY PROCEEDIGN FOR DECLARATION
MAKING IN THEIR PRESENCE, WHETHER LEVERAGING PAST FILINGS
REBRANDED OR NOT...
2. Due process
Procedure in which Board of Governors, the body responsible for finances of bar
association, functioned as factfinder in disciplinary proceeding against attorneys,
involving costs which were substantial and which were recoverable by state bar only
upon finding of misconduct, violated due process. Sup.Ct.Rules, Rules 85, 85, subd. 2,
86, subds. (1-4, 7, 12), 104, subd. 7 (1978); U.S.C.A. Const.Amend. 14. Matter of Ross,
1983, 656 P.2d 832, 99 Nev. 1, rehearing denied 668 P.2d 1089, 99 Nev. 657. Attorney
And Client 54; Constitutional Law 4273(3)
Individual members of disciplinary board had no personal financial stake in outcome of
their deliberations and no executive responsibilities for finances of state bar which
would be inconsistent with due process requirements for disciplinary proceedings,
despite potential for recovery by bar of fines and costs. Sup.Ct.Rules, Rules 86, 103,
subds. 1, 3; U.S.C.A.Const.Amend.
14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d 1201, 98 Nev. 140. Constitutional
Law 4273(3)
State cannot exclude person from practice of law without due process of law.
U.S.C.A.Const.Amend. 14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d 1201, 98
Nev.
140. Constitutional Law 4273(1)
Practice of a profession is valuable property right, of which one cannot be arbitrarily
deprived. U.S.C.A.Const.Amend. 14. Burleigh v. State Bar of Nevada, 1982, 643 P.2d
1201, 98 Nev.
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4. Degree of proof
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Ethical violations by attorney must be proven by clear and convincing evidence. In re

Discipline of Schaefer, 2001, 25 P.3d 191, 117 Nev. 496, modified on denial of
rehearing 31 P.3d 365, certiorari denied 122 S.Ct. 1072, 534 U.S. 1131, 151 L.Ed.2d
974. Attorney And Client 53(2)
In bar disciplinary matters, higher degree of proof is required than in ordinary civil
proceedings; clear and convincing evidence must support any findings of misconduct.
Sup.Ct.Rules, Rule 105, subd. 2(e). In re Discipline of Drakulich, 1995, 908 P.2d 709,
111 Nev. 1556. Attorney And Client 53(2)
In determining questions of fact, higher degree of proof is required in disciplinary
matters han in ordinary civil proceedings; standard is whether findings are supported by
clear and convincing evidence. Sup.Ct.Rules, Rule 105, subd. 2(e). In re Discipline of
Stuhff, 1992, 837 P.2d 853, 108 Nev. 629. Attorney And Client 53(2)
To determine questions of fact, higher degree of proof is required in attorney
disciplinary matters, than in ordinary civil matters; standard is whether findings are
supported by clear and convincing evidence. Sup.Ct.Rules, Rule 105, subd. 2(e). Gentile
v. State Bar of Nevada, 1990, 787 P.2d 386, 106 Nev. 60, certiorari granted 111 S.Ct.
669, 498 U.S. 1023, 112 L.Ed.2d 662, reversed 111 S.Ct. 2720, 501 U.S. 1030, 115
L.Ed.2d 888. Attorney And Client 53(2)
5. Recommendation of board
Although recommendations of disciplinary panel are persuasive, Supreme Court is not
bound by panel's findings and recommendation, and must examine record anew and
exercise independent judgment, in attorney disciplinary proceeding. In re Discipline of
Client 57
Disciplinary board's recommendation is not final and binding upon Supreme Court, even
though attorney has consented in writing to Board's decision. Sup.Ct.Rules, Rule 105,
subd. 3(b). Matter of Kenick, 1984, 680 P.2d 972, 100 Nev. 273. Attorney And Client 57
6. Continuances
Attorney was not entitled to continuance of second hearing date in attorney disciplinary
proceedings to obtain counsel, on basis that second hearing was reset for January 4, not
later in the month, and attorney not able to find new counsel because no one wanted to
work on his case over the holidays, where attorney stated on the record that he needed no
more than one week's notice of the continued hearing, and was aware from November 17
that he needed to find counsel immediately, attorney was notified no later than
December 6 of new hearing date, and even from December 6, attorney had four weeks to
obtain new counsel and to prepare for the continued hearing. In re Discipline of
Client 54
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ASSUMING THERE HAS BEEN SERVICE OF THE COMPLAINT,

WHICH HAS NOT BEEN SHOW, COUGHLIN REQUEST HIS FIRST
CONTINUANCE...
Sup. Ct. Rules, RULE 105, NV ST S CT RULE 105
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NRCP RULE 12. DEFENSES AND OBJECTIONS

WHEN AND HOW PRESENTEDBY PLEADING OR
MOTIONMOTION FOR JUDGMENT ON
PLEADINGS
(a) When Presented.
(1) A defendant shall serve an answer within 20 days after
being served with the summons and complaint, unless
otherwise provided by statute when service of process is
made pursuant to Rule 4(e)(3).
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Coughlin was never served with the Summons and

Complaints under SCR 109, and Bar Counsel cited no
authority to support its apparent contention that merely
mailing a certified mailing purporting to included the
Complaint is sufficient, especially where, as here, Bar
Counsel and the SBN made representations Coughlin was
permitted to reply upon to the effec that the 8/23/12
certified mailing Bar Counsel asserts would never be
offered as proof of or return of service.
(2) A party served with a pleading stating a cross-claim
against that party shall serve an answer thereto within 20
days after being served. The plaintiff shall serve a reply to
a counterclaim in the answer within 20 days after service of
the answer or, if a reply is ordered by the court, within 20
days after service of the order, unless the order otherwise
directs.
(3) The State of Nevada or any political subdivision
thereof, and any officer, employee, board or commission
member of the State of Nevada or political subdivision, and
any state legislator shall file an answer or other responsive
pleading within 45 days after their respective dates of
service.
(4) The service of a motion permitted under this rule alters
these periods of time as follows, unless a different time is
fixed by order of the court:
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(A) if the court denies the motion or postpones its

disposition until the trial on the merits, a responsive
pleading shall be served within 10 days after notice of
the courts action;
Chair Echeverria's Order purporting to require
Couglin file averified Response in less time than allotted
upon any purported ruling on Coughlin's Motion to
Dismiss, makes holding the Hearing on 11/14/12 and
and Order connected thereto void (even whether Bar
Counsel has perpetrated a fraud in standing behind a
certificate of mailing that is knows is not true as to the
October 9th, 2012 certified mailing only (in contrast to
practically everything else the SBN mailed, according to
its certificate's of mailing, the SBN sent the 10 9 12
Notice of Intent to Take Default by certified mial only,
ie, it was not sent via first class mail as well).
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(B) if the court grants a motion for a more definite

statement, a responsive pleading shall be served within 10
days after service of the more definite statement.
(b) How Presented. Every defense, in law or fact, to a
claim for relief in any pleading, whether a claim,
counterclaim, cross-claim, or third-party claim, shall be
asserted in the responsive pleading thereto if one is
required, except that the following defenses may at the
option of the pleader be made by motion: (1) lack of
jurisdiction over the subject matter, (2) lack of
jurisdiction over the person, (3) insufficiency of process,
(4) insufficiency of service of process, (5) failure to state
a claim upon which relief can be granted, (6) failure to
join a party under Rule 19. A motion making any of these
defenses shall be made before pleading if a further pleading
is permitted. No defense or objection is waived by being
joined with one or more other defenses or objections in a
responsive pleading or motion. If a pleading sets forth a
claim for relief to which the adverse party is not required to
serve a responsive pleading, the adverse party may assert at
the trial any defense in law or fact to that claim for relief.
If, on a motion asserting the defense numbered (5) to
dismiss for failure of the pleading to state a claim upon
which relief can be granted, matters outside the pleading
are presented to and not excluded by the court, the motion
shall be treated as one for summary judgment and disposed
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000588
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of as provided in Rule 56, and all parties shall be given

reasonable opportunity to present all material made
pertinent to such a motion by Rule 56.
Couglin presented all the above bolded defense and

Chair Echeverria did not dispose of all such Motions made
by Coughlin.
...
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(d) Preliminary Hearings. The defenses specifically

enumerated (1)-(6) in subdivision (b) of this rule, whether
made in a pleading or by motion, and the motion for
judgment mentioned in subdivision (c) of this rule shall be
heard and determined before trial on application of any
party, unless the court orders that the hearing and
determination thereof be deferred until the trial.
(e) Motion for More Definite Statement. If a pleading to
which a responsive pleading is permitted is so vague or
ambiguous that a party cannot reasonably be required
to frame a responsive pleading, the party may move for
a more definite statement before interposing a
responsive pleading. The motion shall point out the
defects complained of and the details desired. If the motion
is granted and the order of the court is not obeyed within 10
days after notice of the order or within such other time as
the court may fix, the court may strike the pleading to
which the motion was directed or make such order as it
deems just.
(f) Motion to Strike. Upon motion made by a party before
responding to a pleading or, if no responsive pleading is
permitted by these rules, upon motion made by a party
within 20 days after the service of the pleading upon the
party or upon the courts own initiative at any time, the
court may order stricken from any pleading any insufficient
defense or any redundant, immaterial, impertinent, or
scandalous matter.
(g) Consolidation of Defenses in Motion. A party who
makes a motion under this rule may join with it any other
motions herein provided for and then available to the party.
If a party makes a motion under this rule but omits
therefrom any defense or objection then available to the
party which this rule permits to be raised by motion, the
party shall not thereafter make a motion based on the
defense or objection so omitted, except a motion as
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provided in subdivision (h)(2) hereof on any of the grounds

there stated.
(h) Waiver or Preservation of Certain Defenses.
(1) A defense of lack of jurisdiction over the person,

insufficiency of process, or insufficiency of service of
process is waived (A) if omitted from a motion in the
circumstances described in subdivision (g), or (B) if it is
neither made by motion under this rule nor included in a
responsive pleading or an amendment thereof permitted by
Rule 15(a) to be made as a matter of course.
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(2) A defense of failure to state a claim upon which relief

can be granted, a defense of failure to join a party
indispensable under Rule 19, and an objection of failure to
state a legal defense to a claim may be made in any
pleading permitted or ordered under Rule 7(a), or by
motion for judgment on the pleadings, or at the trial on the
merits.
(3) Whenever it appears by suggestion of the parties or
otherwise that the court lacks jurisdiction of the subject
matter, the court shall dismiss the action.
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Also available at that link is the transcript from the criminal trespass Trial on 6/18/12
where HIll and Baker testify, before Judge L. Gardner's (whom recused herself from a
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case Coughlin represented Robert Bell in, filed August 11, 2011, which further proves that
22
Coughlin was a commercial tenant practicing law at the 121 River Rock address,
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something pled in Coughlin's Tenant's Affidavit and set forth repeatedly ad nausuem
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throughout the trial court case, which Hill mistakenly alleges, in his lie filled testimony at
25
the criminal trespass trial, that Coughlin "did not plead" that he was a "commercial tenant"
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in the trial court eviction case. Wrong, Mr. Hill. The record is quite clear that Coughlin
000590
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did. And Judge L. Gardner's recusal (and Judge Flanagan's Presidency of the SBN during
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a period of time in which Coughlin now has pending grievances against members of the
Character and Fitness Committe further complicates matters and augured for a recusal,
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beyond the apparent bad mouthing of Coughlin by Judge Flanagan and Coughlin's former
firm, where they were both a part of at the same time in 2005, to the CBX (unless the CBX
is lying or bluffing, which is entirely possible, as anyone who has ever met a bar counsel
could tell you) is just another reason why recusal was appropriate. Additionally, the
lockout pursuant to the eviction Order, whether the Eviction Decision and ORder of
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October 25th, 2011 or the Findings of Fact, Conclusions of Lw....of 10/27/11 (depending
on how one view NRS 40.253's "within 24 hours" dictate) was either performed to early or
too later, and therefore the Order was stale or
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void at time WCSO Machen and Baker conduted the lockout. (too early under the analysis
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respecting the application, via nrs 40.400 of NRCP 5 and NRCP 6 requiring 3 days for
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mailing for "constructive service" of such and Order, and beyond that the Second Judicial
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District Court appears to have refused for filing from Couglin a filing that may have
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operated as a MOtion to STay under NRAP 8 sometime between October 26th, 2011 and
19
November 2nd 2011 in CV11-03051 or CV11-03126, in violation of Whitman, Sullivan,
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Donoho and NRCP 5(e)'s dictate against clerk's rejecting filings regardles of what a local
21
rule says) or the lockout was conduct too late in light of the testimony by Baker
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concerning how and when the wCSO received the lockout order or either of the eviction
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orders (Baker indicated his office relied upon the usual practice of the RJC to transmit it to
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the wCSO, but curiously the RJC seems to now assert is has no record of such a
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transmission, and the WCSO is lawyering up when it comes to such information.
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000591
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eviction
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Richard G. Hill, Esq. and Casey Baker, Esq. (who has now conveniently absconded back to
Kentucky now that his lies have imperiled Coughlin's law license (see Coughlin's recent filing in 61901 and
60838 for more explication thereof) failed to comply with Nevada law respecting the return of Coughlin's
security/damage/cleaning deposit ($500 for security/damage, $200 for "cleaning" deposit, with the Standard
Rental Agreement giving Coughlin certain options thereto). Coughlin is indigent (largely due to the fraud of
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Baker, Hill, and their client, Dr. Matt Merliss, MD) and asks this Court to recognize that the failure of the
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landlord to comply with Nevada law vis a vis the itemization or return within 30 days of the deposits should
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fulfill any $500 bond on appeal, and then some. Further, the Reno Justice Court is still refusing to return the
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$250 Coughlin deposited with it in compliance with NRS 118A.380 and 118A.385 (further, it is not clear
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how NJCRCP 72 or 73 could apply to summary eviction (even ones like this one that were notice, in writing,
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by the RJC, as a "Trial" after Judge Sferrazza had ruled that Coughlin had met his NRS 40.253 burden to
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prove there was a "genuine issue of material fact", both at and following the 10/13/11 "summary eviction
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proceeding" and during the first part, at least, of the "Trial" which curiously transmogrified into, apparently,
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something other than a Trial when Baker managed to point out, the consequences thereof. Regardless,
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Coughlin filed a Notice of Appeal on October 18th, 2011 (and see also the appeal and associated general
24
civil Complaint in the District Court). Also, court clerk's Michelle Purdee and or Lori Matheus seemed to
25
refuse to file in a document from Coughlin sometime between October 17th to November 1st, 2011 that may
26
have arguably operated as a NRAP 8 Motion to Stay, in violation of the dictates in Nevada law against court
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clerk's unilaterally refusing to file things, like in Whitman, Sullivan, Dohono, Barnes, and their progeny.
000592
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Further,
- 50/71 -

Now the SBN intends to hold a hearing on November 14th, 2012 pursuant to its SCR 105
Complaint against Coughlin wherein all subpoena by Coughlin are sought quashed, even where the SBN
states that Judge Dorothy Nash Holmes will appear by phone to answer question (but apparently not testify,
and she hasn't recused herself from the two matters she has Coughlin as a criminal defendant before her in)
(Coughlin totally objects ot Judge Nash Holmes phoning it in, especially where her 3/14/12 grievance to the
SBN in ng12-0434 and the possible ghost-grievancing done in ng12-0435 (in concert with RMC jUdge W.
Gardner and his sister WDC Family Court Judge LInda Gardner and SBN's Pat King and Laura Peters in
attempts to allow RMC W. Gardner to avoid recusing himself from the richard hill signed criminal trespass
complaint in 11 cr 26405...It may be necessary to check up on rmc judge w. gardner's 2/27/12 order
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transferring jurisdiction of the richard hill incuced january 12th, 2012 custodial arrest of coughlin for
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jaywalking in RMC 12 cr 00696 (and consider all the copying and or erasing of Coughlin's laptops,
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smartphones, and data cards incident to all this arrests under State v. Diaz, including the in court arrest on 11
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30 11 with rmc judge howard in RMC 11 cr 22176 (which resulted in this Court's 6/7/12 temporary
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suspension of Coughlin's law license) (summary contempt for saying "wow"...and the 2/27/12 arrest by reno
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marshals (marshal harley lied during the SITA and issued directive to another marshal to go repeat his lie to
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Judge Nash Holmes....finding a smartphone during a SITA does not entitle Harley to bark out "got tell judge
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nash holmes Coughlin lied! He was recording!....or for judge Nash Holmes to later, in the tape from the
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3/12/12 hearing in 11 tr 26800 to indicate some marshall told her he saw Couglin dissessmbling a smart
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phone in the bathroom stall (this would have been before Judge Nash Holmes even asked Coughlin any
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questions regarding recording or recording devices...whatever she means by "recording device" (wouldn't
21
every laptop brought with any defendant or lawyer be a "recording device" under Judge Holme's apparent
22
analysis?) to testify with regard to Respondent's conduct in connection with Case No. 11-TR-26800 12 in
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Reno Municipal Court.
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Incident to Judge Nash Holmes "summary criminal

contempt" Order against Coughlin within the traffic
citations issued to Coughlin outside Richard Hill's law
office after Coughlin showed up to get his Marshal harley
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000593
violating the courthouse sanctuary rule, on behalf of wcso
deputy machen, whom hill sent to the 2/27/12 trial
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regarding the richard hill traffic citations of 11/15/11 to

serve coughlin the ORder to show cause for the 3/23/12
Hearing in the richard hill eviction appeal in cv11-03628,
based upon a fraudulent motion to show cause and
declaration filed by Hill, his associate Casey Baker, and
Hill's trusy licensed contractor, NBI's Phil Stewart
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to having been informed by the Washoe County Public Defender's Office of the Order for
Comptency Evaluation directed to Cogulin in RCR2012-065630 (the retaliatory "misuse of 911" custodial
arrest and prosecution incident to an arrest made by the same RPD Sargent Sifre, on 1/14/12, who ordered
Couglin arrested by then trainee Officer Wesley Leedy (whom applied excessive force to Coughlin, out of
the blue and prior to any sort of warning, along with another dishonorable and shameful RPD Officer Travis
Look, all captured on video tape as well (though Panel Chair ruled all of that inadmissible as well...though
that pending jaywalking prosecution was not ruled irrelevant or dismissed form King's Complaint.
Somehow, Chair Echeverria accepted Kings argument that video taping of events did not provide reliable
evidence of what happened...rather, having Richard Hill and the McGeorge Mafia come in an wrech shop on
a career of Coughlin's that was many years in the making (and all in Nevada mine you, from kingdergarten
through law school) (in February 2009 Elcano had admitted to Coughlin that he asked several judges,
including Master Edmonson and Judge Linda Gardner what they thought of Coughlin's work before them
and that both of those judges gave Coughlin a positive review....and at that time Elcano also stated that "and
Judge Linda Gardner owes me because I did a big, big favor for her a long time ago...so if she say's your all
right, then...". Elcano has also finally managed to get WLS's fingers in the pie that is the ECR program that
is partners with the Washoe County District Attorney's Office with in denying indigent criminal defendants
their Sixth Amendment Rights (an RMC Court appointed defender, Lew Taitel, was originally Coughlin's
appointed counsel in the Donnie and Marie conflict yet no recusal criminal trespass complaint signed by
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000594
Richard Hill (whom also got Coughlin subject to a custodial arrest for "jaywalking" on January 12th, 2012,
incident to Hill lying to RPD Officers that Coughlin "has lost his appeal" (though the appeal was not decided
until 3/30/12...Further, Hill filed a Declaration on 1/20/12 in that appeal CV11-03628 which clearly contains
numerous lies when reviewing the video tape of that incident....and 61901 further provides video evidence of
the extent to which Richard G. Hill, Esq. is allowed to terrorize the citizenry of Washoe County with his lies
and Rambo litigation tactis, all with more than a little enabling by a cadre of local judges) and the court
appointed defender for Couglin (Keith Loomis, Esq., McGeorge SOL, Class of 1982) who has managed to
collect a paycheck while twice refusing to advocate on Coughlin's behalf (garnering two Orders granting his
withdrawal by RMC Judges, one, in the criminal trespass cases (61901) that Judge William Gardner refused
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to recuse himself on, stemming from Richard G. Hill, Esq. lying to and with the police in 11 CR 26405, even
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where Judge Gardner then had a pending grievance against Coughlin (NG12-0435, wherein Judge Nash
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Holmes filed one on "behalf of all the RMC Judges, from whom you will have our full cooperation" and
13
assitance in carrying out a scheme to discredit and destroy Coughlin that they "planned out" "very carefully"
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(Judge Nash Holmes lied during Coughlin's 11/14/12 Disciplinary Hearing when she testified under oath that
15
she had (because of some unattributed hearsay that Panel Chair Echeverria would not let Coughlin ask
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follow up questions on) "heard Coughlin likes to record things" and that upon her questioning about whether
17
he was recording the proceedings and or had a recording device Coughlin during that traffic ticket trial,
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Holmes testified that Coughlin immediately grew very shitfy and uncomfortable and asked to be allowed to
19
use the restroom, whereupon Holmes ordered RMC Marshal Joel Harley to follow Coughlin into the
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bathroom, whereupon Judge Nash Holmes testified that Marshal Harley witnessed Couglin disassembling a
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recording device in the bathroom and leaving a portion of it in the bathroom, which the RMC Marshal
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discovered later). One, that is a god damn lie. Coughlin did not disassemble anything in the bathroom.
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Two, Judge Nash Holmes lied under oath when she testified that she asked Coughlin any questions
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whatsoever about recording devices or recording the proceedings prior to the ONE restroom break that Judge
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Nash Holmes allowed before she had Coughlin arrested for the "misdemeanor of criminal contempt...NRS
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22.010" . Judge Nash Holmes lied during her sworn testimony in saying that the one restroom break came
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AFTER she interrogated Coughlin about whether he had an recording devices or was recording . The
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certified audio of the Trial clearly reveals there was one, and only one restroom break and that, clearly,
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000595
Judge Nash Holmes asked Coughlin questions related to recording or having recording devices only AFTER
that one restroom break. Judge Nash Holmes clearly lied during her testimony in that regard, seeking to
rewrite the orders of events in an attempt to suggest that she interrogated Coughlin (sua sponte, of course, as
is her wont, wherein she mixes in her experiences as a prison warden type with her lifelong devotion to
being a prosecutor, wiretapping attorneys, etc., etc....ask Henry Sotelo, Esq., the RMC defender that says he
left the law for awhile completely given what a terrible taste was left in his mouth after working under her
while she was the Washoe County District Attorney in 1993-1996 or so...or ask the Washoe County Deputy
whom Coughlin overhead, during one of his several trips to the Courthouse (it wasn't Cummings, and it
wasn't the Hawaiian one, but it was the other one) reveal the extent to which he felt Judge Nash Holmes was
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completely out of her mind and inordinately punitive, sentencing a youth whom she had the week previous
11
"put in some hug a thug program" to six months in jail following his reappearring before her one week later
12
after having bee arrested for "jaywalking". (As to her 2/28/12 and 3/12/12 Orders speaking to the
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"contempt conviction" actually, Judge Nash Holmes just chose the most penal aspects of a variety of
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criminal and civil contempts statutes, along with making a pastiche of theose sanctions requiring the least
15
due process attendant thereto, and also managaed to transmogrify the "simple traffic citation trial" into a full
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blow Disciplinary Hearing, whereupon on February 12th, 2012, she took another bite at the apple (not
17
satisfied with her 2/28/12 Contempt Finding and Order of Sanctions or the fact that she and her Court
18
promised Coughlin's mother that her payng $100.00 would get Coughlin released one day early on the
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unfathomable 5 day jail sentence she ordered to start immediately after Coughlin testified that "RPD Sargent
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Tarter lied when he..." (BOOM...Coughlin didn't even get to finish his sentence...Judge Nash Holmes
21
immediately found Coughlin in contempt and had him cuffed, and laughed at the idea of granting any sort of
22
stay to allow Coughlin, then a licensed attorney, and opportunity to make arrangements for his client's
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interests to avoid being prejudiced. Judge Kenneth Howard, (McGeorge SOL, '81), while noting that it
24
"saddened him" to think of the 3 day contempt incarceration that he himself ordered upon Coughlin to start
25
immediately following the 11/30/11 rendition of the conviction of petty larceny of a "candy bar and some
26
coughlin drops" (at the Wal-Mart that is on land rented from the Indian Colony, in an arrest made by tribal
27
police for a misdemeanor-Wal-Mart's Thomas Frontino testified that neither he nor anyone with Wal-Mart
28
made a citizens arrest on 9/9/11 of Coughlin) that violated the law in that NRS 171.1255 forbids tribal police
000596
- 54/71 -

from making arrests other than those for gross misdemeanors and felonies.
Michael Smily Rowe, Esq, a person whom Coughlin had indicated would invoked a conflict upon a showing
of sufficient connection thereto...)
13
SBN cLERK OF cOURT Laura Peters (the SBN has filed not proof of service of the
summons and complaint sufficient to satisfy SCR 109 in view of the representations made
by the State Bar of Nevada, including those by Laura Peters on the phone and in writing
to Coughlin and found in Peters Affidavit on file in this matter. The first alleged certified
mailing of 8/23/12 is not sufficient to show service where Peters herself (and this is
spoken to in her affidavit) represented that the SBN would not be attempting to use it to
proof service of any sort of the Complaint, but rather, Peters would send, soon after
September 11th, 2012 a certified mailing copy of the SCR 105 SBN v zach Coughlin
complaint to Coughlins SCR 79 address, and that the complaint would not be deemed
served or by the SBN, nor would the SBN attempt to represent in any way that it had
been served, until zach coughlin had signed the return receipt requested and or certified
letter signature card and it had been received by the SBN.
2. 11/14/12 hearing go forward, which it clearly should not, at least not in its current
unbifurcated, due process violating, unnoticed, no service of the 10/9/12 NOtice of INtent
to Take Default, no "at least 30 days" service of the Designation of Witness and Summary
of Evidence BY THE PANEL, NOT BY THE SBN, BAR COUNSEL, OR THE CLERK
OF THE SBN, under SCR 105(2)(c)
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whom appears to be related to
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eviction
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Dear Bar Counsel and Panel Members,

Please find attached my Emergency Ex Parte Motion (perhaps not "ex parte" given Bar Counsel was
provided it). Also, please note, the October 9th, 2012 certificate of mailing by the SBN for the Notice of
Intent to Take Default was never served on me in any way shape or form until I received the copy of the
"entire" file form Sierra Legal Duplicating. The State Bar of Nevada knows this. They put the wrong postage
on the certified mail envelope containing the Notice of Intent to Take Default. When I went to pick it up
"Tim" USPS counter attendant at the Vassar Postal Station here in downtown Reno refused to allow me to
pick up that certified mailing given that is was about $5.00 deficient in postage. I did not have $5.00 and it is
000597
not be responsibility to pay it, as far as I know. In fact, I have asked the Bar and this Panel to allow me to
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proceed in forma pauperis in this matter, and am doing so again here (I am flat broke, I have a 1996 Honda
Accord, rent a room for $300 a month, have less than $200 in my bank account, no stocks, no bonds).
I have been mislead or lied to by the SBN in numerous ways in this proceeding. I was told I could issue
subpoenas despite being a suspended attorney (and there is case law that says even when suspended, one is
still an "attorney"). I was told I would not be required to pay subpoena fees. I was told the August 23rd, 2012
certified mailing would absolutely not be used to prove proof of service of the Complaint in this matter, SBN
v. Coughlin. Yet a review of the files reveals that the SBN and Panels only Return of Service (and see SBN
Ethics Committee Member Joseph Garin's recent Brief in 60302 seeking to dismiss my entire wrongful
termination lawsuit against Washoe Legal Services) for a real ironic example of just why the hearing on
November 14th, 2012 must not go forward. It is fraudulent for the State Bar of Nevada to stipulate with me
that the August 23rrd, 2012 certified mailing of the Complaint is alleges was sent and that Clerk of Court
Peters admits to having received back on September 10th, 2012 would never be cited to as effecting service
of the Complaint upon me or otherwise put forward as proof of return of service etc. Now the SBN seeks to
get around the inconvenient fact that, instead of holding my hearing on September 25th, 2012 (Clerk Peters
told me it was on the calendar, I was noticed of it in writing, I agreed to that date for the Hearing amongst a
choice of dates, etc..) Bar Counsel King attempted to shove a document he alleges was the Complaint in my
suit jacket, then persisted in ordering Clerk of Court Peters (whom King alternately claims to have
separation from and no authority over with ordering her not to file my Motion to Dismiss, attempting to
reneg on stipluations and representations made by the SBN, etc). Further, it is wrong for Clerk of Court
Peters to be signing the certificates of mailing for both the SBN and for the Panel Chair. Additionally, under
SCR 105(2)(c), it is the Panel that must send the Respondent the Notice of Hearing "at least 30 days" prior to
the Hearing date, and that Notice must include with it the Designation of Witnesses and Summary of
Evidence, and it must be served in the same manner as the Complaint. It is impermissible for Pat King to
attempt to mail out the Notice of the Hearing and Designation of Witnesses weeks before the Panel is even
announced (how can you possibly be pretending to take your duty as a Panel member seriously when you are
essentially showing up the day of the first game, skipping all the practices and pre-season games....we all
saw how that turned out for Bret Farve in his last season. It is appalling to me that you intend to hold this
hearing given these blatant violations of SCR 105(2)(c), but when you add to that the fraudulent conduct of
Pat King, in failing to amend his and or Clerk of Court Peters certificate of mailiing or return of service for
the purported certified mailing (and, contrary to the SBN's established practice detailed in the certificates of
mailing I have review upon finally being granted a copy of the "file", though, the rule says I get to go to the
SBN's offices and review certain things "up to three days"...not have Pat King and Laura Peters manufacture
some nonsense about why I am not allowed at the building or otherwise violating my rights (which is
something King and Peters do everytime they get caught violating the rules.) Further, I have been (and some
might say this was largely by design) jammed into having this Disciplinary Hearing on November 14th,
2012 in impermissible proximity to the petty larceny trial in rcr2011-063341 (see Montiero for why it is not
even appropriate for King to be seeking to force me to prejudice my defense in that matter) on November
19th, 2012, in Department 2, before Judge Sferrazza, whom presided over the summary eviction/unlawful
detainer "Trial" from my former home law office that the criminal trespass arrest, jaywalking arrest (King's
Complaint doesn't manage to specify that the January 12th, 2012 arrest was for jaywalking outside my
former home law office shortly after my collecting video evidence revealed the fraud attendant to Hill's
contractor havig used my own plywood to board up the back porch of the property....Hill, also, at that time,
went and got a TPO that was based largely upon an outright lie, ie, that I "climbed up on" the contractor Phil
Stewart's truck). I believe this Panel should review (I cannot affor the $35 to $70 for the video of the two
hearings on Hill's Motion for Order to Show Cause of January 20th, 2012 (the Order to Show Cause was
served by RMC Marsm hal Harley, despite what WCSO Deputy Machen said he personally served in his
affidavit (Machen also lied about personally serving the eviction lockout order for HIll, and HIll lied at the
trespass trial when he testified that Machen "posted it on the door becaues you ran away", Hill also lied at
trial when he alleged the Reno PD announced themselves as law enforcement and issued a lawful order to
emerge form the basement prior to the landlord kicking in the door, and Hill also lied about whether anyone
that day warned Coughlin to leave the property prior to Hill's signing the criminal complaint to affect a
custodial arrest for criminal trespass).
Additionally. I moved recently, and updated my SCR 79 address in compliance with that Supreme Court
28
Rule well within the 30 days of my moving. Further, I filed an official Change of Address with the USPS,
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000598
and that caused delays in receiving my mail incident to the typical forwarding procedures of the USPS, and I
have the yellow stickers on the envelopes to prove it. Further, besides submitting an official Change of
Address form to the Vassar Station on October 5th, 2012, Coughlin wrote the SBN on October 14th, 2012,
and provided his new 1471 E. 9th St. mailing and physical address, in addition to updating the online portal
and the NV CLE Board even prior to that, all in compliance with SCR 79.
"We nevertheless conclude that discipline orders appearing in the Nevada Lawyer may
be cited to this court for the limited purpose of providing examples of the discipline
imposed in similar fact situations. This approach has also been taken by several other
courts. n22
n22 See. e.g., Berman v. City of Daly City, 21 Cal. App. 4th 276, 26 Cal. Rptr, 2d 493,
496 n.5 (Ct. App. 1993); Marez v. Dairyland Ins. Co., 638 P.2d 286, 289 n.2 (Colo. 1981);
Manderfeld v. Krovitz, 539 N.W.2d 802, 807 n.3 (Minn. Ct. App. 1995): Leisure Hills of
Grand Rapids v. DHS, 480 N.W.2d 149, 151 n.3 (Minn. Ct. App. 1992)." LAUB.
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Then there is Judge Hardesty being a one of the three Justices signing the 6/7/12 Order that
temporarily suspended Coughlin's law license over a conviction for petty theft of "a candy bar and some
cough drops" (despite the recently reinstated Stephen R. Harris, Esq. not having a temporary suspension
even where he admitted to, upon being forced to by his wife law partner, misappropriating some $740,000
and using it on...(NVD Judge Beesley's, a Bankruptcy Judge in Federal Court who has a specialization in
"Creditor's Rights" listed on his contact page at www.nvbar.org, (McGeorge Law School class of 1979,
meaning he attended with Reno Municipal Court Judge Dorothy Nash Holmes name was supplmeneted to
the Designation of Witness by a November 7th, 2012 filing by Bar Counsel King...which means Couglhin
did not have much notice at all that Beesley would testify. Neither did, apparently, Judge Beesley, as, for
one testifying as to whether a man shoudl retain his law license and the Judge being willing to so weigh in
with definitive opinions (even where a multitude of conlficts of interests where present that should have
arguably precluded him from so doing under the canons of his profession....Nash Holmes/McGeorge
connection, Karen Sabo/Beesley Peck/Coughlin suing Washoe Legal Services/ Beesley close personal friend
of Elcano's angle) Judge Beesley sure didn't have much in the way of specifics to support his strong
opinions. IN fact, he seemed to trip up on things rather easily and wish to vague it all way when Coughlin
pressed for specifics. One thing that seems particularly untoward is the extent to which Judge Beelsey failed
to, in any way, mention the extremely noticeable filing (made accesible to all via the RECAP plugin on
28
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000599
Firefox for those using Pacer, wherein Judge Beesley's McGeorge Class mate (they were one year apart and
are almost exactly the same age) Dorothy Nash Holmes illegally confiscating an pro se attorney defendant's
smart phone and micro sd data card, well after any period for her Marshals to conduct a "search incident to
arrest" and without any warrant or Order made available to Coughlin was mentioned and extensive
supporting documentation was provided for in the adversary proceeding 10-05104 Cadle Company v. Keller.
Further, Coughlin dispalyed a profound level of professionalism in connection with the John Gessin
adversary proceedings, particulary where Coughlin owned up to the extent to which the rules of court as
currently applied in the NVD make one attorney or record regardless of whether the agreement between
attorney and client is of an "unbundled services" nature, and regardless of Gessin himself telling Coughlin he
10
was monitoring the case on Pacer, did not want Coughlin to work any further on the case, etc.... Gessin soon
11
became Panel Member Shelly O'Neill's client.
12
Regardless, a review of Coughlin's filing in the three NVB cases wherein Coughlin practice before
13
Judge Beesley will reveal extremely comptenet work. Perhaps what Judge Beesley was unable to elucidate
14
specifically in support of his contentions (which, again, sought to accomplish through a leveraging of the
15
Coe Swobe/mental health care apparatus that which is not supportable through more straighforward means)
16
is that Judge Beesley's McGeorge SOL Class of 1977 class mate, RMC Judge Dorothy Nash Holmes'
17
extremely questionable conduct and rulings in RMC 11 TR 26800 on 2/27/12, 2/28/12, and 3/12/12
18
(resumption of Trial in spite of NRS 178.405 and NRS 5.010 and Holmes' own assessment of Coughlin's
19
"mental health" issues in both her 2/28/12 Order and here 3/12/12 ruminations rendered and subsequent
20
contradictory Order signed, in addition to the), 3/13/12 (various other orders by Judge Nash HOlmes, and
21
3/14/12 (grievance letter to SBN), and 10/4/12 (again, Judge Nash Holmes refuses to follow NRS 189.010-
22
050 in striking another attempt by Coughlin to have the fact that a summary contempt order is a final
23
appealable order, and therefore the RMC and Judge Nash Holmes, once again, are permitted to skirt the law
24
with respect to the Court, under NRS 189.030 being required to order the preparation of the criminal
25
appellant's transcript (and certainly, if Judge Nash Holmes wishes to issue a "misdemeanor of criminal
26
contempt" conviction in a summary fashion (based upon unattributed hearsay by "some Marshal" whom,
27
contrary to the dictates of NRS 22.030 did not have to sign an affidavit to have a contempt finding for
28
conduct allegedly occurring outside the presence of the court be consiered (good thing for Marshal Joel
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000600

Harley...because either he is lying or Judge Nash Holmes is lying some more, specifically with respect to
this categorically false non-sense about Coughlin "disassembling a smart phone" or recording device in the
restroom and leaving part of it there (the implication being, given Judge Nash Holmes lies about the order of
her sua sponte interrogation of Coughlin regarding recording issues and Coughlin needing to use the
restroom-ie, Judge Nash Holmes lied, under oath, on 11/14/12 when she said Coughlin's request to use the
restroom came only AFTER she began her interrogation about recording or recording device...which, if
Chair Echeverria would have allowed Coughlin to enter the certified copy he had to have his mother buy for
him (becuase the RMC thrice rejected Coughlin's attempts to buy one himself, and in fact, Judge Nash
Holmes attempted to levy some unfathomable sanction or sua sponte disbarment about some piddly
10
nonsense related to Coughlin's filing of an in forma pauperis application (truly a low, even here...especially
11
where Judge Nash Holmes alternately writes bar counsel on 3/14/12 a greivance directed to Coughlin where
12
she mentions, via some unattributed hearsay (which seems to be a common theme running through Judge
13
Nash Holmes work) that ) using an Affidavit that was from November 22, 2011 in a March 2012 filing (IFP
14
Orders typically last 6 months, so....? And to whatever extent Judge Nash Holmes seeks to make Coughlin's
15
interlineating a different case number on that notarized IFP or Coughlin's adding "Request for Audio
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Recording of Trial in 11 TR 26800" onto that IFP as tantamount to conduct supporting her desire to sua
17
sponte disbar Coughlin...welll...Coughlin wonders why that Hug-a-Thug program was not given more of a
18
chance before Judge Nash Holmes went all "six months in County for jaywalking" on him. Coughlin's
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friend Geof Giles, Esq. (big ups to the Masjid here in Reno, including Rafik Beekun, a member of the
20
Muslim centers board of directors and everyone there who was so kind in giving Coughlin a place to go for
21
food and pleasant company, during their celebration of Ramadan, no less, incident to Coughlin attempting to
22
recover from the Leviathan wrath of the Reno Municipal Court and the McGeorge Mafia's, some might say,
23
"approach") may have said it best when he mentioned something about "the community college professors of
24
the legal landscape..."
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Also Panel Chair Echeverria is running the Panel like a thug, basically. See WLS's attorney Joe
26
Garin's argument respecting Coughlin's right to insist on technical compliance with service rules....NOw
27
what that mean? It mean that the SBN and King and Peters do not get to put on testimony by Judge Beesley
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and Elcano (even though lots of stuff was said by both that damages the SBN's case and only further drives
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000601

home the McGeorge Mafia meme, and the extent to which King and Echeverria cheerfuly defile any
conception of due process that might attache to a Dsiciplinary Hearing (to which they seem to drag along
Clerk Peters...what is she supposed to do? Get fired like Coughlin at WLS? See Caryn Sternlicht's approach
at the hearing on the Objection to Master Linda Gardner's Recommendations in the the Santiago v.
Vaxevanis TPO deal FV08-03380, where she filled in for Coughlin, whom took issue with then Master
Linda Gardner making Orders in TPO's where opposing counsel was Richard Molezzo, Esq., that purported
to rule on the title to vehicles...despite NRS 33.018 seeming to clearly lack any jurisdictional basis for her to
do so, particularly where the vehicle was being given to the accused abuser, and further where that Order
was seemingly later recharacterized as an "agreement"....uh, no. See a similar "this ORder is an agreement
10
so no appeals will be allowed from it, even the 12/26/12 one you filed, Coughlin" this summary eviction
11
"Trial" appeal (from which this 61383 atty fees of $42, 050 appeals stems...) incident to the 12/20/11
12
Hearing (six weeks late because Hill (but what about Casey Baker, Esq., who has absconded to Kentucky
13
and left Rich to face the music?) had to go on a six week vacation, a fact about which he claimed to be able
14
to control the RJC into not complying with NRS 40.253(7)-(8). Coughlin hereby asks this court to stop the
15
trial of 11/19/12 in rcr2011-063341 (the iphone case presided over by judge sferrazza, whom managed to
16
confiscate all of Coughlin's subpoenas on the auspices that Skau's fraudulently noticed ex part motion
17
provided sufficient grounds too...but then failed to return any of them to Coughlin in time to have them
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served for the 11/19/12 hearing...and entered an Order that purports to take away from Coughlin the right to
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have served subpoenas issued propertly under a reading that doesn't include the rendered order by Judge
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SFerrazza of 10-/22/12 in 063341)...So, while Coughlin likes and respects Judge Sferrazza, he must recuse
21
himself from that continuation of Trial in 063341 on 11/19/12.
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Also, both Echeverria and Pat King are seeking to take a page out of the Judge Nash Holmes
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"Contempt Statute Pastiche Cookbook" to accomplish their nefarious aims, includign disobeying the
24
following authority by trying to "preserve for the record" and "admitting for the limited purpose of establish
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Coughlin's "altering" a previously filed document, where Coughlin, in complete exasperation at Echeverria
26
demonstrating the highest possible level of evident impartiality in ruling irrelevant or not properly
27
authenticated every single thing Coughlin offered into evidence

000602
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- 60/71 -

As for Coughlin's inability to get Echeverria to admit anything into evidence for any purpose other than in
support of some Summary Disciplinary Hearing violation of the RPC that Echeverria sought to enter in an
Order in violation of Schaeffer (when Echeverria was not grimacing noticeably and telegraphing displeasure
to Coughlin at Coughlin mere mention of the mitigating quality of local law enforcement misconduct or that
of members of the judiciary or prosecution team...much less Echeverrias verbally suggest that Coughlin
forget about the permission to do so found in Laub and instead cease comparing his case to Stephen R.
Harris, Esq.'s (despite the ripe ground to consiering Judge Beesley's improprly notice (no signed green car
certifie dmailin in compliance with the requirements of SCR 109 considering Laura Peter's announcing of
the rules on September 11th, 2012 and subsequent indications of assent to electronic service by the nndb,
10
sbn, and panel, and declaration of the rules attendnat to the running of time vis a vis materials required
11
served under scr 109, incident to a certified mailing (ie, Peters announced the SBN and Panel would only
12
begin the running of such time periods upon the date on which Coughlin's signature was made on one of the
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green certified mailin return receipt requested cards...and given the SBN can't show as much for the
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Supplemental notice announcing the Designation fo Witnesses of Judge Beesley or WLS's Elcano
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(Echeverria seemed to indicate he did not understand what Coughlin was referring to when Coughlin
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suggested that given he was suing wls and elcano in 60302, and garin was elcano and wls's attorney of
17
record there, that questioning elcano may be tantamount to communications with represented parties (dollars
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to donuts elcano has not told garin about this, and Coughlin didn't have the time to given the "jUdge
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sferrazza auhtorize me to serve you notice of the ex parte emergency hearing to quash your subpoenas on
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basis that judge sferrazzas himself seemed to approve your using in connection with utilizing such
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subpoenas on 10/22/12 in rcr2011-063341" by Reno City Attorney Creig Skau (who, ironically sought to ex
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part quash Coughlin's subpoenas based upon insufficiency of procedural rules compliance grounds even
23
where he was apparently lying about Jduge SFerrazza granting him the authority to serve Coughlin notice of
24
the hearing by email....and or of the 11/7/12 order by Judge sferazzaa. Local government really doesn't like
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complying with subpoenas...just ask the SEcond Judicial District Court and WCDA's Office, whom
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waitinged until 11/13/12 at 4:46 to even fax Coughlin notice of its intent to fail to appear at the 11/14/12
27
Disciplinary Hearing (despite the fact that the basis for such objections by Watts-Vial (and thats another
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thing...is that the Watts-Vial whom is a 2nd Judicial judges staff member? Is the Judicial Assistant
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000603
Townsend in the RMC connected to the Marshal Townshend? Is Sargent AVansino of the RSIC connected
to Dena Avansino? We know ecomm 911 dispatcher jessica duralde is married to rpd Nick Duralde, the
officer who effected the wrongful, admittedly retaliating "how's that?" arrest on 8/20/11 in rcr2011-063341
that started all this off....and that jessica duralde was on duty that day and that wcda jim leslie failed to
provide the materials or response from kelley odom and ecomm incident to the 10/3/12 subpoena he sent her
(Judge Sferrazzaoffering the scant time Coughlin's case in chief was accorded, which amount to 1/8th of the
total running time of the on the record portion of the proceedings (and the stoagie breaks "Boss Hog"
Echeverria (and his med mal background provides yet another specious connection to Elcano via the
"panopay" case Elcano constantly reminsces about...) grew more and more frequent once the Hearing turned
10
to the time allotted to Coughlin's case in chief...), a couple people name Cummings in the WCSO/WCDC,
11
ec., etc.
12
But as to King and Echeverria's attempt to make the Discipinary Hearing one where some summary
13
profssional conduct ORder may be issued (an allegation that coughlin "altered a previously filed document"
14
is so laughable from Echeverria where Coughlin is alleged to have scratch out and or notated his doing so a
15
file stamp on the 10/31/12 Pre Hearing Memorandum of Law, and interlineated that the document was now
16
being titled a "Declaration" or something similar in an exasperated attemtp to get somethign, anything, into
17
the record in that ng12-0204 case...Violations of professional conduct rules not charged in attorney
18
disciplinary complaint could not be considered by Supreme Court. In re Discipline of Schaefer, 2001, 25
19
P.3d 191, 117 Nev. 496, modified on denial of rehearing 31 P.3d 365, certiorari denied 122 S.Ct. 1072, 534
20
U.S. 1131, 151 L.Ed.2d 974. So, if the SBN and Echeverria want to charge coughlin with some violation
21
there, it will require due process, and they must refrain from a Nash Holmsian transmogrification of one type
22
of proceeding into another type wholly unsupportable under the law (judge Nash Holmes sought to make a
23
traffic citation trial a full blown "Summary Disciplinary Proceeding" in 11 tr 26800, whereas Echeverria and
24
King seek to turn a Disciplinary Proceeding that they have rigged to cheat Coughlin out of every single due
25
process protection possible into a "Summary Disciplinary Proceeding"...which doesn't even exist in Nevada
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law. a SCR 102(5)? maybe....but not a Summary Disciplinary Proceeding Order Finding Coughlin to have
27
"Altered" a Previously Filed Document just because Chair Echeverria was flummoxed by the ingenuity of
28
Coughlin in getting into the record all that stuff on the cd/dvd's and in the two different "Declarations" or
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000604

similarly titled submissions into evidence that had those cd/dvd's attached to them....(and the panel and nndb
and sbn's assent to electronic service makes required that the materials in the SkyDrive and via email
attachments, as well as the cd/dvd's Coughlin provided be included in the record on appeal).
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5
Plus, it was wrong for Chair Echeverria to deny Coughlin the right to record the
11/14/12 Disciplinary Hearing and Couglin HEREBY PLACES THE STATE BAR OF
6
7
NEVADA, SUNSHINE REPORTING SERVICES, CAROL HUMMEL, LINDA SHAW,
PAT KING, LAURA PETERS, THE NORTHERN NEVADA DISCIPLINARY BOARD
AND ITS PANEL ON NG12-0205 ET AL ON A LITIGATION HOLD NOTICE.
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Also, kind of odd that NVB Judge Beesley didn't mention the 3/30/12 (hey, thats the same date Judge
Flanagan dismissed Coughlin's appeal of the summary eviction /"Trial" from his former home law office...."
filing by Couglin in Cadle Company v. Keller wherein Coughlin attached as exhibits that pesky filing of a
notice of appeal by coughlin against the RMC and City ATtorney and Judge Nash HOlmes following his
release from 5 ays summary incarceration, no stay (though Judge Nash HOolmes sure does care about those
clients, to be sure, right? she wouldn't, nor would Jduge Howard, be seeking to get back at Coughlin more by
attempting to arrange greater damage theml;kjasdfl;
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/It is categorically false for Judge Nash Holmes to assert, in the audio record on
3/12/12 the order of events and when she asked Coughlin her questions about
recording, considering when a restroom break took place an exactly what it is she
asked Couglin and when, and what his responses were, and when some allegations by
25
"the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the
26
audio transcript reads 7 minutes into the audio record the RMC provided the SBN:
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Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from
000605
some extreme form of mental illness. during the trial I asked the defendant attorney
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then he quote took the fifth a few other times and then he requested to be excused to go to the
bathroom and the Marshal later reported to me that while the gentleman was in the
and that was retrieved and it was put into his possession at the Sheriff's office and when they
booked him into jail for the contempt charge that was booked into evidence and I asked the
Sheriff's office to hold that into evidence. I believe he has violated Supreme Court Rule
229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her
statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering
from some extreme form of mental illness." Further, that which Judge Nash Holmes had
communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to
under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her mental
processes" loophole, as he has done.
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matter...
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Nash Holmes mentions on the audio record. And that sua sponte interrogation of Couglin occured
IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES
REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH
OCCURED AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE
WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND
MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE QUESTIONS
COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF
TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF
THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found,
and how odd that was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr
00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and
indications that local law enforcement and prosecutors and public defenders were non too happy with
Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan
that neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time
Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about
Coughlin that RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405?
Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of
2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately 11/28/12,
which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was
duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab
makes his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty,
apparently. That, and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of
000606
2:55pm a fugitive document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as
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CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order
finding Coughlin competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial
seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405
(including within NRs 5.010) here in Northern nevada..
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Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge
Nash HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the
recording is entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash
Holmes, maybe she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an
inappropriate, particulary where she not only purports to issue a "summary criminal contempt" conviction
against an attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a
simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel
and the Panel...That Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to
have to put something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat
King wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn
testimony, but rather just some musings by Judge Nash Holmes purporting to make "rulings" finding "by
clear and convincing evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King,
SBN Bar Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge Gardners
Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin faxed to her
(allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was dismissed under an
NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction
resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based upon a
civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in
place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the
trial for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's
preparation would absolutely not start until a down payment was made. Plus, even where Coughlin caved to
the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf
too...
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NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in King's 000607
3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
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3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would
need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King
for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's
April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have
anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
"

Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against
Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the problems
with the practice of this attorney being experienced by myself and the other three judges in Reno
Municipal Court. My two most recent Orders in what should be a simple traffic citation case are
self-explanatory and are included, together with copies of massive documents Me. Coughlin has
faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also
included. He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our
Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't
seem to locate him between cases very easily. We are setting that case for trial and attempting to
th
serve him at the most recent address we have (1422 E. 9 St. #2 Reno NY 89512), although I
heard today he may be living in his vehicle somewhere. We do have an address for his mother,
however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now
on appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a
matter currently pending in his court with Mr. Coughlin as the defendant. I have enclosed some
copies of documents from those matters, in chronological order, simply because they appear to
demonstrate that he is quickly decompensating in his mental status. Our staff also made you some
audio tapes of Coughlin in the him and him and him and him and him and him and him him and I
will him and him and him and him and him in Departments 2 and 4 so you can hear for yourself
how this attorney acts in court. You can see his behavior in my traffic citation case does not
appear to be an isolated incident.
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It is my understanding that Reno Justice Court also has a matter pending on this attorney.
My Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr.
Coughlin jailed for Contempt of Court and they stated that they represent him in a Gross
Misdemeanor matter in RJC. I have no other information on that.
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You will have the full cooperation of myself, the other judges, and the staff of Reno
Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious
000608
litigant in our court, antagonizing the staff and even our pro temp judges on the most simple
traffic and misdemeanor matters. I do think this is a case of some urgency, and I apologize for
- 66/71 -


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1

IN THE SUPREME COURT OF THE STATE OF NEVADA

Jul 18 2013 10:21 a.m.

/s/ Zach Coughlin, signed

Zach Coughlin, Esq.

DATED THIS: Dated thi 7 17 13

/s/ Zach Coughlin

1. Exhibit 1: various relevant materials.

IN THE SUPREME COURT OF THE STATE OF NEVADA

NOTICE AND DECLARATION AS TO SBN CLERK OF COURT PETERS

Petitioner, ZACHARY BARKER COUGHLIN, representing himself files

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MOTION FOR LEAVE TO FILE OPPOSITION TO SCR 111(4) PETITION IN 61901,

7 C.J.S. Attorney & Client

V. Discipline, Suspension, and Disbarment

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71. Fraud in procuring admission

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107. Deliberations, scope of inquiry, and verdict or findings

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far as on Page 4 as to be very specific in listing the rules of professional conduct

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Judge Beesley whom testified at Coughlin's 11/14/12 formal disciplinary

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HEARING - Vol. I, (Page 16:1 to 16:18) CROSS-EXAMINATION BY MR.

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("received" as a greivance in the SBN on 3/15/12)... Ex. 6 - Letter dated February

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HEARING - Vol. I, (Pages 154:3 to 156:1) BY MR. COUGHLIN: Q Did you or

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As to judges refusing stays to practicing attorneys representing clients where the

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under the exact same circumstances (summary contempt incarcerations or

HEARING - Vol. I, (Pages 99:21 to 100:21) MR. ECHEVERRIA: Is this certified?

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was originally mailed to Coughlin (with insufficient postage placed thereon

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On that note, I reference the "Dispositional Order' entered by Clerk

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AMJUR CLERKSOFCT 21" 44. Breach of duty affecting rights of

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committed against an employer, an employee of the employer while the employee

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failed to respond to until 12/19/12, with Chair Echeverria's 11/17/12 Order

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