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http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence Dear Filing Officer Unit Manager Purdy,
I respectfully submit this to you in connection with the eFlex rejection noted in the subject line.
Judge Flanagan awarded against me five stacks one time for making the argument that the opposing sides listing the wrong court name or case number in the caption had some legally operative effect sufficient to support a nrcp 59 or 60 motion.
And, again, WCDR 18 specifically provides that WDCR 10 does not apply. If your position is that a "criminal appeal" is not a "criminal case", please explain how such is not making a discretionary, beyond ministerial decision in your official capacity. A "criminal appeal" has a "case" number. A number which is identified as "criminal" via the "CR" designation therein.
WDCR Rule 18. Papers which do not comply with rules. Except in criminal cases and writs arising from criminal cases, filing office personnel shall refuse to file any document or pleading which is not properly signed by all persons, or which does not comply with these rules, Nevada Rules of Civil Procedure, the District Court Rules, or applicable statutes.
http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence
Extremely suspect is the NNDB Panel and Bar's steering well clear of the 8/21/12 Order by Judge Flanagan in CV08-01709 that Coughlin references in his own DoWSoE, or 10/31/12 Designation of Witnesses, Summary of Evidence, where, at page 2 thereof such reads:
“"17. Kevin Kelly, strip club ownin' Character and Fitness Committee Chairman is expected to testify regarding the imperissible matters related to Peter Christiansen's "representation" of Coughlin between 2002-2005.
18. Mike Rowe, ditto what Kelly will to . Dear D10 Judge Elliot, Judge Flanagan, and the Second Judicial District Court Clerk of Court Joey Orduna Hasitings, WDC Custodian of Records, Associate Clerk of Court Julie Wise: Included in the relevant materials and information sought is the legal basis for incarcerating in Cr12- 0376 (despite DDA Young violating NRS 178.405’S mandatory stay, in his moving for a “Motion for Revocation of Bail” (despite WDCR 19 requiring a hearing be set, Coughlin never got one in cr11- 2064, nor in cr12-1262 (both Judge Elliot appeals involving pro se Coughlin, nor did Coughlin get a hearing in cv11-03628, well, there was two hearings on Hill’s fraudulent Motion for Order to Show cause, but that it not what wdcr 19 is invoking)Coughlin between april 19th, 2012 to April 26, 2012 (during which time the $40,050 attorneys fees motion resulting in an Order awarding it in CV11- 03628 was filed) for appealing a summary eviction as a pro se tenant ,apparently deemed residential tenant with rnet of less than $1K a month) also, despite Chief Civil Clerk constantly rejecting Coughlin’s filign under wdcr 10, Coughlin was actually sanctioned yet another $5K by his former coworker , Judge Flanagan (whom declined to recuse himself form the order to show cause hearings despite, arguably, Coughlin requeting as much, in violation of nrs 22.030(3)… But RCS/QLS in the Carpentier v Aames case (that Richard hill copied Coughlin’s January 13th, 2012 filing on in cv08-01709 in hills 1/24/12 grievance to bar counsel against Coughlin…which Coughlin was subject to custodial arrest for jaywalking by rpd and hill on 1/12/12, and another arrest for “misuse of 911” on 1/14/12, (- 2/6 - coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE) Seemingly connected to filing in carpentier matter of 1/13/12… violated WDCR 18 and 38 Rule .Caption for all pleadings and other legal documents. Every document submitted 1. For filing in the family division shall bear the following caption: “IN THE FAMILY DIVISION OF THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA I
Titre original
10 31 12 0204 Email to SBN President Flaherty Filing Complaint Against Bar Counsel FW Character and Fitness
http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence Dear Filing Officer Unit Manager Purdy,
I respectfully submit this to you in connection with the eFlex rejection noted in the subject line.
Judge Flanagan awarded against me five stacks one time for making the argument that the opposing sides listing the wrong court name or case number in the caption had some legally operative effect sufficient to support a nrcp 59 or 60 motion.
And, again, WCDR 18 specifically provides that WDCR 10 does not apply. If your position is that a "criminal appeal" is not a "criminal case", please explain how such is not making a discretionary, beyond ministerial decision in your official capacity. A "criminal appeal" has a "case" number. A number which is identified as "criminal" via the "CR" designation therein.
WDCR Rule 18. Papers which do not comply with rules. Except in criminal cases and writs arising from criminal cases, filing office personnel shall refuse to file any document or pleading which is not properly signed by all persons, or which does not comply with these rules, Nevada Rules of Civil Procedure, the District Court Rules, or applicable statutes.
http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence
Extremely suspect is the NNDB Panel and Bar's steering well clear of the 8/21/12 Order by Judge Flanagan in CV08-01709 that Coughlin references in his own DoWSoE, or 10/31/12 Designation of Witnesses, Summary of Evidence, where, at page 2 thereof such reads:
“"17. Kevin Kelly, strip club ownin' Character and Fitness Committee Chairman is expected to testify regarding the imperissible matters related to Peter Christiansen's "representation" of Coughlin between 2002-2005.
18. Mike Rowe, ditto what Kelly will to . Dear D10 Judge Elliot, Judge Flanagan, and the Second Judicial District Court Clerk of Court Joey Orduna Hasitings, WDC Custodian of Records, Associate Clerk of Court Julie Wise: Included in the relevant materials and information sought is the legal basis for incarcerating in Cr12- 0376 (despite DDA Young violating NRS 178.405’S mandatory stay, in his moving for a “Motion for Revocation of Bail” (despite WDCR 19 requiring a hearing be set, Coughlin never got one in cr11- 2064, nor in cr12-1262 (both Judge Elliot appeals involving pro se Coughlin, nor did Coughlin get a hearing in cv11-03628, well, there was two hearings on Hill’s fraudulent Motion for Order to Show cause, but that it not what wdcr 19 is invoking)Coughlin between april 19th, 2012 to April 26, 2012 (during which time the $40,050 attorneys fees motion resulting in an Order awarding it in CV11- 03628 was filed) for appealing a summary eviction as a pro se tenant ,apparently deemed residential tenant with rnet of less than $1K a month) also, despite Chief Civil Clerk constantly rejecting Coughlin’s filign under wdcr 10, Coughlin was actually sanctioned yet another $5K by his former coworker , Judge Flanagan (whom declined to recuse himself form the order to show cause hearings despite, arguably, Coughlin requeting as much, in violation of nrs 22.030(3)… But RCS/QLS in the Carpentier v Aames case (that Richard hill copied Coughlin’s January 13th, 2012 filing on in cv08-01709 in hills 1/24/12 grievance to bar counsel against Coughlin…which Coughlin was subject to custodial arrest for jaywalking by rpd and hill on 1/12/12, and another arrest for “misuse of 911” on 1/14/12, (- 2/6 - coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE) Seemingly connected to filing in carpentier matter of 1/13/12… violated WDCR 18 and 38 Rule .Caption for all pleadings and other legal documents. Every document submitted 1. For filing in the family division shall bear the following caption: “IN THE FAMILY DIVISION OF THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA I
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Formats disponibles
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http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence Dear Filing Officer Unit Manager Purdy,
I respectfully submit this to you in connection with the eFlex rejection noted in the subject line.
Judge Flanagan awarded against me five stacks one time for making the argument that the opposing sides listing the wrong court name or case number in the caption had some legally operative effect sufficient to support a nrcp 59 or 60 motion.
And, again, WCDR 18 specifically provides that WDCR 10 does not apply. If your position is that a "criminal appeal" is not a "criminal case", please explain how such is not making a discretionary, beyond ministerial decision in your official capacity. A "criminal appeal" has a "case" number. A number which is identified as "criminal" via the "CR" designation therein.
WDCR Rule 18. Papers which do not comply with rules. Except in criminal cases and writs arising from criminal cases, filing office personnel shall refuse to file any document or pleading which is not properly signed by all persons, or which does not comply with these rules, Nevada Rules of Civil Procedure, the District Court Rules, or applicable statutes.
http://www.scribd.com/doc/168734000/10-31-12-0204-62337-Coughlin-s-DoWSoE-Designation-Witnesses-Summary-Evidence
Extremely suspect is the NNDB Panel and Bar's steering well clear of the 8/21/12 Order by Judge Flanagan in CV08-01709 that Coughlin references in his own DoWSoE, or 10/31/12 Designation of Witnesses, Summary of Evidence, where, at page 2 thereof such reads:
“"17. Kevin Kelly, strip club ownin' Character and Fitness Committee Chairman is expected to testify regarding the imperissible matters related to Peter Christiansen's "representation" of Coughlin between 2002-2005.
18. Mike Rowe, ditto what Kelly will to . Dear D10 Judge Elliot, Judge Flanagan, and the Second Judicial District Court Clerk of Court Joey Orduna Hasitings, WDC Custodian of Records, Associate Clerk of Court Julie Wise: Included in the relevant materials and information sought is the legal basis for incarcerating in Cr12- 0376 (despite DDA Young violating NRS 178.405’S mandatory stay, in his moving for a “Motion for Revocation of Bail” (despite WDCR 19 requiring a hearing be set, Coughlin never got one in cr11- 2064, nor in cr12-1262 (both Judge Elliot appeals involving pro se Coughlin, nor did Coughlin get a hearing in cv11-03628, well, there was two hearings on Hill’s fraudulent Motion for Order to Show cause, but that it not what wdcr 19 is invoking)Coughlin between april 19th, 2012 to April 26, 2012 (during which time the $40,050 attorneys fees motion resulting in an Order awarding it in CV11- 03628 was filed) for appealing a summary eviction as a pro se tenant ,apparently deemed residential tenant with rnet of less than $1K a month) also, despite Chief Civil Clerk constantly rejecting Coughlin’s filign under wdcr 10, Coughlin was actually sanctioned yet another $5K by his former coworker , Judge Flanagan (whom declined to recuse himself form the order to show cause hearings despite, arguably, Coughlin requeting as much, in violation of nrs 22.030(3)… But RCS/QLS in the Carpentier v Aames case (that Richard hill copied Coughlin’s January 13th, 2012 filing on in cv08-01709 in hills 1/24/12 grievance to bar counsel against Coughlin…which Coughlin was subject to custodial arrest for jaywalking by rpd and hill on 1/12/12, and another arrest for “misuse of 911” on 1/14/12, (- 2/6 - coughlin's DESIGNATION OF WITNESSES AND SUMMARY OF EVIDENCE) Seemingly connected to filing in carpentier matter of 1/13/12… violated WDCR 18 and 38 Rule .Caption for all pleadings and other legal documents. Every document submitted 1. For filing in the family division shall bear the following caption: “IN THE FAMILY DIVISION OF THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA I
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Téléchargez comme PDF, TXT ou lisez en ligne sur Scribd
Christiansen, Patrice Eichman From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Wed 10/31/12 12:57 PM To: fflaherty@dlpfd.com (fflaherty@dlpfd.com) 1 attachment combined collection of materials for State Bar of Nevada Grievance against Peter Christiansen, Kevin Kelly, Michael Sanft, Patrice Eichman, etc adobe 4 and later grey revised to be smaller.pdf (10.8 MB) Dear President Flaherty, Can I get a case number for this matter, I have not heard anything about it in forever. I also, I would like to file a grievance or Complaint against Bar Counsel Pat King and NNDB Chairman Susich for failing to follow the June 7th, 2012 Order of the Nevada Supreme Court and SCR 111(7)-(8), in addition to SCR 102(4)(d). Under the Ching or Chang decision, the SBN is the "complainant" and wit respect to these matters, wherein I allege misconduct by Peter Christiansen, Character and Fitness Chairman Kevin Kelly, Esq. and others, the SBN has not known about these matters for more than 4 years. Further, King refuses to undertake any investigation against Richard G. Hill, Esq., Judge Nash Holmes, Casey Baker, any of the RMC "court appointed defenders" (like Loomis, Puentes, Taitel, Sotelo) or WCPD's Leslie, Goodnight, Dogan, or Bosler. Now, King is trying to jam me into a combo hearing on November 14th, 2012 in his ng12-0205 ng12-0434, and ng12-0434 scr 105 complaint, which impermissilby seeks to skirt scr 111(7)-(8) vis a vis King's SCR 111 petition in 60838 (please see my filings in that regard). Furhter, the "courthouse sanctuary" rule makes the RMC Marshal Harley's conduct in personally serving me notice of an Order to Show Cause Hearing in the appeal of the eviction matter in cv11-03628 (Richard HIll got me evicted from my former home law office) on behalf of WCSO Deputy Machen (whom HIll hired to serve it despit the Caplow decision making clear that is not even required...basically, its wrong to have the RMC Marshal barge in to my plea bargaining session with city attorney ormaas on february 27th, 2012 incident to the traffic citations in 11 tr 26800 that the rpd gave me at hill's office when I went to get my wallet, key's, drivers license, and client's files from hill after being released from a fraudulent custodial arrest for criminal trespass at my former home law office in a criminal complaint signed by hill, judge nash holmes held that 11 tr 26800 trial later that day, despite her apparent admission that she was made aware by the wcpd and or wcpd biray dogan that an order for competency evaluation had been entered respecting me on 2/27/12 at 1:31 pm and nrs 178.405 and nrs 5.010 shoudl have prevented judge nash holmes from holding that trial, and In re Oliver (us supreme court case requiring sixth amendment right to council in cases like 11 tr 26800 where Judge Nash Holmes convicted me of "summary criminal contempt" despite her order resting upon alleged conduct outside her presence, in a bathroom stall that she alleged in her 3/ 12/12 hearing in that matter an RMC Marshall witnessed by peering through a bathroom stall I was in where "dissassemblign a smartphone" or some nonsense like that peeping tom crap...RMC Harley was serving an Order to Show Cause on behalf of WCSO Deputy Machen (who didn't want to wait around to serve me it....just like on 11/1/11 when machen didn't want to follow the law in serving me the eviction order, and instead filed a false affidavit attesting to personal service, then conducted a lockout using a stale or invalid eviction order when I was not present, only to attest to having "personally served" me.. This is a mess, the SBN doesn't have jack on me (give me my hearing under the court's 6/7/12 order for the "sole purpose" of determingin my punishment over the "walmart candy bar" petty larceny conviction, which I completely showed to lack due process (dismissing appeals for failure to cite to a transcript where the rmc is breaking the law in not preparing the transcript? i proved perjury by all the city's witnesses, and prosecutorial misconduct, clearly)....then the criminal trespass conviction is so flawed its unbelievably. the judge was the brother of the family court judge garnder who got me fired from washoe legal services, and the brother passed her sanction order to judge nash holmes who passes it to the sbn, and it becomes ng12-0435, but sbn king doesn't want to admit that that is how he got it? and the brother judge gardner refuses to recuse himself from that criminal trespass case rmc 11 cr 26405, despit my filing mandamus against his sister's order in 54844 and despite his sister's order being a bar grievance against me, submitted by judge holmes, on behalf of the brother judge gardner and all the other rmc judges? and the rmc "loses" my n otice of appeal an it gets dismissed in cr12-1262 by the same judge elliot of d10 whom put me in jail between 4/19 and 4/26/12 impermissibly based upon lies by the competency evaluators and a motion by dda young that violated nrs 178.405's mandatory stay? and during that incarceration richard hill's $40k attorneys fees motion against me in the eviction cv11-03628 is filed, which flanagan ultimately awarded? the sbn is gambling a large chunk of yours and its reputation on a bunch of asinine arrest by the rpd, and extremely suspect co-signing of richard hill's bullshit this year by people who should know better. 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; davidc@nvbar.org; glennm@nvbar.org Subject: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman Date: Fri, 16 Mar 2012 13:48:17 -0700 Dear Bar Counsel, I write respectfully asking an inquiry be conducted into whether Kevin Kelly indicated at my June 2002 hearing that 3 pro bono attorney's name would be provided to me, but that only one was, Peter S. Christiansen, and that, despite Christiansen saying he was doing my case on a pro bono basis, he was paid at least $5,000, and pretty much the only work he or his office did was attend the June 2002 hearing, and that Christiansen and Kelly are very, very close, and that they sent me to a psychologist who specializes in gambling addictions (I have never really even gambled) who cost approximately another $2,000....Then Ms. Eichman failed to submit my application for admission or my Request For Reconsideration (sent to her and Christiansen's office on September 15th, 2003, as confirmed by my fax records, in additional to being mailed to them) to the Nevada Supreme Court. There are numerous other issues that deserve a grievance there, including whether Christiansen supervised the newly licensed Sanft in any way, whether a writing wherein I addressed alcoholism was forward to the Bar despite the express dictate that it not be, whether second Consent Agreement sent to the Christiasens on 9/27/04 was ever forwarded to the Bar. Additionally, Mike Rowe wrote very stern letters to me basically telling me not to follow up on things, whereupon my attorney's and Ms. Eichman failed to follow up on things, essentially tying my hands in the matter. I intend to supplement this grievance with additional matters soon, but wish it to begin now. Sincerely, Zach Coughlin Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
10 31 13 72675 Motion To Strike Sentencing and Remand Etc Plus Voxox Proof of Service Fax On WCDA Z Young and Stege 65630 63341 71437 72675 and Wastts in 599 607
10 31 13 72675 65630 63341 71437 607 599 Filing and Voxox Fax Proof With 4 4 13 Fax Header's Motion To Strike Remand and Sentencing Memor and Extension of Time Sought Appt of Counsel Etc. Vacate Epo
10 24 13 72675 Printed Notice of WCDA's Attempt To Remand Coughlin and Revoke Two Probations and Addendum To Post-Trial Motions Stamped With Ex 1 Opt A9 Printed
10 31 13 72675 Motion To Strike Sentencing and Remand Etc Plus Voxox Proof of Service Fax On WCDA Z Young and Stege 65630 63341 71437 72675 and Wastts in 599 607