records of any greivance from Judge Gardner to

SBN re CoughlinFW: my attempt to be provided

access to the grievances filed today
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 7/18/13 8:28 AM
To: joey.hastings@washoecourts.us (joey.hastings@washoecourts.us);
renoattorney@gmail.com (renoattorney@gmail.com);
lcastillo@nvcourts.nv.gov (lcastillo@nvcourts.nv.gov);
dwatts@da.washoecounty.us (dwatts@da.washoecounty.us)
Cc: david.hardy@washoecourts.us (david.hardy@washoecourts.us);
judge.hardy@washoecourts.us (judge.hardy@washoecourts.us)
37 attachments
4 2 12 0204 email from SBN King re my attempts King lies in alleging
he received grievance from Judge L. Gardner.pdf (159.4 KB) , 3 16 12
ng12-0434 SBN King letter containing RMC Judge Nash Homes 3 14
12 grievance against Coughlin and ng12-0435 linda gardner sanction
from april 2009.pdf (1857.6 KB) , 4 19 12 0204 1708 03628 Hil and
Baker's Motion for Attorney's Fees tagged reduced.pdf (2.8 MB) , 4
19 12 Transcript of Hearings in CR12-0376 dogan young elliot
competency evaluation rjc rcr2012-065630 rcr2011-063341.pdf
(199.7 KB) , 5 28 09 email from Michelle.Purdy@washoecourts.us
0204 01168 54844 - Copy.pdf (31.3 KB) , 5 28 09 0204 01168 54844
letter to Coughlin from Springgate - Copy.pdf (62.9 KB) , 5 26 09
0204 01168 01955 email from Springgate with 5 21 12 Req Submit
and Proposed Order spare on sanctions compared to 4 10 09 Order -
Copy.pdf (265.7 KB) , 6 9 09 Coughlin's Mtn to Stirke or Objections
to Proposed FOFCOLDOD Divorce Decree 01168-109788 26405
54844 0435 - Copy.pdf (236.2 KB) , 7 23 09 0204 01168 2JDC's L.
Garnder Order to Amend Decree of Divorce.pdf (481.8 KB) , 7 15 09
0204 01168 2JDC L Gardner's Order Denying Motion to Strike in
Part, Granting Motion Strike in Part.pdf (1725.3 KB) , 5 26 09 0204
01168 email from 2JDC Fladager responding to Coughlin's inquiry of
5 24 09 re 5 20 09 filing not filed prior to 5 21 09 Order.pdf (221.6
KB) , 5 20 09 email from 2JDC Fladager DV08-01168 regarding
Eflex copying Purdy.pdf (118.8 KB) , 3 12 09 0204 Uribe EPO
Hearing Exhibit photographs of abuse DV09-00886 0204 CAAW
Advocate Aghast WLS Pres Breckenridge Ord hearing cd 4 10 09
01168 01955 red.pdf (3.2 MB) , 8 14 09 Minutes EPC FV09-00866
907 Uribe v Valdez CAAW Advocates Aghast Horror Edmondson
Request Drug Test Refused Ordered anyway 0204 WLS 01168.pdf
(296.3 KB) , 1 15 10 Isakson D14 L. Gardner and Springgate WLS
Client DV09-00163 0204 01168 01955 54844.pdf (1140.3 KB) , 5 28
09 email to 2JDC RE DV08-01168 0204.pdf (207.7 KB) , 5 24 09
0204 01168 email to 2JDC Fladager about curious refusal to file
Couglin's 5 20 09 Reply Oppos 5 21 09 Ord Deny Reconsid.pdf
(212.8 KB) , 5 28 09 0204 01168 54844 letter to Coughlin from
Springgate.pdf (62.9 KB) , 6 19 09 0204 01955 01168 FOFCOLDOD
Final Order or Decree of Divorce in Joshi 01168 overrides 4 13 09
Ord.pdf (415.8 KB) , 11 14 12 0204 full size transcript 170008ch-Full
NO NUMBERS.pdf (2.1 MB) , 12 14 12 Panel's FOFCOL and 8 23 12
SBN Complaint untouched.pdf (228.3 KB) , 12 14 12 stamped 0204
Order by Chair Echeverria Findings of Fact Conclusion of Law
seeking to disbar Coughlin bz.pdf (1602.3 KB) , 12 20 12 RJC Chief
Judge Sferrazza 12-01 Administrative Order 0204 063341 065630
067980 1048 607 599 074328 ocrd tagged .pdf (606.4 KB) , 1 16 13
copy cat Administrative Order by RMC Administrative Judge W.
Gardner from RJC Judge Sferrazza's 12 20 12 Order 0202 063341
26405.pdf (707.9 KB) , 2 25 13 0204 Order to Show Cause Order
2012-01 RJC Sferrazza Pearson.pdf (1430.0 KB) , 7 17 13 0204
71437 065630 63341 email to Lindsay.pdf (520.0 KB) , 7 15 13 0204
63227 notice.pdf (147.5 KB) , 6 24 13 0204 61383 03628 letter to
2JDC Judge Flanagan from Hil Coughlin as alleged vexatious AOC8
28 12 Order Hill lied disciplinary hearing 6 25 13 atty fee sanction
a9.pdf (309.9 KB) , 8 30 12 0204 email from SBN King attaching
Flanagan's 8 28 12 Order in 03628 that admits the 6 25 12 Order was
not a sanction but rather a DCR 13(3) application, also no post
judgment sanction motions allowed.pdf (120.6 KB) , 8 30 12
attachment to King email Flanagan Order (8-28-12).pdf (93.8 KB) , 8
30 12 0204 email from SBN King attaching Flanagan's 8 28 12 Order
in 03628 that admits the 6 25 12 Order was not a sanction but rather a
DCR 13(3) application, also no post judgment sanction motions
allowed.pdf (120.6 KB) , 5 20 09 0204 01168 60302 Reply To
Opposition Joshi edited final - Copy (29329842).pdf (199.2 KB) , 5
20 09 email from 2JDC Fladager DV08-01168 regarding Eflex
copying Purdy.pdf (118.8 KB) , 5 21 09 0204 01168 2JDC L
Gardner's Order Denying Request for Reconsideration.pdf (353.6 KB)
, 0204 01168 handwritten notes about peculiarties in dates and certs of
service in Joshi 60302.pdf (2.3 MB) , 12 12 12 0204 599 607 emails
between WCPD Leslie WCDA Kandaras and SBN OBC King 3913
3914.pdf (380.6 KB) , 12 12 12 email from Coughlin to sbn leslie 607
599 0204 I Ain't No White Trash Piece of Shit from Cape Fear Quotes
- Hark.pdf (388.7 KB)
Dear Clerk of Court Hastings,
In a 4/2/12 email to Coughlin the SBN OBC's King wrote: "The Grievance from
Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v
Barti Joshi, Case Number DV08-01168, wherein she describes your conduct at
pages 12 and 13."
Will you please provide any records of any sort of NCJC Rule 2.15 report or
grievance by Judge Linda Gardner to the SBN regarding Zachary B. Coughlin,
Esq. This becomes important in that a failure by Judge Gardner (or Flanagan, or
Elliott, or whoever) to report any alleged professional misconduct by Coughlin to,
say, the SBN, invokes an analysis under NCJC Canon 2 Rule 2.15 as to whether
any such "appropriate action" (see the comments thereto) being such reporting to
the SBN, and an absence of such, therefore yields support for the view that
Coughlin did not commit any professional misconduct in, say DV08-01168, or
CV11-03628, or, well, certainly Judge Elliott would prefer as little be known
about the hearing he presided over on 4/19/12 in CR12-0376, one would imagine,
so, there is probably no record of him reporting anything about that, to be sure...
Please share this with Chief Judge Hardy and copy any necessary "parties" to
avoid any allegation of ex parte contact should such be necessary or please direct
me as to whom I should copy specifically. If you know the SBN's King, like I do,
you know he is a compulsive liar, and I suspect that Judge L. Gardner made no
such grievance to the SBN. Rather, Judge Nash Holmes admitted at Coughlin's
11/14/12 formal disciplinary hearing that she "probably" included in the materials
she provided to the SBN along with her 3/14/12 grievance against Coughlin
(which she alleged to be making with the "full cooperation and support of the
Reno Municipal Court, its staff, and other judges of the RMC" (which would
included Judge L. Gardner's brother, RMC Judge W. Gardner, whom, only
disclosed that L. Gardner is his sister (failing to during the 2/2/12 hearing) upon
Coughlin prompting for such disclosure a the 4/10/12 criminal trespass trial that
the City of Reno and RMC attempted to hold in violation of NRS 178.405 (not to
mention violating Marsden and Stankewitz, but whatever...)
2/2/12 criminal trespass hearing before RMC Judge W. Gardner where he fails to
disclose that his sister is the same 2JDC Judge L. Gardner that Coughlin filed a
mandamus petition against in 53833 and 54844, and whose 4/13/09 Order After
Trial in DV08-01168 Washoe Legal Services (see 60302 and Judge Elliott's
abominable "jurisprudence" appealed in 60317) Exec. Director Paul Elcano cited
as the sole reason for terminating Coughlin in his 5/1/09 and 5/7/09 letters to
Coughlin (though Elcano conveniently changed his song come time for his sworn
testimony at Coughlin's formal disciplinary hearing on
11/14/12): http://www.youtube.com/watch?v=Yg9B1IdQXUQ
Then, on 4/10/12 Judge W. Gardner was forced to admit 2JDC Judge L. Gardner
is his sister upon Coughlin prompting for such disclosure
only: http://www.youtube.com/watch?v=VVPx1zoVw5c
The 6/18/12 criminal trespass trial at which Coughlin was convicted (see 61901
for the SCR 111(4) Petition by the same Bar Counsel, Pat King, whom went out of
his way to avoid hearing or viewing the evidence of the Sheriff's burglaries and
misconduct at Coughlin's former home law offices and rentals, and the misconduct
of Richard G. Hill, Esq., Casey D. Baker, Esq., Gayle Kern, Esq., and Nevada
Court Services/Western Nevada Management....: http://www.youtube.com/watch?
v=3uG_-2J129A&feature=youtu.be
emails between Coughlin and the City of Reno attorney's who "happily" do their
dirty deeds:
http://www.scribd.com/doc/136383507/9-8-11-to-1-3-13-emails-to-reno-gov-
addresses-0204-60838-26800-22176-26405-00696-12420
http://www.rgj.com/article/20130701/NEWS/307010033/Reno-happily-defend-
police-sued-custody-death
The SBN's OBC King's 4/2/12 email to Coughlin is revealing:
"Subject: RE: my attempt to be provided access to the grievances filed today?
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Mon 4/02/12 3:57 PM To: zachcoughlin@hotmail.com
(zachcoughlin@hotmail.com) Dear Mr. Coughlin, I have opened 3 disciplinary
files against you. They are identified by number below: NG12-0204 Zachary B.
Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill NG12-0435 Zachary B. Coughlin,
Esq. Bar No. 9473 (2005) Judge Holmes NG12-0434 Zachary B. Coughlin,
Esq. Bar No. 9473 (2005) Judge Gardner You have received the grievance
from Mr. Hill and also the grievance from Judge Holmes. The Grievance from
Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v
Barti Joshi, Case Number DV08-01168, wherein she describes your conduct at
pages 12 and 13. I have received certified copies of the contempt orders, a
certified copy of the conviction at Wal-Mart, and an incident report from
Marshals Thompson and Coppa regarding your conduct on March 22, 2012. I also
have the recordings of the court proceedings at issue. At this time, I do not expect
to be providing you with any additional information. If you have additional
information that you want me to be made aware of in response to the grievances
identified above please feel free to mail them to me. Sincerely, Patrick King,
Assistant Bar Counsel"
5/8/12: Keith Loomis, Esq.'s swan song as to his imitation of defense:
http://www.youtube.com/watch?v=SW76cMukZPc&feature=youtu.be Judge W.
Gardner imposes a no faxing order just for Coughlin's benefit, and, of course
Loomis, Judge W. Gardner, and RCA Hazlett-Stevens continue their rampage on
the mandatory stay required under NRS 178.405 given Judge Elliott's Order
finding Coughlin competent to stand trial did not even get entered until the
following day, 5/9/12, and his Order remanding jurisdiction was not entered until
5/19/12 (not that the RMC thinks that matters, given the blatant level of disrespect
they have for both the 2JDC and Nevada Supreme Court).
RMC Judge L. Gardner's level of jurisprudence did not improve much at the
6/18/12 trial in the criminal trespass matter, but at least Richard G. Hill, Esq. and
Casey D. Baker, Esq. hemmed themselves in to a lot of really bad testimony that
would come back to bite them at the 11/14/12 formal disciplinary proceeding now
on appeal in 62337, and Reno City Attorney Deputy prosecutor Hazlett-Steven's
distinguished himself by committing professional misconduct in violating SCR
123 by citing to an unpublished opinion a TN Case, State v.
Lovins: http://www.youtube.com/watch?v=3uG_-2J129A Really, its ironic that
a big a hater as Hazlett-Stevens would cite to a case called Lovins, no? Haven't
seen that mix of enmity, irony, and word play since Bob Love wrote that hit piece
to the Nevada Appeal in 1995: http://www.scribd.com/doc/154433989/3-20-95-
Nevada-Appeal-Sports-Letter-Rand-Should-Be-Player-of-the-Year-by-Robert-
Love-the-Hater-0204
Its just sad to see justice and municipal court judges doing things that some might
say tend to besmirch the reputation of of those judges whom oversee their, uh,
jurisprudence, even those President of the District Court Judges Association. It
would be nice if the Chief Judge of, say, the Reno Justice Court could take some
cues from his august superior, Second Judicial District Court Judge David Hardy,
and consolidate the raft of baseless prosecutions and jurisdictional predicate and
prerequisite wanting summary evictions involving tenant and defendant Coughlin
in the RJC, but, some might say, his fellow judges would rather burden current
Chief Judge Pearson with the Nev. Const Art. 6 Sec.6 mischaracterizing 12/20/12
Administrative Order 2012-01's of former Chief Judge Sferrazza, and the
extremely ill advised approach taken by Judge Clifton (he of the 11/27/12 on the
record comment "What Judge Pearson says isn't law to me, ha" comment) in the
"misuse of 911" prosecution of the very same Coughlin whom Master Edmondson
found to be a victim of domestic violence at the hands of not one, but both of his
sublessors in FV12-00187, and 188. To be clear, RMC Administrative Judge
William L. Gardner, brother of 2JDC Family Court Judge Linda Gardner, seems
to have been led down that primrose path by then Chief Judge Sferrazza in
copying, verbatim, Sferrazza's 12/20/12 Administrative Order which such clearly
misstate's the text of Nev Const. Art. 6 Sec. 6 in indicating that "Nevada courts"
have authority to enter such overreaching abuses of process and denials of the
access to justice when, in fact, such constitutional section speaks only to the
authority granted "District courts". To be clear, though, it was only upon Judge
Pearson's assigning a criminal case number to such specious "Administrative
Order 2012-01" on 3/14/12 that the separation of powers blurring usurping of the
executive branch's prosecutorial charging decision function was put into such
stark relief from the otherwise excellent jurisprudence and guidance (not to
mention clarion call of propriety) provided by the current President of the District
Court Judges Association.
Its just a wonder that more of these limited jurisdiction court judges are not met
with a Canon 2 Rule 2.15 level of consternation. One thing is clear, however,
Coughlin was not, not by Judge L. Gardner, not by Judge Patrick Flanagan, or any
other Second Judicial District Court Judge. Unless, the 2JDC wishes to provide
something to indicate otherwise, I will take any lack of response as conclusive
proof that such did not occur.
Sincerely,
Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
7402 ZachCoughlin@hotmail.com
PS: King's email to Coughlin below evince a willingness to lie about the source
of the NG12-0435 "grievance", which he compounded by lying about whether or
not Coughlin responded to such (includign the fact that King's 4/19/12 email to
Coughlin only asks for a response to Hill and Judge Nash Holmes's grievance, yet
his 4/2/12 email to Coughlin mentions the "grievance" from Judge L. Gardner,
which Hill, purportedly feels he attached to the same 3/16/12 letter he alleges he
sent Coughlin:
"RE: Mr. King's assertion in his 3/16/12 letter? From: Patrick King
(PatrickK@nvbar.org) This sender is in your safe list. Sent: Thu 4/19/12 2:28
PM To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com) April 19,
2012 Zach Coughlin Dear Mr. Coughlin, A screening panel of the Northern
Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the
grievances filed against you. The panel directed me to proceed to a formal
disciplinary hearing. As such, I will be preparing a formal Complaint. I
understand from the e-mail below, that you do not believe you should have been
found guilty of the theft at Wal-Mart and that you should not have been found in
contempt of Court. However, it must concern you that you were found in contempt
of Court by more than one Judge in two different trials. You wanted to know how
I learned of or obtained a copy of Judge Gardners Order after trial that was
filed in 2009. It was sent to me by the clerk of the court at my request,
pursuant to my investigation. It would help me and perhaps yourself, if you
would respond and explain why you were convicted of theft and why you were
held in contempt of Court. You may be well served to explain what remedial
measures you are taking to make sure you do not repeat the conduct complained
about. I cannot give you legal advice. However I can suggest you cooperate
with Bar counsels investigation and that you respond specifically to the
allegations contained in Judge Holmes and Richard Hills grievance letters to
the office of Bar Counsel. Patrick King"
So, in his 4/2/12 email to Coughlin King's story is presented one way ("NG12-
0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner You
have received the grievance from Mr. Hill and also the grievance from Judge
Holmes. The Grievance from Judge Gardner relates to her Order After
Trial in the case of Ashwin Joshi v Barti Joshi, Case Number DV08-01168,
wherein she describes your conduct at pages 12 and 13." ) but by his 4/19/12
email to Coughlin, after being caught in his lies and the stickiness of the
remarkably suspect "receipt stamping" of the alleged "grievance from Judge
Gardner" (her) marked 3/15/12 (with the "5" in the "15" presenting in various
interlineated iterations, dubiously), while Judge Nash Holmes 3/14/12 grievance
letter is marked as received on "3/14/12"...) King admits: :You wanted to know
how I learned of or obtained a copy of Judge Gardners Order after trial that
was filed in 2009. It was sent to me by the clerk of the court at my request,
pursuant to my investigation."
Also, as to King's being a compulsive liar:
http://www.youtube.com/watch?v=DhCMlfGhPfc that is King's "testimony"
"representing the State Bar of Nevada and I will be a witness (in violation of RPC
3.7 and NRS 33.250) ..and also in attendance with me is Laura Peters she is a
paralegal and the official court clerk of the State Bar of Nevada as well..."
It really does not take much discernment to determine that the link the the email
King indicates Coughlin sent to the WCPD and copied him on is to an audio clip
only (not a "movie" or "video") and that there certainly is not any "gun shots" or
"shooting" or
King of funny for King to allege that he "received a grievance from a federal
judge" in NVB Judge Beesley when no such grievance was ever provided to
Coughlin (which did not stop King from identifying Beesley as a witness the day
before the 11/14/12 formal disciplinary hearing in an egregious violation of SCR
105(2)(c)) and where Judge Beesley just did not seem to recall the fact that
Coughlin's 3/30/12 filing included exhibits that detailed to illegal confiscation and
search not incident to arrest of his smartphone by the Reno Municipal Court and
Judge Beesley's 1977 McGeorge School of Law Classmate, RMC Judge Dorothy
Nash Holmes (both of whom share Washoe Legal Service's Paul Elcano as a
fellow alumn of that class of 1977, with Coughlin suing Elcano and WLS in 60302
and 60317 for wrongful termination, where Elcano indicated Coughlin was being
fired solely in response to 2JDC Judge L. Gardner's 4/13/09 Order After Trial in
DV08-01168, which was subsumed by her own 6/19/09 Final Divorce Decree
anyways, and which itself violated the incorporation of NRCP 11's 21 day safe
harbor provision via NRS 7.085 (making her allegation that such an attorney fee
award was just due to "failure to follow procedural rules" particularly suspect,
especially where it was Springgate whom failed to timely file his Pre-Trial
Statement or comply with Judge L. Gardner's own Pre-Trial Order, particularly
where the main source of Judge Gardner's criticism of Coughlin related to
Coughlin's insistence that Springgate was in violation of her own pre-trial order
("like the rule states" meaning the rule of law, ie, the law of the case, ie her own
2/25/09 Pre-Trial Order) for failing to have bound, tabbed, and index, his exhibits
where Springgate sought the introduction of in excess of ten exhibits.
Also, there is "issues" with the 2JDC's apparent rejection fo Coughlin's 5/20/09
filing in that matter and the preservation of arguments such would engender,
compared to the curious timing of a 5/21/09 Order denying Coughlin's Motion for
Reconsideration....Then there is the attached handwritten notes detailing some of
the peculiarities with respect to the inconsistent service of various filings or
proposed orders in DV08-01168, particularly after Coughlin's termination from
WLS, especially where Coughlin was a necessary party or otherwise obviously
had a stake in such matters.
Then there is King's admitting to, in his 10/10/12 email to Coughlin, attempting to
fraudulently skip out on his duties as assistant bar counsel under SCR 104(1)(d)
and SCR 111(4):
SCR Rule 104. State bar counsel. 1. State bar counsel shall: (d) File with the
supreme court petitions with certified copies of proof of conviction demonstrating
that attorneys have been convicted of serious crimes, as defined in Rule 111..." "
SCR Rule 111. Attorneys convicted of crimes. 4. Bar counsels responsibility.
Upon being advised that an attorney subject to the disciplinary jurisdiction of the
supreme court has been convicted of a crime, other than a misdemeanor traffic
violation not involving the use of alcohol or a controlled substance, bar counsel
shall obtain a certified copy of proof of the conviction and shall file a petition
with the supreme court, attaching the certified copy. Upon being advised that an
attorney subject to the disciplinary jurisdiction of the supreme court has been
convicted of a misdemeanor involving the use of alcohol or a controlled substance
and the offense is not the attorneys first such offense, bar counsel shall
investigate and present the matter to the appropriate panel of the disciplinary
board prior to the filing of the petition. The petition shall be accompanied by the
panels recommendation regarding the appropriate disciplinary action, if any, to
be imposed under these or any other rules of the supreme court that pertain to the
conduct of attorneys."
"Subject: RE: pending final disposition of disciplinary proceedings....language
SCR 111(7) versus SCR 111(8) and the June 7th, 2012 Order of the NV. S. Ct.?
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Wed 10/10/12 9:44 AM To: Zach Coughlin
(zachcoughlin@hotmail.com) Cc: David Clark (DavidC@nvbar.org) Dear Mr.
Coughlin, When you met with me and David Clark to discuss the Complaint and
the process. Mr. Clark explained that since there was a conviction, the sole issue
to be determined was the extent of the discipline. Not if you committed the
crime, since that was already determined beyond a reasonable doubt. It is that
context that we are reading the rule. Not that the state bar is precluded from
bringing additional allegations against you. Any additional allegations that have
not already resulted in criminal convictions will need to be proved by clear
and convincing evidence. As such, at the hearing, on the issue of your criminal
convictions, the only issue for the panel to decide is the appropriate discipline.
However, I will be providing evidence as to the other allegations in the
Complaint. The Panel will decide if the state bar has met its burden of proof as to
those allegations in the complaint, other than the criminal convictions, and will
decide the appropriate discipline on the totality of the case, including mitigating
and aggravating factors that may be presented at the hearing. As such, I do not
intend bifurcate these proceedings. I think to do so would cause unnecessary
confusion, undue time and expense and would be prejudicial to the
administration of justice. I am advised that you have not yet filed an Answer to
the Complaint... Patrick King, Assistant Bar Counsel."
Interestingly, King flips and flops between admitting Coughlin "filed an answer"
when he wishes to establish that Coughlin was "served" in accord with SCR 109,
only to allege (judicial estoppel, much?) that Coughlin violated in SCR 105 in
allegedly failing to file a "verified answer or response" in a timely fashion to
Complaint in seeking a default:
HEARING (of 11/14/12) - Vol. I, (Pages 6:21 to 7:6) "MR. KING: As the record
reflects, Mr. Coughlin was served a copy of the complaint to the address that he is
mandated to provide to the State Bar. MR. COUGHLIN: I don't believe that's
correct. MR. ECHEVERRIA: Please don't interrupt, Mr. Coughlin. Go ahead.
MR. KING: Subsequently, Mr. Coughlin filed, immediately after we mailed the
complaint via certified and regular mail, Mr. Coughlin filed a motion to dismiss
the complaint."

King alleges his Complaint in SBN v Coughlin was mailed on 8/23/12...so, which
is it? Did Coughlin "file" an Answer or not? If such was "filed, immediately
after we mailed the complaint", then why would not the 9/17/12 Motion to
Dismiss that Coughlin fax filed with the SBN in compliance with the manner and
method the SBN/Clerk of Court/NNDB/Panel approved for filing not be given the
old DCR 13(3) treatment where King failed to file an Opposition to such until the
deadline to do so had passed (how embarrassing for an assistant bar counsel, talk
about violatign RPC 1.1, 1.2, 1.3, etc., pot meet kettle).
For whatever reason, (and one can be sure there is a good one...oh wait, there it
is, that darn Coughlin making such a fuss over the number of "grievances" and
from whom they were issued, and just how many judges were involved...shucks,
cornered ol' Pat King into a lie, and now Pat got stuck with being unable to seek to
admit his purported 3/16/12 letter to Coughlin, which completely undermines his
whole allegation that Coughlin failed to answer some grievance or respond to
some request for some response, etc....and who would have thought the word
"several" would become so important: "several [sev-er-uhl, sev-ruhl] 1. being
more than two but fewer than many in number or kind: several ways of doing
it.... (source www.dictionary.com)") King chose not to seek to admit his
purported 3/16/12 letter to Coughlin which may or may not have read (either way,
definitely did not meet his burden, King, to show some failure to answer or
cooperate by Coughlin, by "clear and convicing" evidence where King was so
hemmed up by Coughlin's approach that he was too afraid of his lies getting
exposed to seek to admit any such purported 3/16/12 letter to Coughlin, and
instead, King had to take the perplexing (to some, to be sure) tact of seeking to
admit only a letter from Judge Nash Holmes to the SBN regarding Coughlin,
which, of course, begs the question, just how does such a letter prompt any
response from Coughlin? Simply put, one does not expect Domino's to delivery
them a pizza when they place a call to China Diner, right? Real head scratcher that
was..."uh, well, Panel, I, Pat King am seeking to admit this letter to the SBN from
Judge Nash Holmes as evidence of Coughlin's failure to respond to Judges letter
to the SBN..." huh? Face it, Pat, you made your bed with all your lies in
overstating the vast multitude of grievances and the army of judges you allegedly
had at your disposal in your various early March-April 2012 communications,
meeting, and correspondence with Coughlin...you went for the group think
intimidation play and it backfired on you spectacularly. This is particularly true
where such purported 3/16/12 letter from King, King would necessarily be too
afraid to put into the record, where such reads: "The Office of Bar Counsel has
received several grievances concerning your conduct as a lawyer. The
grievances include supporting evidence ,,, and copies of pleadings and
documents prepared and filed by you in Justice and District Court. ... I am
enclosing with this letter copies of a grievance letter, from the Municipal Court
and a copy of an Order 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."
See how awkward seeking admission of such a letter would be for King? First, he
wold have to explain his use of the term "several", which would be especially
difficult after Judge Beesley testified that he didn't send any letter to the SBN
(grievance or otherwise) until "about six weeks" after the 3/15/12 hearing in NVB
10-05104 Coughlin appeared at minutes after the WCSO burglarized his home
law office in connection with the summary eviction order Gayle Kern, Esq.
fraudulently obtained just that morning in Rev12-374.
Then, King would need to explain why, where he is offering in writing to allow
Coughlin to "make available for your review and inspection the supporting
documents and audio recordings" Coughlin was therafter afforded no such
opportunity to, one, obtain the audio recordings (or some of them, at least) until
after three more months went by, whereupon King finally emailed Coughlin the
announcement on 6/25/12, that he would allow Coughlin to obtain some leftover
copies of the audio discs provided to the Screening Panel, and, two, why
Coughlin was not provided any such "supportin document" until a full six months
later, just three judicial days prior to the 11/14/12 formal disciplinary hearing.
King of hard to argue that Coughlin failed to respond to this or that under those
facts, much less make a case for failing to cooperate with disciplinary authorities.
Then, King would really be smarting from the problems associated with his
writing "I am enclosing with this letter copies of a grievance letter, from the
Municipal Court and a copy of an Order from District Court" upon a close
comparison of King's subsequent writings and statements (and King really, really
does not want there to be any, uh, evidence of just what it was he said, exactly, to
Coughlin during the 3/26/12 appearance by Coughlin at the SBN to take King up
on his offer to allow "make available for your review and inspection the
supporting documents and audio recordings"), especially as to King's 4/2/12
email to Coughlin and the statements therein indicating he received a "grievance"
"from Judge Gardner" that "relates to her "Order After Trial"...:
So, in his 4/2/12 email to Coughlin King's story is presented one way ("NG12-
0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner You
have received the grievance from Mr. Hill and also the grievance from Judge
Holmes. The Grievance from Judge Gardner relates to her Order After
Trial in the case of Ashwin Joshi v Barti Joshi, Case Number DV08-01168,
wherein she describes your conduct at pages 12 and 13." ) but by his 4/19/12
email to Coughlin, after being caught in his lies and the stickiness of the
remarkably suspect "receipt stamping" of the alleged "grievance from Judge
Gardner" (her) marked 3/15/12 (with the "5" in the "15" presenting in various
interlineated iterations, dubiously), while Judge Nash Holmes 3/14/12 grievance
letter is marked as received on "3/14/12"...) King admits: :You wanted to know
how I learned of or obtained a copy of Judge Gardners Order after trial that
was filed in 2009. It was sent to me by the clerk of the court at my request,
pursuant to my investigation."
Because, then King would just look like a liar whom was asserting some sort of
Canon 2 Rule 2.15 "appropriate action" collateral bar application as to the
allegations that anything from that DV08-01168 Joshi case supports any finding of
professional conduct by Coughlin...its a much different animal when King actually
received that "Order After Trial" from the Joshi case from RMC Judge Nash
Holmes on 3/14/12, only for King to then fraudulently affix a "received 3/15/12"
stamp on it, proceed to shuck and jive his way along, alluding to "several
grievances" from "at least three judges" (as King indicated during the 3/26/12
meeting with Coughlin, though refusing to identify them by name, and quickly
storming off with his "box of materials", which King lied about at the 1/4/13 EPO
hearing, in attempting some lame "Coughlin was very frightening to me, yikes"
approach). Further, its particularly messy when King is stuck admitting that he
received such Order After Trial by Judge L. Gardner from RMC Judge Nash
Holmes, whom admits to having received it from Judge L. Gardner's brother
RMC Judge W. Gardner...just seems kind of tawdry and awkward, no? If Judge L.
Gardner wanted to file a grievance or pursue any Canon 2 Rule 2.15 "appropriate
action" then she should have done so herself, but then again, she was pretty
hemmed up by her own 6/19/09 Final Decree subsuming her 4/13/09 Order After
Trial, especially where such Final Decree granted the very alimony she alleged
Coughlin was "vexatious" in arguing for...huh? Yeah.
"March 16, 2012 Sent Via U.S. Mail, Certified Mail and via E-Mail Zachary B.
Coughlin, Esq. 1422 E. Ninth Street, #2 reno, NV 89512 RE: Attorney Discipline
Dear Mr. Coughlin: The Office of Bar Counsel has received several
grievances concerning your conduct as a lawyer. The grievances include
supporting evidence in the form of: audio of your conduct in court
proceedings and copies of pleadings and documents prepared and filed by you
in Justice and District Court. Together these grievances raise serious questions
regarding your competency and ability to practice law.
These concerns are serious and the Office of Bar Counsel is considering the
necessity of seeking a Petition to Determine Competency pursuant to Supreme
Court Rule 117. I am enclosing with this letter copies of a grievance letter, from
the Municipal Court and a copy of an Order 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.
I have left phone messages and sent you an e-mail asking you to call me. As of the
drafting of this letter you have not called me. I would like to meet with you so that
we can discuss this important matter and see if there is a way that we can help you
Again, please call me at your earliest opportunity. Sincerely, /s/ Patrick King
Assistant Bar Counsel"
"From Assistnat Bar Council, Patrick King? From: Patrick King
(PatrickK@nvbar.org) This sender is in your safe list. Sent: Tue 6/26/12 2:52 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com) Cc: David Clark
(DavidC@nvbar.org) June 26, 2012 RE: Recordings of Court proceedings
Dear Mr. Coughlin, I spoke with David Clark regarding your request that we
provide you with copies of the CD discs of Court proceedings. David Clark
authorized me to provide you with copies. Please let me know the address to use
to send you the copies. There is a total of 5 disks. Patrick King, Assistant Bar
Counsel"
(NOTE: interestingly, despite indicating in his 3/16/12 letter to Coughlin that he
would "make available for your review and inspection the supporting
documents and audio recordings" it was not until King's 6/25/12 email to
Coughlin that he indicated he would provide some of the audio recordings, and it
was not until three judicial days before the 11/14/12 formal disciplinary hearing
that King would afford Coughlin any access to some 3,200 pages of "materials"
(especially suspect in that such practice clearly violated SCR 105(2)(c), not to
mention that, while Coughlin was "constructively noticed" of the "supplemental"
designation of NVB Judge Beesley and Elcano as witnesses on the day before the
hearing (ie, 11/13/12), such 3,200 pages contained not any "grievance" from
Judge Beesley (and, in fact Beesley's testimony failed to indicate he filed any
"grievance" against Coughlin, and further, the dating of King's 3/16/12
correspondence to Coughlin, which indicates that the "Office of Bar Counsel has
received several grievances concerning your conduct as a lawyer" contradicts
King's assertion that "several grievances" had been received where Judge Beesley
(even if one considers any letter he claims to have sent the Bar some "six weeks"
after the 3/15/12 hearing in NVB 10-05104 held just minutes after Coughlin was
evicted at gunpoint by Sheriff's whom had burglarized Coughlin's former home
law office in violating NRS 40.253(5)'s requirement that any eviction order be
"received" by the tenant for at least "24 hours" before any such lockout is
performed) clearly indicated in his testimony that he had not even contacted the
bar about Coughlin at such time, leaving only two "grievances" that the "Office of
Bar Counsel" could have "received". This goes to the extent to which King is
compulsive liar. Consider the definition of the word "several" then consider
whether Judge Nash Holmes (as she admitted she "probably" did) including 2JDC
Judge L. Gardner's 4/13/09 Order After Trial (FHE 3) with those "materials" she
provided to the SBN along with (and referenced in) her 3/14/12 "grievance"
amounts to "receiving" a "grievance" from either someone other than Judge Nash
Holmes (unless King wants to maintain some ridiculous argument that Judge Nash
Holmes filed two different grievances...bringing into focus the attempts by King to
obscure the fact that 2JDC Judge L. Gardner refused to file a grievance against
Coughlin with the SBN (providing Coughlin with the argument that her failure to
do so provides a collateral bar under Canon 2, Rule 2.15 in that the matter of
whether Coughlin committed any professional misconduct sufficient to required
2JDC Judge L. Gardner to take any of the "appropriate action" identified in the
commentary to Rule 2.15 was, in essence, "actually litigated".
While King would like to assert that Judge Nash Holmes 2/28/12 Order finding
Coughlin to have violated a civil contempt statute (a plenary one, in NRS 22.100,
no less, despite her summary incarceration of Coughlin and application
thereof) somehow amounts to a "criminal conviction", or that such somehow
obviates the duty King has to file a Petition with the NSCT reporting such
"conviction" under SCR 104(1)(d) and SCR 111(4) (and then wait for direction
from the court as to the jurisdiciton and NNDB Panel may or may not have to
pursue a disciplinary hearing), even where that so, such application would only
extend an SCR 111(5) "conviction is conclusive proof of guilt" (nevermind
Claiborne or SCR 114, apparently) as to the matter of whether Coughlin
committed the "misdemeanor of criminal contempt" (nevermind that ther is an
NRS for such (NRS 199.360, which Judge Nash Holmes, a longtime prosecutor,
failed to cite to and could not identify during her sworn testimony), not as to
whether Coughlin committed the multitude of violations of the various RPC's
that Judge Nash Holmes alternatively mused that Coughlin "probably" violated
(Schaeffer's "clear and convincing evidence" burden requires more than the
"preponderance of the evidence" standard provided by Nash Holme's assessment
("I think there is probably a question of whether Mr. Coughlin violated those
Rules of Professional Conduct" Holmes expounded on the record of the 3/12/12
hearingin 26800), on the audio recording that Coughlin sought to introduce into
evidence (the RMC indicated such copy purchase by Coughlin (through his mother
given the RMC refused to sell Coughlin one, natch) was "certified", while King's
arguing that it was somehow just to bring a grievance based upon the very audio
recordings he admits the RMC provided him that he argued were "inadmissible"
at the formal hearing it truly perplexing, to say nothing of the Panel Chair's ruling
excluding such materials).
"FW: Mr Coughlin? From: Patrick King (PatrickK@nvbar.org) This sender is in
your safe list. Sent: Thu 8/30/12 1:46 PM To: zachcoughlin@hotmail.com
(zachcoughlin@hotmail.com) Attachments: 1 attachment Order (8-28-12).pdf
(147.4 KB) Good Afternoon Mr. Coughlin, Attached is an Order that pertains to
you. I have not yet received an answer to the Complaint that I filed against you.
Could you let me know when you expect to file an Answer? Thank you. Patrick
King" (NOTE: that 8/28/12 Order King attached was Judge Flanagan's in CV11-
03628, the one which
Hill demonstrates his own RPC 3.1, 3.3, and 3.4 violations where he falsely characterizes the
"reasons" Judge Flanagan provides for entering the attorney fee award of 6/25/12 in CV11-
03628 (FHE 2): "HEARING - Vol. I, (Pages 40:25 to 41:4) I have provided Mr. King with a
copy of Judge Flanagan's orders in which he sets forth the reasons for such an extraordinary
award, being Mr. Coughlin's behavior, and the quality of the work that he was filing."
Actually, as Hill and King (see King's inclusion of such 8/28/12 Order in his 8/30/12 email to
Coughlin) well know, Judge Flanagan's 8/21/12 and 8/28/12 Orders in 03628 clearly contradict
Hill's assessment that Judge Flanagan's 6/25/12 Order in 03628 "sets for the the reasons for
asuch and extraordinary award, being Mr. Coughlin's behavior, and the qualiity of the
work that he was filing...". Rather, Judge Flanagan's 8/28/12 Order in 03628 makes clear:
"...Coughlin's Motions here attempts to re-litigate substantive issues this Court has already
decided, or frivolous claims this Court has previously ignored.."
"RE: citation to legal authority?? From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Tue 9/25/12 11:34 AM To: Zach Coughlin (zachcoughlin@hotmail.com) Cc: David Clark
(DavidC@nvbar.org); Laura Peters (LauraP@nvbar.org) 9-25-2012 Dear Mr. Coughlin, Please be
advised that the State Bar of Nevada will not accept or file any documents submitted by you via e-
mail. Further, if you intend to send or serve me with a copy of a document it will not be accepted if sent via
e-mail. Sincerely, Patrick King, Assistant Bar Counsel."
"RE: Motion to Dismiss SBN v. Coughlin? From: Laura Peters (LauraP@nvbar.org) This sender is in your
safe list. Sent: Wed 9/26/12 11:54 AM To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
I never said that you could file items via e-mail I dont make those calls. I have to file documents in so you
have to serve them here. I want to cooperate with you but I cant change the procedural requirements. -
Laura"
Why the strange focus on email and silence as to filing by fax, such is particularly suspect given the flip
flopping Clerk of Court Peters did with respect to her declaration that such was accepted on 9/11/11, on to
change her tune upon Pat King being informed by Coughlin on 10/7/12 that King had failed to Opposed
Coughlin's 9/17/12 Motion to Dismiss (which would be a verified response, in contrast to the "Verified
Answer" King told Coughlin he was required to file in King's suspect misstatement of SCR 105:
"RE: Motion to Dismiss SBN v. Coughlin? From: Patrick King (PatrickK@nvbar.org) This sender is in your
safe list. Sent: Mon 9/24/12 3:10 PM To: Zach Coughlin (zachcoughlin@hotmail.com) Cc: David Clark
(DavidC@nvbar.org) Dear Mr. Coughlin, You have an ongoing obligation to cooperate with the State Bar.
Your refusal to provide the state bar with your present address for service of process is not acceptable. I
understand you have a copy of the Complaint filed against you. You are required to file a verified Answer to
the complaint. If you do not have a copy of the complaint you may pick up a copy of the complaint at the
Northern State Bar Center. If you refuse or fail to file an Answer the matter may proceed against you on a
default basis. If the matter proceeds against you on a default basis, the allegation in the Compliant may be
accepted as true. I would encourage you to take this matter seriously. Sincerely, Patrick King, Assistant Bar
Counsel"
"RE: citation to legal authority?? From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Tue 9/25/12 10:49 AM To: Zach Coughlin (zachcoughlin@hotmail.com) Cc: David Clark
(DavidC@nvbar.org) September 25, 2012
Good Morning Mr. Coughlin, This morning you were served with the Disciplinary Complaint, for Case No:
NG12-0204, NG12-0435 and NG 12-0434. A verified Response or Answer to this Complaint must be
filed with the Office of Bar Counsel, State Bar of Nevada, 9456 Double R. Blvd, Ste. B, Reno, Nevada
89521 within 20 days. The Procedure regarding service is addressed in SCR 109. The reason I have
requested your physical address is to facilitate our ability to contact you. The mail that was sent to
you via certified mail was returned to the State Bar as unclaimed. Patrick King, Assistant Bar Counsel"
Again, the strange appearance (and non-service until a month after the fact and buried among some 3,200
other pages provided Coughlin just three judicial days before the 11/14/12 formal disciplinary hearing, of the
11/9/12 Affidavit of Laura Peters is just too much considering Coughlin's 10/6/12 email to the SBN
announced the failure of King to file an opposition to Coughlin's 9/17/12 Motion to Dismiss, especially
considering the incongruous placement of such 10/9/12 Affidavit of Laura Peters after the filings of
10/30/12 in the original version of the hearing pleadings file provide by the SBN...hmmmn
FW: motion to dismiss attached? From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Sat
10/06/12 4:36 AM To: patrickk@nvbar.org; laurap@nvbar.org; tsusich@nvdetr.org Attachments: 1
attachment sbn v coughlin motion to dismiss.pdf (80.5 KB)
Dear Bar Counsel, Please note that the Motion to Dismiss that I filed in SBN v. Coughlin,
on September 17th, 2012, has gone unopposed, and therefore, should be granted...Mr. King was
telling me the other day: "Zach, you don't take responsibility for your actions and that is why things don't
work out for you..." I wonder, does Mr. King take responsibility for his actions here, or lack thereof, in
failing to oppose my Motion to Dismiss? It will be interesting to see. Sincerely, Zach Coughlin PO BOX
3961 Reno, NV 89505 Tel 775 338 8118 Fax 949 667 7402 ZachCoughlin@hotmail.com From:
zachcoughlin@hotmail.com To: patrickk@nvbar.org; tsusich@nvdetr.org Subject: motion to dismiss
attached Date: Mon, 17 Sep 2012 23:59:42 -0700 Zach Coughlin PO BOX 3961 Reno, NV 89505 Tel
775 338 8118 Fax 949 667 7402 ZachCoughlin@hotmail.com
"RE: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and
the June 7th, 2012 Order of the NV. S. Ct.? From: Laura Peters (LauraP@nvbar.org) This sender is in
your safe list. Sent: Wed 10/10/12 6:01 PM To: Zach Coughlin (zachcoughlin@hotmail.com)
Please don't put words in my mouth, Zach. You are the one that indicated that you had not received the
Complaint when we talked on the phone. Why, then, would I file in a Motion to Dismiss? I am responsible
for my own actions. - Laura (aka Clerk Peters)"
Then Pat King the fraud alleges at the 1/4/13 hearing to extent the TPO in RCP12-607 that Coughlin was
harassing just about everyone in trying to get a copy of the record/transcript of the 11/14/12 disciplinary
proceeding...only problem is, King failed to answer any of Coughlin's requests for such starting the day after
the hearing...despite his being required to under SCR 119. King finally responded to Coughlin's requests
one month later, after King was able to obtain an unfair advantage in having the transcript ahead of Coughlin:
"Transcript? From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Tue 12/18/12
3:07 PM To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com) Cc: David Clark
(DavidC@nvbar.org) Attachments: 1 attachment Transcript receipt_121812.pdf (41.8 KB) December 18,
2012 Good Afternoon Mr. Coughlin, I am advised that you called the State Bar to ascertain how you may
obtain an official copy of the transcript of your disciplinary hearing. David Clark asked me to respond to
your request. While I cannot give you legal advice, I can direct you to Supreme Court Rule 119. Pursuant to
that rule, The record of a hearing shall be made available to the attorney at the attorneys expense on
request made to bar counsel. See SCR 119 1. I have asked Sunshine Reporters to provide me with the
amount it will cost to purchase a copy of the transcript. The cost of the transcript is $2,518.20. You may
purchase a copy of the transcript directly from Sunshine Reporting. A copy of the invoice that
Sunshine sent us is attached. Patrick King, Assistant Bar Counsel"
So King argues for a Workplace Harassment TPO/EPO based on his non-sequitur allegation that Coughlin
"called the court reporter" seeking a transcript (which King alleged somehow "frightened" her), only for King
to then write Coughlin and direct him to seek any purchase of a copy of the transcript directly through that
very firm...
Such is similar to King's ridiculous act of sending Coughlin a letter demanding that he call the SBN ahead 15
minutes to announce if he would be appearing to file a document, then alleging Coughlin scared him and the
SBN so bad by doing just that, calling ahead and announcing he would be there shortly to do so.
"RE: pending final disposition of disciplinary proceedings....language SCR 111(7) versus SCR 111(8) and
the June 7th, 2012 Order of the NV. S. Ct.? From: Patrick King (PatrickK@nvbar.org) This sender is in
your safe list. Sent: Wed 10/10/12 9:44 AM To: Zach Coughlin (zachcoughlin@hotmail.com) Cc: David
Clark (DavidC@nvbar.org)
Dear Mr. Coughlin, When you met with me and David Clark to discuss the Complaint and the process. Mr.
Clark explained that since there was a conviction, the sole issue to be determined was the extent of the
discipline. Not if you committed the crime, since that was already determined beyond a reasonable doubt.
It is that context that we are reading the rule. Not that the state bar is precluded from bringing
additional allegations against you. Any additional allegations that have not already resulted in criminal
convictions will need to be proved by clear and convincing evidence. As such, at the hearing, on the issue
of your criminal convictions, the only issue for the panel to decide is the appropriate discipline. However, I
will be providing evidence as to the other allegations in the Complaint. The Panel will decide if the state bar
has met its burden of proof as to those allegations in the complaint, other than the criminal convictions, and
will decide the appropriate discipline on the totality of the case, including mitigating and aggravating factors
that may be presented at the hearing. As such, I do not intend bifurcate these proceedings. I think to do
so would cause unnecessary confusion, undue time and expense and would be prejudicial to the
administration of justice. I am advised that you have not yet filed an Answer to the Complaint. I have sent
you a notice of intent to proceed on a default basis. The hearing date is expected to be Wednesday
November 14, 2012. I will be sending you a notice of hearing, along with a list of witness, and evidence that
I intend to introduce at the hearing. Patrick King, Assistant Bar Counsel."
King thinks he makes the ruling on whether to bifurcate or not, and, in reality, he probably does given the
slapdash justice provided by the NNDB.
And soon, King would drop his more accurate recounting of the burden and extent to which an criminal
convictions could provide preclusive effect as to the various other allegations, and adopt the more fraudulent
approach of Panel Chair Echeverria:
"HEARING - Vol. I, (Pages 72:23 to 75:5) "MR. KING: Mr. Chairman, if I could respond by pointing out the
fact that the order from Judge Flanagan, which has been admitted, suggests that that was -- that those fees
were generated because of Mr. Coughlin's vexatious conduct. And that the fees were reasonable and were
awarded against Mr. Coughlin, not one cent of which has been paid. So I think any suggestion to the contrary
is irrelevant, because Judge Flanagan's order is to be accepted by the panel. MR. COUGHLIN: ...I
don't know that's actually pled in your complaint, Mr. King, or included amongst one of the three
grievances. ... Am I here today on Judge Flanagan's sanction? Is he a grievant and accorded a case
number too? ... MR. ECHEVERRIA: I believe you're here today to measure all of your conduct as a
practicing lawyer. ... MR. COUGHLIN: So we're not here today based on what's been noticed? MR.
ECHEVERRIA: We're not here today to relitigate orders that have been filed that you have appealed, and that
you have lost. MR. COUGHLIN: ... I'm asking what is it limited to? Because it sounds like from what you
just said it's not limited. MR. ECHEVERRIA: I don't intend to impose any limits on you in terms of what you
attempt to proffer as evidence. I will rule on what you proffer as evidence. MR. COUGHLIN: I'm saying
what he's limited to, your Honor. MR. ECHEVERRIA: The issue here, sir, as I understand the supreme
court's order with respect to your conviction of theft, and the issues here with respect to the other grievances
that have been filed against you are to the extent as to what, if any, should be the punishment that you should
sustain as a result of your conduct. MR. COUGHLIN: Yet this is entered into evidence. MR. ECHEVERRIA:
This is what? MR. COUGHLIN: This order has been entered into evidence. MR. ECHEVERRIA: Exhibit 2
has. MR. COUGHLIN: But it's not pled in any complaint. Judge Flanagan's not a grievant. I wasn't noticed
that that was the purpose of this hearing to some extent today. MR. ECHEVERRIA: You were noticed that
the issue of your conviction of trespass was an issue, that your handling of that case was an issue, and it's
relevant as to that."
HEARING - Vol. I, (Page 71:10 to 71:18) MR. ECHEVERRIA: I believe the issue that this panel has to
determine is what the degree, if any, of punishment should be for the conduct that you have alleged to have
been involved with, in terms of candor to the court, candor to counsel, candor to witnesses, competency to
practice law. MR. COUGHLIN: Including -- MR. ECHEVERRIA: I believe those are the issues that this
panel should focus on.
HEARING - Vol. I, (Pages 235:7 to 241:15) MR. ECHEVERRIA: You've already proffered that. I've
sustained the objection. MR. COUGHLIN: I'd like to play a copy of a video I took of Sergeant Lopez
admitting certain things with respect to the criminal trespass. MR. ECHEVERRIA: Mr. King? MR. KING: I
would object to the extent that Mr. Coughlin is trying to suggest in any way that he wasn't guilty of the criminal
trespass, because he was convicted and exhausted his appeal rights. And to retry that I think shouldn't occur
here. MR. ECHEVERRIA: The relevance of this -- MR. KING: To the effect he wants to produce it for
some other reason, I think he would need to explain specifically what that reason is. If it goes to whether or
not he's guilty of a criminal trespass, I would say it's not relevant. MR. ECHEVERRIA: And your relevance,
Mr. Coughlin? MR. COUGHLIN: I would like to give you the 30-minute notice that I would like to cross-
examine Judge Nash Holmes and Richard Hill or call them in my case in chief, rather. I'll do that now. I note
that I have a time of 2:55. MR. ECHEVERRIA: Right now we're dealing with the relevancy of a videotape
that you claim to have taken. And how is that relevant? MR. COUGHLIN: Because it goes to rebut
everything that you deem relevant to which Richard Hill testified. MR. ECHEVERRIA: Everything? MR.
COUGHLIN: Yeah. MR. ECHEVERRIA: What is contained in this proffered video? MR. COUGHLIN:
There's a couple of them. There's video of the arrest, the trespass arrest. The discussion between myself and
Richard Hill, and his client, and the police officers. Then -- and that was -- and then there is a video of a
couple months later of me interviewing Sergeant Lopez about whether or not they identified themselves as
police officers before the door was kicked in, or whether they issued a lawful warning to leave. MR.
ECHEVERRIA: Those are relevant to what issue that this panel is to determine? MR. COUGHLIN: You
listened to Richard Hill go on and on about what he thinks about me and my candor and competency. And
these videos show he's a fricking liar. Then it bears on the legitimacy of his testimony. MR. ECHEVERRIA: I
asked you to specifically address what portion of his testimony this addressed. You said everything? MR.
COUGHLIN: Yeah. MR. ECHEVERRIA: He also testified to us how long he's been practicing law. Does
this video impeach that? MR. COUGHLIN: It impeaches the extent to which putting a number of years
behind how long somebody has been practicing law somehow is determinative of anything or bearing some sort
of indication of the legitimacy or competency or fidelity to the principle that this Bar is supposed to uphold, but
which some people might say it doesn't seem as to a lot of the time. MR. ECHEVERRIA: Anything else?
MR. COUGHLIN: It also goes to mitigation, I think. MR. ECHEVERRIA: How so? MR. COUGHLIN: I
think it places me in a lot more sympathetic light to the extent that it shows police misconduct. MR.
ECHEVERRIA: Mr. King? MR. KING: Mr. Chairman, there has been a multitude of videos taken by Mr.
Coughlin. Some you might recall when he was in his bedroom in his pajamas, and he was talking about things
like Mr. Hill taking bribes. He posted information about court personnel, their salaries, et cetera. Those, all of
those YouTube, have been taken off of YouTube by Mr. Coughlin so they cannot be accessed. I have viewed
a videotape of Mr. Coughlin and the 9-1-1 calls where every other word out of his mouth is starting with F-you
to the police officers. MR. COUGHLIN: Objection. Lack of foundation. MR. KING: However, it's not
admitted in this case -- MR. ECHEVERRIA: Excuse me. Mr. Coughlin, I've tried to be very patient in terms
of your interruptions. You continue to do so. Can you find it within yourself to refrain from doing that? You will
have every opportunity to respond. But I do not appreciate your continuing interruptions of virtually every
person that speaks, including your mother. So please refrain from doing it. Proceed, Mr. King. MR. KING: In
review of some of the excerpted videos that Mr. Coughlin submitted to me, they are cut, and I don't know the
word, because I can't do it, I'm not an editor, but they're not complete, they don't show the story. And I
suspect that whatever he's going to show you would put him in a more sympathetic light, because I suspect
he's taken out all of the derogatory things he said to the police officers. More important, those were not part of
my case against Mr. Coughlin. I did not allege in the complaint that he abused the police officers, or resisted
arrest, or used profanity with the police officers. I said he was convicted of theft, convicted of criminal
trespass, and has demonstrated here a pattern of contempt for the court, and a lack of ability to practice law.
What Mr. Coughlin is attempting to do is to steer you back to whether or not he was guilty of the crimes of
which he was convicted, and to show you that perhaps somebody within the arrest process either did or didn't
follow all of their procedures, which are irrelevant to this proceeding. And so I would just say that because the
video excerpts that he intends to play are suspect, and there's nobody to testify that they're the complete or
accurate videos other than Mr. Coughlin himself. I think they're irrelevant, and in this case would be highly
prejudicial, plus a waste of time. MR. ECHEVERRIA: Anything further? MR. COUGHLIN: Your Honor, if
I could just enter for the record. Mr. Johnson's been on his smart phone throughout this proceeding. I mean
you no disrespect, sir. Maybe he doesn't feel much of a connection to what's going on here today. And I would
indicate that to the extent that this is presented as a panel, and somehow some sort of consensus thereby
suggested, I would just enter for the record, Mr. Johnson does not seem to find much of a consensus being
found here today. So much so that he's been on his smart phone throughout this proceeding. And I'm just going
notate that for the record. MR. KING: If I can respond briefly. MR. ECHEVERRIA: So far you've attacked
me. Now you've attacked Mr. Johnson. Do you wish to attack any other panel member? MR. COUGHLIN: I
do not find that I've attacked anybody, sir. I find that I've demonstrated my fidelity to fundamental notions of
due process and fair play. MR. ECHEVERRIA: Let's return to the video that you claim to have taken that
you now intend to proffer. Is it a video of your arrest that ultimately led to your conviction for criminal
trespass? MR. COUGHLIN: Not the one of the admission by Sergeant Lopez. MR. ECHEVERRIA: What
is it that you intend to play of Sergeant Lopez? MR. COUGHLIN: A video where I'm asking her some stuff
about police misconduct. MR. ECHEVERRIA: Police misconduct. That's not an issue here. MR.
COUGHLIN: Incident to the Richard Hill deal. MR. ECHEVERRIA: I'll rule it as irrelevant. Proceed. MR.
COUGHLIN: Okay. Can I play a video where, incident to t
HEARING - Vol. I, (Pages 241:14 to 243:2) MR. COUGHLIN: Okay. Can I play a video where, incident
to the Walmart conviction, it shows that I did give my driver's license to the officer, the tribal officer, and that
given that his testimony at trial was that the only reason he was allowed to effectuate an arrest was my lack of
giving him my driver's license. MR. ECHEVERRIA: That is not an issue for this panel to determine. The
supreme court specifically directed that the only issues with respect to that conviction was the nature and
extent of punishment. We're not going to relitigate your conviction for theft. MR. COUGHLIN: So the -- MR.
ECHEVERRIA: Next, Mr. Coughlin. MR. COUGHLIN: Can I enter my objection? MR. ECHEVERRIA:
Pardon? MR. COUGHLIN: Can I enter my objection or basis for my objection? MR. ECHEVERRIA:
Basis for your objection to your own? MR. COUGHLIN: Wanting to put that in an offer of proof, I guess.
Something like that. Have you read the Claiborne case? MR. ECHEVERRIA: Yes. MR. COUGHLIN:
Does that have any applicability here? MR. ECHEVERRIA: I'm governed by the case that the supreme
court decided with respect to Zachary Barker Coughlin in which they tell us that the only issue that this panel
is to determine is what the nature and extent of the punishment is flowing from your conviction for theft. We're
not to address the underlying issues involving that conviction. MR. COUGHLIN: How are you addressing so
many issues completely divorced from that Walmart theft case? How did you do that today? MR.
ECHEVERRIA: Mr. Coughlin, I'm dealing with one issue at a time. You have proffered a videotape that the
supreme court tells us is not relevant. Proceed with your next witness.
HEARING - Vol. I, (Pages 224:15 to 225:11) MR. ECHEVERRIA: However you think you need to lay a
foundation. MR. COUGHLIN: Mr. King, he can't lay the foundation? He was provided these by the muni
court. MR. ECHEVERRIA: This is your case, sir. MR. COUGHLIN: Can I call Pat King and say, Pat, were
you provided these copies of the audio? Everything is a copy, okay, it's not -- MR. ECHEVERRIA: What's
the offer of proof? What are you intending to prove? MR. COUGHLIN: To show she is so reckless. To show
a lot of things. But one, this idea that a conviction is completely dispositive, he cited no authority for that. MR.
ECHEVERRIA: Mr. Coughlin, the supreme court issued an order in your case that says with respect to, in
essence, a conviction, that the sole issue to be determined here is the nature and extent of the punishment.
MR. COUGHLIN: But that's the candy bar thing. You guys made a hearing about 30 other things.
Tennessee Bar Assn v. Berke, 48 Tenn.App. 140 (1960) 344 S.W.2d 567"This March 22,
1960, at Chambers in Cookeville, Tennessee.[1] [2] [3] The record sustains the Special
Chancellors decree and it is affirmed. However, there are two legal propositions in connection
with this appeal which we should like to discuss briefly. The first is, that it is not the rule that an
opinion of a chancellor, or of this Court, or a decree thereon, any more than a judgment of the
Circuit Court in a civil matter as distinguished from one criminal in nature, in a suit not brought
to disbar an attorney, has *147 the effect of estopping a lawyer in a subsequent disbarment
proceeding so as to prevent the introduction of any proof therein contrary to the opinion and
decree. The rule is that records,that is pleadings and proof in cases in which an attorney
appeared either as an attorney or as a partycan be offered in evidence to the extent they are
relevant to the issue of fitness to practice, but that such records and judgments are not res
judicata and do not necessarily work an estoppel in a subsequent disbarment suit.

The law on this subject is best discussed in the case of In re Santosuosso, 318 Mass. 489, 62
N.E.2d 105, 107, 161 A.L.R. 892. In that case which was an inquiry into certain alleged
misconduct of Santosuosso, an attorney, upon a petition of the Bar Association of the City of
Boston, the petitioner offered in evidence the entire printed record in the files of the clerk of
the Supreme Judicial Court for the Commonwealth of Massachusetts in a civil case in equity in
which Santosuosso had been a defendant, and the findings and order in the case. Santosuosso
objected that the evidence was not admissible under the doctrine of res adjudicata and also that
apart from the doctrine of res adjudicata, the statements made by a judge in his findings and
decree were not admissible as evidence. In holding that the paramount considerations
supporting proceedings to investigate the worthiness of members of the bar to practice law
could not be defeated by the application of strict rules of evidence governing the trial of
adversary proceedings between parties, and that the necessity for the preservation of the
integrity of the courts and the safety of the public rises above strictly technical rules of
evidence that govern such adversary proceedings between parties, the court said:
*148 We are of opinion that the evidence contained in the record offered by counsel
designated by the court to conduct the proceeding, that is, the evidence adduced at the hearing
in the Superior Court of the equity suit in question, at which the respondent, a party thereto, was
present and represented by counsel, testified and had full opportunity to present and examine
witnesses and to cross-examine those called by the plaintiff, is admissible in the present
inquiry. See State ex rel. Nebraska State Bar Assn v. Gudmundsen, [145] Neb. [324], 16
N.W.2d 474. We reach this conclusion without dependence upon such cases as Selling v.
Radford, 243 U.S. 46, 37 S.Ct. 377, 61 L.Ed. 585, Ann.Cas.1917D, 569, and Matter of Ulmer,
268 Mass. 373, 167 N.E. 749, in each of which a judgment of disbarment in another
judisdiction was held to settle the issue that the attorney in question was unfit to practice. We
are unwilling to attach such conclusive effect to a judgment at law or a final decree in equity,
based upon alleged corrupt conduct on the part of a defendant attorney, where the judgment or
final decree entered rests upon findings that the attorney has been guilty of corrupt conduct. * *
* we are of opinion that the evidence in the proceeding in equity in question is admissible in an
inquiry such as the present, and like any other evidence is to be given such weight as the single
justice shall deem proper, when considered together with all other evidence that the respondent
may produce **571 at the hearing, in the course of which he must be heard with full
opportunity to present all relevant evidence that he may wish to adduce.
*149 The foregoing view finds support in such cases as In re Lacy, 234 Mo.App. 71, 112
S.W.2d 594; In re Pate, 232 Mo.App. 478, 119 S.W.2d 11; State ex rel. Nebraska State Bar
Assn v. Gudmundsen, 145 Neb. 324, 16 N.W.2d 474; Werner v. State Bar, 24 Cal.2d 611, 150
P.2d 892, and Fairfield County Bar v. Taylor, 60 Conn. 11, 22 A. 441, 13 L.R.A. 767. See also
Matter of Becker, 229 App.Div. 62, 6566, 241 N.Y.S. 369; Id., 255 N.Y. [223] 233, 174 N.E.
461; Wigmore on Evidence, 3d ed. 4(7). In the Gudmundsen Case the court, after stating that
there had been some doubt as to the admission of evidence such as that offered in the present
proceeding, said: It is thought, however, that this question should no longer remain in doubt. It
is therefore the holding of this court that the finding in a civil action that an attorney at law has
been guilty of conduct justifying disbarment is not conclusive on the same question when
presented for determination in an action for disbarment; that notwithstanding the finding in the
civil action the culpability of the attorney must be established in the disbarment action by a
clear preponderance of the evidence. For this purpose the evidence taken at the trial of the civil
action and all other competent evidence is admissible (page 476 of 16 N.W.2d).

Other cases holding, in general, to this same effect are: In re Berkeley, 174 App.Div. 205, 160
N.Y.S. 1093; In re Bailey, 31 Ariz. 407, 254 P. 481; Fairfield County Bar v. Taylor, 60 Conn.
11, 22 A. 441; In re Durant, 80 Conn. 140, 67 A. 497; State ex rel. Nebraska State Bar
Association v. Gudmundsen, 145 Neb. 324, 16 N.W.2d 474; Metropolitan Street R. Co. v.
Oppenheim, 58 App.Div. 510, 69 N.Y.S. 524.
*150 State v. Bomer, 179 Tenn. 67, 162 S.W.2d 515, supports this view. This was a proceeding
against Bomer for his disbarment on the ground he had instituted prior disbarment proceedings
in Chancery Court against two attorneys for no just reason and without any probable cause,
being actuated by motives of personal hatred and ill will, and had thus abused the courts
process as a means of carrying out his desire for personal vengeance. Upon Bomers objection
to the introduction of the decrees of the Chancery Court in the suits which he had filed against
the two attorneys (which decrees recited the suits were without merit), our Supreme Court said
that such decrees could be received in evidence, not as conclusive proof of the charges against
Bomer, but only as evidence in the case, to show the result of the prior trials, and in that case
the recitation in the decrees that the suits were without merit, was not taken as foreclosing that
issue to Bomer and other proof in regard thereto was offered by him and heard.
[4] [5] The second proposition upon which we should like to comment is with respect to the
application of the doctrine of laches to this case. The doctrine of laches may be applicable in a
disbarment proceeding and the Special Chancellor could very well have predicated his opinion
and decree in good part thereon. The incident out of which this disbarment proceeding arose
occurred in 1950. It was fully investigated by the Chattanooga Bar Association in that year with
the result that that Association recommended that no disciplinary action be taken against Berke.
The petitioner had immediate notice of the incident and caused investigation to be made of it.
However, no court action was taken against Berke until the commencement of these
proceedings in 1959, nine years after *151 the incident. We think such long delay, unexplained
as it is in this record, coupled with proof that witnesses have died or otherwise have become
unavailable, constitutes laches (Gibsons Suits in Chancery, 5th Ed. 81) and was a ground for
**572 dismissal of the petition. In 7 C.J.S. Attorney and Client, 25b, it is stated Staleness in
a charge against an attorney may prevent its being considered, because an unreasonable delay in
the presentation of a charge of misconduct may make it impossible for an attorney to procure
the witnesses or the testimony which would have been available at an earlier time to meet such
charge. That is the condition here. The gravity of the charges demanded that they be examined
fully at the first opportunity. That this was not done does not appear to have been the fault of
Berke, who offered to appear before the petitioner and submit to an investigation. Nor, does it
appear the delay has been to his benefit but rather, strongly, to his detriment. Moreover, it
appears that in the nine year period Berke has not transgressed against the ethics or the morals
of the legal profession, but to the contrary sustains a good reputation as a lawyer. In such case,
the doctrine of laches was applicable." Tennessee Bar Assn v. Berke, 48 Tenn.App. 140
(1960) 344 S.W.2d 567
Perhaps the best example of the fraud that is Panel Chair Echeverria is his allowing Paul Elcano
to "lay a foundation" for the alleged copy of Judge L. Gardner's Order After Trial, after King got
caught lying about whether or not he had a certified copy, in comparison to Echeverria's
ridiculously over the top evidentiary rulings on anything and everything Coughlin sought to
admit, particulary where the audio transcripts of the traffic citation trial were so clearly
relevant to that which Chair Echeverria was determined to avoid having any fact finding done
one (as, clearly Echeverria was intent on skipping past the part of due process where the Panel
takes evidence and testimony as to whether Coughlin, say, violated the multitude of RPC's that
King's Complaint does not really indicate just upon what and before whom such alleged
conduct occurred (heavy on the Judges Holmes, Howard, and L. Gardner Orders as a proxy for
"conclusive proof of a "conviction" or "violation" of every RPC under the sun)). So, Echeverria,
the ol' knuckballer junk artist that he so clearly is, simply wasted everyone's time (and their
reputations) by rendering the entire hearing useless in ruling inadmissible the transcripts of the
various trials and hearings (and Coughlin provided the transcripts for all of the matters at issue,
including the dates before Judges Holmes, Howard, and L. Gardner upon which the entirety of
the non-criminal conviction aspects of King's 8/23/12 Complaint rested) for "lack of
foundation", a ruling made all the more outrageous given the treatment Echeverria gave his
"boyhood chum" Paul Elcano when King sought to have Elcano provide just such a "foundation"
for the admission of Elcano's good friend, Judge L. Gardner's, Order After Trial:
HEARING - Vol. I, (Pages 228:2 to 241:12) DIRECT EXAMINATION BY MR. COUGHLIN:
Q Mom, did you have to buy an audio of the trial with that Judge Nash Holmes? A Did I have
to buy an audio? Q Yeah. Did you buy a copy of the proceeding? A Yes. Q Did you give it to
me? A Oh, God. I think so. I did several things. I paid $100 for something -- no, that was
something else. Q Right. You paid a hundred dollars for bail, and she wouldn't let me out, but
she kept the money anyway? A Yes. And the man that I gave the money to told me that you
would be released within several hours, and you weren't. Q They did the old switcheroo, right?
A I'm sorry? MR. ECHEVERRIA: Mr. Coughlin, I would appreciate it if you would refrain
from interrupting even your own mother. THE WITNESS: Especially his own mother. MR.
COUGHLIN: Is that good enough? MR. ECHEVERRIA: No. BY MR. COUGHLIN: Q Mom,
was it an official copy? A I don't know. Q Did you go to the court and say I want a copy of the
proceeding, and you paid the money they asked you to pay? A I don't know that it was official
or not. But I requested a copy, yes. I would assume it would be official. I was requesting it in
the courthouse. Q And you filled out whatever form it was they made you fill out, and paid
whatever money it was they wanted right? A Yes. MR. COUGHLIN: I would like to move to
admit that into evidence. MR. ECHEVERRIA: Do you have any further questions? BY MR.
COUGHLIN: Q Mom, you paid $100 bail, and the muni court kept the money but didn't let me
out? A Yes. Q What did that Tom guy, the counter clerk, say about that? A When I went back
on Monday, he said, no, he should have been released. And I said, well, he wasn't, and I would
like to get my money back. And he made a phone call. And he said, I'm sorry, but that's not
possible. Q Did he say that she had done something wrong? A No. No, he didn't say anything
to me like that. He just said it was not what he expected. When I went down there and paid the
hundred dollars, he said you would be out within three hours. And that didn't happen. And I
believe that was on a Thursday. The courts were closed Friday, so I went back on Monday to
find out why you weren't released, and to see if I could get my hundred dollars back. Q Did my
dad say the State Bar of Nevada's Coe Swobe kept hounding him, calling him up, trying to lean
on me so Washoe Legal Services and Paul Elcano could get out -- A I'm sorry, I could not hear
that. Q Did my dad ever tell you that the State Bar of Nevada's Coe Swobe called him up trying
to get him to make me settle easier with Washoe Legal Services whose director is friends with
the chairman here, close childhood friends, they both went to Stanford together, 1966? MR.
KING: Objection, hearsay. THE WITNESS: Your father told me -- MR. ECHEVERRIA:
Sustained. THE WITNESS: -- yes, they wanted you to settle. MR. ECHEVERRIA: Excuse me,
Ms. Barker. There was an objection made to the question. I'm sustaining the objection. It's also
argumentative. MR. COUGHLIN: Mom. I don't want to take up any more of your time,
sweetheart. You have better things to do. I'm going to let you go. Okay? THE WITNESS: All
right. Sorry this wasn't clear, but now I'm in the parking lot. MR. COUGHLIN: You're the
clearest thing I've heard today, Mom. THE WITNESS: Good luck. MR. ECHEVERRIA: Any
questions, Mr. King? Well, she hung up. MR. KING: I have no questions of the mother, but I
would think it was patently clear when the direct question was, did you give me the official
copies, she said I don't know. And that's how it was left. And Mr. Coughlin does not have the
official copies which would be identified on the disk by the court as an official copy. Since he
does not have them or they are -- whatever he has downloaded on the record may not be the
official one, I would still object. Plus, as I said before, since he's attempting to prove negatives
that this wasn't said, this wasn't done. Without the ability to read the transcript or see on either
side the context of listening to a little blurb totally out of context is going to provide no
relevant information to you, because there's no way you can say with a certainty that's the end of
the story. Because elsewhere in the transcript it could be made crystal clear. I would suggest
that Mr. Coughlin's efforts to have you listen to excerpts, aside from being very time-
consuming, is irrelevant. MR. ECHEVERRIA: Anything further to offer in terms of laying a
foundation? MR. COUGHLIN: Penalty of perjury, I'm going to play an official copy of it. MR.
ECHEVERRIA: No. MR. COUGHLIN: I've given you the opportunity to go review the stuff to
your heart's content if I'm lying. MR. ECHEVERRIA: Playing it doesn't lay a foundation. We
need a foundation laid. MR. COUGHLIN: Foundation is -- MR. ECHEVERRIA: Do you have
anything further to offer? MR. COUGHLIN: -- I, Zach Coughlin, under penalty of perjury, this
is the official transcript, audio transcript. MR. ECHEVERRIA: What do you base that on? MR.
COUGHLIN: That the court gave it to us. MR. ECHEVERRIA: No, the court didn't. MR.
COUGHLIN: This is just amazing. Okay. Let's move on. MR. ECHEVERRIA: We need to
comply -- MR. COUGHLIN: I would like to play a video I can provide a foundation of, because
I filmed it. MR. ECHEVERRIA: We're dealing with whatever it was you were going to proffer
with respect to the traffic citation. MR. COUGHLIN: We have eaten up 40 percent of my time
with this. You wouldn't let me play a copy of an audio tape that I paid money for from the court.
MR. ECHEVERRIA: But you haven't laid a foundation for it, Mr. Coughlin. That's what you
don't understand. Your mother said she went and bought something. She doesn't know if it's an
official transcript. You didn't establish whether she gave it to you or not -- MR. COUGHLIN: I
got an official one from Pat King. MR. ECHEVERRIA: More important, sir, you haven't
established what you're about to play is what she bought. MR. COUGHLIN: If we just move on
from hers. I got an official copy from Pat King after we paid for it with our money -- MR.
ECHEVERRIA: That's not a foundation, sir. MR. COUGHLIN: I'm saying I got it from the
State Bar of Nevada. Directly from Pat King. MR. ECHEVERRIA: That's not a foundation. MR.
COUGHLIN: In that Mr. King told me it's an official copy from the Reno Muni Court. MR.
KING: Absolutely not true, Mr. Coughlin -- MR. COUGHLIN: You are testifying now, Pat. I'd
like him sworn if he's going to testify. MR. KING: I'd be happy to be sworn. And that's a lie.
MR. ECHEVERRIA: Mr. Coughlin, laying a foundation is a rather rudimentary procedure. MR.
KING: Sorry. MR. ECHEVERRIA: I do not believe you have laid a proper foundation -- MR.
COUGHLIN: I'll move on. MR. ECHEVERRIA: -- proper to play. So I'm sustaining the
objection to playing whatever it was you're going to play, and proceed. MR. COUGHLIN:
Okay. I'd like to play an official copy of the transcript from that Reno Muni Court traffic
citation case. MR. ECHEVERRIA: You've already proffered that. I've sustained the objection.
MR. COUGHLIN: I'd like to play a copy of a video I took of Sergeant Lopez admitting certain
things with respect to the criminal trespass. MR. ECHEVERRIA: Mr. King? MR. KING: I
would object to the extent that Mr. Coughlin is trying to suggest in any way that he wasn't guilty
of the criminal trespass, because he was convicted and exhausted his appeal rights. And to retry
that I think shouldn't occur here. MR. ECHEVERRIA: The relevance of this -- MR. KING: To
the effect he wants to produce it for some other reason, I think he would need to explain
specifically what that reason is. If it goes to whether or not he's guilty of a criminal trespass, I
would say it's not relevant. MR. ECHEVERRIA: And your relevance, Mr. Coughlin? MR.
COUGHLIN: I would like to give you the 30-minute notice that I would like to cross-examine
Judge Nash Holmes and Richard Hill or call them in my case in chief, rather. I'll do that now. I
note that I have a time of 2:55. MR. ECHEVERRIA: Right now we're dealing with the relevancy
of a videotape that you claim to have taken. And how is that relevant? MR. COUGHLIN:
Because it goes to rebut everything that you deem relevant to which Richard Hill testified. MR.
ECHEVERRIA: Everything? MR. COUGHLIN: Yeah. MR. ECHEVERRIA: What is contained
in this proffered video? MR. COUGHLIN: There's a couple of them. There's video of the
arrest, the trespass arrest. The discussion between myself and Richard Hill, and his client, and
the police officers. Then -- and that was -- and then there is a video of a couple months later of
me interviewing Sergeant Lopez about whether or not they identified themselves as police
officers before the door was kicked in, or whether they issued a lawful warning to leave. MR.
ECHEVERRIA: Those are relevant to what issue that this panel is to determine? MR.
COUGHLIN: You listened to Richard Hill go on and on about what he thinks about me and my
candor and competency. And these videos show he's a fricking liar. Then it bears on the
legitimacy of his testimony. MR. ECHEVERRIA: I asked you to specifically address what
portion of his testimony this addressed. You said everything? MR. COUGHLIN: Yeah. MR.
ECHEVERRIA: He also testified to us how long he's been practicing law. Does this video
impeach that? MR. COUGHLIN: It impeaches the extent to which putting a number of years
behind how long somebody has been practicing law somehow is determinative of anything or
bearing some sort of indication of the legitimacy or competency or fidelity to the principle that
this Bar is supposed to uphold, but which some people might say it doesn't seem as to a lot of
the time. MR. ECHEVERRIA: Anything else? MR. COUGHLIN: It also goes to mitigation, I
think. MR. ECHEVERRIA: How so? MR. COUGHLIN: I think it places me in a lot more
sympathetic light to the extent that it shows police misconduct. MR. ECHEVERRIA: Mr.
King? MR. KING: Mr. Chairman, there has been a multitude of videos taken by Mr. Coughlin.
Some you might recall when he was in his bedroom in his pajamas, and he was talking about
things like Mr. Hill taking bribes. He posted information about court personnel, their salaries,
et cetera. Those, all of those YouTube, have been taken off of YouTube by Mr. Coughlin so they
cannot be accessed. I have viewed a videotape of Mr. Coughlin and the 9-1-1 calls where every
other word out of his mouth is starting with F-you to the police officers. MR. COUGHLIN:
Objection. Lack of foundation. MR. KING: However, it's not admitted in this case -- MR.
ECHEVERRIA: Excuse me. Mr. Coughlin, I've tried to be very patient in terms of your
interruptions. You continue to do so. Can you find it within yourself to refrain from doing that?
You will have every opportunity to respond. But I do not appreciate your continuing
interruptions of virtually every person that speaks, including your mother. So please refrain
from doing it. Proceed, Mr. King. MR. KING: In review of some of the excerpted videos that
Mr. Coughlin submitted to me, they are cut, and I don't know the word, because I can't do it, I'm
not an editor, but they're not complete, they don't show the story. And I suspect that whatever
he's going to show you would put him in a more sympathetic light, because I suspect he's taken
out all of the derogatory things he said to the police officers. More important, those were not
part of my case against Mr. Coughlin. I did not allege in the complaint that he abused the police
officers, or resisted arrest, or used profanity with the police officers. I said he was convicted of
theft, convicted of criminal trespass, and has demonstrated here a pattern of contempt for the
court, and a lack of ability to practice law. What Mr. Coughlin is attempting to do is to steer
you back to whether or not he was guilty of the crimes of which he was convicted, and to show
you that perhaps somebody within the arrest process either did or didn't follow all of their
procedures, which are irrelevant to this proceeding. And so I would just say that because the
video excerpts that he intends to play are suspect, and there's nobody to testify that they're the
complete or accurate videos other than Mr. Coughlin himself. I think they're irrelevant, and in
this case would be highly prejudicial, plus a waste of time. MR. ECHEVERRIA: Anything
further? MR. COUGHLIN: Your Honor, if I could just enter for the record. Mr. Johnson's been
on his smart phone throughout this proceeding. I mean you no disrespect, sir. Maybe he doesn't
feel much of a connection to what's going on here today. And I would indicate that to the extent
that this is presented as a panel, and somehow some sort of consensus thereby suggested, I
would just enter for the record, Mr. Johnson does not seem to find much of a consensus being
found here today. So much so that he's been on his smart phone throughout this proceeding.
And I'm just going notate that for the record. MR. KING: If I can respond briefly. MR.
ECHEVERRIA: So far you've attacked me. Now you've attacked Mr. Johnson. Do you wish to
attack any other panel member? MR. COUGHLIN: I do not find that I've attacked anybody, sir. I
find that I've demonstrated my fidelity to fundamental notions of due process and fair play. MR.
ECHEVERRIA: Let's return to the video that you claim to have taken that you now intend to
proffer. Is it a video of your arrest that ultimately led to your conviction for criminal trespass?
MR. COUGHLIN: Not the one of the admission by Sergeant Lopez. MR. ECHEVERRIA:
What is it that you intend to play of Sergeant Lopez? MR. COUGHLIN: A video where I'm
asking her some stuff about police misconduct. MR. ECHEVERRIA: Police misconduct. That's
not an issue here. MR. COUGHLIN: Incident to the Richard Hill deal. HEARING - Vol. I,
(Page 241:12 to 241:13) MR. ECHEVERRIA: I'll rule it as irrelevant. Proceed."
Now compare the "boyhood chum" treatment given to Elcano:
HEARING - Vol. I, (Pages 112:8 to 116:21) And Mr. Coughlin is not stupid. So I took that in
large part to be a competency issue. MR. KING: I very much appreciate your testimony and
candor. I'll pass the witness. MR. ECHEVERRIA: Thank you, Mr. King. Mr. Coughlin, it's now
11:31. You have 15 minutes. MR. COUGHLIN: Yes, sir. Thank you. MR. KING: I apologize. I
meant to have this admitted. Did I lay a proper foundation? I would move for Exhibit 3 to be
admitted. MR. ECHEVERRIA: Any objection now, sir? MR. COUGHLIN: I didn't hear the
foundation. I'm sorry. MR. ECHEVERRIA: The foundation was Mr. Elcano attended the
hearing, reviewed this order, and determined it to be -- This is a true and correct copy of the
order that you looked at following the hearing? THE WITNESS: Yes. The one that was
transmitted to us by the judge. MR. COUGHLIN: Transmitted just by the judge? THE
WITNESS: We have a copy of it in our file. MR. COUGHLIN: Transmitted to you? THE
WITNESS: Washoe Legal Services. I checked it with my order. It appears to be the same order.
MR. COUGHLIN: But you're not saying how it was transmitted to the State Bar? MR.
ECHEVERRIA: I'm interested in how it was transmitted. I'm interested in if this is a true and
correct copy of the order issued by Judge Gardner in the Joshi case -- MR. COUGHLIN: You
mentioned he attended trial. He didn't attend the trial. MR. KING: He said he -- MR.
COUGHLIN: You said he attended the trial. But he didn't attend the trial. MR. ECHEVERRIA:
Mr. Elcano testified he attended the hearing. THE WITNESS: No, I reviewed the tape of the
hearing. I wasn't at the hearing. But in the family court they are on tape. MR. ECHEVERRIA:
I'm focused on whether or not this is a true and correct copy of the order issued by Judge
Gardner. And have you determined this to be the true and correct copy? THE WITNESS: Yes.
It's the order I relied on. MR. ECHEVERRIA: It will be admitted. (Exhibit 3 admitted.) MR.
ECHEVERRIA: Go ahead, Mr. Coughlin. MR. COUGHLIN: One thing, your Honor, with
respect to the received stamp on it. That's something that was on the order. MR.
ECHEVERRIA: Pardon me? MR. COUGHLIN: See the received? MR. ECHEVERRIA: Right.
MR. COUGHLIN: That's State Bar. MR. ECHEVERRIA: Right. MR. COUGHLIN: Put that
there. MR. ECHEVERRIA: Right. MR. COUGHLIN: So it's not really a copy of the order. It
has something that was not on the order. MR. ECHEVERRIA: Okay. Overruled. Is that your
objection? MR. COUGHLIN: It has a funny 5 on it. It's one day after Judge Gardner submitted
hers. It seems kind of funny, like ghost reading is going on, because we don't know who
submitted this. Who submitted it, Pat? MR. VELLIS: Mr. Elcano, do you have another copy of
the order that you received from the court after the hearing that you compared this one to? I
think you said you did? THE WITNESS: I compared it to it. Mine has two blank spots in it
though, two short areas, but otherwise they seem to be verbatim and end on the same pages.
MR. VELLIS: Is there a stamp from the State Bar on the one that you got from the court? MR.
COUGHLIN: You didn't get this from Joey or Gina Hastings -- MR. ECHEVERRIA: Mr.
Coughlin, I'm not going to permit questions among the attorneys. That's improper. MR.
COUGHLIN: Yes, sir. MR. ECHEVERRIA: So if you have a question, you need to address it
to the panel. MR. COUGHLIN: It's improper to say it's certified when it's not. THE WITNESS:
The copy I reviewed is filed electronically by Howard Conyers, the clerk of the court. MR.
VELLIS: And there's no stamp from the State Bar on the one that you reviewed? THE
WITNESS: No. MR. VELLIS: That's the one you received from the court? THE WITNESS:
Yes. MR. VELLIS: And that one is the same as the one that's been admitted, Exhibit 3? THE
WITNESS: Save and except two blank spots that are the fault of the copier. MR.
ECHEVERRIA: Mr. Coughlin, it's admitted. Proceed. MR. COUGHLIN: Yes. Thank you.
CROSS-EXAMINATION BY MR. COUGHLIN: Q Mr. Elcano, did you tell me when I was
working at Washoe -- I'll say Washoe for short -- and I'll say I like Mr. Elcano a great deal. I
respect him a lot. I do. MR. ECHEVERRIA: I'm not interested in your side issues. If you have a
question of Mr. Elcano, please ask him. MR. COUGHLIN: Okay."
From: PatrickK@nvbar.org
To: zachcoughlin@hotmail.com
Subject: RE: my attempt to be provided access to the grievances filed today
Date: Mon, 2 Apr 2012 22:59:08 +0000

Dear Mr. Coughlin,

I have opened 3 disciplinary files against you. They are identified by number
below:

NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill

NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes

NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner

You have received the grievance from Mr. Hill and also the grievance from Judge
Holmes. The Grievance from Judge Gardner relates to her Order After
Trial in the case of Ashwin Joshi v Barti Joshi, Case Number DV08-01168,
wherein she describes your conduct at pages 12 and 13. I have received
certified copies of the contempt orders, a certified copy of the conviction at Wal-
Mart, and an incident report from Marshals Thompson and Coppa regarding your
conduct on March 22, 2012. I also have the recordings of the court proceedings at
issue.

At this time, I do not expect to be providing you with any additional information.
If you have additional information that you want me to be made aware of in
response to the grievances identified above please feel free to mail them to me.

Sincerely,

Patrick King, Assistant Bar Counsel




From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, April 02, 2012 2:39 PM
To: Patrick King
Subject: RE: my attempt to be provided access to the grievances filed today

Mr. King,
I need for basic procedural due process protections to be afforded before any
consideration of any arrangement you have in mind would be appropriate. It is my
understanding that we are still in the stage of the process where you are providing
me indication of the allegations against me and documentation in support and
explanation thereof, and that there is still additional materials and complaints
which you have so far chosen not to allow me access to, even to view upon my
responding to your stipulation that I could only so view such materials upon
visiting the Reno office of the State Bar of Nevada in person. Such as, please
answer the questions I have posed you in my recent emails, especially with regard
to providing copies of and information related to these "other different judges"
supposedly submitting written complaints about me to you. Further, please
explain whether you requested materials from Judge Nash Holmes, as her letter to
you appears to indicate, in her statements that she "apologizes for taking two days
to get these materials to you" that you requested such materials rather than she
sending them to you on her own accord? Please explain.
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax:
949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473