12 6 12 0204 62337 63341 ROA in CR12-2025 804 Pages Filed by RJC With 2JDC Ocr XP

Code 3700
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

IN AND FOR THE COUNTY OF WASHOE
8
9
ZACHARY BARKER COUGHLIN, .
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Case No.
Plaintiff,
Dept. No., 'II)
vs.
THE STATE OF NEVADA,
Defendant.
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~+-'~~I'\:l
PROCEEDINGS
In the Justice Court of Reno Township, County of Washoe

State of Nevada
ZACHARY BARKER COUGHLIN,
Appellant,
vs.
The State of Nevada,
Respondent.
APPEAL
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
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27.
Case No.: RCR 2011-063341

Complaint of: Zach Young
Charging: COUNT I PETIT LARCENY, a
violation ofWCC 53.160 and 125.050;
COUNT II POSSESSION OF STOLEN
PROPERTY, a violation ofNRS 205.275, both
misdemeanors.
Committed in: RENO TOWNSHIP
DISTRICT ATTORNEY Zach Young
RECEIPT
Notice Of Appeal; Designation of Record; Request For Transcripts

Application For Appointment Of Public Defender
Washoe County Sheriffs Office own Recognizance Release Request Form
Order For Competency Evaluation Pursuant To NRS 178.415
Points And Authorities
Letter
General Appearance By Named Defendants
Custody Change Request
Request For Audio Copy Of Proceedings
Request For Discovery
Motion to Suppress
Authorization to Represent
Motion To Allow Late Filing Pre-Trial Motions
Pre-Trial Motions
Notice Of Appearance And Supplement To Motion To Accept Pre-Trial
Motions Where Untimely
Motion to Strike Fugitive Document
Motion to Continue Trial Date
Motion to Appoint Co-Counsel
Opposition To Motion to Suppress
Opposition to Motion to Contmue Trial Date and Motion To Appoint CoCounsel
Reply To State's Opposition To Motion to Suppress
Oraer Transferring Jurisdiction to Mental Health Court
Order Returning Case From Specialty court to Original Department
Motion To Proceed In Forma Pauperis
Second Amended Criminal Complaint (Stricken)

28.
29.
Pre-Trial Brief: Motion For Summary Judgment

30. Order For Competency Evaluation Pursuant To NRS 178.415

31. Request For Audio Copy Of Proceedings
34. Evaluation From Lakes Crossing
35. . Request For Audio Copy Of Proceedings
36. Authorization to Represent
37. Motion To Quash Subpoena Duces Tecum
38. Response To Subpoena Duces Tecums
.
39. Motion For Protective Order To Quash Subpoenas And For ProtectIve Order
Regarding Issuance Of Subpoenas
40. Ex Parte Emergency Order Pending Hearing
41. Affidavit of Service
42. Motion to Quash Subpoenas
43. Motion for Mistrial And Memorandum Of Law
44. Submission Of Materials Related To Return Of Service Of Subpoena And .
Motion For Order For Austin Lichty's Address From DMV (Truck he was m
had plate of288 PFV Teal Ford F-[50) And For Identity Of Owner Of And
Call records for day of arrest for 775-378-6673
45. Order Denying Motions For Mistrial And Continuance
46. Order
47. Motion For Mistrial And Or Continuance
48. Order To Attend
50. Misdemeanor Judgment
5l. Request For Audio Copy Of Proceedings
53. Motion (Illegible)
54. Emergency Ex parte Motion For Extension Of Time To file Motion For New
Trial: MotIon For Mistrial; Motion Strike; Motion For Arrest of Judgment
55. Emergency Ex parte Motion For Extension Of Time To file Motion For New
Trial: MotIon For Mistrial; Motion Strike; Motion For Arrest of Judgment
56. Miscellaneous Filings; Addendum to Motion for New Trial Revealing
Further Conflicts Requiring Recusal Of Both The RJC and the WCDA
Office
57. Miscellaneous Filings
60. Order
61. Affidavit Of Service
62. Amended Criminal Complaint
63. Criminal Complaint
64. Arrest Report And Declaration Of Probable Cause
65. States Exhibit "A"
66. States Exhibit "B"
67. Defendant's Exhibit" 1"
68. Defendant's Exhibit "2"
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
80.
83.
84.
85.
86.
87.
88.
89.
Defendant's Exhibit "5"

Disk/CD Zach Coughlin PD#I44825
Case Summary Sheet
Dated this December 5, 2012.
; I pEe 06 2011
By :. . -.',
r. .........
Dep ,. ....(!9urtClerk
,
. '..:~'
":
/
,
..;
CERTIFICArn'~et~J{K""'~'~:::'
I hereby certify that the enclosed documents are certified as true and correct
copies of the original documents on file with the Reno Justice Court.
Dated this 5th day of December, 2012.
Steve Tuttle
Court Administrator
By:
---=~--~--~~------
Deputy Court Clerk
FILED
With Document Code:
lach Coughlin
1012 DEC -3 AM 1\: 18
1471 E. 9th 51.
Reno, NV 89511
Tdcphone and Fax: 949 6677401
REB J" I. E C'JL!RT
pro [lcr uelcndant dcnicd his Sixth Amcndment Rigbt to COl[l~ _' _____ ....__ _
'IF?, i;
IN THE JUSTICE COUR r OF RENO TOWNSHIP

IN AND FOR THE COUNTY OF WASHOE, STATE OF NEV ADA
STATE OF NEV ADA:
)
)
)
Plaintiff:
) CASE NO: RCR2011-063341

vs.
) DEPT. NO: 2
11
i2
ZACHARY COUGIILlN;
)
)
)
Defendant.
1.1
----------------------------)
&
, ,")
~U feCc.v.-.j.
l6
\X,? K{jIe~
i ~-->/~~/ r~~t/;?'
,.NOTICE OF APPE0'r>
COMES NOW, ZAGl COUGHLlN, and files tbis NOTICE OF APPEAL on his own behalf
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as to any and all Orders Onlcuding those as to by Judge Sferrazza and or any RJC Judge presiding
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over any aspects oftbis case in Judge Sferrazza's abscence, and it is based on the argument and
?tl
,authorities herein, and the attachments and filings on record and or submitted for tiling with this
,
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,
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Icourt and requests the transcript be prepared at public expense and in accord with nrs 189.030 given
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\that nrs 4.14(a) only applies to civil cases.

FACTS AND LA W
i
I\PPEALS TO DISTRICT COURT

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Appeal bv DefenJant
,
-
.
: NRS 189.0 I0 Appeal must be taken within 10 days. Except as otherwise provided in NI<S 177.0 I5, a defendant in a
,
~rimit1al action tried befor~ a justice of the peace may appeal from the final judgment therein to the di:-.trict coul1 of the
'I,
-1/4'
NOTICE OF APPEAL
counly II here Ihe court of Ihe juslice of Ihe peace is held, al any lime with in 10 days from Ihe time of Ihe rend ilion of Ihe
judgment.
11911 Cr. PrJc.
662; RL
7512; NCL
*113091---(NRS A 1995, 1536)
N RS 18<) 010 Notice of Intention to appt!al: Filing and ~ervicc: stay ofjuugmcllt pending appeal.
I. I he parly inlt:IHJing to appCall11l1!'1l tile with th~ ju~ticc and serve upon the dbtrict attorney a notice entitled in the
ac.;tioll. ~cttillg forth tht: character of the judgment. and the infL'nlion of the party to appeal thcrcfrorn to the district court.
2. Stay ofjuJgmcnt pending appeal is governed by NRS 177.1 ns and 177.11 ).
11911 Cr. i'mc.
663; RL 7513; NCL 11310J----{NRS A 1967,
1~67)
NRS 189.0]0 Transmission oftranscripl, other papers, sound recording and copy of docket to district court.
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I. rhe justice shall, within 10 days alter the notice of appeal is tiled, transmit to the clerk of the district court the
transcript of U,e case, all other papers relating to the case and a certified copy of the docket.
2. I he justice shall give notice to the appellant or the appellant's attorney that the transcript and all other papers
relating to the case have beenliled with the clerk of the district court.
HI
il
3. II' the district judge so requests, hefore or aller receiving the record, the .justice of the peace shall transmit to the
district judge the sound recording of the case.
[1911 Cr. Prac. 664: RL 7514; NCL 113IIJ---(NRS A 1973,631; 1979, 1512)
NRS 189.035 Procedure where transcript defective.
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LC
I. Except" provided in subsection 2. if the district court linds that the transcript of a case which was recorded by
sound recording equipment is rnatenally or extensively defective, the case must be returned tor retrial in the justice court
from which it came.
2 If all panies to the appeal stipulate to being bound by a particular transcript of the proceedings in the justice court.
or stipulate to a particular change in the tran<;cript. an appeal based on that transcript as accepted Or changed may be
heard by the district court without regard to any detects in the transcript.
fAdded to NRS by 1979, IS 12)
NRS 189050 Action to be judged on record. An appeal duly perfected transfers the action to the district court to be
judged on the record.
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IPart 1911 Cr. Prac. 666; RL 7516: NCL 11313]-(NRS A 1979, 1512)
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NRS 189.060 Grounds for dismissal of appeal; enforcement of judgment.

I. The appeal may be dismissed on either of the tollowing grOlJnds:
(a) For failure to take the 5Jame in time.
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(b) For failure to appear in the district court when required.

2. Ifthe appeal is dismissed, a copy of the order of dismissal must be remitted to the justice, who may proceed to
~ntorce
?l
rhe judgment.
IPart 1911 Cr. Prac.
*666; RL 7516; NCL *11313]
NRS 189.065 Dismissal tor failure to set or reset appeal for hearing.
I. An appeal. m~lSt be dismissed by the district court unless perfected by application of the defendant, within 60 days
ailer the appeal IS hied m the Justice court, by having it set for hearing .
. 2 .. I f an appeal has. bC:11 s~t for hearing and the heJring is vacated at the request of the appellant, the appeal mu<.;t be
lInies", application 1<'; made by the appellant to reset the hearing \..'r'ithin 60 days aftcr the date on which the
hearing wa~ vacated.
dlsm.I<.,~ed
(Added to NRS by 1965,376; A 1985.57,972)
- 2/4 -
NOTICE OF APPEAL
NRS 189.070 Grounds Ill!" dismilsal of complaint on appeal. Any complaint, upon motion of the defendant, may be
dbmisscd upon any of the following grounds:
I. That the justIce of the pc"ce dId l10t have jurisdiction ofllle offensc.
1
That more than one offense is dwrgcd in anyone COllilt of the complaint.
3. That the fact'i stated do not
con~litllte
a public
olfcn~e
CONCLUSION
The undersigned hereby request this Court consider these materials presented herein in
IJ
deciding upon this matter.

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AFFIRMATION AND DECLARATION

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I declare, pursuant to NRS 53.045, under penalty of perjury under the laws of the State
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of Nevada that the foregoing is true and correct and that this document does not contain any
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social security numbers, pursuant to NRS 2398.030, an affirmation to that effect this hereby is.
l5
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DATED this 28th of August, 2012:

1 I
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u lin
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lin,!Esq:"'
tl Co.'Counsel for Coughlin
/!
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NOTICE Of APPEAL
PROOF OF SERVICE
,1
On this date, I caused a copy of the ic)rcgoing document s to be served upon the following by
sending to their registered email address and fax number as found on WW\\'.llvoar,org" hand delivery
to dropslot or li'ont desk, and by placing a true and correct copy of the foregoing document in the
U.S. mail addressed to:
'J
I,
Zachary N. Young, Esq,

Washoe County DA
1 South Sierra P.O. Box 30083
Reno, NY 89520
Phone Number: 775-328-3200 Fax number: 775-325-6703
Email: zymmg@da.washoecounty.lls
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II
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Jim LcIsie, Esq.

Washoe County Public Defender's Office
P.O, Box 30083 Reno, NY 89509
Email: jleslie@washoecounty.us
JEREMY T. BOSLER, Esq.
Bar No. 4925
One Califc)rnia Ave
Reno, NY 89509
(775) 337-4800
Atlorncys for Defendant
,;
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"- - -----
DA TED this 28th of August 201-'2:
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Zach C ghlin, Esq./<'

Defen ntl Co-CQunsel for Coughlin
/ /
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"
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- 4/4 NnTJr~j:;' {)V
nor
v
IN THE JUSTICE COURT OF
WASHOE COUNTY, ST ATE OF NKV AIM
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THE STATE OF
~EVADA.
)
)
Plaintiff.
VS.
'-' m6{..& !Ker e ..

illJb 1,0
C(
Defendant.
)
)
)
)
)
)
APPLICATION FOR APPOINTMENT

OF PUBLIC DEFENDER
CASE NO.
PCN
ii- ,~ 3'7{J
... --+- - -----
I hereby apply for appointment of the Washoe County Public Defender and declare under
: penalty of perjury: (1) I am indigent; and (2) I am without financial means to hire an attorney
8
I further declare under penalty of peljury the financial and employment mformation I provided
verbally to Pretrial Services with this application is true and accurate to th est of my
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knowledge.
_-'/
"
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S. {; Inbe..dLl'-1,..l_-
WITNESSED:
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PRETRiAL SERVICES OFFICER
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ORDER
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The Court has reviewed the Defendant's answers to the Financial Inquiry to Detennine
Eligibility assessment and this Application executed under penalty of peJjury. Good cause
appearing it is hereby ordered that:
o the Application is DENIED. The Court finds the Defendant is not indigent.
('(lnJnl~nL
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-------------_._-_.
__
_ _ _ _ _ _ __
GRANTED. The Court

~he Applicationorisotherwise detemlines that tinds that the Defendant is without means to
mployan attorney
representation by the Washoe County Public
Defender IS reqUired. Reimbursement may be ordered by the Justice Court or Dlstnct Court at a
later time. The Washoe County Public Defender is appointed to represent the Defendant on the
following condition(s):
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DATED
2S
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b~~~--~o. ~ ~..----.-.-
'-+J+.---!4~.---
G ~-
u
....
Washoe County Pretrial Services

Assessment Report
,<~ase
Filing
-- ---------- ---- -------------- -I
: rl'Dt! l\:,liIH'
I COUGHLIN,
ZACHARY BARKER
Arrest
Booked Name
COUGHLIN,
Arresllng Agency
- Case Number
ll-16399
!'IOC
00327
Type
F
Defendant Information
-
=1'
-----_._--------- ---- ----Age

Height
Blrthdale
Race
WHITE
34
09/27/1976
08/21/2011
Counts Court Bail Amt/Type
()cscription
GRAND LARCENY
~:
Se,
11-14657
Arrest Dale
Booking Nomber
RENO POLICE DEPT
ZACHARY BARKER
Weight
220
6' 04"
~
2,500
RJC
SS Number
On File
--
Address
ResIdence
Born
121 RIVER ROCK ST.

RENO, NV 89501
County: 04 Yr 00 Mo
BELVIEW. WA,
UNITED STATES
Telephone
Pnmary Language
lime at Current Addross

00 Yr 05 Mo
(775) 338-8118
Uves With
Relationship
ENGLISH
Expiration
Type
10 Number
Oat~
ALONE
How Long
Marital Status
Military Service
SINGr..:s
Discharge
NONE
---------,-Hew long
l Cmp!oynlcllt:S:...-PPor[ Si~1U;--
Employed
Employef
Employe, Telephone
(775)
GENERAL PRACTICE
Defcndant Justicc Identifier Codes/Criminal History

FBI
Nu;;.b;----
Arrests
SID Numbe'
VIolent Fels
Felonies
VIOlent Misd
Misdemeal10fs
MMSD
TraffIC
Pending
DUI
Comments
THE DEF STATES THAT HE HAS BEEN IN THE RENO AREA SINCE 2003 AND HAS BREN AT HIS CURRENT
THB OBI" STATES THAT liE IS SELF EMPLOYED.
THE DRl" S CRIMINAL
ADDRBSS POR 5 MONTHS.
HISTORY WAS UPDATED AND REVIEWED.
SE2 ~NTilRN"'L NOTES.
Assessment Status
1 - - - - - - I-------
L_______L
Incident No. L000144bb
Assessment
IM!a.ls
FRLONY NR
SJ(IMBERL
lI
lJ'agc 1
v.
OBl2V2011
Determination of Indigency Report
Page j of 1
Client: COIJGHL IN, ZACHARY BARKER
Cue#: 11-16399
DOS: 09(27/1976
Identification
Court:
RENO JUSTICE COURT

Charge(s):
GRAND LARCENY
Address:
length:
Phone:
121 RIVER ROCK ST. RENO, NV 89501
co Yr: 05 Mo
775 338-8116
Occupation and Employer:

l .. TTO?NEY
GENERAL PRACTICE
Financial Information
Income
Expense
Asset
Expense
Liability
SUMMARY,
INCOME
RENT/UTU ! FOOD
'96 HONDA
INS/GAS
STUDENT LOANS
GOO
2 t OOO
900/100/1000
2,000
300
100/200
60,000
2,000
-80,000
EXPENSES:
-2,300
NET WORTH,
Determination:
ASSETS:
LIABILITIES,
~7a!ooo
CASH FLOW:
-1,700
INCOME:
600
INDIGENT
I
Recommendation
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The allove constitutes my recommendation to the court. I have explained my recommendation to the party.
Screening AgentlWitness: Shann0n
Ki!l.b;rli~1
Oale: _ _ _ _ __
Comments:
THE DEFENDANT STATES THAT HE IS A PRACTICING LAWYER. HE STA7ES THAT HIS VEHICLE IS HIS
ONLY ASSET AND THAT HE DOES NOT HAVE THE FINANC[~ MEANS TO RETAIN PRIVATE COUNSEL.
:1
FILED
DA #
Case No.
Dept. No.
td2.11- 0 fJ334-{
11 SEf'-6 AM
c9-.-
TUm
. STEVE
RENO JUSTICE
cou T
IN THE JUSTICE COURT OF RENO TOWNSHIP BY-~~,--L
DEPUTY
COUNTY OF WASHOE, STATE OF NEVADA
5
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Plaintiff,
vs ..
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ZtlCtfMLy BM1LEpe Co~~2 it!.

. Defendant.
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ORDER FOR COMPETENCY EVALUATION PURSUANT TO NRS 178.415

Upon motion of counsel for Defendant herein and. good
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15
cause appearing therefor,

IT IS HEREBY ORDERED that the Defendant be examined
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.17
by
psychiatric
social
qualified
especially
19
Developmental Services of the
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Services
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1.
to
the
or'
NRS
Division
other
of
person
Mental
who
Health
is
determining:
pursuant
by
worker
18
and
Department of Health and Human

178.417,
for
the
purpose
of
If the Defendant is not of sufficient mentality
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to be able to understand the nature of the criminal charge (s)
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against him; and
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31
2.
If,
because
of
mental
insufficiency,
the
Defendant is not able to aid and assist counsel in the defense
!
(
interposed upon the trial or against the pronouncement of the
judgment thereafter.
IT IS FUTHER ORDERED that the Defendant is to appear
3
4
before
Justice
the
Honorable
court,
Department
20 /{
~fe. /2.il A Zl4
P.e f('
No.
at
DATED this
the
competency evaluation hearing.
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on
hour
of
12
the
of
the
to ~ ()O.m.
Reno
day
for
20--11.
of
a
\" /!).
~ 16 fI/\
u
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FlLEB
Document Code:
Zach Coughlin,Esq.
121 River Rock St.
Reno, NV 89501
11 OOl-S \>3 ',46
ruSTICE COURt'
OmWNSHIP
WASHOE COUNTY, NEVADA
8
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) CASE NO: RCRII063341
ch Coughlin;
Plaintiff,
vs.
)
) DEPT. NO: 2
arl Hylin, Esq., personally and in his capacity

5 attorney at WASHOE COUNTY PUBLIC
EFENDERS OFFICE, WASHOE COUNTY
UBLlC DEFENDER;
Defendant.
) f..l.lte.'>'
}F"\ o-t"\
ct E.>I
(j)#l.rr!:_
) MOTION FO SANCTIONS PURSUA3!.

) TO NRCP 11; 4- 1Il 1) "'TIfl'J!. {:/1/ ('..:'/)
)
)
)
)
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POINTS AND AUTHORITIES
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Pursuant to NRS 7.085, NRCP Rule II, NRS 18.010, NRS 69.{)3{), and NRS 118A.290, N. R. S.
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COMES NOW, the undersigned Tenant and states that:
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118A.360 sanctions are sought. NRCP II (b) empowers the court to impose appropriate sanctions on
a party and his counsel when a motion is presented for any miproper purpose, such as to harass an
opposing party. Before the court may do so, a Rule II motion must be servcd on the offending party,
and 21 days must elapse without the offense having been remedied, however, the court may, perhaps,
25
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sua sponte impose sanctions absent such a 21 day safe harbor period. The motion must describe the
specific conduct alleged to have violated NRCP I I(b). On September 8,2011 a written motion was
sent by the lUldersigned to the Defendants, included with a letter again requesting these attorney's
28
- 1 -
Mctior, for Sancticns
;
,
withdraw any pleadings, writings, or arguments made in support of the Order for Competency
Evaluation Pursuant to NRS 178.415, thereby satisfying NRCP lJ(c}(I)(A), A True and Correct
copy of the August 17, 2011 correspondence and the September 6, 2011 correspondence is attached
hereto as Exhibit I.
5
6
N.R,S, 18.010, suM 2(b); Rules Civ.Proc., Rule 12(b)(5). Bergmann v. Boyce, 1993, 856 P.2d 560,
109 Nev. 260.
For purposes of an award of attorney fees, under statute governing award of attorney fees, a
claim is groundless if the allegations in the complaint are not supported by any credible evid10
11
encc at trial. NKS. 18.010, suM. 2(b). Bobby Berosini, Ltd. v. People for the Ethical Treat-
12
ment of Animals, 1998,971 P,2d 383, 114 Nev. 1348, rehearing denied. Costs 194.44
13
Buyers of recreational vehicle (RY) who prevailed in action to revoke their acceptance of thc
14
RV due to nonconformity, were not entitled to costs for computerized legal research, given
15
that those costs were not sufficiently itemized, Waddell v. L.V,R.v, Inc., 2006,125 PJd
16
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1160, lZ2 Nev, 15. Costs 198
18
To support an award of attorney fees based on a party asserting claims without reasonable
19
grounds, there must be evidence in the record supporting the proposition that the complaint
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was broughl without reasonable grounds or to harass the other party. Kahn v. Morse & Mow-
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bray, 2005, J17 P.3d 227, 121 Nev. 464, rehearing denied. Costs 194.44
23
Determining whether attorney fees should be awarded requires the court to inquire into the ac-
24
tual circumstan.ces of the case, rather than a hypothetical set of facts favoring plaintiffs aver-
25
ments, Baldonado v. Wynn Las Vegas, LLC, 2008,194 P.3d 96. Costs 194.44
26
To support award of attorney fees without regard to recovery sought, there must be evidence
27
in record supporting proposition that complaint was brought without reasonable grounds Of to
28
I
j
- 2 Motior. for Sar.ctions
.'
harass other party. N.R.S. 18.010, subd. 2(b). Semenza v. Caughlin Crafted Homes, 1995,901
P.2d 684,111 Nev. 1089
Surgeon had reasonable grounds to bring action against hospital and others after hospital re-
fused to expunge reprimand from surgeon's file and, therefore, hospital and others were not
5
6
entitled to recover statutory attorney fees, even though surgeon did not prevail; although sur-
geon did not succeed in obtaining expungement, copy of verdict showing that surgeon had not
abandoned his patient was also placed in file and, in essence, nullified reprimand. N.R.S.
IS.OIO, subd. 2(b). Chowdhry v. NLVH, Inc., 1993,851 P.2d 459, 109 Nev. 478, rehearing
10
denied.
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6. Groundlessness
13
Although a district court has discretion to award attorney fees against a party for unreasonably
14
maintaining a lawsuit, there must be evidence supporting the district court's finding that the
15
laim or defense was unreasonable or brought to harass. Bower v. Harrah's Laughlin, Inc.,
16
2009,215 P.3d 709,125 Nev. 37. Costs 207

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Hylin articulated no reasonable basis in law or fact for countemlanding his client's dictates
that Hylin not unduly his client by seeking a "competency evaluation." Clients have a right to contro
the means and objectives of a litigation, yet Hylin disobeyed a direct order from Coughlin. Imagine,
if you will a doctor who suggest a certain treatment for cancer. They patient declines to follow the
suggestion. The doctor rams it down the patient's throat anyways. Karl Hylin. When Hylin finally
relented and attempted to explain why he insisted upon seeking a competency evaulation, he cited
retaliatory rationale, indicating that he was upset that Coughlin is alleged to have "kicked furniture in
the lobby of the Public Defender'S office". The undersigned hereby swears, under penalty of perjury
that no furniture was kicked by the undersigned at any time in the Public Defender's office or lobby.
Mr. Hylin needs to he a lot more careful with putting bis name on arguments and pleadings when he
is buttressing his contentions with materials devoid of fact or law. As someone actually trying to
make a livin' in the private sector, the undersigned can attest to Mr. Hylin that the 160 large he gets a
year would require he read the 2 pages of discovery in this case and be able to spot tbe patent Inconsistency in Officer
Duralde's account of Zarate's testimony and Zarate's own Written Statement
Name
Position
Base Pay
Benefits Total Pay & Benefits Jurisdiction Year
Hylin Car! F DEPUTY P. D. IV $119,730.16 $36,845.97 $160,233.61
Washoe County 2010
Carl F Hylin DEPUTY P. D. IV SI14.370.56 $36,254.37 $154,432.98
Washoe County 2009
Carl F Hylin DEPUTY P. D. IV $102.047.60 $30,560.09 $132,607.69
Washoe County 2008
- 3 -
Motion for Sanctions
v
1
For purposes
claim is groundless if the allegations in the complaint are not supported by any credible evid-
of an award of attorney fees, under statute governing award of attorney fees, a
ence at trial. N.R.S. 18.010, subd. 2(b). Bobby Berosini, Ltd. v. People for the Ethical Treat-
ment of Animals, 1998,971 P.2d 383, 114 Nev. 1348, rehearing denied. Costs 194.44
5
Claim is groundless and will justify award of attorney fees if complaint contains allegations
which are not supported by any credible evidence at trial. Semenza v. Caughlin Crafted
Homes, 1995,901 P.2d 684, III Nev. 1089. Costs 194.44
To extent that claim is fraudulent, it also must be groundless, and, therefore, district court may
10
award attorney fees for defense of fraudulent claim under statute permitting award of fees to
11
12
prevailing party when court finds that claim of opposing party was brought without reasonable
13
ground or to harass prevailing party. N.R.S. I 8.oIO, subd. 2(b). Allianz Ins. CO. V. Gagnon,
14
1993,860 P.2d 720,109 Nev. 990. Costs 194.44
15
7. Frivolousness
16
Trial court did not abuse its discretion by awarding shareholders and director attorney fees
17
18
after it entered default judgment against majority directors as a discovery sanction, in breach
19
of fiduciary duty action majority directors commenced against fourth director in which fourth
20
director and shareholders asserted derivative claims against majority directors; majority dir-
21
ectors refused to comply with trial court's discovery order, majority directors did not appear at
22
their deposition or refused to answer questions, and majority directors' claims and defenses
23
24
werc frivolous and not based on law or fact. Foster v. Dingwall, 2010, 227 P.3d 1042. Pretrial
25
Procedure 46
26
Trial court's finding that former wife's motion to disqualify judge who presided over her mo-
27
tion for modification of child custody and child support was meritless was not permissible
28
- 4 -
basis for awarding husband attorney fees to defend motion as sanction; rather, in order to im-
pose sanctions for filing frivolous motion, trial court was required to make specific findings as
to whether motion was unreasonable or brought to harass. Rivero v. Rivero, 2009, 216 P.3d
213. Costs 2
5
The decision to award attorney fees as a sanction against a party for pursuing a claim
Frivolousness of claim is determined as of time claim is initiated, rather than time of trial, for
purposes of award of attorney fees to prevailing party when opposing party brings suit witbout
reasonable grounds or to harass prevailing party. N.R.S. I 8.010, subd. 2(b). Barozzi v. Benna,
10
1996,918 P.2d 301,112 Nev. 635. Costs 194.44

11
12
Guarantors' claims against bank director, arising from bank's decision to call loan to maker,
13
for breach of fiduciary duty by director, and for intentional infliction of emotional distress by
14
director in intentionally violating his duty, were frivolous when guarantors initiated claims,
15
and guarantors thus were liable for director's attorney fees, if guarantors had conducted even
16
cursory investigation, they would have found that, because note was for less than $1,000,000,
17
18
19
director would have had no connection with bank's decision to call loan. N.R.S. 18.010, subd.
2(b). Barozzi
V.
Benna, 1996,918 P.2d 301,112 Nev. 635. Costs 194.44
20
21
22
23
24
25
26
27
28
- 5 -
v
.,
w"b J C'
:AI
rl
t .
-stn" '3 is
'bE
3I
"5 must 'Q msks 'hiP 7 $1* kgbits' '

, . 'J ajm
51
t'Sst "
2sgs iB1
@n!!? 'g"ypgt b" 2 rts'iztw niSin ]I ,
a:e r d
Dji iF 'gmther K5snent1 t' Nst? d
'tiP isen
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'2 ;)
the un1
6
7
09'1 mjt
em? est eMs I5heruzi to est csz
I ,
r Ig1l34S3!1
I'
72I
Sanctions will be imposed for filing "frivolous claim," which is one that is both baseless and
10
made without reasonably competent inquiry. Rules Civ.Proc., Rule II; N.R.S. 18.010, subd.
11
12
2(b). Bergmann v. Boyce, 1993,856 P.2d 560,109 Nev. 670. Costs 2
13
For purposes of determining whether sanction should be imposed on frivolous action, court
14
considers whether pleading is well grounded in fact and is warranted by existing law or good-
15
faith argument for extension, modification, or reversal of existing law and whether attorney
16
made reasonable and competent inquiry. Rules Civ.Proc., Rules II, 12(bX5); N.R.S. IS.OIO,subd.
17
18
2(b). Bergmann v. Boyce, 1993,856 P.2d 560,109 Nev. 670.
19
Under Nevada law, award of attorney fees as item of damages is permitted where award is
20
based on showing of bad faith by losing party or special circumstances entailing undue hard-
21
ship to a defendant. N.R.S. 18.010, subd. 3. Swallow Ranches, Inc. v. Bidart, 1975,525 F.2d
22
995. Costs 194.44

23
24
Bad faith in bringing fraudulent claims against property insurer and adjuster's successor in in-terest
25
made case for awarding attorney fees even stronger under statute permitting award of
26
fees to prevailing party When court finds that claim of opposing party was brought without
27
reasonable ground or to harass prevailing party. N.R.S. 18.010, subd. 2(b). AlIianz Ins. Co. v.
28
- 6 Motion for Sanctions
.,
"
Gagnon, 1993, 860P.2d 720, J09Nev. 990. Costs 194.44
Insurer's bad-faith refusal to pay legitimate claim persisted from a time prior to enacffilent of
statute, which provided for award of attorney fees to prevailing party when court finds that
claim, counterclaim, cross claim or third-party complaint was brought without reasonable
5
6
ground or to harass prevailing party, after enacffilent and to the present time; therefore, in-
sureds could recover attorney fees pursuant to that statute. N.R.S. 18.010, subd. 2(b). Fanners
Home Mut. Ins. Co. v. Fiscus, 1986,725 P.2d 234,102 Nev. 371. Costs 4
In absence of fraud, malice or wantonness, where there were no findings that any of affidavits
10
presented by city and power company were given in bad faith or solely for purpose of delay in
11
12
taxpayers' suit to enjoin city and power company from placing power lines above ground in
13
violation of ordinance, and where neither damages nor attorney fees as damages were awar-
14
ded, award of attorney fees to taxpayers' attorney was unauthorized. NRCP 56(g}; N.R.S.
15
18.010, subd. 3(a}. City of Las Vegas v. Cragin Industries, Inc., 1970,478 P.2d 585, 86 Nev.
16
933. Municipal Corporations 1000(7)

17
18
19
When a court is requested to award attorney fees as a cost oflitigation, the matter is decided
20
based upon pleadings, affidavits and exhibits, and on rare occasions, a eourt may even detenn-
21
ine the amount of the attorney fees based upon the court's personal observation of the time the
22
attorney spent in hearings and the quantity and quality of pleadings filed by the attorney.
23
24
25
26
27
;1
-j
Sandy Valley Associates v. Sky Ranch Estates Owners Ass'n, 2001,35 P.3d 964, 117 Nev.
Coughlin incurred expens'1 consulting with other local attorneys in this mattcr.
L. ~-~c..tJ. .1""
WHEREFORE, toaalt plays that the court exercisc its diseretion,PUTSuant to N~CP" II and
I~ 1""",- -j. f! IJ )-rt~-::;

impose significant monetary and/or merit based sanctions against both pliIj1rl'ifrardo!:~ AP sel; for
28
- 7 -
.1\1" ~
...,
. If'<\. ""..0 (tJ t1 i ( f L 1; c: ,-,;2 () l;;.f\

V'
~. C::L,,,,,Pfrc:''C'''-I l!:V:4Lv,IL;"7c.- I . F~;.0;?v-"
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an award of attorney's fees and costs incurfed by defendant, who has sought counsel with a local "'ft...e::~r,--
2
3
attorney other than himself on this matter, as a result of plaintiff's and her counsel's violation; and for
vr
such other, further and additional relief as seems just to the court in the premises, and damages and
other relief requeste~herein.

5
6
I declare under penalty of perjury under the laws of the State of Nevada that the
foregoing is true and correct and that this document does not contain any social security
numbers, pursuant to NRS 239B.030, an affirmation to that effect this hereby is.
10
c:::vc:I
. 5'"~ \.
Dated tlrD$ib, day iii Sepi8lii1wr, 2011
11
12
...MZMco!!.b.QnWll~L"/
13
Plaintlff/Accus~d
Zach Coughlin, ..'
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- 8 Motion for Sanctio~s
l .
..o
t- . ~c..j
(-~.",-
-,
CERTIFlCATE OF SERVICE
2
3
Lori Townsend, certifies: (a) she is a citizen of the United States, over 18 years of
age, and not a party to the within action, and (b) that affiant served II copy of the attached on the
persons, at the addresses, on the date, and in the manner indicated below:
6
7
8
LORI TOWNSEND, Secretary to

PETER 1. SFERRAZZA, Justice of the Peace
Reno Justice Court, Department 2
10
11
12
13
Name:
Address to which
mailed/delivered:
14
October 6, 2011
15
16
Darcy Spencer, Esq_

Deputy District Attorney
P. O. Box 30083
Reno, NY 89520
date hand delivered.
date placed in county interoffice maiL
date placed in county mailing system for postage
and deposit in UB. mail.
17
18
19
Name:
Address to which
mailed/delivered:
20
21
22
23
24
25
26
October 6, 2011
Carl Hylin, Esq.

Deputy Public Defender
P. O. Box 30083
Reno, NY 89520
date placed in county interoffice mail.
date placed in county maiJing system for postage
and deposit in U.S. mail.
2l\tUll mustier Grllud

PETER
J. SFERRAZZA
STATE OF NEVADA
WASHOE COUNTY
P.O. 30083
RENO, NEVADA 89520-3083
,JUSTICE OF THEi: PEACE
(77S) 3256505
DEPARTMENT TWO
October 10,2011
Zach Coughlin, Esq.

121 River Rock Street
Reno, NV 89501
Re: State ofNevada v. Zachary Barker Coughlin, Case No. RCR 2011-063341
Dear Mr. Coughlin:
. The Emergency Ex Parte Motion for Sanctions Pursuant to NRCP 11; and
Other Relief you filed in the above entitled case has been received and has been placed in
the Court's file. A copy has been forwarded to both the Washoe County District
Attorney's Office and the Washoe County Public Defender's office, along with a copy of
this reply. As a general rule, it is inappropriate for the Court to receive and/or consider
correspondence when it is submitted on an ex parte basis.
I
1
!
PJS:let
cc:
Washoe County District Attorney's Office
i'
FILED
1
JEREMY T. BOSLER, Bar No. 4925
CARL F. HYUN, Bar No. 2726
PO Box 30083
Reno, NV. 89520-3083
Attorneys for Named Defendants
ZlII1 OCT 18, AM 10: 24
6
7
IN THE JUSTICE COURT OF RENO TOWNSHIP
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA
****
lQ
11
ZACR COUGHLIN,
Plaintiff
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13
14
15
16
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Vs.
)
)
)
)
Case No. RCRll-063341

Dept. No.2
[C}ARL F. HYLIN, ESQ., personally and )

In his capacity as attorney at Washoe
)
County Public Defender'S Office, and
)
WASHOE COUNTY PUBLIC
)
DEFENDER
)
)
Defendants.
----------------------)
GENERAL APPEARANCE BY NAMED DEFENDANTS
COMES NOW, the Defendants above-named in Propria Persona, and hereby file jointly
this GENERAL APPEARANCE to contest the jurisdiction of this Court to the EMERGENCY
22
EX PARTE MOTION FOR SANCTIONS PURSUANT TO NRCP 11; AND OTHER

23
RELlEF, filed by Plaintiff in this Court on October 5, 2011. By filing this GENERAL
24
25
26
APPEARANCE, the named Defendants intend NOT to submit to the personal jurisdiction of
the Court for the purpose of Plaintiff's motion. This GENERAL APPEARANCE is for the
1
sole purpose of contesting the jurisdiction of this court over the named Defendants and is
premised upon the following propoundments:
1. Neither Defendant has ever been properly served any documents concerning th,is
motion pursuant to NRCP 4 or JCRCP 4. The criminal procedure in this state has no equivalent
5
method of service but there appears to be no attempt at all to achieve prnper service by
6
Plaintiff. Without proper service, no personal jurisdiction by the Court is obtained. Doyle v.
Jorgensen. 82 Nev. 196,414 P. 2d 707 (1966).
2. By the express terms of the Nevada Rules of Civil Procedure and the Justice Court
10
11
Rules of Civil Procedure, these rules apply only to "all suits of a civil nature." NRCP 1;
JCRCP 1. This action was filed by the State of Nevada solely as a criminal charge against the
12
above named Plaintiff, Zachary Coughlin. There exists no counterpart to these rules in the
13
criminal procedure of Nevada. Therefore, the Plaintiff s Ex Parte Motion for Sanctions is ultra
14
15
16
vires, and, therefore must be deemed a fugitive document as it has no relation to the criminal
action filed by the State.

WHEREFORE, Defendants above-named request that this Court enter an order
17
18
denying the Plaintiff s motion in it's entirety.
19
AFFlRMATION
20
We, the undersigned, under penalty of perjury pursuant to the laws of the state of
21
Nevada declare the foregoing is true and correct and this document does not contain any social
22
23
24
security number, pursuant to NRS 239B.030.

1111111
25
Iliff!
26
1111/1
1
,
j
RESPECTFULLY submitted this LLday of {2/'(72
5
6
JEREMY . OSLER
WASHOE C UNTY PUBLIC DEFENDER
Defendant
Defendant
9
j
I
1
1
,2011
t~
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15
16
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18
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20
21
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24
2S
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"
;
1
2
CERTIFICATE OF SERVICE
I hereby certify that I am an employee of the Washoe County Public Defender's Office,
Reno, Washoe County, Nevada, and that on this date I forwarded copies of the foregoing
documents through inter-office mail, addressed to :

5
j
j
I
j
ZACHYOUNG
DEPUTY DISTRICT ATTORNEY
1 SOUTH SIERRA STREET
RENO,NV
8
9
:0
11
ZACH COUGHLIN, ESQ.

121 RIVER ROCK ST.
RENO NV 89501
DATED this 17th day of October, 2011.
12
13
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16
17
18
19
20
21
22
23
24
25
26
l '
1753283206
17. 00 '17
11-14-2011
C.wODY CHANGE REQUESTV

Defcndanrs namc:
Coughlin, Za~hary Barker
Date of birth: 09127/1976
Social security number:
Case #:RCR2011-06334J
Warrant # Booking #'.1 1-14657 Agency: RPD
Charge(s}: Petit Lar-.mY (IY')

Next court date: 11128/11 i@, 8:30 ~Jl) Bail: $465.
Court: DOis!ric!
DRcno Municipal
lX/Reno Justice
OSparks Municipal
DSparks Justice
DOther,_ _ _ _ _ _ _ _ _ __
Requested action:
Dbail increase 10:$
bail decrease 10:$'_ _ __
oO.R. release with supervision by Pretrial Services
DO.R, release to inpatient trcabnent program.
Defendant to be transported by:
Olnmate Assistance Program
DOther~:_ _ _ _ _-:--_
DO.R. with self-admittance by Defendant
&,!O.R. release revocation
Inpatient lreatment will begin on
._ _ _~,at,_ _ _ _ _ _and has been confirmed
by the requestor(s).
Requested by: Lori Pit
1
1
I
1
J"",o',
"'~""
Title: Pretrial Sgyj!;S Officer
~.IIff.!lIftor
Date: 11/14120 II
D,,,-;;I;4 ~
j../...
:cial conditions of release:

The defendant was out on OIR ~n was rearrested on 09i09!ll for Petit Larceny. He posted bail
and continued to report in with eso. The defendant has been rearrested again on 11113111 for
Trespassing. OIR is being revoked. The detcndant remains in cu!\\()dv.
Fax completed fom! to Pretrial Services at: (775) 325-6617
WI
111
Case No.
FILED
R~R .:A6 I t -Db93 LJ \
Department No. _...:...~-==-
11 HOY 30 AM 9: 19
____
STEVE TUTTLE
RENO JUSTICE COURT

8Y_-=,~
__
IN THE JUSTICE COURT OF THE STATE OF ffWADA

-l1f&::: :;>T!jrb OF !V6V4J?,tt

Plaintiff,
REQUEST FOR AUDIO COpy

OF PROCEEDINGS
\'8.
2M HI-JK~~VEfZ.. CQu C; ttL I N

Defendant.
_________________ 1
The
Plaintiff
of proceedings of the following:
1)
2)
,
I
;
I
!
Hearing Date
Hearing Date
3)
Hearing Date
4)
~Defendant has requested an audio copy
(0/12/11
(~ Fel{ f.-A ZZ?- ) ( C:)
Hearing Date
jV/24-LII
(srt5RfV~2;Z,f-) (0 )
II /2'8 / I !
(Peo.~n ) (C')
Date
/V6V~1xr
Clly,S..... Zlp
Contact telephone numbtr
A $35.00 fee is due at the time ofthe request.

Please indicate if you wish to have the CD mailed to you.
Call (775) 325-6575 if you have any questions.
27I
,20 I!
I
I
i
~
I
,
1
I
1.
~L
n
JEREMY T. BOSLER
,;i
Bar No. 4925

One California Ave
Reno, NV 89509
(775) 337-4800
Attorney for Defendant
2011 DEC 19 AM /0: 32

7

Plaintiff,
10
v.
Dept. No.2
11
12
13
14

Defendant.
________________________
~I
REQUEST FOR DISCOVERY

15
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his
16
17
18
attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the
following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive.
19
20
21
1
1
22
I
J
'J
1.
Inspect and receive copies or photograph any written or recorded statements or
confessions made by the Defendant or any witness, or copies thereof, within the possession,
custody or control of the State, the existence of which is known or by the exercise of due
diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any
23
video and audio recordings, including those preserved on pocket recording devices, 9-1-1
24
J
l
1
25
26
I
!
emergency calls, and any dispatch logs, written or recorded. generated in connection with this
case.
1
2
3
2.
Inspect and receive copies or photograph any results or reports of physical or
mental examinations, scientific tests or experiments, and chemical tests made in connection
with this case, or copies thereof, within the possession, custody or control of the State, the
existence of which is known, or by the exercise of due diligence, may become known to the
5
prosecuting attorney. NRS 174.235(1)(b).

6
3.
Inspect and receive all items favorable to the Defendant, including items within
the custody, possession or control of the State. the existence of which is known to the State or
its agents, or by the exercise of due diligence may become known to the prosecutor. as required
10
11
12
by Brady v. Marvland, 373 U.S. 83 (1963), Giglio v. United States. 405 U.S. 150 (1972),
United States v. Agurs. 427 U.S. 97,108 (1976), United States v. Bagley, 473 U.S. 667 (1985),
Kyles v. Whitley. 514 U.S. 419 (1995), Strickler v. Greene, 527 U.S. 263 (1999), related state
13
caselaw, see. e.g., Lay v. State. 116 Nev. 1185 (2000); State v. Benn~ 119 Nev. 589, 81 P.3d 1
14
15
16
(2003), and Rule 3.8(d) of the Nevada Rules of Professional Conduct.
4.
The Defendant request~ the opportunity to inspect and receive the criminal
17
histories of alleged victim/witness, Cory Goble, and witness, Nathaniel K. Zarate, to the extent
18
that these records contain impeachable convictions. Specifically, the Defendant requests any
19
record or records of criminal history demonstrating that Cory Goble and/or Nathaniel K. Zarate
20
has been convicted of a crime or crimes that were punishable by death or imprisonment for
21
more than one year nnder the law under which the witness was convicted. This request does
22
not encompass convictions for which a period of more than 10 years has elapsed since the date
23
of the release of the witness from confmement or the expiration of the period of the witness's
24
parole, probation or sentence, whichever is the later date. See Nev. Rev. Stat. 50.095; U.S.
25
v. Price, 566 F.3d 900 (9th Cir. 2009); Crivens v. Roth, 172 F.3d 991 (7th Cir. 1999).
j
I
I
I
I
26
5.
Inspect and receive copies of all photographs, books, papers, documents,
tangible objects, and surveillance video related to this case, or copies thereof, which are within
2
v
c
the possession, custody or control of the State, the existence of which is known or by the
exercise of due diligence may become known to the prosecutor. NRS 174.235(l)(c). This
request does not entitle the defense to the discovery of internal reports, documents, or
memoranda made by State agents in connection with the investigation or prosecution of the
5
case, or to materials otherwise privileged or protected from disclosure. NRS 174.235(2).
7.
If the prosecutor is unable to detennine whether certain materials are favorable to the
9
10
Discovery of records of the Defendant's criminal history. NRS 179A.l 00.
Defendant, or material or exculpatory in nature, these materials should be submitted to the

court for in camera review. See United States v. Gardner, 611 F.2d 770 (9th Cir. 1980).
11
Provided an appropriate request is made, the prosecutor may receive reciprocal
12
discovery of eligible materials that are within the Defendant's possession, custody, or control,
13
or by the exercise of due diligence may become known to the Defendant. NRS 174.245(1). A
14
15
reciprocal discovery request does not authorize the discovery of intemal reports, documents, or
16
memoranda prepared by or on behalf of the Defendant, or hislher attomeys or agents, in
17
connection with the investigation or defense of the case. NRS 174.245(2).
18
19
20
There is a continuing duty to disclose discovery materials. If, before or during trial, a
party discovers materials that are subject to this request, all parties must be promptly notified of
the additional material. NRS 174.295(1). If one party fails to comply with this request, or with
21
any portion of NRS 174.235 to NRS 174.295, inclusive, the non-disclosed material is subject to
22
exclusion at trial. NRS 174.295(2).

23
24
/11
25
III
26
III
3
v
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AFFIRMATION PURSUANT TO NRS 239B.030

The undersigned does hereby affinn that the preceding document does not contain the
social security number of any person.
4
5
,2011.
JEREMY T. BOSLER
Washoe County Public Defender
By
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17
18
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20
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24
25
26
..
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1, JOSEPH GOODNIGHT, hereby certify that I am an employee of the Washoe County
Public Defender's Office, Reno, Washoe County, Nevada, and that on this date I forwarded a
true copy of the foregoing document through inter-officemail to:
5
6
8
9
10
';
!
,
I
ZACH YOUNG, Deputy District Attorney

District Attorney's Office
DATEDthis ICo
Day of
&.::A-v-./.....~
J!JJ~dIid
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1
i
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I
j
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17
j
1
16
18
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20
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22
,2011.
23
24
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26
"
<,
COf'~ , ~
L;f
1
2
3
4
FiLED
JEREMY T. BOSLER
BarNo. 4925
One California Ave
Reno, NV 89509 '
(775) 337-4800
i'D/2FEB f 3 M! 101 15
::U.CI :j~'f"
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.'

6

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8
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Plaintiff.
10
v.
11
12
13
Dept. No.2
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MOTION TO SUPPRESS
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Defendant.
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attorney of record. Joseph Goodnight, Deputy Public Defender, and hereby moves to suppress
all evidence obtained as a result of his detention and arrest on August 20, 2011.
TIlls motion is based upon the attached points and authorities and any testimony,
documentary, and real evidence as may be presented at the hearing on this matter.
I. Facts
On August 20, 2011, Mr. Coughlin was detained under suspicion of his involvement in
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a report of a larceny.l This detention occurred on the Center Street Bridge in downtown Reno.
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1 These facts are taken from the police report of RPD Officer Nick Duralde,
case number 11-16399, witness statements, audio recordings and anticipated
testimony to be presented at the hearing regarding this matter.
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witness Nathaniel Zarate alleged to have seen Mr. Coughlin pick up an iPhone belonging to
Cory Goble, place it in his pocket, and then refuse to give it back when asked to. 2 Mr. Goble
indicated that he called the phone and saw it light up in Mr. Coughlin's left front pocket. Mr.
Coughlin was wearing shorts and aT-shirt at the time of his detention. Upon contacting Mr.
Coughlin, Reno Police Department officers Nick Duralde and Ron Rosa immediately placed
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surrounded by numerous young adults when the police arrived. According to the police report,
Mr. Coughlin was found near his bicycle and accompanied by a small Pekinese dog. He was
him in handcuffs and began questioning him regarding his alleged possession of the missing
iPhone. Mr. Coughlin was told by the officer that Mr. Goble would "probably be fine if [he]
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you're gonna go to jail." Mr. Coughlin is an attorney licensed to practice law in Nevada and
when he asked the officers a question they told him 'just don't talk anymore." Mr. Coughlin
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g[a]ve him the phone back." But continued, "if not, we're gonna get it out of your pocket and
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provided the officers with his name and Nevada Bar number as requested. During the initial
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interview by the police, Mr. Coughlin asked if he could tie his dog to something, as it likes to
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run away. Officer Duralde, pursuant to his 'training and experience' and the fact that Mr.
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Coughlin was wearing baggy clothing, performed a pat-down search of Mr. Coughlin to check
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for weapons. The pat-down revealed to the officer's touch objects resembling a cellular phone
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in each of Mr. Coughlin's front pockets.
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Officer Duralde next obtained the phone number of the alleged missing iPhone from
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Goble and called the number. Officer Duralde did not see any phone screens light up but
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alleged he could hear a vibrating noise coming from the left front pocket of Mr. Coughlin. He
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placed his hand on Mr. Coughlin's pocket where he had previously felt the object resembling a
phone. During this second search he felt a vibration coming from the pocket. The vibrations
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2 Gross inconsistencies exist between the police report and witness Zarate's
witness statement regarding whether witness Zarate saw Mr. Coughlin pick up
the phone. ACCording to witness Zarate's written statement another man
ini tially picked up the phone, not Mr. Coughlin.
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stopped when he ended the calL At this point Mr. Coughlin was placed under arrest for Felony
Grand Larceny and an iPhone was removed from his left front pocket pursuant to a search
incident to arrest.
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Mr. Coughlin asks this court to suppress the evidence retrieved from his front pocket
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based on a violation of his Founh Amendment right to be free from unreasonable search and
seizure. The initial pat-down check for weapons was unjustified under ImY and Nevada
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Revised Statute 171.1232 as Officer Duralde did not have a reasonable belief that Mr.
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Coughlin was armed with a dangerous weapon or may have posed a danger to police or others.
A search of such nature requires a warrant and without such the search is illegal. The
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exclusionary rule and NRS 171.1232 call for the suppression of the evidence found in Mr.
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Coughlin's pocket as its presence was unlawfully obtained.
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a. Officer Duralde did not have a reasonable belief that Mr. Coughlin was armed
with a dangerous weapon or posed a threat to the safety of the officers or
others and, thus, tbe pat-down he performed was not justified resulting in an
unlawful search and the seizure of inadmissible evidence.
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The Founh Amendment of the U.S. Constitution protects people from unreasonable
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searches and seizures. It provides that "the right of the people to be secure in their persons,
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houses, papers, and effects, against unreasonable searches and seizures, shall not be violated."
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US CONST. Am. IV. "This inestimable right of personal security belongs as much to the
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citizen on the streets of our cities as to the homeowner closeted in his study to dispose of his
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secret affairs." Terry v. Ohio, 392 U.S. 1, 8-9 (1968). When a police officer accosts an
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individual and restrains his freedom to walk away, he is "seized" within the meaning of the
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FounhAmendment. rd. at 16. Likewise, even a stop-and-frisk "pat-down" of a person's
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clothing is a "search," governed by the framework of the Constitution. Id.
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Nevada has codified the boundaries an officer must observe before making an
investigative stop and detention of a person. A peace officer is authorized to "detain any
person whom the officer encounters under circumstances which reasonably indicate that the
person has committed or is about to commit a crime." NRS 171.123(1). The Nevada Supreme
Court has further clarified the statutory standard, saying:
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"Pursuant to this standard, in order to justify a stop and detention, the police
officer must be able to point to specific and articulable facts which, taken together
with rational inferences from those facts, lead the officer reasonably to conclude,
in light of his experience, that criminal activity may be afoot." Stuart v. State, 94
Nev. 721, 722 (1978).
Further. "[a] lawful frisk does not always flow from a justified stop and detention for
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questioning." Rice v. State, 113 Nev. 425, 429 (1997). quoting United States v. Thomas, 863
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F.2d 622. 628 (9th Cir.1988). The Nevada Legislature has likewise limited the scope of a "stop
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and frisk" or ''pat-down'' search:

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1. 1 any peace officer. reasonably believes that any person whom he has detained or is
about to detain pursuant to NRS 171.123 is armed with a dangerous weapon and is a
threat to the safety of the peace officer or another, the peace officer may search such
person to the extent reasonably necessary to ascertain the presence of such weapon. 1
the search discloses a weapon or any evidence of a crime, such weapon or evidence may
be seized.
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2. Nothing seized by a peace officer in any such search is admissible in any proceeding
unless the search which disclosed the existence of such evidence is authorized by and
conducted in compliance with this section.
NRS 171.1232 (emphasis added).
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Reasonable belief for both the detention and the pat-down search for dangerous weapons "must
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be based on specific articulable facts that warrant the search and seizure." Somee v. State, 124
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Nev. 434, 187 P.3d 152 (2008). Finally, "all evidence obtained by searches and seizures in
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violation of the Constitution is, by that same authority, inadmissible in a state court." Mapp v.
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Ohio, 367 U.S. 643,655 (1961). Nevada Revised Statute 17Ll232(2), quoted above,
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codifies this Constitutional requirement in Nevada.

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In this case, Officer Duralde did not have a reasonable belief that would justify a pat-
down search for weapons. Mr. Coughlin was detained due to suspicion of larceny, i.e., he
allegedly picked up the iPhone of another. The nature of the alleged offense was in no way a
violent act nor did it indicate in any way that Mr. Coughlin was armed with a dangerous'
weapon or a threat to anyone's safety. In fact, Mr. Coughlin was accompanied by a Pekinese
which he begged the officer to let him tie up prior to being hand-cuffed so that it would not run
away. This act indicates that Mr. Coughlin had no intention of leaving the scene without his
dog. He was not presenting any "fight or flight" behavior that would indicate the need for a
pat-down search. See Rice v. State, 113 Nev. 425 (1997) (court found situation where
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defendant remained on his bicycle, showed signs he had been drinking, refused to identify
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himself, and raised his voice, presented sufficient evidence that defendant may be dangerous or
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may try to escape and substantiated the officer's reasonable belief that a pat-down was
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necessary). Mr. Coughlin provided the officers with his name and even offered his Nevada Bar
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number. When attempting to speak to the officers, he was told to '1ust don't talk anymore." .
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He did not raise his voice and presented no indication that he was dangerous or attempting to
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flee. A licensed attorney in Nevada has been screened for moral character and fitness by the
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licensing board and he identified himself as such to the officers. He was polite with the officers
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and he showed no signs of intoxication.
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Officer Duralde relies on his 'training and experience' that baggy clothing may contain
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a dangerous weapon to form the reasonable belief that Mr. Coughlin's clothing may have
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contained the same. Though valuable to every officer in the field. 'training and experience' is
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woefully insufficient to establish the specific articulable facts necessary to justify a reasonable
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belief that a person is armed with a dangerous weapon. Law enforcement does not have leave
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to pat-down every person they detain that happens to be wearing cargo-pocketed pants, a
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hooded-sweatshirt, a fanny pack, a sport coat, or a top hat, all of which could conceal a
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dangerous weapon. In this case, Mr. Coughlin was wearing shorts (without cargo pockets) and
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was armed with a dangerous weapon and was a threat to the safety of the officer or others. He
is unable to do so as there are no facts that would indicate any such weapon and danger. In
fact, the officer reveals his true disregard for the Fourth Amendment when he tells Mr.
Coughlin that he is going to get it out of his pocket prior to having any valid and particularized
basis for a legal search. Thus, the pat-down search of Mr. Coughlin was unlawful and the
information gained from it, i.e., the presence of the iPhone, must be suppressed pursuant to
aT-shirt. Again, the officer must be able to point to specific articulable facts that Mr. Coughlin
NRS 171.1232(2) and the exclusionary rule.
b. Officer Duralde's subsequent touching of Mr. Coughlin's left front pocket

constitutes a search and without a legitimate warrant exception it was unlawful
and any evidence obtained from said search must be suppressed.
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The ~ Court stated, "it is nothing less than sheer torture of the English language to
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suggest that a careful exploration of the outer surfaces of a person's clothing in an attempt to
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touching of Mr. Coughlin's pockets requires a warrant or an exception to the warrant
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requirement under the Fourth Amendment. ''Time and again, [the Supreme Court of the United
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States] has observed that searches and seizures "'conducted outside the judicial process,
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without prior approval by judge or magistrate, are per se unreasonable under the Fourth
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fmd weapons is not a 'search.'" Terry v. Ohio, 392 U.S. 1,16 (1968). As such, the subsequent
Amendment - subject only to a few specifically established and well delineated exceptions."'"
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Minnesota v. Dickerson, 508 U.S. 366, 372 (1993) (quoting Thompson v. Louisianl!, 469 U.S.
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17, 1920 (1984) (quoting Katz v. United States, 389 U.S. 347, 357 (1967)(footnotes
omitted).
Here, Officer Duralde placed his hand on the outside of Mr. Coughlin's shorts pocket to
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feel for the missing iPhone. This search occurred post pat-down and without a warrant or
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legitimate exception tu the warrant requirement. Thus, the evidence gained frum this unlawful
search must be suppressed.
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c. The Plain Feel Doctrine sanitizes neither the pat-down search nor the
subsequent search of Mr. Coughlin's pocket.
The Supreme Cuurt of the United States in Minnesuta v. Dickersun reoognized the
rorollary to the plain view doctrine when analyzing a Thm: pat-down and the subsequent
suppression of contraband that the search revealed. 508 U.S. 366 (1993). In setting out the
requirements for the plain feel doctrine, the Dickerson Court made clear that the initial pat9
down must be lawful under Th!;n::. Id. at 375. Further, the search must not go "beyond what is
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under Th!;n:: and its fruits will be suppressed." Id. at 373. By analogy to the plain view
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doctrine, "[i]f a police officer lawfully pats down a suspect's outer c\Qthing and feels an object
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whose contour or mass makes its identity immediately apparent, there has been no invasion of
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the suspect's privacy beyond that already authorized by the officer's search for weapons; [and]
if the object is contraband, its warrantless seizure would be justified [... J." Ill. at 375-376
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(emphasis added). However, the object's incriminating character must be immediately

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necessary to determine if the suspect is armed, [ ... J" and if it does so, "it is no longer valid
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apparent, and if not, its seizure is not justified by the plain view nor the plain feel doctrine. Id.
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at 375. Further, the officer must have probable cause tu believe that the item is contraband and
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this prubable cause may not be generated through an unlawful Th!ri pat-down. Id. at 376-377
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(footnote 4 Citing Ybarra v.lllinois, 444 U.S. 85 (1979. (See also Arizona v. Hicks, 480 U.S.
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321 (1987) holding that seizure of stolen stereo equipment found during a valid search for other
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evidence was invalid because inCriminating character of stereo equipment was not immediately
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apparent; i.e., probable cause to believe that the equipment was stnlen arose only as a result of a
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further search - moving the equipment to read its serial numbers).

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In Mr. Coughlin's case, as argued above, Officer Duralde did not have a lawful
justification for a
n.m pat-down. Assuming arguendo that the Court fmds the pat-down
lawful, the plain feel doctrine does not permit the seizure of the iPhone by the officer. Officer
Duralde reports that he felt two objects; one in each or Mr. Coughlin's front pockets that he
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determined to feel like phones. However, he in no way can determine these objects'
incriminating character or whether they are contraband by this initial pat-down. Indeed,
Officer Duralde had to come back to Mr. Coughlin's pocket a second time. He had to search
Mr. Coughlin again to determine whether one of the items was possibly contraband. This
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conduct is clearly unrelated to "the sole justification of the search (under Th!n::] ... the
protection of the police officer and others nearby." Dickerson at 378 (citing Terrv v. Ohio, 392
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U.S. 1,26 (1984)). Similar to the facts in Arizona v. Hicks cited above, Officer Duraide's
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probable cause to believe the object in Mr. Coughlin's pocket was the missing iPhone only
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arose as a result of a further search that was not authorized by a search warrant or by any
exception to the warrant requirement and the evidence thus gained must be suppressed.
Ill. Conclusion
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Based on the above, Mr. Coughlin respectfully requests that this court grant his motion
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to suppress the evidence and the fruits thereof obtained via violations of his Fourth Amendment
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rights through illegal searches of his person.
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The undersigned does hereby affirm that the preceding document does not contain the
DATED this
f 3 Day of-..L6....:~~L-"''''"',eA/:!...::\''+-_. 2012.
JEREMY T. BOSLER
By
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I, JOSEPH W GOODNIGHT, hereby certify that I am an employee of the Washoe
County Public Defender's Office, Reno, Washoe County, Nevada, and that on this date I
forwarded a true copy of the foregoing document through inter-office mail to:

DATED this
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Day of
f~ ,2012.
p~~
OSEPH W GOODIG
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~"
IN THE JUSTICES' COURT OF RENO TOWNSHIP,F \

COUNTY OF WASHOE. STATE OF NEVADA ' '
LEO
2012 FEB 15 PM \2: 00

RCRl1;jD~134iU\ iLF
Citation No.~ _ .
or
Case No. RCR~'t
THE ST 1\TE OF NEV ADA.
Plaintiff
i{'~ "!i'~
("',
ll.lltt?ufY
vs
Department No, _ _ _ _ _ _ _ __
Defendant.
-------~/
ZACHARY COUGHLIN
AUTHORIZATION TO REPRESENT
I
ZACHARY CQ;JGH_LI_N _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ " Defendant above-named.
_
,------co COUNSEL WITH GOODNIGHT _ _ _ _ _ _--" 1-:5Q. t0 represen t me
IS ZACH COUGHLIN, ..ESQ
~__ _ _
here byauthOflZC my attorney, _~ ,~~
at _ _ _ _ _ _,.-,,=====c--c'c-_________in this case and hereby request that
ALL STAGES
h'fI'"grrr-'_I!n;>t(lk-:t,:IU~el';)
the Court approve this authorization,
JUDGE SFERRAZZA ALREADY APPROVED THIS CO-COUNSEL ARRANGMENT
THIS IS FILED AS A
FORMALITY~
"'" '"'"''''.
2/13/12
DATED
DEFENDANT
,",.~
Thc Court has reviewed the foregoing AUTHORIZATION TO REPRESENT, Pursuant to NRS
178.388. the Court hereby:
o
o
approves Defendanfs request. DefCndant is ordered released on his own recognizance

pending trial ifhc has not already been admitted to bail.
denies Defendant'S request.
~l
JUSTICE OF THE PEACE
R..;viscd 10/02
.....
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f\t En
Document Code:
Zach Coughlin,Esq.
Nevada Bar No: 9473
1422 E. 9th SI., #2
Reno. NV 89512
Co-counsel for Defendant Coughlin
lMLfES 15 p~ \2:(10
,(E~\': ~1\;Cf)\~"
BY"~"--'-0f~;l0 ~'~";'
------'"

IN AND toR THE COUNTY OF WASHOE. STATE OF NEVADA
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STATE OF NEVADA:
) CASE NO: RCRll-063}41

)
Plaintiff.
) DEPT. NO; 2
)
)
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vs.
II
) RPD RPll-Ql6399
..L ZACHARY COUGHLlN;

"
Defendant.
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COMES NOW.
1.9
2.0
FACTS
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7.6
Motion tor Personnel files of Roas and Ofticer Nicholas Duralde admitted. on the night of the
arrest. to Defendant Zach Coughlin that he had complaints filed against him in the past stemming
Ii-om his employment as a police officer, and further indicated that he had been sued in that capacity
previously. A 1994 case against the RPD and Rosa shows up on court connect for the Second Judicial
District Court.
RPD misconduct justifies a dismissal or application of exclusionary rule in several ways. RPD
Duralde joked and mocked Coughlin, menacingly indicated he was overcharging the oftense as
"grand larceny" for all older moldel 3g iPhone that clearly wasn't worth more then $60. Upon
information and belief and Duralde's own menacing statements. this was done because it would
inconvenience and punish Coughlin more given the gravity of the charge, damage his reputation.
require great bail, and prevent the offense from needing to occur in the RPD Officers present (a
misdemeanor custodial arrest is uol)' permissible were this is the case under NRS). Futher the DA
ha~ an interest in helping out the Reno City Attorney, whom knows they likely ought be sued for
numerous wrongfully arrest recently in a coordinated "gang bang" of sorts against Coughlin, whom
has pretty much just worn it up til now, even where DDA Young is refusing a continuance.
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HOW MANY TIMES DOES DDA YOUNG GET TO AMEND THE CRIMINAL COMPLAINT?
IN CIVIL ACnONS ONE GETS ONE AMENDED BEFORE NEED TO SEEK LEAVE Of court.
Too many. and there were a variety of other procedural deficiencies here related to the incarceration
bail, delay in OR release, arraignmnet, etc.
Zach Coughlin, Esq. grew up in Nevada. His mother and father hail from Dayton, Ohio (his father is
a local family practitioner who has an emphasis in addiction medicine and has becn involved in
numerous interventions for individuals fairly high up in the judicial branch of government. Tim
Coughlin, M.D. played fullback for Tulane University and did a residency at Duke... Coughlin's
Mother is Mary Barker who has worked as a Grant Coordinator for local non-profit Very Special Arts
of Nevada for many years, and was formerly a school teacher and a graduate of the University of
Miami (Ohio. Coughlin's mother divorce his father in Texas in 1978 and moved to Gardnerville,
NV 'With her new husband. Coughlin's father followed and they have all been here ever since. Zach
Coughlin, Esq. attended CC MenealJy elementary school in Gardnerville, NV, Swope Middle School
in Reno. and was a National Merit Finalist (as was WCPD Joe Goodnight) and All-State Basketball
player at Reno High School, finishing his time playing as the school's then all time leading scorer.
Coughlin is listed in the National Federation of High School's record book for having one of the top
ten highest shooting percentages tor a single season, all time, tor those 'With at least 400 attempt~.
with a rate of 65.4%. Coughlin and his Reno High team lost the zone finals to Carson High School
43-42 in 1995. Coughlin has coached 9th grade basketball at Reno High School in the past, and was
formerly employed at Hale Lane and Washoe Legal Services in addition to doing piece meal work for
Geof Giles, Esq., Tom Hall, Esq. and various other attorneys. Coughlin is friends with Chester "Coe"
Swobe. Esq. Coughlin graduated with a B.S. in Biology from the University of Nevada Reno and
passed the July 200 I Nevada bar examination with the inaugural graduating class of UNlVs Boyd
School of Law during the summer follow his second year of law school, going back to school to
finish his last semester and graduate in December of 2001. Coughlin has a history with the police
that has been rather trying, and it would take quite some lime to go into it. Wedgies have been
involved. Threats to have things "shoved" up Coughlin's ass have been involved. Tackling, "white
boy" rebukes. etc., etc. Coughlin is a 6 foot 4,250 pound former All-State Center in basketball and
it seems his physical characteristics, combined with a typically Irish resentment of any authorities
encroachment upon what he perceives to be "his rights" can often result in mlfortunate
"misunderstandings" with law enforcement. Again, Coughlin passed the July 2001 bar examination.
He.was sworn in by Judge Breen, with Coe Swobe and Keith Lee, Esq. looking on at this example of
their success!UI powers of rehabilitation in March of2005. Coughlin's fllther called up the then Dean
of UNl~ V, ~Ichard Morgan an announced Coughlin either a drunk or a drug addict or crazy or
somethm II~c tha~. Coughlin was denied a license to practice law in California despite passing that
b,ar exa~:natlon Wlt~out s~ud~ing for it. on the basis of UNL V's Dean Morgan reporting what
Coughhn s father said 10 him In confidence on the telephone to the State Bar of Cali fornia, whose
LAP. ~rogra.ms likes !o have people who are license a marriage and family therapists practice
medlcme Wlt~out a i,,:ense with impunity whilst charging inordinate fees for the privilege of such
help. Coughlm and hIS father disagree on whether Dr. Coughlin's approach to parenting is of the
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Munchausen by Proxy School, but they remain close nonetheless. Coughlin is and has been sober for
many years, but he what "God damn bidness that is of anybody's anyway, effin Nanny State
motheretrers .... ". Coughlin is also licensed to practice patent law before the United States Patent and
Trademark office, and, untortunately is, in Dr. Coughlin's expert opinion, afflicted with the terminal
disease of "being a musician". This is not the first time one of the Coughlin elders has brought shame
upon the Coughlin name through their departure from fidelity to the Rill of Rights:
http://www.daytondailyncws.comlnewsldayton-news1defendants-tried-without-Iavv),crs-in-huberheights-court-win -appeals-585793 .hlm!
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LEGAL ARGUMENT
(10) WHERE IS THE LINE BETWEEN A "STOP' AND AN
"ARREST'?"
I. In Hayes v. Florida, 470 U.S. gIl (1985) the U.S. Supreme Court said that
although there is no "bright line rule" to answer this question. at some point in the
invcstigation police procedures can become so qualitatively and quantitatively intrusive
regarding a suspect's freedom of movement and privacy that an "arrest" occurs. The
Court said this occurs when the police, without PIC or a warrant, forcibly require a
person to go to a police station where he is detained even briefly for investigatioQ,.
2. "'There is no brigbt line rule ... therefore whether an arrest has occurred
depends on aU the circumstances. Pointing a weapon, ordering him to lie on the ground.
handcuffing and placing in a police vehicle for a brief period of time either singly or in
combination does not always convert a (Terry) stop into an arrest requiring PIC .. , police
need not use the least intrusive means of responding to an exigent situation ... as long as
their actions are reasonable." Allen v. City of Los Angeles, 66 F.3d 1052 (9th Cir. 1995).
Same rationale in U.S. v. Torres- Sanchez, 83 F.3d J 123 (9th Cif. /996) and U.S. v.
Blackman. 66 F.3d 1572 (11th Cir. 1995).
3. In Washington v. Lambert. 98 F.3d 1181 (9th Cir. 1996) Two black
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businessmen were seen leaving a restaurant by a police officer. The officer thought the
two men matched the description of two armed robbers in multiple robberies, although
the court noted that the actual size and weight of Washington and Hicks were several
inches and 50 pounds different from the suspects. The officer called for a backup and
tollowed the rental car to a hotel. A radio check said the rental car was not stolen. At the
garage in the hotel, the police got out and one of them pointed a gun at the two men,
ordered them to put their hands up and handcuffed them, then searched their persons and
the car. No weapons Of contraband was found. The two men sued the police under 42
U.S.C. 1983 .
. The Court held that "in determining whether the use of intrusive techniques turns
a stop into an arrest, we examine the reasonableness of the police conduct in light of a
number of factors, such as I) where the suspect is uncooperative or takes action that
raises a reasonable possibility of danger or flight, 2) where the police have information
that the suspect i~ currently armed. 3) where the stop closely follows a violent crime and,
4) where the police havc inlormation that a crime that may involve violence is about to
occur. Some combination of these factors may also justify the use of agl,,'fessive police
action without causing an investigatory stop to tum into an arrest.
- 3 MOLio;} for Sar:c~:o~lS
I,
In the present case the police action constituted an arrest with no

probable cause, (also arguably no RlS to justity a Terry stop either) thereby making
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the officers and police department liable for damages. 42 U.S.C. 1983.
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F. ARREST: THE HIGHEST LEVEL OF CONTACT
It is important to distinguish arrest from Terry-type detention. (Arrest is only
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legal if made on probable cause).
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l. STATUTORY DEFINtTION
NRS 171.124 says you can arrest for felony or gross misdemeanor with or
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without a warrant, day or night, if "reasonable cause" to believe subject has committed a
felony or gross misdemeanor .
2. THE U.S. SUPREME COURT CASE LAW
" The U.S. Supreme Court says: "probable cause" is a term dealing with everyday
probabilities, not legal technicalities. Draper v. United States. 358 U.S. 307(1959),
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"whether a man of reasonable caution would believe an offense was being or had been
10 committed" -- not a question of the "good faith" of the officer but a need to articulate
facts causing reasonable belief.
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The "objective test" is used to determine whether and when an arrest occurs. A
court may consider that there was an arrest even though the suspect was not told "you are
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under arrest". Factors such as show of authority, involuntary restraint or movement and
passage of time are important.
P
Dunaway v. New York, 442 U.S. 200 (1979), police lacked probable cause to
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arrest -- went to suspect's neighbor's horne and asked him in a compulsive way to go to
police station where he was placed in interrogation room -- wasn't told he was frec to go ]5
- the trip from the residence to the police station was several milcs and took 1 hour-Held -- although he wasn't told he was under arrest and wasn't booked -- this was same as
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an "arrest", because the police told him he needed to go to the police station, he
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" . acquiesced, and the trip took an hour and went many miles from his residence. His
subsequent confession to a crime was suppressed as a "fruit" of the "arrest" without
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probable cause.
Florida v. Royer, 460 U.S. 491 (1983). police suspected defendant as drug
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courier, approached and asked to speak to him and requested to see his ticket and driver's
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license--noted that names didn't match -- asked him to go to nearby room while retaining
his ticket and license. Held -- this con~'tituted a "seizure". 15 minutes after initial stop he
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consented to search of suitcase. Court ruled that this police conduct effectively
constituted an "arrest" and required probable cause. Since there was no PIC, (although
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there was RJS) the illegal "arrest tainted the consent.
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3. NEVADA CASES
Probable cause to make a warrantless arrest exists if the facts and
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man in believing that a felony had been committed by the person arrested. Thomas v.
Sheriff, 85 Nev. 551 (1969).
The "probable cause" test is based on the totality of the circumstances
known to the otlicer. Minor v. State, 91 Nev. 456 (1975).
4. STANDARD FOR PROBABLE CAUSE
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Basically, the same standard (quantity of proof) is needed for arrests as for
searches, so the Illinois v. Gates, 462 U.S. 213 (1983), totality ofthe circumstances test
applies - i.e.: a fair probability, but not necessarily a certainty.
In U.S. v. Ornelas. 116 S. Ct. 1657 (l996)The Court ruled: Articulating
precisely what "reasonable suspicion" and "probable cause" mean is not possible. They
are common sense, nontechnical conceptions that deal with" 'the factual and practical
considerations of everyday life on which reasonable and prudent men, not legal
technicians, act.' " As such. the standards are "not readily, or even usefully, reduced to a
neat set oflegal rules.". We have described reasonable suspicion simply as "a
particularized and objective basis" for suspecting the person stopped of criminal activity,
and probable cause to search as existing where the known facts and circumstances are
sufficient to warrant a man of reasonable prudence in the belief that contraband or
evidence of a crime will be found. We have cautioned that these two legal principles are
not "finely-tuned standards," comparable to the standards of proof beyond a reasonable
doubt or of proof by a preponderance of the evidence.
In U.S. v. Covarrubias. 65 F.3d 1362 (7th Cir.l995) the Court held that "Police
have PIC to arrest if at the moment of the arrest the facts and circum~1ances within their
knowledge of which they had reasonably trustworthy information were sufficient to
warrant a prudent person in believing that the suspect had committed an offense. While
PIC requires more than mere suspicion, we do not require it to reach the level of virtual
certainty. "
In Brinegar v. U.S., 338 {J .S. 160 (1949) the Court held, "PIC requires less than
(the amount of) evidence that would justit'y a conviction but more than mere suspicion."
and in Spinelli v. U.S., 393 U.S. 410 (1 %9) the Court held that "onJy the probability and
not a prima facie showing of criminal activity is the standard of PIC." Also, in Gerstein
v. Pugh, 420 U.S. 103 (1975), in ruling on a magistrate's determination ofP!C after a
warrantless arrest, the Court held that "a PIC determination does not require the fine
resolution of conflicting evidence that a reasonable doubt or prepondcrance (more than
50% probability) demands."
In Greene v. Reeves, 830 F.3d 1101 (6th Cir. 1996) police arrested the parents for
promoting sexual performances by a minor based on their sending of a postcard with a
photograph of the genital area of their unclothed minor daughter. The Court upheld the
arrest stating that, . the PIC standard does not mean that the ( evidence of the suspected
criminal act) is more likely than not."
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In U.S. v. Mathnay, 895 F.2d 1418 (9th Cir. 1990) "The test for probable cause is
whether the fact~ and circumstances within the arresting officer's knowledge are
sufficient to warrant a prudent person to believe a suspect has committed, is committing,
or is about to commit a crime." A court may consider both the experience and collective
knowledge of all officers involved in the investigation and their respective levels of
expertise.. A court may also consider any reasonable inferences drawn from the officers'
collective knowledge.
In U.S. v. Ocampo, 937 F.2d 485 (9th Cir. 1991) the Court held that "PIC
evaluation depends on the totality of the facts (of the case) even though there is an
innocent explanation for each fact."
Note: In Terry v. Ohio, 392 U.S. I (1968) the police detective with more than 20
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years experience saw Terry and his partners walk from a street comer to look in the front
window of a jewelry store without entering to shop about a dozen times in twelve
minutes. Even though this action was (superficially) innocent, the Supreme Court agreed
that under all the circumstances there was RlS that they were casing the store for an
armed robbery.
Although Terry involved RlS. Ocampo and numerous other cases hold that
"obvious criminal" behavior (pointing a gun at a victim)is not required for PIC.
S. SOURCES OF PROBABLE CAUSE
Reliable Confidential Informant
See the section in this manual on search warrants to learn factors that make an informant reliable.
McCray v. Illinois, 386 U.S. 300 (1967). A strong proven reliable informant with
first-hand information is enough for probable cause. "The Court has never required a rule
of compulsory disclosure of an infonnant where the issue is the preliminary one of
probable cause, and guilt or innocence is not at stake" Even an informant of lesser
reliability can be enough if the informant predicts future actions and details. Draper v.
United States, 358 U.S. 307 (1959).
In U. S. v. Fixen, 780 F.2d 1434,( 9th Cir . 1986), the Court held the arrest was
lawful and based on PIC. "The informer, enlisted by the police, met with the defendant to
arrange delivery of some cocaine; he then told police that the source of supply was a
Latin male from Los Angeles. The defendant was surveilled traveling to Los Angeles
where. in a series of moves apparently designed to discourage detection, he appeared to
ohtain a brown paper bag from a Latin male. Upon his arrest, cocaine wa~ found in the
bag." Although verification offacts from the informer's story was largely of'innocent"
behavior. credibility was enhanced by the accuracy and detail of the information given.
Generally, policelDA are not required to disclose informant's identity
Defendants always want to know the identity of an informant for obvious reasons
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such as threats to make the informant change his story or to lie about information given to
police, and sometimes more drastic means. The following cases explain the view of
federal courts on the issue of informant disclosure.
In U.S. v. Fixen (supra) The trial court refused identifying the CII and the 9th
Circuit upheld that ruling. "A proper balance depends on the particular circumstances of
each ca~e, consideration of crime charged, possible defenses, possible significance of the
informer's testimony, and other relevant factors."
Although the informer's privilege must give way where the disclosure of the
informant's identity "is relevant and helpful to the defense of an accused, or is essential to
a fair determination of a cause," the burden is on the defendant to demonstrate the need
for the disclosure.
A trial court need not require disclosing the identity of a reliable informant where
the sole ground for seeking that information is to establish the existence of probable
cause for arrest Fixen's request for disclosure expresses his concern there may not have
been an informant or that police lied as to the information related to them. An in camera
hearing (without presence of defendant or his lawyer) could have served to allay these
fears:
Through disclosure of the informer's identity to the trial judge, and such
subsequent inquiries by the judge as may he necessary. the Government can be protected
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from what could be serious police misconduct.

Nonetheless, a district court need not conduct an in camera hearing whenever the
identity of an informant is requested.
In U.S. v. Gordon, 173 F.3d 761 (10th Cir. 1999) the court held that a defendant
seeking to force disclosure of an informant's identity has the burden to show the
informant's testimony is relevant or essential to the fair determination of defendant's case.
"Where it is clear that the informant cannot aid the defense, the government's interest in
keeping secret the informant's identity must prevail over the defendant's asserted right of
disclosure."
The informant's role in Gordon's arrest was extremely limited. He did not detain
Gordon. and did not participate in or witness Gordon's detention or the transaction in
which Gordon purportedly agreed to transport cocaine in exchange for money. We have
refused disclosure in similar cases where the informant ha'l limited information, was not
present during commission of the offense, and cannot provide any evidence that is not
cumulative or exculpatory.
[n U.S. v. Hickman, 151 FJd 446 (5th Cir. 1998) (Reversed on other grounds in
179 FJd 230 (5th Cir. 1998), the court held that it wa'l not necessary to disclose the
identity of an informant. ''This circuit has crafted a three-part test to determine whether
disclosure of a (CII's) identity is necessary. We examine: I) the inlormant's degree of
involvement in the crime; 2) the helpfulness of the disclosure to the defense; and 3) the
Government's interest in non disclosure. As to the first prong, we have held that mere
"tipsters" are not so closely related to a crime as to require the disclosure of their identity.
67
In U.S. v. Mangum, 100 FJd 164 (DC Cir. 1996) Mangum argued that he
needed to interview the (Cn) in order to determine whether the cn might have planted
the gun in the knapsack in order to help secure an arrest and curry favor with the
government. He never cited any specific facts supporting his motion to disclose the
identity of the informant, but merely wanted to interview the (Cn) because the (C/l)
might possess information that could exculpate him.
The court found that the defendant was not entitled to know the (C/I's) identity
"because there is no evidence in the record supporting the Defendant's speculation that
the (C/I) actively participated in the offense." He failed to meet his burden by "showing
that the informant's testimony is necessary to his defense so as to justifY placing the
informant's safety in jeopardy."
"Mere speculation that the (C/I) may possibly be of some assistance is insufficient
to meet this burden. To overcome the public interest in protection of the (C/I)," the
delendant must show that the (ell) was "an actual participant in or a witness to the
offense charged," and identity is "necessary to the defense."
U.S. v. Fields, 113 FJd 313 (2d Cir. 1997) Government is not generally required
to disclose the identity of (CII's). Its interest in protecting anonymity of (ell's) who
furnish information regarding violations oflaw is strong-- withholding a (Cn's) identity
improves the chances that the person will continue providing information and encourages
potential (CII's) to aid the government.
The defendant bears the burden of showing the need for disclosure of a (C/I's)
identity, and must establish that, absent such disclosure. he will be deprived of his right to
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a fair trial.
Even if. as the defendants claim. the informant's information was uncorroborated
and constituted the bulk of the probable cause upon which the police relied, the district
court's in camera interview of the (Cfl), conducted with a view to matters defense counsel
identified in writing as potentially relevant, adequately protected defendants' rights. An in
camera interview of a (Cil)thal finds no (substantial) inconsistency with police testimony
can mitigate any concern that the (Clf's) testimony would in fact be useful to the defense
U.S. v. Kime, 99 F.3d 870 (8th Cir. 1996). Kime argues that the disclosure of
(Ts identity was necessary to test the veracity of his or her information and the quantum
of probable cause behind the aflidavit offered in support of the application for the
interception of wire and oral communications. But Kime offers no basis other than bald
speculation for his assertion that such a disclosure and an opportunity to interview CI-l
would allow him to impeach Cl-l's affidavit testimony. The movant's burden "requires
more than mere speCUlation that the testimony of the informant might prove to be helpful
to the defense."
Information from Victim Of Witness
Gates, held that citizen-informant is presumed reliable unlike a criminal CI
In Easton v. City of Boulder Colorado, 776 F.2d 1441(10lh Cif. 1985)
The Court held that "when examining informant evidence used to support claim of
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probable cause for warrant for arrest, Of warrantless arrest, skepticism and careful
scrutiny usually found in cases involving informants, sometimes anonymous. from
criminal milieu, is appropriately relaxed if informant is identified victim Of ordinary
citizen witness.
Because citizen witnesses are presumptively reliable, the officers in this situation
had no duty to examine further the basis of the witness' knowledge Of talk with any other
witnesses. The proposition that private citizen witnesses or crime victims are presumed
reliable docs not "dispense with the requirement that the in/ormant ... furnish underlying
facts sufficiently detailed to cause a reasonable person to believe a crime had been
committed and the named suspect wa~ the perpetrator." (Just as police need to state facts
learned by them to justify RlS or PIC)
U.S. v. Butler, 74 F.3d 916 (9th Cir.l996) Court held "you look at the totality of
the circumstances to determine PIC. "PIC can be based on hearsay ... or on information
relayed through oflicial police channels '" and through the collective knowledge of police
officers involved in an investigation even if some of this information was not known by
the arresting oflicer (and) if an unquestionably honest citizen comes forward with a
report of criminal activity which if fabricated would subject him to criminal liability we
have found rigorous scrutiny of the basis of knowledge unnecessary."
Tangwail v. Stuckey, 135 F3d 510 (7th Cir. 1998) Court held that "When an
officer received his information from some person--normally the putative victim or eye
witness--who it seems reasonable to believe is telling the truth: he has(P/C)." No deepseated
logic or rationale underlies this principle. (PIC) is a common sense determination,
measured under a reasonableness standard.
Sharrar v. Felsing, 128 F.3d 810 (3rd Cir. 1997) Court held that "EvCl1 if the
ot1tcer heard the victim' s claim that another person atlacked her it was reasonable for the
officer to assess her demeanor, find her story credible, and rely on her subsequent
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identification of her husband as the attacker. When an officer has received a reliable ID
by a victim of his or her attacker. the police have PIC to arrest. Same ruling Lee v.
Sandberg, 136 F.3d 94 (2d Cir. 1997).
Official Channels
Whitlcy v. Warden, 401 U.S. 560 (1971 )(Fellow officer rule). An officer who
does not personally possess sufficient information to constitute probable cause may
nevertheless make a valid arrest if he acts upon the direction or as a result of a
communication from a fellow officer and the police, as a whole, possess sufficient
information to constitute probable cause. People v. Freeman, 668 P.2d 1371 (Colo.
1983).
In Dolcman v. State, \07 Nev. 409 (1991), police arrested a murder suspect based
on information flum an informant and citizen witness (facts are somewhat complicated).
Even though the arresting officer may not have been aware of each and every fact
included in the probable cause, collectively he and the other officers involved in the
investigation did possess probable cause and this made the arrest valid. This decision
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extends the "fellow officer" rule to its fullest.
Personal Observations by police
This is the most common ingredient of probable cause - what you see, hear, smell,
feel or taste may give probable cause by itself or as corroboration of information received
from informant.
Discrepancy between information received and suspect confronted
This does not automatically mean that there is no probable cause. Some
discrepancies normal due to human nature. Brown v. U. S., 365 F.2d 976 (D.C. Cir.
1966), where police had description of robber as black male, driving maroon 1954 Ford
and about a mile away, minutes later, police saw car which was 1952 maroon Ford and
had occupant with different clothing and height was 6" off -- Held: probable cause
existed, despite the discrepancy to stop the car and arrest occupant
U.S. v. Tilmon, 19 FJd 1221 (7th Cir.1994) Police had PIC to arrestTilmon for
bank robbery once he stepped out of car and officers could compare him with description
of robber, due to fact that police already identified his distinctively marked car; although
defendant wore different clothes from those described by robbery eyewitnesses, and two
hours had passed since robbery.
Lallemand v. U. R. 1. , 9 F.3d 214 (I st Cir. 1993) Aftidavit which set forth
victim's version of rape and followed it with description of victim selecting arrestee's
photograph from picture array and positively identifying him as the man who raped her
provided probable cause for arrest, even though there were discrepancies between
arrestee's appearance and description of the perpetrator.
U.S. v. Valez. 796 F.2d 24 (2nd Cir. 1986) Observing officer's description of
cocaine seller was adequately detailed, despitc his silence on matter of seller's facial hair,
and defendant. who wa~ in immediate area of drug transaction, sufficiently fit description
to give another oUicer probable cause to arrest defendant within short space of time
follOwing transaction.
6. NO NEED TO "PRESERVE" PROBABLE CAUSE
Frequently an officer stops (or arrests) a person for a small offense and then
continues the investigation and finds PIC for a major crime. In such cases, the officer
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some judges have ruled that this makes the entire arrest bad because the officer didn't
"preserve the probable cause." This is nOI the law. In Scott v. State, 110 Nev. 622
(1994) the defendant was in a car stopped for an improperly affixed license plate. After
the stop it was determined that Scott was an ex-felon and had a gun. He was arrested for
that, but no citation was issued. The Nevada Supreme Court said this made no difference
in the validity of the stop. In U.S. v. Woody, 55 F.Jd 1257 (7th Cir. 1995) the court said,
70
"An arrest may be perfectly reasonable even if the police officer ultimately does not
charge the suspect with the offense giving rise to the officer's probable cause
determination.
7. WHEN WARRANT NEEDED IN ARREST SITUATION
The Supreme Court said in U. S. v. Watson, 423 U.S. 411 (1976), that you don't
need an arrest warrant for a lawful arrest in a public place --probable cause is enough,
even if you had time to get an arrest warrant. Same ruling in Florida v. White, 526 U.S.
559 (1999), U.S. v. Levine, 80 f.3d 129 (1996), U.S. v. Snow, 82 F.3d 935 (10th
Cir. I 996), and numerous other cases.
"The Supreme Court has refused to attach significance to the fact that the poliee
had ample time to get an arrest warrant but declined to do so. For an arrest in a public
place ... the only requirement is probable cause." U.S. v. DeMasi, 40 FJd 1306 (lst
Cir.1994).
There are two situations where a warrant must be obtained in arrest situations
(unless police can prove an emergency or consent exception exists) both involving entry
into premises to arrest. These are the "PAYTON RULE" and the "STEAGALD
RULE."
(a) DISCUSSION ON PAyroN RULE
Payton v. New York, 445 U.S. 573 (J 980). the court held that police cannot make
a warrantless non-consensual entry into a suspect's home to make an arrest unless exigent
circumstances exist.
In Payton, police developed pic to arrest suspect for murder occurring two days
earlier. Police went to suspect's home wherc lights were on and music playing. When
nobody answered knock or door, police made entry. Payton wasn't home but shell casing
to murder weapon was in plain view and was seized.
The U.S. Supreme Court ordered this evidence suppressed stating that the privacy
interest in a home was very hi gh and police needed either an arrest warrant for Payton (or
a search warrant for his home) to enter his home.
Although the U.S. Supreme Court has not decided all possible sub-issues that
arise at1er Payton - the following rules have been applied by high ranking State and
Federal courts.
(I) If police are otherwise lawfully in a person's home, for example, with a search
warrant, and probable cause to arrest appears it is OK to arrest without arrest warrant.
Mahlberg v. Mentzer, 968 F.2d 772 (8th Cir. 1992), Jones v. City of Denver, 854 F.2d
1206 (lOth CiT. 1988)_
(2) In People v. White, 512 N.E.2d 677 (ilL I 987),the court held that whether a
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place is "homc" depends on things like length of stay, regular use, relationship to other
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occupants, storing possessions there and payment of rent.

(3) The Payton rule can be violated even if police don't physically enter the
home, so held in Walters v. State, 106 Nev. 45 (1990). Walters became a suspect in a
murder case. The next morning, without obtaining a warrant. police used a helicopter
and bullhorn and ordered him out of his home. He complied, was arrested, and was given
Miranda warnings and gave an incriminating statement during the 100 mile drive to the
police station. The Court held the statement should be suppressed since Walters was
technically arrested in his home (by surrounding it with police and ordering him out)
without a warrant and the confession was the "fruit" of an illegal warrantless arrest.
(Note: This was overruled allerthe U.S. Supreme Court decision in New York v. Harris,
110 S.C!. 1640 (1990) holding that even after Payton violation police giving Miranda
away from residence or at police station OK's interrogation).
Other courts have ruled the same in "surround" or"bullhorn" cases. U. S. v.
Azzawy, 784 F.2d 890 (9th Cir. 1985), U. S. v. Maez, 872 F.2d 1444 (lOth Cir. 1989), U.
S. v. Morgan, 744 F.2d 1215 (6th Cir. 1984).
(4) The Payton rule applies to the suspect's place of business as well as his home.
(5) Most courts hold in addition to the warrant requirement police also need
"reasonable belief' (not probable cause) to believe a particular premises is that of the
suspect and that the suspect is "home" at the time of police entry. U.S. v. Risse, 83 F.2d
212 (8th Cir. I 996)"officers executing an arrest warrant must have a 'rea~onable belief that
the suspect resides at the place to be entered ... and have reason to believe that the suspect
is present' at the time the warrant is executed. The suspect's home means he has common
authority or some other sib'llificant relationship to the premises even if the premises is
owned by a 3rd person" "Reasonable belief' ruling followed in U.S. v. Lauter, 57 FJd
212 (2d Cir. I 995) U.S. v. Magluta, 44 F.3d 1530(llth Cir.1995)1l.S. v. Route, 104 F.3d
59(5th Cir.1996).
[n Valdez v. Pheters, 172 FJd 1220 (lOth Cir. 1999) Court held that the proper
inquiry is whether there is a reasonable belief that the suspect resides at the place to be
entered ... and whether the officers have reason to believe that the suspect is present. In
U.S. v. Edmonds, 52 FJd 1236 (3d Cir.l995) although "the information available to the
agents clearly did not exclude the possibility that the suspect was not in the apartment,
the agents had reasonable grounds for concluding that he was there.
In United States v. Albrektsen, 151 F.3d 951 (9th Cir. I 998) the court recently
cited with approval both Route and Risse for the proposition that officers executing an
arrest warrant must have "some reason to believe that the defendant might live at and be
present within the premises" entered. making no mention of any higher standard of
knowledge.
(6) No need to have warrant in hand. Whenever possible officers should have a
copy of the arrest warrant, but as long as a fellow officer confirms that the written signed
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warrant is in existence this is suflicient. U.S. v. Munoz. 150 FJd 401 (5th CiT. 1998).
(7) Misdemeanor warrants. Whenever possible officers should not make a forced
home entry to serve a misdemeanor arrest warrant. However, NRS 171.138 appears to
contemplate a house entry to make arrest on a misdemeanor warrant. See also, Jones v.
State, 513 So. 2d 8 (Ala. 1986), Lyons v. State, 787 P.2d 460 (Okla. 1989). The Nevada
Supreme Court implied in Hatley v. State. 100 Nev. 214 (1984), that police could make
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an in home arrest on a misdemeanor warrant as long as it was not a pretext to gain

evidence reference an unrelated felony investigation.
(8) Usc of Ruse. NOTE: You cannot use a ruse to gain entry into a premises to
avoid the Payton warrant requirement. However, the majority of ca<;es on this issue hold
that you can use a ruse to get the subject whom you wish to arrest (without a warrant) to
exit the residence.
The rationale of these cases is rock-solid. The purpose oftlle Payton rule is to
prevent warrantless police entries into a residence to arrest. Since police can legally
arrest outside a residence with probable cause and without a warrant, what difference
does it make if police use a ruse to get the suspect to leave the premises instead of
waiting outside until the suspect left on his own? The answer is obvious - no difference
and no Payton violation.
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The following cases upheld use of a ruse to get person out of premises:
In U.S. v. Rengifo, 858 F.2d 800 (1st Cir. 1988) A goverrunent agent's telephone
call to defendants' motel room warning them that there had been "problems" with a
cocaine delivery and that it would be best if they left the room and the area did not
improperly avoid requirement for arrest warrant by artificially creating exigent
circumstance.
In U.S. v. Vasiliavitch, 919 F. Supp. 1113 (NO Illinois, 1996) The Court held
that" courts have found no constitutional violation when police officers use tactics of
misinformation to solve crimes. Most prominent is the Supreme Court's 1969 decision in
Frazier v. Cupp, 394 U.S. 731 (1969) in which Justice Marshall held that an officer's lie
to the defendant that his co-conspirator had confessed was insufficient to make an
otherwise voluntary confession inadmissible. The ruse at issue in Frazier was
substantially more serious in its scope and its consequence than the ruse here. The
defendant in Frazier was tricked into making a full confession."
In this case, the oflicer's use of trickery only obtained Vasiliavitchious' arrest, an
inevitable consequence since the officers had probable cause. Unsurprisingly the courts
have upheld the use of subterfuge to trick a defendant into leaving his home on many
occasions under circumstances very similar to the ones here. People v. Witherspoon,
576 N.E.2d 1030, (Illinois, 1991) ("The use of deception to lure a defendant from his
home in order to effectuate an arrest without a warrant has been held not to violate
fundamental fairness.")
(b) DISCUSSION OF STEAGALD RULE
Steagald v. United States,451 U.S. 204 (1981), held that while an arrest warrant
does permit entry into the suspect's own home to effect the arrest, it does not allow police
to enter a third person's home in search of the suspect. Absent either consent or exigent
circumstances, police must have a separate search warrant authorizing them to enter the
third person's home.
(1) The search warrant will require not only a showing of probable cause that the
suspect is inside the third person's residence. but a showing of why it is reasonable to
seek the search warrant and make the entry to arrest as opposed to waiting for suspect to
depart and arrest elsewhere.
(2) The Steagald rule also applies to business oflices and other areas where there
is a high reasonable and legitimate expectation of privacy.
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Civil Liability
In addition to suppression of evidence, police andlor District Attorneys may be
civilly liable for Payton-Steagald violations.
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In Pembaur v. City of Cincinnati, 106 S.C!. 1292 (1986). Pembaur, a doctor,
wa~ indicted by grand jury for welfare fraud. Subpoenas were issued for two of his
employees and when they failed to appear. warrants for their arrest issued. The two
employees were located at the Pembaur's clinic, but he, Pembaur, refused to admit the
officers serving the warrant. The officers called the District Attorney who advised the
officers to "go in and get" the two employees. They complied. Pembaur filed a suit
under 42 U.S.C. section 1983 alleging a violation of his Fourth and Fourteenth
Amendment rights. He sued the County, the officers and the District Attorney for 20
million dollars.
The U. S. Supreme Court Held: The DA was implementing "official policy." In
this case, the DA had the fmal authority in such matters, therefore, the municipality
"officially" sanctioned the unconstitutional and tortious conduct. Therefore, the County
is liable. (Important note: County and police policy usually resulted in District Attorney
making these decisions and a state law granted the District Attorney the authority to give
such legal instructions.)
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SMELL, HEARING AND TOUCHING 7. Related to open view are (a) open smell and (b) nonelectronic augmented hearing. The courts look at these basically the same way and upheld the
overhearing with the naked ear of a phone conversation at an unenclosed telephone in a public place.
United States v. Muckenthaler, 584 F.2d 240 (8th Cir. 1978) and Siripongs v. Calderon, 35 F:3d 1308
(9th Cir. 1994). In U.S. v. Aquapito, 620 F.2d 324 (7th Cir. 1980) and U.S. v. Hessling, 845 F.2d 617
(6th Cir. 1998) the facts were the same (police listened to conversation in adjoining hotel room
without electronic equipment (naked ear and both courts held no 4th Amendment violation. Same
ruling in State v. Ortiz. 257 Neb. 784 (1999). However, in cases where police used electronic
equipment to augment hearing and gain information, virtually all courts hold that this is a 4th
Amendment privacy violation. 8. In U.S. v. Gault, 92 FJd 990 (10th Cir. 1996) police officer lifted a
gym bag from the aisle of a train. The court ruled that this action was not a search. Similar facts,
same ruling in U.S. v. Ward. 144 FJd 1024 (7th Cir. 1998) Smelling marijuana coming from
packages or baggage is OK. Sims v. State, 425 So.2d 563, (Fla. 1983). In Bond v. U.S., 529 U.S.
(2000) the Court ruled that police could not manipulate a passenger's soft luggage bag without
consent because such action would violate the passenger's right to privacy. 9. In U.S. v. McDonald,
100 F.3d 1320 (7th Cir. 1996) and U.s. v. Guzman. 75 F.3d 1090 (6th Cir. 1996) the Courts both
ruled that a police officer on a public transportation vehicle could grab and feel (without opening)
bags which were on overhead racks. However, some courts hold that such conduct by police is a
search, and if 18 done without PIC, the results would be suppressed. U.S. v. Nicholson, 144 FJd 632
(lOth Cir. 1998). USE OF FLASHLIGHT, BINOCULARS, ELECTRONIC DEVICES 10. Texas v.
Brown, 103 S.Ct. 1535 (1983) held that using a flashlight to see something at night which would
have been in the open during the day did not violate the Fourth Amendment. See also State v. Wright,
104 Nev. 521 (1988), which OK'd shining a flashlight into a car, and State v. Calvillo, 792 P.2d 1157
(N.M. 1990), which held that police shining a flashlight into a residence was not a search. Other cases
holding that use of a flashlight to see what could have been seen in daylight was lawful are U.S. v.
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Willis, 37 FJd 313 (7th Cir. 1994) and U.S. Y. Ortiz, 63 F.3d 1952 (lOth CiT. 1995). 11. The great
majority of decisions have held that use of an airborne "FUR" device to detect heat coming from
premises was not a search under the Fourth Amendment. United States v. Penny-Feeney, 773 F.
Supp. 220 (Haw. 1991) (upheld on other grounds but no specific holding for or against the FUR in
this case in the 9th Cir.. Penny-Feeney 984 F.2d 1053 (9th Cir 1993). Other courts approving FUR as
a "non search" are United States v. Deaner. 1 F.3d 192 (3rd Cir. 1993); U.S. v. Myers. 46 FJd 668
(7th Cir. 1995); U.S. v. Robinson. 62 F.3d 1325 (11 th Cir. 1995); and U.S. v. Ishmael, 48 FJd 850
(5th Cir. 1995). United States v. Kyllo, 809 F. Supp. 787 (Ore. 1992) (Note: This decision was
reversed by 9th Cir. 140 F.3d 1249 (1998) but that decision was withdrawn and it is unknown now
how the 9th Circuit will rule).!n U.S. v. Cusamano, 83 F.3d 1247 (10th Cir. 1996) the Court held that
the search warrant which included use of FUR was valid on the basis that there was enough
additional PIC for the warrant. The Court refused to rule on whether the FUR was a search. A few
courts have reached the opposite result on use of FUR saying that it was a search. 12. There is a
conflict in holdings with regard to looking into the interior of a house or an office building through a
telescope or binoculars. Some courts say that it is an invasion on 4th Amendment privacy. See U. S.
v. Taborda, 635 F.2d 131, 138-39 (2d Cir. I 980); People v. Arno. 153 Cal. Rptr. 624 (1979); U. S. v.
Kim, 415 F.Supp. 1252, 1255-57 (D.Haw.1976). But there is contrary authority on telescopic and
binocular observation, stating that it is not an invasion on 4th Amendment privacy. Commonwealth v.
Hernley, 263 A.2d 904 (Penn.l970), and dicta in two Supreme Court decisions, On Lee v. U. S., 343
U.S. 747 (1952), and U. S. v. Lee, 274 U.S. 559 (1927) Several State Supreme Courts upheld the
concept that use of vision enhancing devices such as binoculars or night vision scopes does not
intrude on a reasonable and legitimate expectation of privacy. State v. Carter, 790 P.2d 1152 (Ore.
1990) (reversed in 1988 on othcr grounds), State v. Vogel, 428 N. W.2d 272 (S.D. J988), Saylor v.
State, 365 S.E.2d 493 (Ga. 1988). 13. U. S. v. Knotts, 460 U.S. 276 (1983) police put a beeper on a
suspect's car and used the beeper to trail the car. Court said that since the police could have followed
the car by visual surveillance as it moved around in public areas. monitoring of the beeper signals did
not invade any legitimate expectation of privacy. 19 PUBLIC UTILITY AND BUSINESS
RECORDS 14. Phone company records. Smith v. Maryland, 442 U.S. 735 (1979) said "in all
probability a person had no actual expectation of privacy in the phone numbers he dialed, and even if
he did. his expectation was not legitimate." Consequently, the use of a pen register was not a search
and no warrant was required. (See section on Electronic Surveillance in this manual). Same ruling
U.S. v. Plunk, 153 F.3d 1011 (9th Cir. 1998) "there is no expectation of privacy in phone company
records." 15. United States v. Miller, 425 U.S. 435 (1976) said, "defendant urges he has a 4th
Amendmcnt interest in records kept by (his) bank. Even with original checks and deposit slips, we
perceive no legitimate expectation of privacy." 16. Western Union customers have no privacy interest
in W.U. records as they arc not the customers' property. In re Grand Jury Subpoena Duces Tecum,
827 F.2d 301 (8th Cir. 1987). In U.S. v. Phibbs, 999 F.2d 1053 (6th Cir. 1993) federal officials could
subpoena business records, credit cards and phone company records. The information was accessible
to employees of those companies during the nonnal eourse of business, and there was no standing for
the customers to complain because there was no expectation of privacy. 17. In Commonwealth v.
Cote, 556 N.E.2d 45 (Mass .. 1990) the Massachusetts Supreme Court held that there was no
expectation of privacy in messages taken down by a contracted answering service as use of such
service "necessarily involved a conveyance ofinfonnation to that third party." 18.In State v.
Maxtield, 886 P.2d 123 (Wash., 1994) the Wa~hington Supreme Court held that there was no
expectation of privacy in power consumption records. STOP AND FRISK (lNVESTIGA TlVE
DETENTION): MIDLEVEL CONTACT (I) THE TERRY CASE AND NEVADA STATUTES: In
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1968 the U.S. Supreme Court said in Terry v. Ohio, 392 U.S. 1 (1968) that police could stop (conduct
an investigalive detention where the suspect was not free to leave) a person based on "articulable and
reasonable suspicion" that the person "is committing, has committed or is about to commit a crime,"
even where there is not 40 probable cause for an arrest. If there is reasonable suspicion in addition to
that which justifies the stop which causes you to believe the suspect may be armed, you can pat down
clothing for weapons. Just because "stop" is legal and based on reasonable suspicion doesn't
automatically mean that "frisk" is OK too. Sibron v. New York, 392 U.S. 40 (1968). Terry is codified
in N.R.S. 171.] 23 as follows: 171.123 Temporary detention by peace officer of person suspected of
criminal behavior: Limitations. I. Any peace officer may detain any person whom such officer
encounters under circumstances which reasonably indicate that such person has committed, is
committing or is about to commit a crime. 2. The officer may detain such person only to a~certain the
identity of such person and the suspicious circumstances surrounding his presence abroad. Any
person so detained shall identify himself, but may not be compelled to answer any other inquiry of
any peace officer. 3. No person may be detained longer than is reasonably necessary to effect the
purpose of this section, and in no event longer than 60 minutes. Such detention shall not extend
beyond the place or the immediate vicinity of the place where the detention was first effected. (1969,
p.535; 1973, p.597, 1975). 171.1232 Search to ascertain presence of dangerous weapon; seizure of
weapon or evidence, I. If any peace officer rea~onably believes that any person whom he has
detained or is about to detain pursuant to NRS 171.123 is armed with a dangerous weapon and is a
threat to the safety of the peace officer or another, the peace officer may seareh such person to the
extent rea~onably necessary to ascertain the presence of such weapon. If the search discloses a
weapon or any evidence of a crime, such weapon or evidence may be seized. The question arises as
to whether the police, during a "Terry type stop" can lawfully require that the person identify him or
her self. In Adams v. Williams, 407 U.S. 143 (1972) where the court found that a seizure of the
person had occurred. the court implied that questioning as to the person's identity and a request for
identification were not in violation of the 4th Amendment. In Brown v. Texas, 443 U.S. 47 (1979) the
police arrested Brown when he refused to identify himself. However. the Court noted that the
investigative stop of BrowlI was invaJid because Police had no reason to stop him. The request for 41
identification, refusal and arrest were "fruits of the poisoned tree." In Kolander v. Lawson, 461 U.S.
352 (1983) a Calif state law required a person lawfully stopped by police to produce a "credible and
reliable id," lbe Court held that this language was unconstitutionaJly vague.
Neither case held that it was unconstitutional for police to require identification from a person in a
lawful "Terry Stop." In Martinelli v. City of Beaumont, 820 F.2d 491 (9th Cir. 1987) the court ruled
that officers had reasonable suspicion to stop the person, but the CaJif. Statute allowing arrest if the
person refused to identify himself was unconstitutional. The 9th Circuit Court erroneously construed
the U.S. Supreme Court's decision in Kolander v. Lawson to justity this ruling even though it is clear
that the U.S. Supreme Court has never decided this question. In Albright v. Rodriguez, 51 F.3d 1531
(10th Cir. 1995) thc court ruled that if police made a valid Terry stop, and the person refused to
identity himself, and ifthere was a state statute which aJlowed police to arrest for failure to identify,
then the request for identification, refusal and arrest was constitutionally valid. In State v. Flynn, 285
N.W. 2d 710 (Wisc. 1979), cert. denied 449 U.S. 846 the Court noted language in Adams v. Williams
a stop and frisk case where the Supreme Court said that the officer in a brief(valid) stop "in order to
determine (the suspect's) identity .. may be most reasonable:' The Flynn court noted that unless the
officer is entitled to ascertain the identity of the suspect, the Terry stop can serve no useful purpose.
Same ruling in U.S. v. Basey, 816 F.2d 980 (5th CiT. 1987), State v. Landry, 588 So.2d 345(La.
1991), In U.S. v. Vanicromanee, 742 F.2d 340 (7th Cir. 1984) the Court held that mere detention is
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not an arrest; a police officer may, short of an arrest, detain an individual briefly in order to determine
his identity momentarily while obtaining more information if the officer has articulable facts
sutlicient to give rise to RlS that the person had committed or is committing a crime. The Nevada
Supreme Court has not ruled on this issue although a requirement for identification is in NRS
171.123. The cases of Brown v. Texas and Kolander v Lawson do not rule on the identity
requirement in NRS 171.123 (see detailed explanation in Albright v. Rodriguez). Until the Nevada
Supreme Court rules on this issue, police officers should be selective in arresting for failure to 10
with factors such as the strength of the articulable suspicion for the stop and the type of crime
suspected. For example if police see a person continuously hanging around a grade sehool with minor
children present. a Terry stop is valid. If the person has a prior record for molestation of minor
children it would be devastating for the community if the police officer was not permitted to request
identification. A related issue about police obtaining identification during a valid Terry Stop is 42
whether police can pat down or search the person for documentable 10 such as driver' s license. The
cases in this area are few and the validity of the practice is uncertain. In People v. Long, 254 Cal.
Rptr. 483 (1987), the officer had RlS to stop Long in a bar where he was with an under aged girl. The
officer asked for ID and Long stated his name but said he didn't have any 10. The officer noted a
wallet sized bulge in his rcar pants pocket. again asked for written ID and Long said he had none. The
officer directed Long to look through his wallet, which Long did, and the officer saw some plastic
baggies containing drugs. The Court upheld the officer's demand for written ID, citing Flynn and
Adams v. Williams. Same ruling in People v. Loudermilk. 194 Cal. App.3d 447 (1987) where an
officcr had RlS to stop a person suspected of firing a gun. Pat down felt wallct but pcrson refused to
ID, and in Harperv. State, 532 So. 2d 1091 (Fla. 1988). In State v. Frazier, 318 N. W. 2d 42 (Minn.
1982) an officer stopped a person and took her purse and reached in to get 10 and found a gun. The
gun was suppressed because the court ruled that such a search was unconstitutional without giving
the detainee an opportunity to voluntarily produce !D. (2) WHAT CONSTITUTES A "STOP" AS
OPPOSED TO "NONSEIZURE?" The Hodari D. case and the Bostick case define the pre-stop or
pre-seizure area. Remember a "Terry stop" is a form of seizure - the person is not free to go. Drawing
the line between a "Bostick encounter" and a "Terry stop" has to be done on a case by case basis.
Remember, the defense lawyer will try to push the time ofthe "Terry stop" as early as possible in the
contact when the officer has less articulable suspicion, hoping to persuade the court that you made an
illegal Terry stop and if so, \~iping out your case with a fruit of P.T. argument. CASE EXAMPLES:
I. U. S. v. Garcia, 866 F.2d 147 (6th Cir. 1989), an important factorin distinguishing seizures from
casual contacts is when the person is asked to accompany the police to a place where the person had
not planned to go. An officer may approach a traveler in an airport and ask to speak to him, and
continue that conversation until a reasonable person would no longer feel that the person was free to
go. Once that point has been reached, the officer must have a reasonable articulable suspicion, or else
the stop or detention is illegal. and fruits of that search must be suppressed. Garcia was not seizure
because "there were only two agents present, no weapon was displayed, he was not physically
touched, and the agents did not raise their voices or threaten him in any way." 2. U.S. v. Glass, 128
F.3d 1398 (10th Cir. 1997) has some factors that courts use in determining whether a police-citizen
contact is a seizure. These factors include: (a) Telling a person that he is a suspect for a particular
type of crime (b) The nunlber of officers that are present (e) Moving the conversation from public to
private place or whether the contact 43 is in a public or private place (d) Whether the person is told
that he need not talk to the officers (e) Whether the person's egress was blocked 3. U.S. v. Kim, 27
F.3d 947 (3rd Cir. 1994) utilizing essentially the same factors in the Glass case which had been
related in earlier US Cireuit Court cases held that none of these factors alone is determinative
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regarding whether a 4th Amendment seizure of the person occurs. 4. A few federal cases (pre
Bostick) gave strong weight in their analysis of seizure to a police otlicer's asking directly
incriminating and focused questions, almost to the point of per se rule making such contacts a
seizure. U. S. v. Nunley, 873 F.2d 182 (8th Cir.1989) U.S. v. Jaramillo, 891 F.2d 620 (7th Cir.1989)
However. Nunley was modified by U.S. v. Perdue, 961 F.2d 723 (8th Cir. 1992) and Jaramillo was
reversed by U.S. v. Ornelas-Ledesma, 16 F.3d 714 (7th Cir. 1994)(Both post Bostick cases). 5. U.S.
v. Cardoza, 129 F.3d 6 (1st Cir 1997) Defendant was not "seized" within meaning of Fourth
Amendment be10re police saw him with contraband. even thougb police cruiser turned "'Tong way up
one-way street. making clear officer's intent to come into contact with him, and officers asked him
what he was doing out at that time; reasonable person would not have concluded that he was not free
to leave. as officers did not use flashing lights or sirens, and officers did not ask defendant to stop, or
even to approach patrol car. The result, therefore. "is the directive that police conduct. viewed from
the totality of the circumstances. must objectively communicate that the officer is exercising official
authority to restrain the individual's liberty ofmovement before we can find a seizure occurred." 6.
U.S. v. Rodriguez-Franco. 749 F.2d 1555 (lith Cir. 1985), held that INS agents approached a group
of "Hispanic looking" persons in a mall and asked questions about citizenship and asked (not
commanding) two persons to step over to a bench there was no Terry stop. (This type of police
procedure might arguably have been improper had it been done by other than INS agents. See the
next case). Tn Lopez v. Garriga, 917 F.2d 63 (1st Cir. 1990) an INS agent asked questions of persons
before boarding airlines in Puerto Rico. The Court held that INS agents at an airport gate may,
without violating the Constitution. inquire about a prospective passenger's citizenship and
destination. The mere posing of questions by a government official is not considered to be a seizure.
The Court noted that under federal law, the INS has authority to ask questions of a person they think
may be violating immigration laws. 7. Ozhuwan v. State, 786 P.2d 918 (Alaska, 1990), held that a
Terry stop occurred when an officer partially blocked a person's car with the police car while
activating the overhead lights. 8. U.S. v. Waskal, 709 F.2d 653 (lIth Cir. 1983), held that a Terry
stop occurred when police spokc to a person in an airport and took his ticket and asked him to go to a
44 nearby office without returning the ticket. 9. U.S. v. Tavolacci, 895 F.2d 1423 (D.c. Cir. 1990),
held no Terry stop where an officer knocked on a door to a person's train compartment, asked
permission to ask questions and requested and received a train ticket and personal identification, then
promptly returned them. 10. U.S. v. Torres-Guevara. 147F.3d 1261 (lOth Cir. 1998) Officers
encountered thc defendant at an airport and asked for and received her identification and an airline
ticket. The officers looked at these items returned them immediately and told her she was not under
arrest and could leave. The officers never touched or restrained the woman but asked her twice lor
consent to search for drug:;. When the officer again asked lor permission to search her she did not
respond. The officer asked her again and she again did not respond. The officer then told her if she
had drugs, she should turn them over. Another officer, asked "you have drugs, don't you?" When she
put her head down instead of answering. he asked: "don't you?" She responded:"yes." Police detained
her and had a female police officer search her and found the drugs "Ibe Court
ruled that this was a non-seizure encounter stating that asking incriminating questions does not per se
make this an investigative SlOp although accusatory and persistent questioning, display of weapons,
or commanding or threatcning tonc of voice would amount to an investigative detention. (3) WHAT
CONSTITUTES "REASONABLE SUSPICION?" "Reasonable suspicion" is a term like "probable
cause" which evades precise definition. Although the rules for police-citizen contacts are based on
objective standards, a decision by a court that reasonable suspicion exists depends on the opinion by
that judge (or in the case of an appellate court - a group of judges). The same articulable factors
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which might be no more than a "hunch" in one court's mind may amount to overwhelming reasonable
suspicion in another court's mind. This is a human factor we all have to live with. For example, read
the Case of U.S. v. Mendenhall, 446 U.s. 544 (1980), involving an encounter between police and a
suspected drug courier at an airport. Three Supreme Court Justices thought that the contact between
the police and Mendenhall was a non-seizure contact requiring no justification. Three other Justices
thought it was a Terry stop, but that reasonable suspicion existed. Three other Justices thought it was
a Terry stop, but was illegal because there was not RlS. Otlicers should know the view of the vast
majority of courts about the factors that may indicate RlS and factors which have little or no support
for RlS or PIC. NERVOUSNESS (I) In U.S. v Wood. 106 F.3d 942 (10th Cir 1997) the Court ruled,
"We have 45 repeatedly held that nervousness is of limited significance in determining reasonable
suspicion and that the government's repetitive reliance on the nervousness of either the driver or
passenger as a basis for reasonable suspicion "in all cases of this kind must be treated with caution."
"It is common knowledge that most citizens, whether innocent or guilty, when confronted by a law
enforcement otlicer who asks them potentially incriminating questions are likely to exhibit some
signs of nervousness." Same ruling on nervousness in U.S. v. Peters, 10 FJd 1517, 1521 (10th
Cir, 1993) and U.S. v. Beck, 140 F.3d 1129 (8th Cir. 1998). Sec U.s. v. McRae, 81 FJd 1528 (10th
Cif. 1996) holding that nervousness along with other objective factors may contribute to RlS.
REFUSAL TO COOPERATE (2) In Florida v. Bostick, III S.Ct. 2382 (\991) in addition to holding
that the police contact was non- seizure, the Court also stated that the suspect's refusal to cooperate
with police (i.e.: answer questions and/or consent to search) would not have given the police
reasonable suspicion let alone probable cause to seize the subject or search his luggage. Same
decision by all Federal and State Courts: U.S. v. Fletcher, 91 F.3d 48 (8th Cif. 1996), U.S. v. Torres,
65 F.3d 1241 (4th Cir. 1995), Kames v. 8krutski, 62 F.3d 485 (3rd Cir. 1995) and Gasho v. United
States. 39 F3d 1420 (9th Cir. 1994). TRAINED OBSERVATIONS (3) Several US Circuit court
cases hold that, "when used by trained law enforcement otlicers, objective facts, meaningless to the
untrained, can be combined with permissible deductions from such facts to form a legitimate basis for
suspicion." U.S. v. 8holola, 124 FJd 803 (7th CiT. 1997) and U.S. v. Lujan, I 88FJd 520 (lOth CiT.
1999). (4) U.S. v. Cortez, 449 U.s. 1 (1981), dealt with an investigati()n by the Border Patrol into
smuggling aliens. Over several months, officers saw sets offootprints, one of which had a unique
pattern, coming across the border and ending up near a highway which ran parallel to the border. The
tracks led into obstacles which would have been visible during the day. The tracks turned easlward at
the highway, then disappeared after a short distance. The officers set up a vantage point at night,
about 27 miles east of the location where most of the footprints disappeared into the highway. They
estimated it would take about I Yz hours for a vehicle to pass their location, go to the pickup point and
return to their location. They stopped a pickup with a camper shell which went past and then returned
in that time frame. The U.S. Supreme Court held: reasonable suspicion did exist on these facts to
justify a stop of the truck. Prosecutors should read and cite this case often. It contains language telling
courts that even "innocent" actions when viewed by police otlicers who have knowledge of the
modes or patterns of certain types of criminal activity can give RlS. "A trained officer draws
inferences from data that might well elude an 46 untrained person." "The test for reasonable
suspicion is not in weighed in terms of library analysis by scholars." (5) U.s, v, Lender, 985 F.2d
151 (4th Cif, 1993) officers observed four or five men "huddled on a comer" in a known drug area.
One of the men "had his hand stuck out "ith his palm up, and the other men were looking down
toward his palm." When the group saw the police, they "began to disperse, and the defendant walked
away from the officers "ith his back to them." Based on the hour of the day, the group's dispersal
upon seeing the officers, the known character of the neighborhood, and the officers' practical
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experience in recognizing drug transactions, the court upheld the stop. (6) U.S. v. Mattarlo, 191 F.3d
1082 (9th Cir. 1999) Late at night, an officer WaS on a dark secluded country road and saw a pickup
truck in the driveway of a fenced construction storage area, with the gate closed. The truck left the
drivcway with a threefoot square cratc in the back. At that hour there was no business activity. The
officer stopped the defendant. The Conrt held, "The officer has an objective basis for hi~ suspicions
based on all the circumstances. It is not a matter ofhard certainties, but of probabilities. This requires
more than an officer'S hunch. but a preponderance of the evidence to show proof of wrong doing is
not required at this stage. RlS therefore can arise from information different in quality and content
and even less reliable than that required for the establishment of probable cause. The officer's training
and experience are fitctors 10 consider in determining if the officer's suspicions were reasonable. See
section on Basis for Frisk tor other part of Mattario case (7) U.S. v. Quinn, 83 F.3d 917 (7th Cir.
1996) An officer saw three men on a street comer in a high drug crime area. Upon seeing the officer,
one threw a plastic bag down and they split up and began to walk away. One man went one way and
the other two went in the opposite direction. The officer ordercd Quinn to stop and saw that he was
carrying a leather jacket "wadded up in his arms." He ordered Quinn to accompany him back to the
police car and to place the jacket on the car. As he did so, the officer heard a "thud" sound. He did a
pat-down search finding no weapons then patted the jacket and telt a hard object inside and removed
a .22 rifle sawed-off and modified into a handgun. He arrested Quinn then went to the corner to
retrieve the suspected crack cocaine. The Court held the police action lawful, "the defendant's
presence in a high crime area is an insufllcient ground (by itself) to stop or search. However, courts
may consider the defendant's presence in a high crime area as part of the totality of circumstances
confronting the officer at the time of the stop. DEFINING REASONABLE SUSPICION (8) U.S. v.
Perrin, 45 F.3d 869 (4th Cir. 1995) the court held "reasonable suspicion is a less demanding standard
than probable cause not only because RlS can be established with information that is less in quantity
than that required to show PtC, but also from information that is less reliable than needed for PIC."
47 (9) U.S. v. Hensley, 105 S.Ct. 675 (1985), is important for at least two points. The United States
Supreme Court held that the "fellow officer" rule applies to Terry stops so that the officer actually
making the stop could rely on a "wanted for investigation" flier issued by police in another state so
long as the issuing police had reasonable suspicion. Also, this case extended the authority to make a
Terry stop beyond reasonable suspicion that "criminal activity was afoot" (i.e., a presently occurring
crime) to a serious crime (armed robbery) that had occurred weeks earlier. (10) In Ornelas v. U.S.,
116 S. Ct. 1657 (1996) police in Milwaukee who were trained in drug interdiction saw a 1981
Oldsmobile with California plates in a motel parking lot in December. The police checked the
registered ownt-'T through dispatch and then learned from the DEA that the RIO was in NADDIS
(DEA computer) as a "suspected" drug trafficker. Police learned from the motel manager that Ornelas
and another man checked in at 4am without reservations. Police also knew that older model GM cars
had large spaces in the doors and other locations. The U.S. Supreme Court said that these facts
constituted RlS. The Court said that although the mosaic which is analyzed for RlS or PIC is multi
faceted and one determination will seldom be useful precedent for another a court should look at all
the precedents in making a decision. The court should determine the "historical facts" (ie: the specific
facts oflhe case) and then make a legal decision as to whether the facts satisfY the constitutional
standard. (11) In State v. Sonnefeld, 114 Nev. 631 (1998) the Court ruled that a deputy sheriff had
reasonable suspicion sufficicnt to make investigatory stop of vehicle based on his corroboration of
bartender's detailed tip to dispatcher that inebriated customer had left bar and was driving under
influencc; bartender provided color of car, description of distinguishing roof rack, license platc
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number, physical description of driver and direction in which vehicle was heading, all of which were
confirmed by the officer thereby establishing RlS. (12) Other Nevada cases are
Wright v. State, 88 Nev. 460 (1972). Jackson v. State, 90 Nev. 266 (1974), Nelson v. State, 96 Nev.
363 (1980). and ldelfonso v. Slate, 88 Nev. 307 (1972). All of these required very little in terms of
"articulable facts" to show RlS. ANONYMOUS AND OTHER TIPS (13) Alabama v. White. 110
S.C!. 2412 (1990), held that an anonymous tip that a female would leave a particular apartment
complex at a particular time, would drive a certain described car. would go to a certain destination
and would be carrying drugs was enough for reasonable suspicion when police corroborated the
details of the tip and stopped the car as it neared the destination. It made no difference that all the
actions observed by the police were "innocent." Ms. White's subsequent consent to search, which
turned up the dope, was not the fruit of an unlawful Terry stop. (14) In U.S. v. Price, 184 F.3d 637
(7th Cif. 1999), the Police received an 48 anonymous tip stating that a white Mercury Cougar, with a
license plate containing the letters "FU," would be delivering one kilogram of cocaine to a specific
residence in Milwaukee. The tipster told the police that the ear had left Sheboygan at about 9:00 p.m.
( About 60 miles from Milwaukee.) and also stated that the ear would contain two black women,
Charlene and Patricia, and one black man named Calvin (also gave last names) Police arrived at the
vicinity of the suspect residence in an unmarked car at around 10:45 p.m .. The officers did not verity
who lived at the residence. and did not perform record checks of three people named by the tipster.
At approximately II :20 p.m., a white Mercury Cougar arrived containing two black women and two
black men. The driver double-parked the car and left the engine running. The license plate contained
the letters "GJl.." All four occupants got out and approached the residence. Police stopped them at
the sidewalk and indicated that they were investigating a narcotics complaint. Several ofthe
occupants produced ID confirming the names given by the informant. Later, narcotics were found.
The Court held that the stop was based on R/S.( Alabama v. White.). (15) [n U.S. v. Bell, 183 F.3d
846 (8th Cir. 1999) Police acted on a tip from Ms. Harris. who provided detailed information that
criminal activity was afoot. "Harris was a close acquaintance of Bell who had previously provided
accurate information about him. Harris's tip--that Bell and Ingram were driving to Little Rock to pick
up crack cocaine from Linda Bee--was consistent with information received from other sources less
than a month earlier and with more recent information that Bell and Ingram were seIling drugs at
23 \ 4 Jean Street. The tip was further corroborated when the oflicers saw a car matching the
description Harris had provided traveling on U.S. Highway 65 in the direction of Pine Bluff. "
Considering the totality of the circumstances, we agree with the district court that the stop did not
violate Bell's Fourth Amendment rights." INDIVIDUAL SUSPICION (16) Ybarra v. Illinois, 100
S.Ct. 338 (1979), wa~ a case where police had a search warrant for a tavern and the bartender, based
on probable cause, that he was selling drugs at the bar. Police entered the tavern during business
hours to serve the search warrant, and patted down the patrons. One of the patrons was Ybarra who
had dope in his pocket which was seized. The United States Supreme Court held: illegal search - no
reasonable suspicion that Ybarra was engaged in criminal activity andlor that he might have a
weapon, just because he was in the bar. Reasonable suspicion and probable cause must be
individualized. (17) A recent ease demonstrates the rule that reasonable suspicion must be
individualized. The difference was whether the RlS did or did not cover more than one person. In
U.S. v. Johnson, 170 F.3d 708 (7th Cir. 1999) police were approaching a residence for a "knock and
talk:' As they arrived, a person exited the residence and was Terry stop detained by police. The
detention and pat down were held to be unlawful because there was no individualized suspicion a~ to
that person. 49 REASONABLE MISTAKE OF FACTS Two cases show that reasonable suspicion
can be found in a case where the police were mistaken about the facts justifying the detention, but the
- 20 Motio:'l [or Sanc:ti ons
announced that they were officers and told defendant to stop. (4) "PROFILING" Quite a bit of
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confusion exists in police circles concerning "profiling" but modern cases make the correct legal
consequences quite clear. In a nutshell. when officers make a stop based on profiling, the fact that
profiling was used has no legal significance at all. It doesn't help or hurt the validity of the stop. This
was the holding of the U. S. Supreme Court in Sokolow. Lin United States v. Sokolow, 109 S.Ct.
1581 (1989), DEA agents stopped the suspect at Honolulu Airport because (I) he had paid $2,100
cash for airline tickets, (2) he traveled under a name that did not match the name under which the
phone number he used was listed, (3) his destination had been Miami which was a "source city", (4)
he stayed in Miami only 48 hours, (5) he appeared nervous and (6) he had no checked luggage. DEA
found I kilo of cocaine in his carry-on luggage after a trained drug sniffing dog alerted on the
luggage and DEA obtained a search warrant. Held: Reasonable suspicion for a Terry
stop existed. Although each factor taken alone was insufficient to justify a stop, when taken together
they amount to reasonable suspicion. The "profile" factors shown here are "probative" and amount to
reasonable suspicion even though none of them are "criminal". The fact that the person fit a "profile"
did not in and of itself equal reasonable suspicion. 51 2. In Karnes v. Skrutski, 62 F.3d 485 (3rd Cir.
1995) the Court ruled that "the drug courier profile has little meaning independent of the objective
facts" presented by the law enforcement officer as sufficient to demonstrate reasonable suspicion. In
other words, the factors that the law enforcement officer uses to establish PIC or RfS must be
articulated (ie: specified) based on the circumstances of each case. The profile itself does not provide
any additional support tor finding PIC or RlS. Same ruling in U.S. v. Malone, 886 F.2d 1162 (9th CiT.
1989), U.S. v. Moore, 22 F.3d 241 (lOth Cir. 1994) and U.S. v. $53,082 in US Currency, 985 F.2d
285 (6th Cir. 1993) as well as numerous state supreme court cases. 3. See the section on "Pretext
Stops" in this manual. The modern law based on the Whren case from the U.S. Supreme Court and
Gama case from the Nevada Suprenle Court make it clear that as long as an officer has any objective
basis for making a stop. the officer's internal motives are irrelevant. This means that an officer can
make a stop based on a "profile" but ollly so long as there is some other basis for the stop. There is no
longer any such thing as an illegal pretext stop. 4. Use of indicators such as membership in certain
racial groups in drug courier profiling has been sharply challenged. "Defendant's nationality
(Mexican) and his friends' use of Spanish cannot support reasonable suspicion of smuggling drugs"
according to United States v. Garcia, 23 F.3d 1331 (8th Cir. 1994). (5) WHAT FORMS THE BASIS
TO FRISK? The right to frisk is not generally automatic with a valid "stop." LIn Sibron v. New
York, 392 U.S. 40 (1968) and Ybarra v.llIinois. 444 U.S. 85 (1979) the U.S. Supreme Court said that
the general rule is that a "frisk" is not always justified because the "stop" is justified. The officer has
to be able to point to particular facts that made him think the suspect "may be" armed. 2. In
Minnesota v. Dickerson, 113 S.Cl. 2130 (1993), the "plain feel" case, Justice Scalia's concurring
opinion makes it clear that the right to "frisk" does not automatically accompany the right to "stop."
(This is the opposite of "search incident to arrest" rule which does automatically accompany any
lawful custodial arrest.). 3. Adams v. Williams, 407 U.S. 143 (1972), held that where a reliable
informant told an officer that a person sitting in a parked car had a concealed weapon. The officer
asked the person to step from the car. but instead Adams rolIed down the window. The officer
reached in the window to his waistband and felt, then seized. a gun. This was enough reasonable
suspicion for a stop and frisk. 4. In U.S. v. Mattarolo, 191 F.3d 1082 (9th Cir. 1999) the Court ruled
that an officer may conduct a limited protective search for concealed weapons if there is a reason to
believe the suspect may have a weapon. The officer must choose between being sure that the suspect
is not armed and jeopardizing his own safety. An officer making a stop 52 under the suspicious
circumstances of the present case who failed to patdown the suspect for weapons within the limited
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scope of Terry could be taking substantial and unnecessary risks." Distinguishing an earlier case, the
Court that the stop in that case was in a bank parking lot during the daylight hours, not on a remote
section of road at midnight. The person stopped was a suspected counterfeiter, not a suspect caught
possibly in the act of committing a nighttime burglary and therefore more likely to be armed. In
Mattarolo, the defendant got out of his car swiftly and walked quickly toward the squad car before
tbe officer had the chance to get out of his car. This caused the officer to get out of his squad car
quickly so as not to be trapped with the means of protecting himself consequently limited. Given the
totality of the circumstances, the patdown search was fully justified and a provident procedure to
follow. 5. In U. S. v. Sinclair, 983 F.2d 598 (4th Cir. 1993) the Court held that "the officer's
reasonable belief may derive as much from his experiences in similar cases as from his knowledge of
the dangerous propensities of the suspect at hand." 6. In U. S. v. Gibson, 64 F.3d 617 (11th CiI. 1995)
the Court said that where the officer had corroborated every item of information from an anonymous
tipster about a certain suspect, the officer had reason to believe the tipster's statement that the suspect
was armed. 7. In U.S. v. Taylor, 162 FJd 12 (1st Cif. 1998) the Court ruled that Informant's tip that
occupants of automobile were in possession of crack cocaine and weapons and were delivering
narcotics exhibited sufficient indicia of reliability to justifY investigatory stop of automobile and frisk
of the occupants; informant had provided reliable information in the past, tip included such details as
make and color of car and description of its occupants, and tip was corroborated in significant aspects
by the officer. 8. In U.S. v. Campbell, 178 FJd 345 (5th Cir. 1999) the Court ruled it was not
unreasonable for police officer to draw his weapon, order armed bank robbery suspect to lie on
ground, handcuff suspect with his hands behind his back, and frisk suspect during course of
investigatory stop, even though suspect complied with officer's orders and robbery had occurred
approximately 30 hours prior to stop; suspect matched description of armed bank robber and he was
getting into driver's side of automobile matching description of getaway car, there were other people
in area during stop, and there were only three officers to control three suspects. REMEMBER - A
FRISK CAN ONLY BE DONE FOR WEAPONS, NOT FOR ANY OTHER ITEMS OR
CONTRABAND. HOWEVER, [F THE FR[SK IS DONE WITH RJS THAT A WEAPON IS
PRESENT, BUT AFTER REMOVING THE ITEM THAT "FELT LIKE" A WEAPON, THE
POLICE FIND THAT IT WAS NOT ACTUALLY A WEAPON, THE SEARCH & SEIZURE IS
STILL VALID 9. U.S. v. Raymond, 152 F.3d 309 (4th eir. 1998) Police stopped a car for speeding.
Raymond was a passenger and the police ordered him out of the car. He got out clutching his
stomach. The officer patted him down and felt a large disc like object which he thOUght might be a
weapon. It turned out to be a 7" rock cocaine disk. The 53 court ruled that the circumstances gave rise
to an articulable suspicion that he might have been armed with a weapon. There was a reasonable
basis for conducting a patdown search based on his strange exit from the car, as ifhe were attempting
to conceal something under his jacket, and the awkward way in which he leaned against the car while
talking to police. 10. U.S. v. Rahman, 189 F.3d 88 (2d CiI. 1999) the Court held that seizure of
forged passports by agents was reasonable, where agents learned that vehicle used in bombing of
office building in New York City had been rented by person listing his address as suspect's address,
agents obtained warrant to search such address, agents observed suspect returning to the building at
accelenited pace when they entered to search, suspect resisted being frisked, and agents felt firm
rectangular object in his pocket that they could have reasonably expected was an explosive device,
but turned out to be envelope containing passports. 11. U.S. v. Edwards, 53 F.3d 616 (3rd Cir. 1995)
the Court ruled police were justified in conducting Terry protective patdown for weapons and
opening envelope found in pocket of jacket on defendant's lap. Police responded to report of credit
card fraud in progress, and were justifiably concerned that small-caliber handgun could be concealed
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in envelope, which measured four by six inches and felt from outside as if it held hard, bulky object.
(found stolen credit cards-OK). 12. U.S. v. Strahan, 984 F.2d 155 (6th Cif. 1993) the Court
recognized the rule that where an officer is doing a lawful "frisk" and feels an object that reasonably
appears to be some sort of weapon, the officer can remove that item, and if it tums out that it was not
actually a weapon, but is contraband, the seizure of the contraband is lawful. (Bulge and hard item
turned out to be money clip) 13. In U.S. v. BrmA-n, 188 F.3d 860 (7th Cir. 1999) the Court ruled that
Officer had articulable grounds for RlS that person in a traffic stop might be armed and dangerous, to
justify an initial pat-do\\.-n search; circumstances included officer's knowledge ofFBl surveillance of
the vehicle as a possible part of a large-scale drug operation, the smell of marijuana smoke from the
car, driver's very nervous demeanor, his failure to makc eye contact, his glancing back to the vehicle,
where the other occupants rolled down the tinted windows during the traffic stop, and the fact that the
stop occurred in a high crime area where there was gang and drug activity and had been recent
shootings. Nervousness, refusal to make eye contact or high crime area alone will not justify a Terry
stop and pat-down. but such behavior may be considered as a faclor in the totality of circumstances.
The Court justified a pat-down search following traffic stop which disclosed a hard object about the
size of a ping-pong ball in suspect's groin area. "It was reasonable for officer to think object was the
butt of a gun, even if omcer would have been more reasonable to think the object was drugs." 14.
U.S. v. Campbell, 178 F.3d 345 (5th Cir. 1999) Court held removal, during 54 course of investigatory
stop, of contents of suspected anmed bank robber's pocket was reasonable and within scope of
permissible Terry frisk, where police officcr had not ruled
out possibility that large bulge, formed by over $1 AOO in currency and cardboard box containing
gold chain. was a weapon. Note: Officers should be aware that an item encountered and lawfully
removed during a "frisk" does not generally give the right to open the item unless it might reasonably
contain a weapon. Otherwise, if it is opened, evidence will be suppressed unless there was
justification. (Remember: RIS is enough to get weapons but PIC + consent or a S/W is needed to get
contraband or evidence. Beware of a pretext arrest to get authority to search) ~The need to discover
weapons cannot justifY opening the matchbox"Pace v. Beto, 469 F.2d 1389 (5th Cir. 1972, same
ruling regarding small pouch People v. Martinez, 801 P.2d 542 (Colo. 1990) and cigarette case in
C.1I. v. State, 548 So.2d 895 (Florida, 1989) Please refer to the "Plain View" section in this manual
under subject of "Immediately apparent," for discussion on "single purpose" containers. The
theoretical distinction between "stops" and "frisks" (that each requires its separate justification) is
sometimes blurred, although the court's decision is correct, for example: 15. In Rusling v. State, 96
Nev. 778 (1980), a police officer saw a person with a car parked in the road, trunk and door open,
walk across the street to a truck where a rubber hose led from the gas tank to a gas can. The suspect
fled and the officer broadcast a description. Another officer stopped the suspect (based on matching
description and location) about one hour later. The suspect was patted down and a gun was found.
Defendant was charged with possession of a firearm by ex-felon. On the pat down issue, the court
said: "The officer need not be absolutely certain that the individual is armed (Terry). The officer had
reasonable grounds to anticipate danger to himself or the other omcer. The suspcct met the
description of one who was possibly engaged in auto theft. The suspect fled and was hiding. The stop
occurred late at night. All these factors led the officer to conclude reasonably that the suspect was
involved in criminal conduct. Therefore, it was not improper for him to infer the possibility of a
concealed weapon." Certain Types of Crime Do lustifY an "automatic" Frisk Many, but not all, courts
hold lhat certain types of criminal activity are commonly associated with weapons, thereby justifying
a frisk for weapons if there is reasonable suspicion of that type of criminal activity. For example,
"high level" drug dealing has been viewed this way in the following cases: U.S. v. Brown, 903 F.2d
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540 (8th Cic. 1990), People v. Lee, 240 Cal. Rptr. 32 (19&7). U.S. v. Peay, 885 F.Supp. 1 (DC D.C.
1995). l.l. S. v. McMurray, 34 FJd 140555 (8th Cir.1994) and U.S. v. Salas, 879 F.2d 530 (9th Cir.
1989) U.S. v. Price, 184 F.3d 637 (7th Cir.1999). Violent domestic disputes can qualify, People v.
Barber, 537 N.E.2d 1171 (Ill. 1989), State v. Vasquez. 807 P.2d 520 (Ariz. 1991). Armed robbery:
U.S. v. Abokhi, 829 F.2d 666 (8th Cir.l987) and U.S. v. Lang. 81 F.3d 1405 (8th Cif. 1994).
Burglary: U.S. v. Walker. 924 F.2d I (1st Cir. 1991). U.S. v. Moore, 817 F.2d 1105 (4th Cir. 1987).
(6) "PLAIN FEEL" Minnesota v. Dickerson, 113 S.Ct. 2130 (1993), is the so-called "plain feel" case.
Unilormed police were on patrol at night near an apartment building knovm to them as a hotbed of
drug dealings. Police had served several drug search warrants at that building and had citizen
complaints of drugs being sold in the hallways. Dickerson was observed leaving the building and
walked toward the marked police car. Upon seeing the police. he turned and abruptly walked the
other way and entered an alley. The officers made a "Terry stop" on Dickerson and also "frisked"
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him. While "lrisking" Dickerson, one oificer felt something in his pocket which the officer slid
around and manipulated. then removed a plastic bag containing 115 gram ofrock cocaine. (The
legality of the "slOp" and thc decision to "frisk" were not an issue before the United States Supreme
Court. It was assumed. but not directly held by the Court, that they were valid.) The issue is whether
and when "plain feel" would allow officers to legally seize items other than suspected weapons. The
Court held as follows: assuming that there is a legal stop and a legal frisk, and during the frisk the
oUicer feels an item that is not a suspected weapon. then if it is immediately apparent from the mass
and contour that the item is probably contraband, the officer can legally seize it (without having to
arrest the person and rely on search incident to arrest). In Dickerson, the Court ruled that the rock
cocaine would have to be suppressed, because the officer continued feeling and frisking after the
officer already concluded no weapon was in the pocket - i.e., plain feel means immediately apparent.
In U.S. v. Proctor, 148 FJd 39 (lst Cir. 1998) police had lawfully entered a premises and seized a
large package of marijuana. About 15 minutes later. Two persons knocked on the door and were
admitted entry. The oUicer patted them down and felt what he thought was a plastic bag containing
marijuana. The Court upheld the frisk and also the seizing of the marijuana based on the officer's
experience and the fact that the persons entered a drug house just after the drugs arrived. In State v.
Conners, 116 Nev. __, 994 P2d 44 (Feb 4, 2000) an officer lawfully stopped and frisked Satan
Renee Conners. After ruling out a weapon the officer changed his grip on a pocket to determine what
an object was and removed a small vial of methamphetamine. The item was suppressed based upon
the Dickerson ruling. Westlaw computer research discloses that many federal courts have followed
the 56 rule established by Minnesota v. Dickerson and that more than 90% of State Supreme Courts
which have dealt with the issue have adopted the same rule. (7) WHAT LIMITS EXIST ON THE
SCOPE AND INTENSITY OF THE STOP? The General Rule In U.S. v. Sharpe, 105 S.Ct. 1568
(1985), a DEA agent developed reasonable suspicion that one of two vehicles traveling in tandem on
a highway was smuggling drugs. The agent got help from a state trooper and a passenger car was
pulled over. The pickup truck suspected to contain the drugs could not be pulled over tor several
miles. The police units lost radio contact and the pickup truck and its driver were detained about 15
minutes before an agent arrived, smelled marijuana and developed probable cause. The criminal
claimed that this time deJay converted the "stop" into an "arrest" and since there was only reasonable
suspicion and not probable cause. he claimed there was an unlawful arrest. The Court held: no arrest
until after the sniff of marijuana - scope of Terry stop was OK. The Court said a Terry stop was a
temporary detention (as opposed to an arrest) and that the scope was lawful as long as the police
diligently pursued a means of investigation that was likely to confirm or dispel their suspicions
quickly. NOTE: In Sokolow. the United States Supreme Court held that the investigative means used
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by police to confinn or dispel suspicion do not have to be the least intrusive means possible - only
that they be "reasonable" means. U.S. v. Owens, 167 F.3d 739 (1st Cir 1999)50 minute detention of
driver and passenger after stop of antomobile for speeding was not so long as to convert investigative
stop into de facto arrest. Length of detention was reasonable under thc circumstances: driver did not
have valid driver's license, need to detennine whether passenger had authority to drive the
automobile, and otlicers' diligent pursuit of means of investigation that would dispel their suspicions.
"The penn issible scope of the detention depends on the facts and circumstances of each case, but in
every case it must be temporary and last no longer than necessary to effectuate the purpose of the
stop:' U.S. v. Sandoval, 29 FJd 537 (J Oth Cir.l994). This rule is the same as set forth in Nevada
Law. But, note that Nevada places an absolute limit of 60 minutes for a Terry stop. See also
Washington v. State, 94 Nev. 181 (1978). N.R.S. 171.123\. Arrest if probable cause appears. At any
time after the onset of thc detention pursuant to NRS 171.123, the person so detained shall be arrested
if probable eause for an arrest appears. If, after inquiry into the circumstances which prompted the
detention, no probable cause lor arrest appears, such person shall be released. in the course of the
detention, further infonnation comes to the knowledge of 57 the otlicer which amounts to"P/C" to
arrest (i.e., more facts than needed tor reasonable suspicion), then you can arrest. In report writing, be
sure to differentiate initial stop as investigatory detention and when and how it escalated into an
arrest. Non-Search Examination In U.S, v. Martin, 806 F.2d 204 (8th Cir. 1986), where an officer
looked through the window of a suspect's pickup truck and saw machine gun parts -- he could scize
them without warrant, or in Texas v. Brown, 460 U.S. 730 (1983), where police shined a flashlight
into a person's car which was stopped at a routine traffic check point and saw white powder and
balloons. This rule was applied in State v. Herbert Wright, 104 Nev. 521 (1988). Temporary Seizure
of Items Reasonable suspicion can support a temporary seizure (without a search) of personal items
such as the suspect's suitcase in U. S. v. Place, 462 U.S. 6% (1983) (although in Place, the 90-minute
detention of the suitcase was too long for an investigative seizure with RlS, but without probable
cause). An ofticer's removal of a suitcase from a baggage area conveyor belt, squeezing the bag and
then sniffing the bag was neither a search nor a seizure. U.S. v. Garcia, 42 FJd 604 (I Oth Cir. J994)
"The temporary moving of unattended luggage from one area of a bus to another to facilitate a dog ,
sniff is not a seizure." U.S.
v. Graham, 982 F.2d 273 (8th Cir. 1992) "The defendant's only interest was that the airline would
place his luggage on the next airplane. The police process of taking the luggage from a cart to an
office and having the dog sniff it was completed prior to the time the luggage would have been
placed on the airline. There was no seizure of the luggage until after the dog alerted." U.S. v,
Furukawa, 99 FJd 1147 (9th Cir.1996) Same result in U,S. v. Ward, 144 FJd 1044 (7th Cir. 1998).
Conducting a one-on-one at the scene or elsewhere. NOTE: NRS 171.123 says in Nevada the "one on
one" must be at place where suspect detained. Although no emergency exception is listed in Nevada
statutes. probably it would be OK to transport the suspect (assuming RlS) to the victim if the victim
couldn't be transported, A 39-minute detention 01'2 sexual assault suspects, including transportation
to a hospital to be viewed by the victim, was valid where based on RfS. At least 25 minutes of the
detention was due to completion of the victim's treatment at the hospital before viewing the suspects.
Police were acting diligently to pursue a means of investigation, namely, display of the defendants to
the victim while her memory was still fresh, which was likely to confinn or dispel their suspicion
quickly, and this means of investigation 58 obviously required the reasonable detention of the
defendants." State v. Mitchell, 507 A.2d 1017, Conn. 1986), (8) USE OF WEAPONS OR
HANDCUFFS IN DETENTION Numerous cases have held that display of weapon or handcuffing
suspect does not in and of itself convert a "detention" into an "arrest" (although these things tend to
If:
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push in the direction of arrest-sec "levels of contact" factors) but you must be able to articulate why
these means were employed (things such as suspicion directed at crime of violence, detection
occurred at night, isolated area otIicer alone, risk of flight), Handcuffs okay, U. S. v. Bautista, 684
F.2d 1286 (9th Cir. 1982). Same result in U.S. v. Blackman, 66 F.3d 1572 (11th Cif. 1995) and also
in U.S. v. Tilmon, 19 F.3d 1221 (7th Cir. 1994) Placing suspect in police car did not equal an arrest.
State v. Braxton, 495 A.2d 273 (1985). Same result in U.S. v. Cannon, 29 F.3d 472 (9th CiT. 1994).
In U. S. v. Merritt, 695 F.2d 1263 (lOth Cir. 1982), the Court held that pointing a gun at a suspect
stopped on a reasonable suspicion of criminal activity does not necessarily turn the encounter into an
arrest requiring probable cause. A pickUp truck believed to contain a murder fugitive and 2 other
persons was surrounded by at least 12 officers, and as many as three pointed guns at the suspects.
This show of force was not unreasonable, considering the potential danger faced by the officers. One
of the persons believed to be in the truek was wanted for murder, and the police had been advised that
he was dangerous and heavily armed. Also, the police had just been to a house where the suspect was
thought to reside, and observed a large assortment of deadly weapons and ammunition, The same
circumstances supported a "frisk" of the pickUp truck for weapons. Merritt has been followed in
numerous other cases: U. S. v. Hardnett, 804 F.2d 353 (6th CiT. 1986)(C/1 said 4 armed men were in
car); U. S. v. Roper, 702 F.2d 984 (lIth Cir. \ 983)(bail jumper); U. S. v. Perate, 719 F.2d 706 (4th
Cir. 1983); U. S. v.Jones, 759 F.2d 633 (8thCir.1985); U. S. v. Trullo, 809 F.2d 108 (1st CiT. 1987),
U.S. v. Alvarez, 899 F.2d 833 (9th Cir. 1990) (possible bank robbery and explosives); U.S. v. Taylor,
857 F.2d 21 0 (4th Cir. 1988) (RIS stop and police knew person had been convicted fOT assault with.
intent to murder and robbery); U.S. v. Tilmon, 19 F.3d 1221 (7th Cir. 1994)(RlS stop of bank robber
who threatened use of explosives; U.S. v. Cole, 70 F3d I I3 (4th Cir. 1995) (police suspected car
occupants had a large amount of drugs and might be armed). In Houston v. Clark County, 174 F.3d
809 (6th Cif. 1999) the Court held that it was valid for the officer, after a RlS stop to handcuff a
suspect in a serious violent crime, but the length and manner ofthe officer's conduct must be related
to the initial basis for the stop; Same ruling in U.S, v. Campbell, 178 F.3d 345 (5th Cir. 1999) valid
for officer (with RlS for the stop) to draw gun and handcuff the suspect who was in a car with the
license number of a recent armed robbery. In U.S. v. Navarrete-Baron, 192 FJd 786 (8th Cir. 1999)
the Court held that 59 police officers did not exceed scope of Terry stop when they handcuffed
occupants of automobile and placed them in separate patrol cars while officers searched automobile;
there were two suspects and only two officers at scene, detention did not last for unreasonably long
time, and in light of dangerous nature of suspected crime of drug trafficking and good possibility that
driver or passenger had weapon, their confinement with handcuff.~ in back of patrol cars during
search was reasonably necessary to maintain status quo, protect otIicers, and allow them to conduct
search immediately and Vvithout interference. In U.S. v. Maza-Corrales, 183 F.3d 1116 (9th CiT.
1999) Drug enforcement agents' temporarily detaining defendant with the use of handcuffs for IS to
30 minutes while questioning him, was reasonable and did not escalate into a full-blown arrest, given
relatively small number of officers present at scene, fact that weapons had been found and more
weapons potentially remained hidden, fleeing persons were on the loose, uncooperative persons were
inside the residence, an armed lookout was outside and blew a car hom when DEA came. The Court
held that "intrusive and aggressive police conduct will not be deemed an arrest in those circumstances
when it is a reasonable response to legitimate safety concerns on the part of the investigating otIicers.
When we make such judgments, common sense and ordinary human experience rather than brightline rules serve as our guide, and we recognize that "we allow intrusive and aggressive police conduct
without deeming it an arrest in those circumstances when it is a reasonable ... "
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Also, where is the proof of service on dda youngs filings? Why should all other litigants have to
comply with such technicalities. DDA Young gets paid enough and has enough staff to comply just
like everyone else must. Docs the Reno Justice Court have a corollary to WDCR 10, requiring and
Index to Exhibits and cover pages for exhibits?
3
According to the court in In re Watts, 557 A.2d 601 (D.C. 1989), a remand would be necessary in the
case of an applicant who had been convicted of theft, a second-degree felony, and sentenced to an
4
indeterminate term of not less than one. nor more than 15, years and fined $1,500, where the state
5
committee failed to conduct sufficient inquiry or to consider adequately the evidence concerning the
applicant's present moral character and fitness to practice law. In so ruling. the court pointed out that
6
a county attorney in Utah, thc state in which the conviction had occurred, initiated proceedings,
pursuant to its discretion. to expungc both of the applicant's convictions. Subsequently, the court
stated, the Utah Supreme Court ordered both of the convictions expunged after finding that the
8 applicant had been rehabilitated and the expungements would not be against the puhlic interest.
Moreover, the court indicated, the state of Utah also admitted the applicant to its bar where he had
9
practiced for approximately two years without incident, the court adding that he had been active in
10 his community, working with the bar, representing indigents, serving on the Board of Directors of the
Children's Center, and undertaking other volunteer activities. Reasoning thusly, the court ordered that
11
the case be remanded to the committee to conduct an independent investigation of, and to make
further findings as to, the applicant's current moral fitness to practice law in the District of Columbia.
12
-the court, denying certification of a bar applicant who had been involved in theft and petjury
13 offenses, riected the applicant's claim that he had reformed himself. the court commenting that the
fact that he was an adult when the al..'tions complained of occurred caused it to approach the
applicant's claim with caution, the court adding that the applicant was a tirstyear law student when he
stole a shirt and perjured himself; one who has set on that final stagc of formal training for admission
15
to the bar is not still to be treated as a youth, who does not yet recognize and adhere to the
rudimentary requirements of legal and moral behavior, and members of the bar can be assumed to
16
know that certain kinds of conduct, generally condemned by responsible people, will be grounds for
17 disbarment, thc court stating that while the applicant submitted letters from several members of the
profession in support of his application, and while the applicant's academic accomplishments and
18
other positive qualities were present, if the court is not convinced that an applicant can withstand
these temptations. it would be remiss to admit the applicant. the court concluding that doubt of
19
consequence must be resolved in favor of the protection of the public, as a result of which the
20 applicant would be denied admission at the present time. Application of Taylor. 293 Or. 285. 647
P.2d 462 (1982)--in a case in which a bar applicant engaged in thievery of a repetitive nature, the
21
court denied the applicant's application since it appeared that the applicant had not undergone the
22 requisite rehabilitation of his good moral character. the court pointing out that the crux of the
applicant's case was that his present moral character fitness justified his admission to the bar and that
23 his repetitive thefts were the result of a temporary aberratio~ that no longer existed and of which
there was no danger of recurrence under the stress of representing clients; the evidence of
;;4
rehabilitation in the case rested primarily on the opinion of a psychologist, yet the report furnished no
insight into why a 26-year-old coUege graduate who had completed one year of evening law school
25
study would repeatedly engage in petty thievery while an invitee in the homes of his customers, and
26 the report offered no explanation of how this compulsion, if indeed it were a compulsion, had been
treated, the court adding that it fumished no reasons why the applicant's rehabilitation should be
27
considered full and complete. Application of G. S., 291 Md. 182,433 A.2d }159 (I 98 I)According to
the court in In re Bar Admission of Rippl. 250 Wis. 2d 519,2002 \VI 15,639 N.W.2d 553 (2002) , a
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bar applicant who had been convicted of misdemeanor theft presented sufficient evidence supporting
her rehabilitation, and would therefore be admitted to the Bar of Wisconsin. The court stated that
while it appreciated that the board of bar examiners may have felt constrained to iind that the
applicant's various infractions precluded certifYing her character and fitness for the purposes of bar
admission, it was nonetheless of the opinion that incidents the board relied upon, while certainly
troubling. were not of suflicicnt gravity to warrant a conclusion that the applicant should be forever
barred from admission to the practice of law in the state. In so ruling, the court commented that it was
influenced by the applicant's strong academic record, which she achieved while working several jobs
and performing extensive community service, the court adding that it was also influenced by the
applicant's evidence of rehabilitation as reflected in the glowing testimonials provided by numerous
employers for whom the applicant had worked. Moreover. the court remarked, it did not appear that
the applicant willfully failed to disclose any relevant information on her bar application, and the
negative effect of her earlier conduct was diluted by the questionable reliability of some of the
information concerning that conduct. The court concluded that the applicant's record, while troubling
in certain of its particulars. was not sufficient, when reviewed in the context of this proceeding, to
warrant the conclusion that she failed to establish the requisite character and fitness to be admitted to
the practice of law in WisconsinIn Florida Bd. of Bar Examiners Re: L. K. D., 397 So. 2d 673 (Fla.
1981), a proceeding instituted on a petition for bar admission, the court held that the findings of the
hoard of bar examiners with respect to an incident in which a bar applicant was charged with, and
was later acquitted of, shoplifting, was not alone sufficient to bar the applicant's admission to practice
of law. The applicant'S jury acquittal, the court noted at the outset, while not binding on the board or
on the court in reaching conclusions regarding the alleged incident of theft itself, had special
significance with regard to the board's conclusion that the applicant lied three times in asserting her
innocence. That is. the court remarked, the jury's conclusion vindicated the applicant's declaration of
innocence of the crime charged before and at the jury trial, the court adding that her acquittal would
continue to justifY her protestation of innocence at her subsequent board hearing, even though the
board might have thought it advantageous to make a showing of repentance. The court concluded that
the applicant had carried her burden of demonstrating good character, and had shown a present
fitness to enter the practice of law, as a result of which her petition for admission would be granted.In
Application of Allan S., 282 Md. 683,387 A.2d 271 (1978). the court held that an applicant for
admission to the Maryland Bar who had been convicted in the past established his "present" moral
character fitness where there was no evidence in the record even remotely 3 A.L.R.6th 49 Page 21 3
A.L.R.6th 49 (Originally published in 2005) 2011 Thomson Reuters. No Claim to Orig. US Gov.
Works. suggesting that he had been involved in any misconduct in the years following his theft
offense and where he presented convincing evidence, including a letter from his attorney-employer,
of his rehabilitation. The ultimate test of present moral character, applicable to original admissions to
the bar. is whether, viewing the applicant's character in the period subsequent to the applicant's
misconduct. he has so convincingly rehabilitated himself that it is proper that the applicant become a
member of a profession that must stand free from all suspicion. That the absence of good moral
character in the past is secondary to the existence of good moral character in the present is a cardinal
principle in considering applications for original admission to the bar, the court concluded.!n
Application of Allan S.. 282 Md. 683. 387 A.2d 271 (1978), the court held that an applicant for
character fitness where there was no cvidence in the record even remotely 3 A.L.R.6th 49 Page 21 3
A.L.R.6th 49 (Originally published in 2005) 2011 Thomson Reuters. No Claim to Orig. US Gov.
Works. suggesting that he had been involved in any misconduct in the years following his theft
~~Gti()n
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offense and where he presented convincing evidence. including a letter from his attorney-employer,
the bar, is whether, viewing the applicant's character in the period subsequent to the applicant's
misconduct, he has so convincingly rehabilitated himself that it is proper that the applicant become a
character in the past is secondary to the existence of good moral character in the present is a cardinal
principle in considering applications for original admission to the bar, the court concluded.!n
Application of Allan S., 282 Md. 683, 387 A.2d 271 (1978), the court held that an applicant for
A.L.R.6th 49
misconduct in the years following his theft offense and where he presented convincing evidence,
including a letter from his attorney-employer, of his rehabilitation. The ultimate test of present moral
character, applicable to original admissions to the bar, is whether, viewing the applicant's character in
the period subsequent to the applicant's misconduct, he has so convincingly rehabilitated himself that
it is proper that the applicant become a member of a profession that must stand free from all
suspicion. That the absence of good moral character in the past is secondary to the existence of good
moral character in the present is a cardinal principle in considering applications for original
admission to the bar, the court concluded.ln Application of Allan S., 282 Md. 683,387 A.2d 271
(1978), the court held that an applicant for admission to the Maryland Bar who had been convicted in
the pa.~t established his "present" moral character filness where there was no evidence in the record
even remotely 3 A.L.R.6th 49 Page 21 3 A.L.R.6th 49 (Originally published in 2005) 2011
Thomson Reuters. No Claim to Orig. US Gov, Works. suggesting that he had been involved in any
including a letter from his attorney-employer, of his rehabilitation. The ultimate test of present moral
the period subsequent to the applicant's misconduct, he has so convincingly rehabilitated himself that
admission to the bar, the court concluded. In Application of Allan S., 282 Md, 683,387 A.2d 271
(1978), the court held that an applicant for admission to the Maryland Bar who had been convicted in
the past established his "present" moral character titness where there was no evidence in the record
even remotely 3 A.L.R.6th 49 Page 21 3 A.L.R.6th 49 (Originally published in 2005) 2011
Thomson Reuters. No Claim to Orig. US Gov. Works. suggesting that he had been involved in any
including a letter from his attorney-employer. of his rehabilitation. The ultimate test of present mont!
the period subsequent to the applieant's misconduct, he has so convincingly rehabilitated himself that
admission to the bar, the court concluded.
From NY Bar Bar Counsel Reports: "NV Bar No.: 9644 Docket No.: 56939 Filed: November 15,
2010 ORDER OF TEMPORARY SUSPENSION Temporary suspension warranted following
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respondent's criminal conviction. Bar Counsel for the State Bar of Nevada filed an SCR III petition
asking this court to refer attorney Jonathan R. Patterson for formal disciplinary proceedings and/or to
temporarily suspend Patterson from the practice of law. On October 22, 2010, we issued an order
referring Patterson to the Southern Nevada Disciplinary Board for commencement of formal
disciplinary proceedings and directing Patterson to show cause why he should not be temporarily
suspended from the practice of law pending resolution of the formal disciplinary proceedings against
him. Patterson filed a timely response to our order. Patterson first contends that he has not sustained a
conviction pursuant to SCR Ill. We disagree. For purposes of the rule, "a 'conviction' shall include
a plea of guilty" (SCR \\\(1)). Patterson admits that, even ifhe complied fully with the conditions of
his stayed adjudication. he will still be guilty or a crime. Accordingly, he has sustained a "conviction"
[or purposes of SCR III (1). Patterson next contends that he had demonstrated good cause why he
should not be temporarily suspended. We disagree. Receiving. treatment, lack of client contact and
financial obligations are insufficient to overcome the fact that the crime to which he pleaded !,'lJilty
reflects adversely on his fitness to practice law. Accordingly. pursuant to SCR 111(9), we hereby
temporarily suspended attorney Jonathan R. Patterson from the practice of law in Nevada. It is so
ORDERED.Pursuant to SCR Ill, temporary suspension and referral to the appropriate disciplinary
board are mandatory when an attorney has been convi(.'ted of a serious crime, which includes felonies
(See SCR 111(6)-(8)).
In Application of Allan S., 282 Md. 683, 387 A.2d 271 (1978), the court held that an applicant for
AL.R.6th 49 (Originally published in 2005) 2011 Thomson Reuters. No Claim to Orig. US Gov.
Works. suggesting that he had been involved in any misconduct in the years fonowing his theft
offense and where he presented convincing evidence. including a letter from his attorney-employer,
the bar, is whether, viewing the applicant's character in the period subsequent to the applicant's
misconduct, he has so convincingly rehabilitated himself that it is proper that the applicant become a
character in the past is secondary 10 the existence of good moral character in the present is a cardinal
prinCiple in considering applications for original admission to the bar, the court concluded. Criminal
Record as Affecting Applicant's Moral Character for Purposes of Admission to the Bar, 3 AL.R.6th
49 (Originally published in 2005) Theft or larceny 4,5, 13, 14.16-19
Examples of Illegal Conduct That Involves Moral Turpitude A list of crimes involving moral
turpitude in which members of the bar have been con- 16 JLEGPRO 261 Page 2 16 J. Legal Prof. 261
~) 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. victed and disciplined by the courts
includes bribery, [FN 12) embezzlement, [FN 13J evasion offederal taxes, [FN14J larceny, [FNI5]
casting fictitious264 votes, [FNJ6] extortion, [FN17J receiving and concealing stolen property,
[FNI8J mail fraud, fFN19] and scxual misconduct.lFN20] Crimes That Mayor May Not Constitute
Moral Turpitude For several reasons, it is impossible to compile an exhaustive list of crimes which
definitely do not involve moral turpitude. First, whether illegal conduct constitutes moral turpitude
often depends on the unique circumstances surrounding the commission of the crime. Second. courts
*265 sometimes do not say whether a crime constitutes moral turpitude. Third, what constitutes such
a crime in one state may not in another state. Fourth, as previously mentioned, the definitional
problems pose difficulties when classifying om~nses. But, the following are examples of offenses that
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the Alabama courts have held do not involve moral turpitude: assault and battery, distilling or
otherwise violating the prohibition laws. public drunkenness and disorderly conduct, speeding,
resisting the officer making arrcsl~, and using abusive and obscene language. [FN21] The remainder
o[the discussion will be divided into four topics, the first being drug related offenses. [FNJO]. See,
e.g., Bartos v. United States Dis!. Ct. for Dist. of NebrdSka, 19 F.2d 722 (8th Cir.I927). [FN II].
Model Rules of Professional Conduct Rule 8.4 comment (1983). [FNI2]. Thc Florida Bar v. Rendina.
583 So.2d 314 (Fla.1991) (per curiam) (attorney's attempt to bribe state attorney to obtain lesser
criminal sentence for client warrants disbarment); In re Barron, ISS W.Va. 98, 181 S.E.2d 273 (1971)
(conviction of conspiracy to commit bribery and of bribing a juror is conviction involving moral
turpitude, requiring annulment oflicense to practice law): Cf. In re Kerr, 86 Wash.2d 655,548 P.2d
297 (1976) (knowingly participating in attempt to suborn peJjury is a crime involving moral turpitude
and warrants disbarment). [FN 13]. In re Shumate. 382 S. W.2d 405 (Ky. I 964) (conviction of attorney
of embezzling money which came into his charge as trustee in bankruptcy and of knowingly and
fraudulently concealing money [rom the trustee and from creditors in bankruptcy proceedings,
involved moral turpitude and was ground lor disbarment). [FN14]. In re Grimes, 414 Mich. 483, 326
N.W.2d 380 (1982) (felony convictions for willful evasion offederal taxes and counseling a client to
lie to investigators in connection with tax fraud case warrant disbarment); See also Kentucky State
Bar Assoc. v. Vincent. 537 S.W.2d 171 (Ky.1976). But cf., Clark v. Alabama State Bar, 547 So.2d
461 (Ala. I 989) (failure to pay federal income taxes after one has filed does not constitute a crime of
moral turpitude as a matter of law); In re Fahey, 8 Cal.3d 842, 505 P.2d 1369, 106 Cal.Rptr. 313
(1973) (knowing 16 JLEGPRO 261 Page 816 J. Legall'rof. 261 2011 Thomson Reuters. No
Claim to Orig. US Gov. Works. and unlawful failure to file a federal income tax retum does not
involve moral turpitude within meaning of the disciplinary statutes where failure is not for purpose of
personal financial gain or with intent to avoid ultimate payment of tax obligations but is result of
professional and domestic pressures and psychoneurotic difficulties). [FNI5]. In re Schuler, 818 P.2d
138 (CaI.1991) (Rabinowitz. C.J., and Matthews. 1., dissenting) (attorney's conviction for
misdemeanor theft warrants two year suspension); See also Kentucky State Bar Ass'n v. Scott, 409
S.W.2d 293 (Ky. 1966). [FNI6]. In re Smith, IS8 W.Va. 13,206 S.E.2d 920 (1974)(federal
conviction of conspiracy to cast fictitious votes for federaL state, and local candidates in primary
election constitutes conviction of crimc involving moral turpitude, requiring annulment of license to
practice law). [FNI7]. Libarian v. Slate Bar of California, 38 Cal.2d 328, 239 P.2d 865 (1952)
(attorney who wrote and mailed a threatening letter in an attempt to secure money for his client found
guilty of extortion, a crime of moral turpitude, and suspended from the practice oflaw for six
months). [FNI8]. In re Thompson 37 Cal.App. 344,174 P. 86 (1918); See generally Annotation.
Attorney's Conviction in Foreign or Federal Jurisdiction as Ground for Disciplinary Action, 98
A.L.R.3d 357, 418 (1980). [FNI9]. In re Comyns, 132 Wash. 391,232 P. 269 (1925) (conviction of
attorney for using mails of United States for purpose of obtaining property under false pretenses was
grounds for disbarment since such offense involves moral turpitUde). [FN20]. In re Kamin, 262
N.W.2d 162 (Minn.1978) (scxual abuse against children of client warrants disbarment); See also In re
Howard, 297 Or. 174,681 P.2d 775 (1984) (in exchange for legal services, attorney and client
engaged in sexual activity; attorney was convicted of prostitution, a misdemeanor involving moral
turpitude, and received a public reprimand). See generally Annotation, Attorneys Sexual
Improprieties, 43 A.I..R.4th 1062 (1986). [FN2IJ. C. Gamble, McElroy's Alabama Evidence
145.01(10) (3d ed. 1977). [f'N22].ln rc Kinnear. 105 N.J. 391. 394, 522 A.2d 414, 416 (1987).
[FN23].ln re Mclaughlin, 522 A.2d 999,1000 (NJ.1987)(quoting In re Kinnear, 522 A.2d 414
(NJ.l987.ln re Schuler, 818 P.2d \38 (Cal.l99l) (Rabinowitz. C.J., and Matthews, J., dissenting)
Mo~ion
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(attorney's conviction for misdemeanor theft warrants two year suspension); See also Kentucky State
Bar Ass'n v. Scott, 409 S.W.2d 293 (Ky.l966).
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Conviction of five counts of thet! of client funds, neglect of probate of estates and conversion of
funds belonging (0 one of those estates is misconduct warranting revocation oflicense to practice
law. SCR 11.05,20.32(3),20.50,21.10(1). Matter of Disciplinary Proceedings Against McLean, 143
Wis. 2d 371. 421 N.W.2d 515 (1988). Sexually harassing female employee resulting in
misdemeanorConviction of misdemeanor theft warrants 18"month suspension from practice of law,
as reciprocal discipline, with suspension to commence from date of filing of disciplinary complaint,
raLi]er than from date of Supreme Court order. SCR 22.25. Matter of Disciplinary Proceedings
Against Sneed, 176 Wis. 2d 126,499 N.W.2d 668 (I 993).Unauthorized retention of funds belonging
to law firm at which attorney is employed, failure to file criminal appeal within applicable time
period, failure to keep client informed as to 113 A.L.R. 1179 Page 416 113 A.L.R. 1179 (Originally
published in 1938) (') 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. status of matter
and promptly comply with client reasonable requests for information, and conviction of felony theft
tor endorsing and depositing law firm client fees into personal account warrants revocation oflicense
to practice law. SCR 20: IA( a), 20:8.4(b, c). Matter of Disciplinary Proceedings Against LeRose, 182
Wis. 2d 595, 514 N.W.2d 412 (l994).Convictions forfelony theft by bailee and theft by fraud
warrant revocation oflicense to practice law. SCR 20.04(3) (Repealed); SCR 20:8.4(b). Matter of
Disciplinary Proceedings Against McBride, 184 Wis. 2d 604, 516 N. W.2d 421 (1994).
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Government is entitled to select cases for prosecution which it believes will promote public
compliance with Selective Service registration laws; while decision to prosecute individual cannot be
made in retaliation for exercise of right under First Amendment to protest Government registration
and draft policies, prosecution of protestors who publicly and with attendant pUblicity assert alleged
personal privilege not to register as part of protest is not selection on impermissible basis. United
States v Martin (1982, ND Iowa) 557 F Supp 681, revd on other gnds (CAS Iowa) 733 F2d 1509, ccrt
den (US) 85 L. Ed. 2d 158, 105 S Ct 1864. What constitutes such discriminatory prosecution or
enforcement of laws as to provide valid defense in state criminal proceedings 95 A.L.R.3d 280
(Originally published in I 979);8[aJ Invidiousness or arbitrariness of particular basis for selection[47J
-Defendant's exercise of constitutional rights [Cumulative Supplement] In the following cases it
was held that selection of the defendants solely on the basis of their exercisc of their constitutional
rights would be invidious. Where the defendants contended that they alone had been singled out for
prosecution 95 A.L.R.3d 280 Page 48 95 A. L.R3d 280 (Originally published in 1979) 2012
Thomson Reuters. No Claim to Orig. US Gov. Works. solely because of their vigorous use of their
First Amendment rights to protest the policies of the school and the school system, the court in
People v Serna (1977, 2d Dist) 71 Cal App 3d 229, 139 Cal Rptr 426, concluded that those
allegations, if proved, would constitute the defense of invidious prosecution, and held that it was
error for the trial court to deny defendants full discovery in connection with their claim. In United
States v Smith (1976, Dist Co! App) 354 A2d 510, the defendant contended that the prosecution's
policy of not granting fIrst-offender treatment to defendants who had litigated any issues in their
cases constituted a policy of unconstitutional discrimination against individuals who chose to
exercise their legal rights. Although fInding that the government's policy did not have that effect in
the case before it, the court said it had no quarrel with the trial court's ruling that a policy intended to
deter defendants from exercising their legal rights could not be tolerated. CUMULATIVE
SUPPLEMENT Cases: See State v Gilbert (1987, App) 112 Idaho 805, 736 P2d 857, 2S[bJ. [Top of
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Section] [END OF SUPPLEMENT] 8[b] Invidiousness or arbitrariness of particular basis for

selection[*]-Sex [Cumulative Supplement] In the following cases, the courts were divided on the
issue of whether the sex of the defendant constituted an invidious or arbitrary basis for selection for
prosecution. In the cases immediately following, the courts held that sex was an invidious ba.~is. [n
People v Superior Court of Alameda County (1977) 19 Cal 3d 338, 138 Cal Rptr 66, 562 P2d 1315,
in which the court rejected defendants' claim that they had been unconstitutionally discriminated
against in the enforcement of the prostitution laws, the court held that sex was an arbitrary .
classification for the purposes of a discriminatory enforcement claim. [n Commonwealth v Kmg
(1977, Mass) 1977 Adv Sheets 2636, 372 NE2d 196, the court concluded that a female charged with
prostitution or nightwalking would be entitled to a dismissal of the charges with prejudice on an
appropriate showing that the police department or the prosecutor's office followed an unjustifiable
policy of selective enforcement against female prostitutes and not male prostitutes. Noting that
Article 106 of the Amendments to the Constitution of the Commonwealth of Massachusetts contains
an express prohibition of discrimination on the basis of sex, grouping it with other prohibited bases
for discrimination which are subject to strict judicial scrutiny, the court concluded that it must view
sex discrimination with the same vigorous disapproval that it would view racial, ethnic, and religious
discrimination. Consequently, the court said. the Commonwealth could not enforce the prostitution
law against female prostitutes, but not against male prostitutes, unless it could demonstrate a
compelling interest which would require such a policy. In State v Maldonado (1978, Mont) 578 P2d
296, the court, in rejecting the defendant's contention that the Montana persistent felony offender
statute had been discriminatorily ap- 95 A.L.R.3d 280 Page 49 95 A.L.R.3d 280 (Originally
published in 1979) 2012 Thomson Reuters. No Claim to Orig. US Gov. Works. plied against him,
stated, in dicta, that the conscious exercise of some selectivity in enforcement was not in itself a
federal constitutional violation absent an allegation and a showing that the selection was delibemtely
ba~ed upon an unjustifiable standard or arbitmry classification such as sex. However, in the following
case in which the defendant claimed that she had been discriminatorily prosecuted on the basis of sex,
the court held that, as a matter of constitutional interpretation, sex had not been declared an invidious
or arbitrary basis for discrimination. In Minneapolis v Buschette (1976) 307 Minn 60, 240 NW2d
500. the defendant, charged with prostitution, contended that the statute was discriminatorily
enforced against her on the basis of sex. Stating that in order to be a violation of the equal protection
clause, entitling defendant to a dismissal of the charge. the arrest must have been based upon an
unjustifiable standard such as race, religion, or other arbitrary classification, the court said that, as a
matter of constitutional interpretation, discrimination based upon sex had not been declared a matter
for strict scrutiny, where the state or local authority must show a compelling interest in employing the
classification. Concluding that all that was needed to be shown was a rational basis for the selectivity,
the court said that while there had been a conscious selectivity in the enforcement of the prostitution
ordinance, there was a mtional relationship between that selectivity and the governmental objective
of controlling prostitution. ClJMlJLA TIVE SUPPLEMI:,'NT Cases: See State v Evans (1985) 73 NC
App 214,326 SE2d 303, 22[a]. [Top of Section) [END OF SUPPLEMENT] 8[c]lnvidiousness or
arbitrariness of particular basis for selection[*J--Type of legal activity illegally conducted
[Cumulative Supplement] In the following case in which defendant contended that he had been
discriminated against on the basis of the particular kind of generally legal activity which he was
conducting in an illegal manner, the court held that discrimination based upon the type of business
conducted by the defendant would represent a reasonable classification. Appealing from his
conviction for violating a Sunday closing law, the defendant in Taylor v Pine Bluff (1956) 226 Ark
309,289 SW2d 679, cert den 352 US 894, I L Ed 2d 85. 77 S Ct 125, contended that the statute wa~
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being discriminatorily enforced, in that the police arrested everyone who operated a grocery on
Sunday, but allowed other businesses to remain open on that day. However, concluding that a
distinction between grocery stores and other businesses would represent a reasonable classification,
the court held the defendant was entitled only to be treated in the same manner as other grocers, and
upheld his conviction. CUMULATIVE SUPPLEMENT 95 A.L.R.3d 280 Page 50 95 A.L.R.3d 280
(Originally published in 1979) 2012 Thomson Reuters. No Claim to Orig. US C'JOv. Works. Cases:
Native American defendant failed to establish prima facie case of selective or discriminatory
prosecution as habitual criminal where. though his evidence established that 26 individuals during
1971 to 1977 were eligible for prosecution as habitual criminals. that 18 were Native Americans
(69.2%) and eight were Caucasian (30.8%), and that of the eight individuals actually prosecuted as
habitual criminals. seven were Native Americans (87.5%), size of group examined rendered statistics
inconclusive. State v Bird Head (1979) 204 Neb 807, 285 NW2d 698. Burglary, extortion,larceny,
robbery. and theft [Cumulative Supplement] In the following cases in which the defendants were
convicted of burglary, larceny. robbery. theft, and extortion, the courts held that the defense of
discriminatory prosecution was not established by the defendant. In Blount v Smith (1977, MD Pal
440 F Supp 528. the court rt:iected the discriminatory enforcement claim of plaintiffs, who were
convicted in state court of fraudulently receiving unemployment compensation benefits. The Bureau
of Employment Security did not institute criminal proceedings against every claimant found to have
received overpayments. but only prosecuted the most serious violators. The court said that to prevail
on their equal protection claims. plaintiffs would have to show not only that they were prosecuted
while others were not, but also that the selection was made on the basis of some arbitrary
classification. Noting that the Bureau of Employment Security manual of operations and procedures
provided extensive nondiscriminatory criteria to guide agency determinations as to which violations
warranted prosecution. the court said that nowhere in the record before it was there any suggestion
that the decision to prosecute plaintiffs was made on any basis other than the criteria set forth in the
manual, and accordingly denied plaintiffs' claim for relief. Where a defendant was convicted of
robbery which occurred when his codefendant, a woman, lured the victim into a building for purposes
of prostitution, the court in People v Williams (1965, 1st Dist) 235 Cal App 2d 389, 45 Cal Rptr 427,
rejected as being obviously irrelevant the claim of defendant that he was discriminated against
because he and his codefendant 95 A.L.R.3d 280 Page 5795 A.L.R.3d 280 (Originally published
in 1979) 2012 Thomson Reuters. No Claim to Orig. US Gov. Works. were prosecuted for robbery,
whereas the victim was not charged with adultery, conspiracy to commit acts of prostitution, or the
like. In People v Thompson (1970. 2d Dis!) lOCal App 3d 129, 88 Cal Rptr 753, in which defendant
was convicted of t1left, the court recognized that the tact that some wrongdoers are proceeded against
while others, equally suspect. are not does not, of itself, amount to illegal discrimination, and that
mere laxity in enforcement of laws by public officials is not a denial of equal protection. Defendant.
convicted of theft of trade secrets, contended on appeal in People v Serrata (1976, 1st Dist) 62 Cal
App 3d 9, 133 Cal Rptr 144, 84 ALR3d 952. that his conviction should be reversed because the penal
code was selectively and discriminatorily enforced against him. Defendant based his argument upon
the fact that there were no cases cited in the annotations to the statute. which had been enacted nearly
10 years earlier, and upon the additional fact that the testimony at the trial established that many
thefts of the detendant's employer's trade secrets had occurred prior to the thefts for which he was
prosecuted and convicted. [n holding that the argument was untenable. the court said that the
selective enforcement of a penal statute was not a denial of equal protection of the laws unless the
selection was deliberately based upon an unjustifiable standard. The court said that the record was
devoid of any evidence that the law enforcement authorities singled defendant out for prosecution
Moti~n
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based upon any such unjustifiable standard, where the record, showing that defendant's prosecution
and conviction were the result of an extremely difficult, complicated, and expensive investigation
instigated by his employer only because the value of the stolen trade secrets was extremely great,
suggested the reason the statute was so rarely enforced. In People v MacFarland (1975) 189 Colo
363,540 P2d J073, defendant, convicted of theft, argued that he was denied equal protection ofthe
law because the prosecution offered immunity to the other parties to the crime, but not to defendant
Stating that the conscious exercise of selectivity in the enforcement of laws is not in itself a
constitutional violation absent a showing that a prosecutor has exercised a policy of seleetivity based
upon an unjustifiable standard, the court, saying that defendant had the burden of proving
discriminatory prosecution, held that bald allegations of such praetices hardly sufficed. Defendants,
found guilty of extortion, contended in People v Plamondon (1975) 64 Mieh App 413, 236 NW2d 86
(disagreed with on other grounds People v Pulley, 66 Mich App 321, 239 NW2d 366) and (disagreed
with on other grounds People v Amison. 70 Mich App 70, 245 NW2d 405) and revd on other grounds
400 Mich 559, 255 NW2d 619 and (ovrld on other grounds People v Sacorafas, 76 Mich App 370,
256 NW2d 599), that the decision to prosecute them, and the manner in which the prosecution was
handled, was done so with an "evil eye" and an "unequal hand," c-Ontrary to the principles ofYick Wo
v Hopkins (1886) 118 US 356, 30 LEd 220, 6 S Ct 1064. Stating that it was well established that
constitutional provisions torbid discriminatory enforcement of the laws, the court said that a violation
of equal protection will not be found unless the decision to prosecute was based upon an arbitrary or
invidious classification. Noting that defendants were advocates for a number of antiestablishment
causes, the court said that defendants failed to show that other alleged extortionists with
proestablishment viewpoints were not subjects of prosecution. Finding that defendants failed to make
an affirmative showing that the decision to prosecute them was premised on an arbitrary
classification, the court held that their argument was ",ithout merit. Defendant, convicted of firstdegree burglary, complained on appeal in State v Andrews (1969) 282 Minn 386,165 NW2d 528, of
the allegedly arbitrary and discriminatory decision 95 A.L.R.3d 280 Page 58 95 AL.R.3d 280
(Originally published in 1979) (J 2012 Thomson Reuters, No Claim to Orig, US Gov. Works, of the
prosecutor to treat him more severely than his accomplice who. after plea bargaining, was charged
with third-degree burglary. The record did not show what considerations impelled the prosecution to
grant leniency to defendant's accomplice or, if it was indeed the result of a plea bargain, why the
same bargain was not negotiated with defendant Defendant attempted to infer that no rational basis
existed for the disparate treatment, claiming that nothing suggested that defendant was a more active
participant in the crime than his accomplice. that defendant's prior criminal record was no worse than
the accomplice's, that thc accomplice gave thc prosecution no greater co-operation than did
defendant, and that their relative rehabilitation potentials were not notably different However, the
court said that the array of elements involved in an evaluation of such factors was obviously too
numerous and complex to test defendant's claim on that basis alone. Stating that a discriminatory
purpose will not be presumed, the court said that the record did not establish that there had been an
abuse of prosecutorial discretion, Defendant, convicted of petly larceny for removing from a public
library a magazine because it contained what he regarded to be an obscene passage, contended on
appeal in People v Gorton (1969) 60 Misc 2d 833, 304 NYS2d 69, that the trial court erred in not
permitling him to present evidence in support of his claim of discriminatory enforcement of the law
against him. Specifically, defendant sought to introduce evidence that the library had departed from
its usual practice regarding overdue books which had not been returned and had singled him out for
criminal prosecution. Stating that defendant's wrongful act could not be equated with the failure to
return a book which had been properly borrowed in the first instance, the court said that the
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procedure customarily employed against delinquent borrowers would be of no relevancy, and held
that there was no genuine issue of discriminatory criminal prosecution. CUMULATIVE
SUPPLEMENT Cases: Defendant convicted of theft failed to establish vindictiveness on part of
prosecution, absent showing in record that, as contended, state attempted to have defensc counsel
removed in court proceedings and that malicious attitude existed toward defendant because of his
nationality, lack of Arizona residency and his defense counseL State v Jahns (1982, App) 133 Ariz
562, 653 P2d 19. ProSl-'"Cution of Black Liberation Army defendants on state bank robbery charges
following federal conviction on bank robbery charges wa~ not discriminatory prosecution where
examination of prosecution history surrounding six bank robberies in same county at time in question
was inconclusive regarding political or racial motivations. State v Haskins (1982) 188 Conn 432,450
A2d 828. Black defendant convicted of theft in prosecution arising from undercover "sting" operation
in predominantly black neighborhood with statistically high burglarly rate failed to establish racially
discriminatory impact and discriminatory intent. Slate v Russell (1984, Minn) 343 NW2d 36. See
People v Drake (1983. 3d Dept) 92 App Div 2d 1011,461 NYS2d 509, affd in part and mod in part
on other gnds. remanded 61 NY2d 359, 474 NYS2d 276. 462 NE2d 376, later proceeding (1984) 126
Mise 2d 309, 482 NYS2d 208, 21. See State v Schmitz (1988, NO) 431 NW2d 305, 8[i]. 95
A.L.R.3d 280 Page 5995 A.LR.3d 280 (Originally published in 1979) 2012 Thomson Reuters. No
Claim to Orig. US Gov. Works. [Top of Section] [END OF SUPPLEMENT]
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OTHER FOURTH AMENDMENT INTRUSIONS (SEARCH &

ENTRIES)
A. SEARCH INCIDENT TO ARREST "SITA"
(l) In General
A "SIT A" is a "policy ju~iitied" search in the sense that it does not require its own
justification in terms of probable cause or reasonable suspicion. All that is required is a
lawful custodial arrest and a SIT A can occur.
In Illinois v. Lafayette, 462 U.S. 640 (1983), the U.S. Supreme Court said, "The
authority to search the person incident to a lawful custodial arrest, while based on the
need to clisarm and to discover evidence. does not depend on what a court may later
decide was the probability in a particular arrest situation that weapons or evidence
would in fact be found on the person ofthc suspect ... the arrest being lawful means
the SITA requires no additional justification."
In United States v. Robinson. 414 U.S. 218 (1979) The Court said all custodial
arrests from murder to traffic violations are equal in justifying SITA.
(2) Scope of SITA
Since the SITA is automatic with a lawful custodial arrest:. the legal issues in this
area all involve the scope of the SITA. How soon must it occur? How far can it go in
tenns of area and intrusion? The following cases provide some guidelines but officers
should realize that the more (I) time goes by and (2) the further away from the exact
place of the arrest and (3) the harder it would be for the arrestee to get into the area
searched, the less likely it will be a valid SITA.
(a) Time
The general rule is that the SITA must be "contemporaneous" with the arrest. It is
a'!:iomatic that a SITA cannot precede an arrest in providing the justification for the
arrest, but if the justification exists already (ie - police had PIC before the SITA) then the
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fact that the fonnal arrest immediately followed the SITA made no difference. Rawlings
v. Kentucky, 448 U.S. 98 (1980).
Although the search must be contemporaneous, courts provide police a brief
cushion of time until they have gained complete control ofthe situation. U.S. v.
$639,558 in U.S. Currency, 955 F.2d 712 (D.C. Cif. 1992) There is no prohibition
against a reasonable de!ay between the elimination of danger and the search. U.S. v.
Han. 74 F.3d 537(4th Cif. 1996) A search incident to arrest must be contemporaneous
but not necessarily immediate. U.S. v. Willis, 37 FJd 313 (7th Cir. 1994).(Different
77
person from U.S. v. Willis in pretext arrest).
In U.S. v. Johnson, 114 FJd 435 (4th Cir. 1997)Applying Han to the facts at
hand, no doubt exists that the car was within Johnson's immediate control at the
beginning of his encounter with the officers; the search was conducted at the scene of the
arrest, after the officers moved the car to the front of the shopping center mall into a
better lighted area; and the delay between the elimination of the danger--Johnson-- and
the search was not unreasonable.
(b) Place searched
In Chime! v. California, 395 U.S. 752(1%9) the U.S. Supreme Court held that
police could not search areas inside a house outside the immediate control of the suspect
at the time of the lawful arrest. Police are not allowed to simulate circumstances
justifYing a SITA merely by bringing the item they wish to search into the area near the
person arrested or vice versa. U.S. v. Perea, 986 F.2d 633 (2d Cir. 1993) However, if the
suspect voluntarily asks to move about his premises (to get a coat or other clothes, etc.),
the officer can monitor the arrestee's movements and SITA may be valid at another
location. Washington v. Chrisman, 455 U.S. I (1982).
Items "immediately associated with the person" can be searched incident to the
arrest of the person including a woman's shoulder bag regardless of whether on her
shoulder or on the ground a few feet away. U.S. v. Nelson, 102 FJd 1344 (4th Cir. 1996)
In U.S. v. Cotnam, 88 F.3d 487 (7th Cir. 1996) OK to search arrestee's jacket laying a
few feet away at arrest. U.S. v. Ortiz, 84 F.3d 977 (7th Cir. 1996) OK to push button on
pager found on defendant at time of arrest revealing numeric messages.
Some courts allow a SITA of a locked area or container, U.S. v. Gonzales, 71
F.3d 819 (11th Cir.1996) and Clemons v. U.S., 72 F.3d 128 (4th Cir. 1995). However, if
the arrestee is handcuffed and in police custody and has no chance of unlocking and
opening the container, it seems that searches of locked containers require a search
warrant or other exception.(such as inventory search or consent).
In U.S. v. Tarazon, 989 F.2d 1045 (9th Cir. 1993) police could search a desk
drawer where defendant was sitting at time of arrest even though he was handcuffed.
Same ruling in U.S. v. Hudson, 100 F.3d 1409 (9th Cir. 1996) OK to search rifle case at
feet of person arrested even though he wa~ removed from the room 3 minutes earlier.
Same ruling in U.S. v. Horne,4 F.3d 597 (8th Cir. 1993) search of seat where he was
arrested even though handcuffed.
(c) Arrestee Handcuffed
Every case decided in SITA law says that it makes no difference that the person
was in handcuffs at the time of the SITA as long as the other SITA requirements are met.
Chimel v. California, United States v. Helmsetter, 56 F. 3d 21 (5th Cir. I995) (See
- 38 Moti.on for Sanctions
cases above).
2
Hiibel v. Sixth Judicial District Court of Nevada

From Wikipedia, the free encyclopedia
Hiibel v. Sixth Judicial District Court of Nevada
4
, Seal of the United States Supreme Courtsvg
J
Supreme Court of the United States
Argued March 22, 2004
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Decided June 21, 2004
Full case name
Larry D. Hiihel v. Sixth Judicial District Court of Nevada, Humboldt County,
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et aI.
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Citations
542 U.S. 177 (more)
124 S. Ct. 2451; 159 L. Ed. 2d 292; 2004 U.S. LEXIS 4385; 72 U.S.L.W. 4509; 17Fla. L. Weekly
9
Fed. S 406
10 PriOT history Defendant convicted, Justice Court of Union Tovmship, Humboldt County; affirmed.
Sixth Judicial District Court, Humboldt County; affirmed, 59 PJd 1201 (Nev. 2002); cert. granted,
11
540 U.S. 965 (2003)
Subsequent history US Supreme Court rehearing denied by !-liibel v. Sixth Judicial Disl. Court,
12
542 U.S. 960.125 S. Ct. 18, 159 L. Ed. 2d 849, 2004 U.S. LEXIS 4868 (U.S., Aug. 23, 2004)
Holding
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Laws requiring suspects to identiJY themselves during investigative stops by law enforcement officers
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do not violate the Fourth Amendment, and do not necessarily violate the Fifth Amendment.[l]
Court membership
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Chief Justice
16 William Rehnquist
Associate Justices
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John P. Stevens' Sandra Day O'Connor
Antonin Scalia' Anthony Kennedy
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David Souter' Clarence Thomas
19 Ruth Bader Ginsburg Stephen Breyer
Case opinions
20 Majority
Kennedy, joined by Rebnquist. O'Connor, Scalia, Thomas
Dissent
Stevens
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Dissent
Breyer, joined by Souter, Ginsburg
Laws applied
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U.S. Const. amends. IV, V; Nev. Rev. Stat. 171.123(3)
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!-liihel v. Sixth Judicial District Court of Nevada, 542 U.S. 177 (2004), held that statutes requiring
suspects to disclose their names during police investigations did not violate the Fourth Amendment if
the statute first required reasonable and articulable suspicion of criminal involvement. Under the
rubric of Terry v. Ohio, 392 U.S. I (1968), the minimal intrusion on a suspect's privacy, and the
legitimate need of law enforcement officers to quickly dispel suspicion that an individual is engaged
in criminal activity, justified requiring a suspect to disclose his name.
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The Court also held thaI the identification requirement did not violate Hiibel's Fifth Amendment
rights because he had no reasonable belief that his name would be used to incriminate him; however,
the Court left open the possibility that Fifth Amendment privilege might apply in a situation where
there wa~ a reasonable belief that giving a name could be incriminating.[l]
Contents
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I Background of the case

2 Majority opinion
J Dissenting opinions
4 See also
5 Notes
6 Extemallinks
[edit I Background of the case
Nevada has a "stop-and-identify" law that allows a police officer to detain any person he encounters
"under circumstances which reasonably indicate that the person has committed, is committing or is
about to commit a crime"; the person may be detained only to "ascertain his identity and the
suspicious circumstances surrounding his presence abroad." In turn, the law requires the person
detained to "identify himself', but does not compel the person to answer any other questions put to
him by the officer. The Nevada Supreme Court has interpreted that "identify himself' to mean to
merely state his name. As of April 2008, 23 other states[2] have similar laws.
On the evening of May 21,2000, the sheriff's department in Humboldt County, Nevada received a
report that a man had assaulted a woman in a red and silver GMC truck on Grass Valley Road. The
responding deputy found a truck parked on the side of the road. A man was smoking a cigarette
beside the truck, and a young woman was sitting inside it. The deputy observed skid marks in the
gravel behind the vehicle, leading him to believe the vehicle had come to a sudden stop.
The deputy explained to the man that there had been a report of a fight between the man and the
young woman, and asked the man if he had any identification on him. The man protested that he had
no reason to provide identification. and became ill-tempered when the deputy continued to press him
for his identification. The man then asked the deputy what crime he was being accused of, as the
deputy continued his requests for identification, stating that he was "conducting an investigation".
The man persisted in his refusal to provide identification, asking instead to be handcuffed and taken
to jail. The deputy continued to ask for the man's identification, stating that the man would face arrest
if he did not cooperate and provide identification.[3] In response, the man declared he would not
cooperate because he had not committed any crime. He then turned around and was arrested by the
deputy.
That man was Larry Dudley Hiibel, the petitioner in this case, and the young woman was his
daughter Mimi Hiibel. Larry Hiibel was charged with "willfully resist[ing], delay[ing], or
obstruct[ingl a public officer in discharging or attempting to discharge any legal duty of his
office."[4]In the Justice Court for Union Township, Nevada Hiibel was convicted of this charge and
fined $250. He appealed to the Sixth Judicial District Court, which affirmed the conviction. He then
appealed to the Nevada Supreme Court, arguing that the requirement that he identifY himself to any
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police officer upon request violated the Fourth Amendment prohibition on unreasonable searches and
seizures and his Fifth Amendment privilege against self-incrimination. The Nevada Supreme Court
rejected these arguments, and Hiibel asked the U.S. Supreme Court to hear the case.
l edit] Majority opinion
Stop-and-identify laws have their roots in early English vagrancy laws that required suspected
vagrants to face arrest unless they gave a "good account" of themselves; this practice, in tum, derived
from the common-law power of any person to arrest suspicious persons and detain them until they
gave "a good account? ofthemselvcs. Modern stop-and-identify laws combine aspects of the old
vagrancy laws with a guide for police officers conducting investigatory stops, such as those
authorized under Tcrry v. Ohio, 392 U.S. 1 (1968).
However. the Court has identified a constitutional difficulty with many modern vagrancy laws. In
Papachristou v. Jacksonville, 405 U.S. 156 (1972), the Court held that a traditional vagrancy law was
void for vagueness because its "broad scope and imprecise terms denied proper notice to potential
offenders and permitted police officers to exercise unfettered discretion in the enforcement of the
law." In Brown v. Texas. 443 U.s. 47 (1979), the Court struck down Texas's stop-and-identify law as
violating the Fourth Amendment because it allowed police officers to stop individuals without
"specific, objective facts establishing reasonable suspicion to believe the suspect was involved in
criminal activity." And in Kolender v. Lawson, 461 U.s. 352 (1983), the Court struck down a
California stop-and-identify law that required a suspect to provide "credible and reliable
identification" upon request.[5] The words "credible and reliable" were vague because they
"provided no standard for determining what a suspect must do to comply with [the law], resulting in
virtually unrestrained power to arrest and charge persons with a violation."
"The present case begins where our prior cases left off. Here there is no question that the initial stop
was based on reasonable suspicion, satisfying the Fourth Amendment requirements noted in Brown.
Further, the petitioner has not alleged that the statute is unconstitutionally vague, as in Kolender.
Here the Nevada statute is narrower and precise." The Nevada Supreme Court had held that the
Nevada statute required only that the suspect divulge his name; presumably, he could do so without
handing over any documents whatsoever. As long as the suspect tells the officer his name, he has
satisfied the dictates of the Nevada stop-and-identify law.
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The narrow requirements of Nevada's stop-and-identify law meant that it did not run afoul of the
Fourth Amendment. "In the ordinary course a police officer is free to ask a person for identification
without implicating the Fourth Amendment." Since Terry, it has been clear that a police officer who
reasonably suspects that a person is involved in criminal activity may detain a person long enough to
dispel that suspicion. Questions related to a person's identity are a "routine and accepted part of many
Terry stops." KnOwing a person's identity may, of course, help to clear a suspect and divert the
attention of the police to another suspect. On the other hand, knowing the suspect's name may just as
quickly confirm to the officer that the person is wanted for another, unrelated crime. Tn cases such as
this, where the police are investigating a domestic dispute, officers "need to know whom they are
dealing with in order to assess the situation, the threat to their own safety, and possible danger to the
potential victim:' "The request for identity has an immediate relation to the purpose, rationale, and
practical demands of a Terry stop. The threat of criminal sanction helps ensure that the request for
identity does not become a legal nullity." Balancing the intrusion into the individual's privacy against
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the extent to which the stop-and-identify law promotes legitimate government interests, the Court
concluded that the Fourth Amendment did not prohibit Nevada from making it a crime for'a person
detained under conditions of Terry to refuse to disclose his name to a police officer upon request.
Furthermore, the officer's request that Hiibel identitY himself did not implicate Hiibel's Fifth
Amendment privilege against self-incrimination. There was no "articulated real and appreciable fear
that [Hiibers] name would be used to incriminate him, or that it 'would furnish a link in the chain of
evidence needed to prosecute' him." Because Hiibers name was not an incriminating piece of
evidence, he could not invoke the Fifth Amendment privilege in refusing to disclose it.
[edit] Dissenting opinions
Justice Stevens opined that the Court's precedent required it to strike down Nevada's stop-andidentify law. Under the Court's Terry jurisprudence, a suspect has always had the right to refuse to
answer questions put to him by police officers during a Terry stop. And the Fifth Amendment
privilege had always attached during custodial interrogations because information extorted by the
police during such interrogations is unavoidably testimoniaL Why else would the police ask for a
person's name, if not to determine whether that person was either wanted for committing a crime or
directly suspected of committing a crime? "The ofticer in this case told [Hiibel] that he wa~
conducting an investigation and needed to see some identification. As the target ofthat investigation,
[Hiibel], in my view, acted well within his rights when he opted to stand mute. Accordingly, I
respectfully dissent."
Justice Breyer noted that 'the Court wrote that an 'officer may ask the [Terry] detainee a moderate
number of questions to determine his identity and to try to obtain information confirming or
dispelling the officer's suspicions. But the detainee is not obliged to respond.' Berkemer v. McCarty,
468 U.S. 420 (1984) (emphasis added) .... the Court's statement in Berkemer, while technically dicta,
is the kind of strong dicta that the legal community typicaJly takes as a statement of the law. And that
law ha~ remained undisturbed for more than 20 years. There is no good reason now to reject this
generation-old statement of the law.?
Justice Breyer also expressed a "slippery-slope" concern that the majority's opinion would lead to
allowing the police to a~k follow-up questions, such as what the person's license number is, or where
a person lives, without running afoul of constitutional protections.
[edit] See also
List of United States Supreme Court cases, volume 542
List of United States Supreme Court cases
Stop and Identify statutes
[edit] Notes
25
1\
a b In upholding Hiibel?s conviction, the Court noted
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"In this ca~ petitioner'S refusal to disclose his name was not based on any articulated real and
appreciable fear that his name would be used to incriminate him .... As best we can tell, petitioner
28
v
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refused to identify himself only because he thought his name was none of the officer's business.?542 U.S. 177, at 190
2
3
But the Court left open the possibility of different circumstances:

"Still, a case may arise where there is a substantial allegation that furnishing identity at the time
of a stop would have given the police a link in the chain of evidence needed to convict the individual
of a separate offense, In that case, the court can then consider whether the privilege applies, and, if
the Fifth Amendment has been violated, what remedy must follow. We need not resolve those
questions here.? - 542 U.S, 177, at 191
10
11
12
" See the article Stop and identify statutes for a list of states with "stop-and-identify" laws.
A From the opinion of the Nevada Supreme Court in Hiibel v. Dist. Ct., as well as the Stilte of
Nevada's brief to the Supreme Court (Brief for Respondent, p. 4), the Court understood the statute to
require only that the suspect state his name or communicate it to the officer by other means. The
majority opinion noted that Hiibel was asked to provide identification, which the Court understood as
a request to produce a driver's license or some other form of written identification. II different times;
however, it did not indicate that Hiibel was ever asked simply to identify himself. Hiibel did not raise
this argument until his petition for rehearing by the Supreme Court (Petition for Rehearing, p. 1).
A Nev. Rev. Stat. (NRS) 171.l23(3) provides that:
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"The officer may detain the person pursuant to this section only to ascertain his identity and the
suspicious circumstances surrounding his presence abroad. Any person so detained shall identify
himself: but may not be compelled to answer any other inquiry of any peace officer."
It was detennined that by refusing to identify himself, Hiibel violated NRS 199.280, which states:
"A person Who, in any case or under any circumstances not otherwise specially provided for,
willfully resists, delays or obstructs a public offieer in discharging or attempting to discharge any
legal duty of his office shall be punished ..."
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A 'The requirement of California Penal Code 647(e) to provide "credible and reliable
identification" derived not frnm the statutory language but from a construction of the statute given by
a California appellate case, People v. Solomon (1973), 33 Cal.App.3d 429. In Wainwright v. Stone,
414 U.S. 21 (1973), the U.S. Supreme Court had held that "[f]or the purpose of determining whether
a state statute is too vague and indefinite to constitute valid legislation 'we must take the statute as
though it read precisely as the highest court of the State has interpreted it.' "
[edit] Extemallinks
Text ofHiibel v. Sixth Judicial District Court of Nevada, 542 U.S. 177 (2004) is available from
State v. Clifford, 14 Nev. 72 234 LARCENY 2341 Offenses and Responsibility Therefor 23411
Taking 234kl6 k. Property lost or mislaid. Nev.,1879 The rule that the finder of property so marked
that the owner can be ascertained is guilty of larceny Abandoned, lost, or mislaid property West's
Key Number Digest West's Key Number Digest, Larceny 10 Trial Strategy Abandonment of tangible
personal property, 25 Am. JUT. Proof of Facts 2d 685 Forms Affidavit-By finder or saver oflost
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property. Am . .lur. Legal Forms 2d, Abandoned, Lost, and Unclaimed Property I: 11 Report by
finder of lost property-To police or sheriff's department. Am. Jur. Legal Forms 2d, Abandoned,
Lost, and Unclaimed Property 1:13 Affidavit-By finder oflost property, Am. Jur. Pleading and
Practice Forms, Abandoned, Lost, and UneIaimed Property 19 Petition or application-By finderTo establish title to lost property, Am. Jur. Pleading and Practice Forms, Abandoned, Lost, and
UneIaimed Property 34 Most modern authority holds that larceny may be committed when a person
finds and retains an owner's lost property, [ I] so long as it was the tInder's intent to deprive the owner
of the property. [2J To establish the offense of theft of lost or mislaid property, the state must prove:
(1) that the property was lost or mislaid, (2) that the defendant knew or learned the owner's identity or
learned of a reasonable method of identifying the owner. and AMJUR LARCENY 58 Page 1 50
Am. Jur. 2d Larceny 58 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. (3) that the
defendant failed to take reasonable measures to retum the property.[3] When one acquires lost
property which he or she knows to have been lost or mislaid and does not take reasonable measures
to return it to its owner, the acquirer commits larceny if his or her intent is to dispose of the property
for the acquirer's own benefit or that of another person.[ 4] Taking or withholding of such property is
not wrongful unless the finder failed to take reasonable measures to return the property to its true
owner. [5 J There is authority that there can be no conviction for the offense of theft oflost or mislaid
property without sufficient evidence that the property was actually lost or mislaid.[6] Other authority
states that, before larceny of such property may be charged. there must be evidence that the owner
still claims a right or interest in the property.[7] Practice Guide: One who seeks to return lost property
in return for a reward that he or she has solicited has not taken reasonable measures to return lost
property and has intended, by seeking a reward, to dispose of the property for his or her own benefit
and thereby commits larceny. [8] Abandoned property is not the subject oflarceny,[9] beca.use
property that has been voluntarily abandoned by the owner becomes subject to appropriation by the
first taker or finder, who acquires it absolutely.[IO] The Model Penal Code provides that a person
who comes into control of property of another knowing it to have been lost, mislaid, or delivered
under a mistake as to the nature or amount of the property or the identity of the recipient is guilty of
theft if, with a purpose to deprive the owner of it, the person fails to take reasonable measures to
restore the property to the one entitled to have it.(ll] [FN IJ Long v. State, 33 Ala. App. 334, 33 So.
2d 382 (1948); Calhoun v. State, 191 Miss. 82,2 So. 2d 802 (1941); State v. Kaufman, 310 N.W.2d
709 (N.D. 1981); State v. Mack, 31 Or. App. 59, 569 P.2d 624 (1977); State v. Jim, 13 Or. App. 201,
508 P.2d 462 (1973). As to stray animals, see 54, 55. As to when finder of lost goods may be
guilty oflarceny, see 88. [FN2] State v. Moore, 46 N.C. App. 259, 264 S.E.2d 899 (1980). [FN3]
State v. Smith, 276 Mont. 434, 916 P.2d 773 (1996). [FN4] People v. Dadon, 167 Misc. 2d 628, 640
N.Y.S.2d 425 (City Crim. Ct. 1996). [FN5] State v. Evans, 119 Idaho 383, 807 P.2d 62 (Ct. App.
1991). [FN6] State v. Mack, 31 Or. App. 59, 569 P.2d 624 (1977). AMJUR LARCENY 58 Page 2
50 Am. Jur. 2d Larceny 58 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. Floral
designs placed upon a grave are of value to their donors so long as they remain in a condition to serve
the intended purpose, but when they have withered and died they cease to be the subject of larceny.
Busler v. State, 181 Tenn. 675,184 S.W.2d 24 (1944). [FN7] Shedd v. State, 350 So. 2d 1085 (Fla.
Dis!. Ct. App. 1st Dis!. 1977). [FN8) People v. Dadon, 167 Misc. 2d 628, 640 N. Y.S.2d 425 (City
Crim. Ct. 1996). [FN9] Morissette v. U.S., 342 U.S. 246, 72 S. Ct. 240,96 L. Ed. 288 (1952); Com.
v. Wetmore, 301 Pa. Super. 370. 447 A.2d 1012 (1982). [FNIO] Am. Jur. 2d, Abandoned, Lost, and
Unclaimed Property 27. [FN11] Model Penal Code 223.5. 2011 Thomson Reuters. 33-34B
2011 Thomson Reuters/RIA. No Claim to Orig. U.S. Govt. Works. All rights reserved. AMJUR
LARCENY 58 END OF DOCUMENT AMJUR LARCENY 58 Page 3 50 Am. JUT. 2d Larceny
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58 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. American Jurisprudence, Second
Edition Database updated August 2011 Abandoned. Lost, and Unclaimed Property Anne M. Payne,
J.D. II. Rights and Obligations of Finders, Owners and Former Owners D. Mislaid Property Topic
Summary Correlation Table References 37. Finders-Owner or occupant of premises where
property found West's Key Number Digest West's Key Number Digest, Abandoned and Lost
Property 10 to 13 A.L.R. Library Liability for loss orhat, coat, or other property deposited by
customer in place of business, 54 A.L.R.5th 393 The right of possession, as against all except the true
owner, is in the owner or occupant of the premises where the property is discovered,[l] for mislaid
property is presumed to have been left in the custody of the owner or occupier of the premises upon
which it is found.[2] When the owner of premises takes possession of mislaid personal property left
by an invitee, he or she becomes a gratuitous bailee by operation of law, with a duty to use ordinary
care to return it to the owner.[3] Where a tenant finds mislaid property in the basement of his or her
apartment, which includes the basement, the tenant, not the landlord, is entitled to the property, as the
person in possession of the premises.[4) The rule that the owner of the premises where mislaid
property is found has rights to possession superior to those of the finder, may, however, be' changed
by statute and, thus, this distinction between lost and mislaid property may be abolished.[5] As
against everyone but the true owner of the mislaid property, the owner of such premises is absolutely
liable for a misdelivery.[6] [FNI] Terry v. Lock, 343 Ark. 452. 37 S.W.3d 202 (2001); Campbell v.
Cochran, 416 A.2d 211 (Del. Super. Ct. 1980) (the owner of the premises is entitled to the property);
State v. Green, 456 So. 2d 1309 (Fla. Dist. Ct. App. 3d Dist. 1984); Corliss v. Wenner. AMJUR
ABAND 37 Page 1 I Am. Jur. 2d Abandoned, Lost. and Unclaimed Property 37 2011
Thomson Reuters. No Claim to Orig. US Gov. Works. 136 Idaho 417, 34 P.3d 1100 (Ct. App. 2001);
Benjamin v. Lindner Aviation, Inc., 534 N.W.2d 400 (Iowa 1995); Kimbrough v. Giant Food Inc., 26
Md. App. 640, 339 A.2d 688 (1975) (the owner of the premises is entitled to the property); Ray v.
Flower Hosp., I Ohio App. 3d J27,439 N.E.2d 942 (6th Dis!. Lucas County 1981); Morgan v. Wiser.
711 S.W.2d 220, 61 A.L.R.4th 1173 (fenn. Ct. App. 1985). [FN2] Schley v. Couch, 155 Tex. 195.
284 S.W.2d 333 (1955). [FN3) Mickey v. Sears, Roebuck & Co.. 196 Md. 326, 76 A.2d 350 (1950);
Kimbrough v. Giant Food Inc .. 26 Md. App. 640, 339 A.2d 688 (1975). [FN4] Rofrano v. Duffy. 291
F.2d 848 (2d CiT. 1961). [FN5) Rofrano v. Duffy, 291 F.2d 848 (2d Cir. 1961) (defining lost property
as including both mislaid and lost property, and giving the finder, with certain exceptions, entitlement
to it as against the person in posst'Ssion of the premises where it is found). As to lost-property
statutes, see 31. As to statutes which determine the rights to property without reference to status,
see 20. [FN6] Dolitsky v. Dollar Savings Bank, 203 Misc. 262, 118 N. Y.S.2d 65 (Mun. Ct. 1952).
2011 Thomson Reuters. 33-34B 2011 Thomson Reuters/RIA. No Claim to Orig. U.S., Govt.
Works. All rights reserved. AMJUR ABAND 37 END OF DOCUMENT AMJUR ABAND 37
Page 2 1 Am. Jur. 2d Abandoned. Lost. and U~c1aimed Property 37 2011 Thomson Reuters. No
Claim to Orig. US Gov. Works. American Jurisprudence, Second Edition Database updated August
2011 Abandoned, Lost, and Unclaimed Property Anne M. Payne, J.D. II. Rights and Obligations of
Finders, Owners and Former Owners D. Mislaid Property Topic Summary Correlation Table
References 36. Finders West's Key Number Digest West's Key Number Digest, Abandoned and
Lost Property 10 to 13 A linder of mislaid property acquires no ownership rights in it,[ 1) and. where
such property is found upon another's premises, the finder has no right to its possession,[2] but is
required to tum it over to the owner of the premises. [3] This is true whether the finder is an employee
or occupier of the premises on which the mislaid article is foundl4] or a customer ofthe owner or
oceupant.[5] The holder of mislaid property is a gratuitous bailee for the owner, and is required to
hold the property indefinitely.[6]If the finder of mislaid property is the employee of another. and he
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or she finds it in his or her status as an employee, then the right of custody of the property is in the
employer and not in the employee or agent who recovers its physical possession.[7) [FNl) Favorite v.
Miller, 176 Conn. 310, 407 A.2d 974 (1978); Hendle v. Stevens, 224111. App. 3d 1046, 166 IlL Dec.
868,586 N.E.2d 826 (2d Dist. 1992). [FN2] Flax v. Monticello Realty Co., 185 Va. 474, 39 S.E.2d
308 (1946). [FN3] Campbell v. Cochran, 416 A.2d 211 (Del. Super.
CL 1980). [FN4] McDonald v. Railway Exp. Agency, 89 Ga. App. 884, 81 S.E.2d 525 (1954);
Schley v. Couch, 155 Tex. 195,284 S.W.2d 333 (1955). [FN5] Foulke v. New York Consol. R. Co.,
22S N.V. 269,127 N.B. 237, 9 A.L.R. 1384 (1920). AMJOR ABAND 36 Page 1 I Am. Jur. 2d
Abandoned, Lost. and Unclaimed Property 36 ~'2011 Thomson Reuters. No Claim to Orig. US
Gov. Works. [FN6j Dolitsky v. Dollar Savings Bank, 203 Misc. 262, ll8 N.Y.S.2d 65 (Mun. Ct.
1952). [FN7] McDonald v. Railway Exp. Agency, 89 Ga. App. 884, 81 S.E.2d 525 (1954); Dennis v.
Northwestern Nat. Bank, 249 Minn. 130,81 N.W.2d 254 (1957). 2011 Thomson Reutcrs. 33-34B
2011 Thomson ReutersIRIA. No Claim to Orig. U.S. Govt. Works. All rights reserved. AMJUR
ABAND 36 END OF DOCUMENT AMJUR ABAND 36 Page 2 1 Am. Jur. 2d Abandoned,
Lost, and Unclaimed Property 36 t) 2011 Thomson Reuters. No Claim to Orig. US Gov. Works.
American Jurispmdence Proof of Pacts 2d Database updated July 201 Categorical List of Articles
Abandonment of Tangible Personal Property[* J Russell L. Wald, LL.B.[**] Correction: The portion
of the mnning heads on pages 686 to 724 that reads "25-671" is an error. The correct reference is: 25685. TABLE OF CONTENTS Article Outline Scope Index Research References Topic of Article:
~'hether tangible personal property was abandoned by its owner, thus entitling the finder to
ownership of it as against the former owner. This fact question may arise in any action in which title
to and right of possession of personal property is in issue. ARTICLE OUTLINE I Background 1
Introduction; scope 2 Definitions and distinctions-Abandoned property 3 Definitions and
distinctions-Lost and mislaid property; treasure trove and property embedded in earth 4 What
constitutes abandonment, gencrally; presumptions and burden of proof 5 What constitutes
abandonment, generally; presumptions and burden of proof-Intent to abandon; particular acts and
omissions 5.5 Uniform Acts II Proof of Abandonment ofTangibie Personal Property A Elements of
Proof 6 Guide and checklist B Testimony of Plaintiff 1 Direct Examination 7 Previous ownership
of property by person abandoning it 25 AMJUR POP 2d 685 Page 1 25 Am. Jur. Proof of Facts 2d
685 (Originally published in 1981) 'f:i 20 II Thomson Reuters. No Claim to Orig. US Gov. Works. 8
Nature of property 2 Cross-examination 9 Voluntary relinquishment of possession 10 Lapse of
time 11 Nonuse of property; failure to reclaim property 12 Character of place where property was
left C Testimony of Defendant 13 Background 14 Previous ownership of property by person
abandoning it 15 Character of place where property was left 16 Voluntary relinquishment of
possession 17 Demand to reclaim property 1& Failure \0 reclaim pIOperty 19 Lapse oftime 20
Appropriation of property following abandonment 21 Condition of property; deterioration in value
D Testimony of Witness Corroborating Intent of Owner to Abandon Property 22 Previous
o\1il1ership of property by person ahandoning it 23 Declaration of intent to ahandon Research
References Topic of Article: Whether tangible personal property was abandoned by its owner, thus
entitling the finder to ownership of it as against the former O\1iner. This fact question may arise in any
a
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10. Bribery In the following cases in which the defendants were convicted of bribery, it was held
that their claims of discriminatory prosecution were without merit In Commonwealth v Beneficial
Finance Co. (1971) 360 Mass 188,275 NE2d 33, 52 ALR3d 1143, cert den 407 US 910, 32 L Ed 2d
683. 92 S Ct 2433 and ccrt den 407 US 910, 32 L Ed 2d 683, 92 S Cl 2435 and cert den 407 US 910,
32 L Ed 2d 683, 92 S Ct 2448 and cert den 407 US 914, 32 L Ed 2d 689. 92 S Ct 2433 and cert den
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407 US 914, 32 L Ed 2d 689, 92 S Ct 2434, the court rejected defendant's contention that he was the
victim of selective prosecution in violation of the equal protection clause. Defendant, a public official
convicted of receiving a bribe, offered to prove that not all officials known to have received bribes
were indicted, and that various members ofthe Massachusetts Crime Commission had stated that
they were interested in getting defendant. The court held that such proof would be insufficient to
support a claim of selective enforcement, which requires a showing of some arbitrary classification,
such as race or religion, upon which prosecutions are being based. The court said that mere failure to
punish other offenders by itsdf was no basis for holding that there was a denial of equal protection.
Indeed, said the court. it may be altogether appropriate to pick out from a group one or more
offenders whose conduct or position is such that a striking example of them can be made in the
expectation that general compliance will follow. The court said that defendant, as the principal public
figurc involvcd in a case before the court certainly had no standing to complain of his indictment
under that standard, especially since he was not the only public official against whom indictments
were returned. In State v Savoie (1974) 128 NJ Super 329, 320 A2d 164, revd on other grounds 67
NJ 439, 341 A2d 598, the court held to be ",ithout merit defendant's contention that the trial court
erred in denying his pretrial motion to dismiss the indictment on the ground that thc state had
unconstitutionally engaged in discriminatory selective prosecution of defendant. Defendant, a
building inspector, was convicted of corruptly engaging in miseonduct in his public office by
receiving a sum of money, allegedly a~ a Christmas gratuity, from a builder in connection with the
inspection of homes beiug constructed. The proof offered by defendant showed that among the
recipients of Christmas gratuities, prosecutions were initiated only against two officials who received
gifts in excess of $1 00. The court said that that did not satisfy the requirement of sho'.';ing that the
selection was based on some unjustifiable standard; selectivity in enforcement by itself, absent a
showing of invidious and arbitrary classification, did not constitute a violation of constitutional equal
protection rights. II. Drug and alcohol offenses (Cumulative Supplementl!n the following cases in
which the defendants were found guilty of violation oflaws governing the use of alcohol, narcotics,
and other drugs, the courts held that the defense of discriminatory prosecution had not been
established by the defendants. Plaintiffs, arrested for possession of marijuana while attempting to
enter a public coli- 95 A.L.RJd 280 Page 60 95 A.L.RJd 280 (Originally published in 1979) <1;j 2012
Thomson Reuters. No Claim to Orig, US Gov. Works. seum, sought to enjoin the enforcement oflhe
drug laws, in Wheaton v Hagan (1977, MD NC) 435 F Supp 1134. Plaintiffs asserted that the
coliseum's official policy of arresting possessors of small amounts of marijuana while not arresting
possessors of alcoholic beverages violated the due process and equal protection clauses of the
Fourteenth Amendment. In holding that the distinction made by law enforcement officials at the
coliseum did not rise to the level of discriminatory or selective enforcement of the law that is
prohibited, the court held that the plaintiffs did not prove they were treated differently than persons
similarly situated since persons violating distinct, separate statutes are not so similarly situated.
Furthermore, the court said that assuming that a single class of violators might be defined that
includes persons who are found to possess either marijuaua or alcoholic beverage, the plaintiffs could
not prevail since there was no evidence to support a finding that any selective enforeement was based
upon some constitutionally impermissible ground such as race, religion, or the exercise of the First
Amendment right to free speech. A District Court determination that Oklahoma's liquor laws were
discriminatorily applied was reversed by the court in National Railroad Passenger Corp. v Harris
(1974, CA I 0 Okla) 490 F2d 572. The evidence before the District Court showed that the alcohol
beverage control board had meticulously enforced the provisions of the law with reference to the salc
of liquor by licensed package stores but had made il~ investigations of places selling liquor by the
- 47 Mo::ion for S:ln.:::tions
drink at the request of other law enforcement agencies only. The District Court said that the board's
efforts to enforce those provisions of the law had been sporadic and nonuniform and that no goodfaith effort was made to enforce the provision uniformly. In reversing the District Court's
determination. the Court of Appeals said that plaintiff did not have any evidence with reference to its
discrimination claim. On the contrary. said the court. the record showed that the prosecution was
initiated by a telephone call from a newspaper reporter to the alcohol heverage control board,
4
advising that Amtrak was selling liquor by the drink on its trains. Furthermore, the court said that the
5
record disclosed that there were in that county alone. approximately 34 prosecutions instituted during
the 9-month period immediately preceding the filing of the instant suit. In Belgarde v State (1975,
6
Alaska) 543 P2d 206, the defendant a~serted that the application of the marijuana laws in Alaska
resulted in invidious discrimination against young persons. Referring to statistics which indicated that
7
two-thirds of the persons charged with the possession of marijuana were within the ages of 18 and 21.
8
the defendant argued that the data showed a discriminatory application of a law neutral on its face,
thus demonstrating a violation of the equal protection clause of the United States Constitution.
However, the court said that it had not becn shown that enforcement of the statute was conducted in
] 0 such a way as to purposely single out young persons as the targets of enforcement while ignoring
violations by others. The court said that the mere showing that many young persons were subjected to
11
prosecution did not prove defendant's thesis since the mosl obvious explanation for the statistically
large percentage of young persons being the object of marijuana law enforcement was that marijuana
12
use occurs with greater frequency among the young than among those of older years. The court held
that a case of unconstitutional, invidious discrimination had not been made out by defendant. [n
United States v Smith (1976, Dist Col App) 354 A2d 510, the court set aside the trial court's order
14 dismissing possession of marijuana charges against defendant. Seeking to compel the government to
present testimony as to why he was not being granted first-offender treat- 95 A,L.RJd 280 Page 6]
]5
95 A.L.RJd 280 (Originally published in 1979) 2012 Thomson Reuters. No Claim to Orig. US
16 Gov. Works. ment, defendant filed a motion stating that he requested such treatment but was
informed that it was policy to deny it to defendants who had litigated any issues in their case, as had
17
defendant. Defendant asserted that such a policy had an unconstitutionally discriminatory effect upon
individuals who chose to exercise their legal rights. On appeal of dismissal of the charges, the court
18
said that it had no quarrel with the trial court's ruling that a policy intended to deter defendants from
19 exercising their legal rights cannot be tolerated. However, the court held that defendant had not made
an adequate showing that the policy of the government had such effect. Noting that if a defendant
20
successfully completed thc first offender treatment program, charges were dropped against him, the
court said that the beneficiary of such a disposition could scarcely be said to have been deterred from
21
exercising his right to defend himself, for, by dismissing such charges, the government had done
away with any reason for him to do so. The court said that should the prosecutor deny first-offender
22
treatment to a defendant, the latter is in no way barred from then invoking his legal rights and
23
defenses. [n affirming defendant's conviction for unlawfully possessing alcoholic beverages, the court
in Cone v State (1937) 184 Ga 316, 191 SE 250, held that the trial court did not err in striking
24
defendant's special plea alleging that the law enforcement officials did not impartially enforce the
25 prohibition laws, but proceeded only against persons toward whom they were prejudiced. Defendant
alleged that while it was generally known that there were many people violating the prohibition law,
26 and that the officers knew those parties and knew they wcre violating the law, they did not arrest
them but only picked out a few of the poorer citizens and paid no attention to the wealthier classes or
27
those who had property and were higher up in lite. In sustaining the slriking of defendant's plea, the
court said that the fact that other persons or classes of persons may have violated the law without
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Motion tor Sanctions
being prosecuted therefor was no excuse for a vi01ation by defendant, In Schmidt v [ndianap0lis
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(1907) 168 Ind 631. 80 NE 632. in which defendant appealed from h is com ietion for violating an
ordinance which prohibited the maintenance. without a license, of a depot or agency
ofa brewery, defendant contended that other persons within the city "ere engaged in buying beer
from breweries and selling the same in a like manner as defendant: that the object of the ordinance
was to oppress and discriminate against businesses of breweries located outside the city: and that the
same was so enforced as to favor the business of breweries located within the city of Indianapolis,
Howe,er, the court said that the charge that the ordinance at a given time was unfilirl\' enforced was
too general to present any questions, The court said that no fac;s were alleged upon V::hich to rest the
conclusion that the ordinance was so enlorced as to favor the business of breweries located within the
city. Without intimating that the validity of a penal ordinance might be assailed on the ground of
partiality in its enforcement, the court hcld that. in the absence of facts pleaded showing a fixed and
continuous policy of unjust discrimination on the pan of the municipality, it would not enter upon a
consideration oj' the question suggested, In State \' Apt (I c)76, Iowa) 244 NW2d gOI. defendant
contended that the proseclltor shcluld not be permitted to prosecute him fol' possession and delivery of
a controlled substance without aiso prosecuting a police infomlcr who also possessed the drugs,
Stating that the conscious exercise of some selectivity in ~nforcement is not in itself a federal
constitutional violation, the court said it was not stated that selection "as deliberately hased upon an
unju<;tifiable standard, and therefore held that it found no equal protection violation, In State v
Jourdain (1954) 2~5 La 1030,74 So 2d 203, the defendant appealed fi0111 his 95 A.L.RJd 280 Page
6295 AL.R,3d 280 (Originally published in 1979) conviction for possession of marijuana,
contending that the manner in which the narcotic law was being administered hy the district attorney
deprived him of equal protection of the law, in that defendant's intraction was being actively
prosecuted whereas the prosecuting ofticials had rerrained
from prosecuting other. more serious violations of the narcoti<: act. Rejecting that claim as untenable,
the court said that it was defendant's contention that the failure of the prosecuting officials to otTer
defendant immunity, ifhe would hecome an informer, operated as a purposeful discrimination against
him and thus denied him equal protection of the law, llowcwr, stating that the fact that not every law
violator had been prosecuted \\as of no concern to defendam in the absence of an allegation that he
was a member of a class being prosecuted solely because of racc, religion, color, or the like, or that
he was the only person who had been prosecuted under the statute, the court said that without such
charges, defendant's claim did not come within the class of unconstitutional discrimination.
Defendant's contention that he was discriminated against by law cnlllrccment officials in the
application ofthc state alcohol prohibition law was rejected on appeal by the court in State v Wood
(1966, Miss) 187 So 1d 82(), Defendant urged that because in cenain counties the law was not
cnf()rccd by local law enforcement officials, he was heing denied his constitutional right of equal
protection of law for the reason that there existed a deliberate or intentional pattern or systematic plan
of not uniformly enforcing the law, However, while conceding that sherin's and police officials were
enf()rccment officers of the statt:, the court said that it did not j()llow that the state had control and
direction over those ofticcrs, and that as a matter of fact the opposite was true. thus partially
explaining why law enforcement had been lax in cel1ain counties, Noting that the record showed that
the sheriff who arrested defendam had demonstrated unusual emltt to enforce the la"
indiscriminately and had heen successrul in so doing, the court said that the fact that the sherin'made
no attempt to enforce the liquor laws inside the corporate limits 0 I' a city within the county did not
amOltntto deliberate, purposeful discrimination since the sheriO'testified that there was an agreement
to the effect that he \\ould enforce the laws in the county and leave city law enforcement to the city
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police. The court concluded that the clement ofpurposeful or intentional discrimination. which
defendant had to show in order to permit him to justly assert that he had been denied equal protection
of the laws, was lacking. In Cairns v Sheriff. Clark County (1973) 89 Ney 113.508 P2d 1015.
dd'endant. charged with the sak of narcotics. sought pretrial habeas relief alleging a violation of his
cllnstitulional rights because of the policy of the law enforcement officers in granting immunity from
prosecution to those arrested I()]' narcotics violations who later became informers. Defendant
contended that the otfer of immunity conditioned on becoming an informant operated as a purposeful
discrimination against him. The court said that even if it conceded that the state had failed to
prosecute law violaters who had agreed to become informers, that did not constitute an unlinvful
administration ofthe statute or evidence of intentional or purposeful discrimination against
defendant. The fact that not every law violater has been prosecuted is of no concern to defendant. said
the court. in the ahsence of an allegation and proof that he is a member ofa class being prosecuted
solely because ofmce. religiOli. color. or the like. or that he is the only person who has been
prosecuted under the statute. Defendant. charged with the criminal sale of a controlled suhstance.
contended in People v Rosenthal (1977) l) 1 Misc 2d 750. :;98 NYS2d 639. that he had been
selectively prosecuted. Although tinding defendant not guilty on other grounds. the court held that
defendant's claim 95 A.L.R.3d 280 Page 63 95 A.L.R.3d 280 (Originally published in 1(79) V 2012
Thomson Reuters. No Claim to Orig. US (}ov. Works. that he had been selectively prosecuted was
without merit since the record before the court was barren of any evidence that defendant had been
denied equal protection of the law because of a possible discriminatory cnt()rcement of the penal law
section under whieh defendant was charged. The court said that in order for defendant to have
prevailed, he would have had to have shown that there was invidious or bad-faith selection of him as
a target. In Commonwealth v Butch (1978, Pa Super) 390 il2d 803. the court rejected the contention
of a defendant that he was unconstitutionally discriminalcd againsl when he was charged with the
more serious crime of delivery of marijuana rather than possession of marijuana when he did not cooperate in leading the pol ice to other drug sources. Stating that the conscious exercise of some
selectivity in enforcement is not in itself a federal constitutional violation unless the selection was .
deliberately based upon an unjusti1iable standard. the court said that even if it were to assume that the
defendant's depiction of the circlimstances was completely accurate. the procedure described was in
no way unreasonable, arbitrary. or unfairly discriminatory. In State v Boutch (1973) 60 Wis 2d 397.
210 NW2d 751. the cOUli rejected the contention of thc defendant. who was convicted of aiding and
abetting the sale of a dangerous drug. that he was the victim of unjust discrimination. Defendant
claimed that such discrimination resulted from the granting of transactional immunity by the trial
court to the seller of the dangerous drug. in order to insure her testimony against dclendant.
Defendant claimed that the offer of immllnitv from the state for testimony bv one involved in a
criminal transaction against another individ~al invoh'ed in the same rran~ac(ion deprived rhat
individual of equal protection of the laws. as an exercise in invidiolls discrimination. However. the
court said that in the absence of an allegation and proof that detendant is a member of a class being
prosecuted solely because of race, religion, color. or other arhitrary classification. or that he is the
only person who has been prosecuted under the statute. dclendant's claim did not come within the
class of unconstitutional diSCriminatory enforcement. CUMULATIVE SUPPLEMEl\T Cases: State
police trooper failed to show that police engaged in selectivc enforcement of law, in violation of his
equal protection rights. by vigorously il1\'cstigating circumstances surrounding his presence in state
vehicle. parked hy side of road during morning hours. while possibly intoxicated. when no showing
was made of how similarly situated members of public were treated. L .S. Cons!. Amend. 14. Diesel
v. Town of Lcwisboro. 232 F.3d 92 (2d Cir. 2000). Claim by appellant convicted of selling cocaine.
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that he suffered discriminatory prosecution based on testimony of investigator that arrestces \vere
routinely offered opportunity to cooperate "'ith narcotic task force in exchange for some lype or
recommendation regarding charges against them. \\as properly rejeckd as failing 10 sho\\ hasis I()r
relict: where appellant did not demonstrate that he had been deliberately singled out tor prosecution
on basis of some invidious criterion. People v Blend (1981. 5th Dist) 121 Cal App 3d 215. 175 Cal
Rptr 263. In prosecution for possession of cocaine. defendant failed to establish defense of
disedminatory prosecution. based on allegations that police omcer lailed to report drug activitics of
his friends or his own alleged drug acti\ity. where defendant failed to allege that prosecutor, by
words or conduct. either explicitly or implicitly. authorized police ofticers to engage in al- 95
A.L.RJd 280 Page 64 95 A.LRJd 280 (Originally published in 1979) f) 2012 Thomson Rcutcrs. No
Claim to Orig. US Gov. Works. leged conduct claimed by defendant. People v Kurz (1992. Colo
App) 847 P2d 194. Pmctice of sheri Il's department to conduct "rcyerse sting" operations (in which
undercover agents offer (0 sell drugs to suspected traffickers) only in cases involving 50 pounds or
more of marijuana did not raise inference of discriminatory enforcement. Owen v State (1983. Fla
App DI) 443 So 2d 173. Retailer prosecuted for selling drug paraphernalia in violation of statute
failcd to establish discriminatory or selective enforcement of the law. v.here only evidence ofTered
v.as that defendant and onc oth~r establishment received wal11ing letters and that only defendant was
subsequently prosecuted. and argument Ihat although hundreds of merchants sold sandwich bags only
defendant was an'ested for selling drug paraphernalia: mere fact that delendants were first to bc
prosecuted under law did not alone establish that district attorney's office engaged in arbitrary
enforcement of the law. State v Dunn (1983) 233 Kan 411. 662 P2d 1286. See People v Barnwell
(1989) 143 Mise 2d 922. 541 ~YS2d 664. ~ 8. Delendant failed to establish prima facie case of
selective prosecution, although delendant alleged that some cocom,pirators were similarly situated
but received favorable treatment: defendant was charged with more serious narcotics offenses and
running corrupt organization. secondary players were ol1ered plea agreements in exchange lor their
testimony against defendant. and evidence established that defendant was more culpable than his
cohorts. Com. v. Rickabaugh. 706 A.2d 826 (I'a. Super. CL 1997). reargument denied. (Feb. 27.
1998). Decision to prosecute intoxicated teenage driver who stnlck and killed three children, and not
to prosecute companion who supplied liquor, was not hased on unjustitiable standard and prosecution
was thus not discriminatory. Stale v Judge (1984) 100 Wash 2d 706. 675 1'2d 219. [Top of Section1
lEND OF SUPPLEMENT] 12. Escape ti'olll custody In the following cases in which the defendants
were convicted of escaping from prison. the courts held that defendants had not established the
defense of discriminatory prosecution. Where, during
a 2-ycar period in which 31 inmates escaped from the Arizona State Prison, only five charges of
escape were filed. including the charges against th" two appellants. the coun in State v Scott (1972)
17 Ariz App 183,496 P2d 609. found no merit in appellants' bare assertion that they were denied
equal protection and due process because they were charged with escape while others were not. and
fUrl her found no suggestion of invidious discrimination toward appellants. In Commonwealth v
Phillips (1977) 248 Pa Super 400.375 A2d 158. deJelldant contended (hat he suffered prejudice at the
hands of the Commonwealth by \'inue of the fact that he \\as prosecuted and received a sentence on
an escape charge, while a cote/on in the escape v.as nOI prosecuted. Stating that in essence defendant
seemed to be arguing discriminatory prosecution. the court said it was well established that a
defendant alleging such conduct must prove the clement of intentional and purposeful discrimination
before a violation of constitutional rights can be shown. In rejecting defendant's claim. the court said
that defendant had presented no evidence to establish sllch an clement and the mere failure of
authorities to prosecute others similarly situated docs not constitute a violation of due process or
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equal protection 95 A.L.R.3d 280 Page 65 95 A.L.R.3d 280 (Originally published in 1979) if; 2012
Thomson Reuters. No Claim to Orig. US Gov. \Vorks. rights. ~ 13. Gambling [Cumulative
Supplement I In the following cases in which the dclendants were convicted of violation of various
laws concerning gambling. it was held that the defense of discriminatory prosecution had not been
established by the defendants. Defendant convicted of violating an ordinance making it a
misdemeanor t()r any person to visit a harricaded housc containing gambling implements, contended
in Ail Sin v Wittman (1905) 198 US 500. 49 L Ed 1142.25 S Ct 756. that tbe ordinance violated I
of the Fourteenth Amendment of the Constitution of the United States. in that it deprived him of the
equal protection oCthe laws. because it was eniorced soldy and exclusively against persons of" Ihe
Chinese race. Stating that ddendant sought to set aside a criminal law. not on the ground that it \Vas
unconstitutional on its face or that it was discriminatory in tendency and ultimate actual operation.
hut on the ground that it \1 as made so by the manner of its administration. the court said it was a
matter of proof and no facts should be omitted to make it out completely. The court noted that there
was no averment that the conditions and practices to which the ordinance \\as directed did not exist
exclusively among the Chinese. or lhat there were ollenders against the ordinance, other than the
Chinese. as to whom it was not enforced. Stating that no latitude or intention should be indulged. and
that there should be certainty to every intent. the court aftlrmed defendant's conviction. In
Washington v Unikd States (1968) 130 App DC 374,401 F2d 915, the conrt rejected the detendant's
contention that it was error for the trial court to refuse to pemlit him to introduce evidence to prove
an unconstitutional distinction in the cnl()rcemcnt of the statute under which he was charged. The
defendant, convicted of two violations of the lottery laws. sought to prove the existence of other
lotteries in the town which were not subjected to the provisions of the statute. The court said that a
deprivation of equal protection must inevitably be found in the actual existence of an invidious
discrimination and not in the mere possibility that there will be other like or similar cases which will
be treated more leniently. Stating that there was no claim of-much less a professed ability to
substantiate--any intentional, purposeful diffurentiatioll. the cOUr! said it would not do simply to
show. as defendant would. that enforcement of the law was lax. or even that other offenders had gone
free. [n affirming defendants' convictions tor bookmaking. the court in People v Oreck (1946) 74 Cal
App 2d 215, 168 P2d 186. rejected defendants' contention that the trial court erroneously sl.1stained
objections to certain questions aimed at showing that the police discriminated against horscracc
betting in that they did not raid certain establishments specializing in election and other types of bets.
Defendants did not offer to prove that they were bcing prosecuted because of thcir racc. eoloL
religion. or political beliefs. but simply sought to show that others equally guilty were not being
prosecuted. Defendants contended that the facts that they sought to prove would demonstrate that
they had been denied equal protection of the laws. Stating that the uiscriminution claimed by
defend,mts was that those engaged in horseracc betting were being prosecuted while those who ran
other types of illegal betting establishments were not the court said that such type of discrimination.
if discrimination it be, was not within the rule of the cases cited bv defendants. The court said that it
was the law that a pcr- 95 AL.R.3d 280 Page 66 95 A.I..RJd
son committing a crime cannot
claim an unlawful discrimination upon a mere showing that other persons or classes of persons have
committed the same offense and have not been prosecuted therefor. The trial court's dismissal of
criminal charges against the defendant on the ground of discriminatory enforcement of the law was
reversed in People \" Garner (1977. 2d Disll 72 Cal App 3d 214.139 Cal Rptr 838. Convictions tor
theft by deception, theft by failure to make required disposition of funds received, criminal
conspiracy, and aiding in the consummation of crimes warrants disbarnlent. 18 Pa.C.S.A. 903,
3921,3922. 3917. 5107. Ofllce of Disciplinary Counsel v. Costigan. 526 Pa. 16.584 A.2d 296
280
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(1990). -in a case in which a bar applicant engaged in thievery of a repetitiyc nature. the 'court
denied the applicant's application since it appeared that the applicant had not undergone the requisite
rehabilitation of his good moral character. the COUrl pointing out that the erux of the applkant's case
was that his present moral character fitnes, justified his admission to the bar and that his repetiti vc
thefts were the result of a tempordry aberration that no longer existed and of which there was no
danger of reClln'cnCC under the stress of representing clients; the evidencc of rehabilitation in the casc
rested primarily on the opinion of a psychologist, yet the report furnished no insight into Ivhy a 26year-old college graduate who had completed one year of evening law school study would repeatedly
engage in petty thievery whiie an invitee in the homes of his customers, and the report otTercd no
explanation of how this compulsioll, if indeed it were a compulsion, had beell treated, the court
adding that it furnished no reasons why the applicant's rehabilitation should be considered full and
complete. Application of G, S.. 291 Md. 182.433 A.2d 1159 (1981) .Conviction of petty theft while
employed as assistant prosecuting attorney warrants oncyear su>pension from practice aflaw. with
that sanction suspended on condition that 110 other violations of disciplinary rule prohibiting illegal
conduct involving moral turpitude be committed. Code of Prof.Resp., DR I" I 02(A)(3 "5).
Disciplinary Counsel v. Nass. 65 Ohio St. 3d 160.602 N.E.2d 610 (1992). Conviction ol'tirst-dcgrec
retail fraud for shopli Iling warrants suspension irom the practice of law for one year without credit
for time served. Govemmel1l Oflho l1ar Rule V (9)(a)(iii): Code of i'roLRcsp .. DR 1"102(A)(3"5).
Disciplinary Counsel v. Abookirc. 63 Ohio St. 3d 391. 588 N.E.2d 793(1992). Attorney petty thcii
conviction il1r shoplifting and her conviction for tampering with records warranted suspension from
practice of law for two years, with one year suspended, and upon completion of suspension, attorney
must submit to psychiatric examination to determine whether she is emotionally fit to resume practice
oflaw. Code ofProf:Rcsp .. DR I "102(A)(4. 5). Toledo Bar Assn. v. Lockhart, 84 Ohio St. 3d 7.
1998-0hio-687. 701 N.E.2d 686 (1998). Attorney convictions for shoplifting and his failure to report
one of those convictions to Bar Association when specifically questioned warranted suspension fi'Oll1
practice oflaw for 18 months, with one lear of suspension stayed pending successful completion of
one-year probation period and appropriate counseling. Code ofProfResp .. DR 1"102(A)(3, 4, 6), DR
1" 103(A). Cincinnati Bur Assn. v. Fidler, 83 Ohio St. 3d 396. I 998-0hio-39. 700 N.E.2d 323
(199S).Thc court in Application of Howard C., 286 Md. 244, 407 A.2d 1124 (1979), held that the
state board of law examiners acted pmperly in not considering two pelty theft otTenses for whieh the
applicant had been placed on probation without verdict, having becn legally exptmged under the
pmvisions of Md. Ann. Code art. 27. 737, in detcnllining the moral character of the applicant for
admission to the Maryland Bar. A bar applicant "ho had been charged with shoplifting, but not
convicted or the crime. 3 A.L.R.6th 491'age 83 3 A.L.R.6th 49 (Originally published in 2005)
2011 Thomson Reuters. No Claim to Orig. US Gov. Works. would be entitled to admission to the
Oregon Bar, particularly since he had apparently made restitution in the criminal matter, the court
held in Application of Tobiga. 310 Or. 46, 791 P.2d R30 (1990). An applicant till' admission to the bar
must prove good character. the cOUli remarked. and. befl)!"e the court may admit an applicant. it must.
pursuant to Or. Rev. Stat. ~ 9.250. direct an order to be entered to the effect that an applica.nt is of
"good moral character." The reason for the requirement. the court continued. is protection ofthc
public in its dealings with practitioners. although the protection of the public does not permit denying
individual applications
on mere suspicion. Herc, the court stated, several circuit court judges, Northwestern Law School
faculty and administrative staff, the law school dean. a nun, other religious professionals. Portland
State University faculty. and over a half-dozen practicing attorneys vouched for the applicant's moral
character and honesty, and strong and uninterrupted crossexamination of many of them did not shake
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their belief in the applicant's cbaracter based upon their acwal experience and contacts v.llh him.
Moreover. the court indicated, arrest records obtained by the bar revealed no other arrests bel()re or
after the applicant's 1985 shoplifting charge. Based on thc lotality of evidence in the record. and
giving due v.eight to the substantial body of evidence hom a wide variety of citizens as to hIS
character and honesty, the comi found by clear and convincing evidence that the applicant was a
person of good moral character entitled to admis,ion to the Bar of Oregon. The court in Application
of Schaeller. 273 Or. 490. 541 P.2d 140() (1975). held that the arrest or citation of an applicant for
admission to the Oregon Bar on a charge of being a minor in possession of beer was not a significant
reflection upon the applicant's moral character for the purposes of admission. However. upon grounds
not relevant in the instant case. the court determined that further investigation of the applicant's
conduct was necessary in order to determine whether he was qualified for admission to the. bar.
a bar applicant who stoic sleeping pills from cllslomer,' homes while working as a salesperson after
his first year of law school and who subsequently WiiS convicted or petty thefts failed to establish
present good moral character. the court related, the court observing. more spccifically, that the
applicant had obtained a joh selling baby pictures, "ark that involved calling on customers at their
homes. and that. some month, after entering this line ofv.ork. the applicant began to steal pills from
his customers when he requested permission to use the customer's bathroom. after which he would
search for, and steal, the medication: viewing the rehabilitation report prepared with respect to the
applicant most charitably, it seemed to renect a lack of appreciation of the serious effect that
repetitive theft by an adult law student has on the difficult task of dctemlining present moral
character fitness lor admission to the bar. the court concluded. Application of O. S., 291 Md. 182.
433 A.2d 1159 (1981) .In Florida Rd. of Bar Examiners Re: L. K. D.. 397 So. 2d 673 (Fla. 1981). a
proceeding instiwted on a petition for bar admission, the court held that the findings of the board of
bar examiners wilh respect to an incident in which a bar applicant was charged with. and was later
acquitted of, shoplifting. was not alone sufficient to bar the applicant's admission to practice of law.
The applicant's jury acquittal, the court noted at the outset, while not binding on the hoard or on the
coun in reaching conclusions regarding the alleged incident of theft itself, had special significance
with regard to Ihe board's conclusion that the applicant lied three times in asserting, her innocence.
That is. the court remarked. the jury's conclusion vindicated the applicant's declaration of innocence
of the crime charged before and at the jury trial, the court adding that her acquittal would continue to
justifY her protestation of innocence al her subsequent hoard hearing, even though the board might
have thought it advantageous to make a showing of repentance. The court concluded that the
applicant had carried her burden of demonstrating good character. and had ShO\\l1 a present fitness to
enter the practice of law. as a resull of which her petition for admission would be granted A bar
applicant whose shopliliing charge had becn dismissed would be entitled to admission to the Oregon
Bar, the court held in Application ofTohiga. 310 Or. 46, 791 P.2d R30 (1990). The court explained
that the applicant's shoplitting charge was dismissed in 1986 as part of a civil compromise in which
the applicant paid $100, the court adding lhat the applicant's attorney on the shoplifting charge
explained to the bar examiners that he convinced the applicant to accept the civil compromise and
dismissal of the cbargcs over tbc applicant's objections that the applicant was innocent. The trial
panel did not lind that the store incident was grounds for rellising admission to practice, though the
fact of a charge and a dismissal is no!. in and of itself. determinative on the question of moral
character. the court declared.-thc court held that an applicant for admission to the Maryland Bar
who had becn convicted for shoplitiing on two occasions. once ill 1966 for stealing a bottlc of rum
from a supermarket and again in 197 I for stealing a tape measurc. e<;tablished his present 1110ral
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character fitness where there was no evidence in the record even remotely suggesting that he had
been involved in any misconduct in )ears following the 1971 the1t offense. Application of Allan S.,
282 Md. 683, 387 A.2d 271 (1978).
An applicant to the bar. who had been convicted of shoplifting and resisting arrest with violence, did
not have the requisite character and fitness to allow admission to the bar at the present time, the court
held in In re Roots, 762 A.2d 1161 (R,l. 2(00). More specifically, rhe applicant. when he was 18
years of age, was charged with and convicted of shoplifting in Florida, and, subsequently, he was
arrested again in Florida and convicted of the felony of res-8) .isting arrest with violence, The court
commented that the applicant had the burden at all times to demonstrate his moral fitness and
character to practice as a lawyer in the state, and here, the applicant's past, including his criminal
record and convictions, gave the court pause in accepting the applicant'S avowal to that he could now
in good faith take and abide by the requisite attorney's oath. The court observed, as well, that the
applicant stated to th'e committee and to the court that he would not only take the attorney's oath if
admitted to the bar, but that he would abide bv it. However, the court stressed, the prior record of the
applicant, including his criminal past and oth~r questionable conduct demonstrating his lack of
candor and truthfulness. cast sllch doubt upon the sincerity of the applicant's professed willingncss to
abide by the terms of the oath that he must take as a mcmber of the bar of this state that his
application should be denied at the present time, Although the r~cord revealed far too many reecn!
and past criminal acts, instances of untruthfulness, and a lingering inability of the candidate to take
the requisite attorney's oath in good faith, to warrant current admission, the couli h~ld that thc denial
of his application would not preclude the possibility of the applicant reapplying for and obtaining
approval of his admission to the bar at some later time, though no sooner than two years from the
date of the opinion,-in bar applicant tltness proceedings, the court. affirming the decision of the
Board of Bar Examiners denying a bar applicant's certification, held that the failure of the applicant
to prove rehabilitation following a conviction on non felony charges. including assault. insulting an
officer, shoplifting, theft by taking, simple battery, trespassing, and possessing a firearm without a
pennie during a IO-year period ending at age 26 precluded certi lication of litness to practice law, the
cOUl1 relating that where an applicant for admission to the bar has a criminal record, his or her burden
of establishing present good moral character takes on the added weight of proving full and complete
rehabilitation subsequent to conviction, Application of Cason, 249 Ga. 806,294 S,E.2d 520 (1982)
,According to the court in Florida Bd, of Bar Examiners Re: L K. D.. 397 So. 2d 673 (Fla. 1981), a
linding of the Board of Bar Examiners with regard to an incident in which the applicant was charged
with, but not convicted of. shoplifting, was not alone sufficient to bar admission to the practice of law
in Florida in light of suostantiai. unrefuted evidence of the candidate's character. The court stated that
it was compelled to conclude that the Board of Bar Examiners' !indings, even though somewhat
supported in the record, was not alone suJ't1cient to bar the applicant's admission. I'he fact that the
Board of Bar Examiners heard he testimony, the court pointed out, did not insulate its filct-linding
from review by the court in a somewhat more detaIled manner than is usual in an appellate review oj'
a jury finding, the COllrt adding that the board's "trial" did not preclude it from reviewing the 1~1Ctual
underpinnings of its recommendation. based on an independent review of the record developed at rhe
hearings. While additional adverse findings were made by the board, the court pointed out, two of
these findings stemmed from the applicant's persistent protestation of her innocence ofwrangdoing
bcf()re or at her criminal trial, and these added nothing at all to her character analysis. Similarly, the
court stressed, the other ad\crse tlnding lacked independent significance in evaluating the applicant's'
character as it Hawed, cLlmulatively, from the board's conclusion that the applicant was, in fact, guilty
of the alleged larceny charges. Attorney who com111its act of professional misconduct by shoplifting
'v
wiil be censured. where. at time of incident. attorney jUdglll<:ot \las suflicicntly impaired to cause her
abetTational conduct and where allorney has sought and obtained appropriate psychological help.
McKinney Judiciary La'" 90: N.Y.Ct.Rules. ~ 691.2. Maner of Mongioi. 213 A.D.2d 107.631
N.Y.S.2d 77 (2d Dep't 1995).
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--Conviction of class B misdemeanor ofthefi and admission to charge of shoplitiing warranted

24"month suspension from practice ofla". stayed on condition that attorn e) commit no further acts
ofthcli. where attorney had no prior disciplinary record. restitulion was made in both instances. he
was well-regarded as competent and talented lawyer. he had recently lost his employment. he was
receiving treatment for personal and emorional stress. including intensive treaUTIent since time of
incidcnts. he made full and free disclosure in disciplinary investigation and was cooperative toward
proceedings. he admitted conduct in both petitions, and he was contritc and remorseful. Rules fl,r
Lawyer Discipline, Rule I.~. subd. A(2): Standards for Imposing Lav,.yer Sanctions, Standard <).3.
Application for Disciplinary Action 113 A.L.R. 1179 Page 340 113 A.L.R. 1179 (Originally
published in 1938) 1997 ND 234. 571 N.W.2d 370 (N.D. I 997).Conviction of first-degree retail Iraud
for shopliliing warrants suspension from the practice oflaw for one year without credit for time
served. Government of the Bar Rule V (9)(a)(iii): Code ofProfResp .. DR l"I02{A)(3"5).
Disciplinary Counsel v. Abookire, 63 Ohio Sl. 3d 391. 588 N.E.2d 793 (I 992),Eight affidavits from
attorneys. attorney employer and other responsible persons as well as lengthy testimony at hearing of
psychiatrist who treated attorney t'Or nearly three years following his shoplifting conviction was
sufficient to demonstrate attorney moral rehabilitation \\ ith clear and convincing evidence. justifying
his reinstatement to practice conditioned upon attorney succe;,sful completion of State Bar
examination and professional responsibililY exam. SDCL 16" 19"84. Petition of Draeger. 463 N. W.2d
346 (S.D. I 990).Nevada Birmingham. Petition ot: 110 Nev. 70.866 P,2d 1150 (1994) -in a case in
which a law school graduate. who had been found guilty of conspiracy to distribute marijuana.
petitioned for a v,.aiver of the rule that an applicant who has been once denied admission to the bar tor
failure to meet necessary characlcr requirements. the court 3 A.I...R.6th 49 Page 39 3 A.I...R.6th 49
(Originally published in 20(5) t 2011 Thomson Reuters. No Claim to Orig. LS Gov. Works. held
that the applicant had clearly and convincingly demonstrated full and complete rehabilitation ti-om his
prior criminal inVOlvement: the COtllt stated that the applicant's "many positive accomplishments
since the commission of his criminal ortenses," along ",ith the number and magnitude of his
achievements, supported the determination that the applicant was rehabilitated and that he would
"distinguish himself in the practice of the law." Petition ofBirmingham. 110 Nev. 70. 866 P.2d 1150
(1994) . According to the court in Petition of flinninghalll, 110 Nev. 70, 866 P.2d 1150 (1994), an
applicant who had pled guilty to a federal charge of conspiracy to distribute marijuana and served
time in prison would nonetheless be entitled to admission to the bar. The applicant was a pilot who,
in 1983. admittedly was in\,o!v'ed in a scheme to smuggle marijuana into the United States from
South America; he 'voluntarily \\ithdrew !I'OIll this illicil activity and entered law school. though,
while in law school, his past "caught up with him." and he was atTested by federal ofticials. The
applicant pleaded guilty to a federal charge of conspiracy to distribute marijuana and was sent to
prison, and, because of his cooperation w'ith law enforcement. he was placed on early parole in
Fenruary 1989. While on parole. the applicant relurned to law school and was able to graduate in
May 1990. whereupon he took the Nevada bar examination and passed it. rhe applicant was
discharged from parole in 1991. and. ancr hearings. the state Board of Bar Examiner<; recommended
to the coun that he be admitted to the practice or law, In a written order. the court initially refused to
accept the hoard's recommendation tor the appli<:ant', admission and questIOned the hoard's
conclusion that the applicant possessed the "suitable moral character" that would qualify him to be
numbered among those licensed to practice law in this state. The graduate petitioned for a waiver of
the rule that an applicant who has been once denied admission to the bar for failure to meet necessary
character requirements may not apply again. and for admission to practicc law. and the court. on
review. granted the petition. The court commented that the Board ofilar Examiners, having given a
good deal of time to the matter in the form of investigations and hearings. is in a better position than
the court to passjudgment on the question of whether admitting the applicant is so destructive of
"public conlidcnce in the bar as a whole" as to require denying him membership in the bar. While
noting that it respected the right ortlle minority to be particularly strict when it comes to dmg
conspirators. there was nonetheless insutllcient rcason in the case to reject the board's favorable
recommendation and to exclude the applicant solely upon the 3 A.L.R.6th 49 Page 56 3 A.LR.6th 49
(Originally published in 1005)
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THE DIFFERENCE BETWEEN SEARCH & SEIZURE Many lawyers. judges and police ofllcers
talk about "search and seizurc" as though it is all one thing. Actually. two different concepts arc
involved. U.S. v. Jacobsen. 466 U.S. lOY (1984) and U.S. v. Avery. 137 F.3d 343 (6th Cir. 1997). I.
II "search" is a police intrusion on a legitimate expectation of privacy. 2. A "seizure" (a) of the
person occurs when police interfere with an individual's treedom of movement; (b) of property is an
interference with a person' s right to possess or control the item. Thc 4th Amendmcnt rules set jl>rlh
by the US Supreme COlirt and other courts are different in the following two police actions: (l)
Seizures of the person (stop and frisk and arrests). (2) All other searches and seizures (interference
with privacy or possession). TilE CAR DIN A L R U L. [ i s d iff ere n t for # I & #2 # I
Seizures of persons need justi Ii cation but generally don't need a search warrant even ifthere is time
to get a warrant. There arc two main exceptions when an UITest or search warrant is required in an
arrest situation. (Payton rule and Steagald rule - discussed later). #2 All other types of privacy
intrusions into places or seizures of items usuallv need a warrant. The United Slates and Nevada
Supreme Courts have stated repeatedly - searches WIthout a warrant are presumed to be unlawful and
police need to be prepared to testify in court and demonstrate (with legal argumenl by the DA) that an
exception applies. California v. Acevedo. III S.C!. 19R2 (1991) and Phillips v. State, I06l'icv. 763
(1990). These concepts are discussed in detail later in this outline. E. THE SL'PREME COURT AND
THE EXCLCSIONAR Y RUI.E For about I no years aner 1791 jew U.S. Supreme Court cases were
decided concerning the meaning of the Fourth Amendment. Between 1886 and 1914 several cases
were decided ending ",ith Weeks v. U.S. (1914) that said in all fcderal courts. evidence seized in
violation oCthe Fourth Amendment would he cxcluded. In 1961. the (I.S. Supreme Court decided
Mapp v. Ohio, 367 U.S. 643 saying the Federal exclusionary ruk applied in State court proceedings
as well. The theory used by the Court to .iustifY Ihis ruling was that the eXClusionary rule "ould deler
unlawful police conduct hv removing the incentive to aet unlawfullv. (Note: no scientific or statistical
study. either before or sin~e Mapp. h~s ever proved or disproved this theory of the 9 Court.) F.
FR[JIT OF THE POISONED TREE In 1963. thc L.S. Supreme Court decided Wong Sun \'. United
States. 371 U.S. 407 (1963) and held that if there is a4th Amendment violation by police, the
evidence thrown out is not only that which is immediately recovered but all evidence that derives
directly from it. For this reason. a defense lawyer will tlleus on the earliest aspect of the pqlice
contact with the defendant and try to find fault with the police conduct. This rule means that, in most
cases. if police commit a 4th Amendment \ iolation, it will poison or .. taint" evidence obtained later in
the same invcstigation cven ifpolice, after committing the violation. then tllllowcd lawful 4th
Amendment procedures before seizing the evidence. An example of this rule is found in the case of
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Arterburn v. State. 111 i\ev. 1121 (1996). In that casco police were investigating a person for the I't or a
motor vehicle and learned that Arterburn \\as associated with the suspect. AI1erhurn was seen ncar
the car parked at a mote!' Police stopped him and. according to the Supreme Court's view of the
facts. required him to go to the police station for questioning. At the station. he consented to a search
of his person which turned up drugs for which he was convicted. The 'icvada Supreme Court said
that even if the consent to search at the station was lawful. the drugs would be suppressed because the
prior actions of the police amounted to his "arrest" without probable cause and the consent was the
'fruit" of the 4th Amendment violation. (Sec this outline "Levels of Contact"' as to why this was an
'arrest.'). The U.S. Supreme Court has followed the same theory on many occasions. For example, in
Erm,", v. Illinois. 422lJ.S. 590 (1975) the Court said that the Wong Sun rule was still law and that a
confession made by a subject shortly after an illegal arrest was thrown out even though correct
Miranda wal11ings werc given alier the illegal arrest. However - over the years up to and including
the present the U. S. Supreme Court has refused to apply the strict Wong Sun (fruit of poisoned tree)
rule in some cases. Note: these situations in which a prior (in time) 4th Amendment violatibn docs
not result in suppression of all subsequent evidence in the same investigation are the exception. not
the rule. and the burdcn is on the police-prosecution side to prove the exception. (I) INDEPENDENT
SOURCE DOCTRINE: Segura v. United States. 468 U.S. 796 (1984). If there is an illegal police
activity which leads to discovery oCthe evidence hut there is also a legal and valid independent
source by which police recovered the evidence - it will not be suppressed. (See "Premises Freeze" in
Search Warmnt Section). (2) INEVITABLE DISCOVERY DOCTRINE: Nix v. Williams. 467 U.S.
431 (1984). If the evidence would have heen discovered anyway - it will not be suppressed based on
illegal police conduct. The theory of the exclusionary rule is that police should not profit from their
misconduct. This rationale is furthered by putting the police in the same position, but not a worse
position than ifno misconduct had occurred. 10 "Inevitahle discovcry" doe, not mean that therc is no
supprcssion ofcvidence if the police "could have" gotten the e\'idence la\\fllily. but didn't. The
burden is on the prosecution to show by a preponderance of the evidence that the police "would
havc" discovered the evidence by la\vful means. (Nix v. Williams) It requires more than an argument
about things that in retrospect the police could have done. For example, in U.S. v. Allen, 159 F.Jd 82
(4th Cir. 1998) the court said. "We reject the contention that inevitable discovery applies where
police have probable causl;' and then search without a warrant (but argue that they "could have"
gotten a search warrant) because then there would never be a reason lar police to seek a search
warrant." See also. U.S. v. Brown. 64 F3d 1083 (7th CiT. 1995). Inevitable discovery requires a
showing that cither (a) at the time of the misconduct. or alier the misconduct, there was an
independent line of police investigation underway which developed filets not as a result ofihe
misconduct and would have led to the discovery of the nidence or. (b lin the alternative. that there
was a standard procedure (such as inventory) in clTect that would have turned up the same evidence.
Cocaine \vas i(mnd by police without a WaiTant in a misrouted suitcase but the court held that the
cocaine would have been found by the airline when it searched the suitcase for identity ofthc owner
U.S. V. Kennedy, 61 FJd 494 (6th Cir. 1995). In U.S. v.l.arsen. 127 F.3d 984 (10th Cir. 19(7), the
court held "inevitable discovery applies whenever an independent inycstigation would have
inevitably led to the discovery of the evidence whether or not the investigation was ongoing at thc
time of the illegal police action:' (An independent investigation is not valid if made as a result of
things learned by illegal rolice action) Other cases upholding inc\ itable discovery arc U.S. \'.
Woody. 55 F.3d 1257 (7th Cir. 1995). Yeoman v. State. 92 Nc\". 368 (1976), Clough v. State. 'l2
Nev. 603 (1976) and Carlisle v. State. 98 Nc\ 128 (1982). (3) ATTENUATION: j\ coul1 will admit
evidence recovercd after police misconduct if the prosecution can show that there is no significant
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relationship between the unlawful ~onduct and the discovery of the evidence. Nardone v. U.S., 308
U.S. 338 (1939) Factors include the lime proximity between the misconduct and discovery. whether
there arc other intervening circumstances. and the purpose and t1agrancy of the police misconduct.
Brown v.lllinois, 422 U.S. 590 (1975) These factors have been recognized by !'he great majority or
courts with results differing based on the faCIS of each case. C.S. Y. Wilson. 36 F 3d 1298 (5th Cir.
I (94), U.S. v. Shephard. 21 FJd 9.13 (9th CiT. 19(4). In Cnitcd States v. Ceccolini, 435 U.S. 268
(1978) the Coun relhsed to suppress the testimony of a liw "itness whose identity was leaJ11cd as a
result of a 4th Amendment Yioi3tion. The factors were: passage of time between illegal search and
contact with witness, the fact that witness was testifying of her own free will and the fact that the
police illegality was not designed or intended to discova the idenlity of witnesses. See also U.S. v.
McKinnon, 92 FJd 244 (4th Cif. 1(96). In United States v. Crews. 445 U.S. 463 (19RO) the
defendant was arrested in yiolation oCthe 4th Amendment. A hooking photo was used in a lineup and
a witness to the crime identified Crews. The COUt1 said that the photo lineup identification was II
suppressed but did allow the witness to testify at trial and identify Crews b"scd on her recollection
from the time of the crime because tb~ ability to identify him came before the police misconduct. The
defendant's face was not the '-fruit" of the illegal mTcs1. "The body or identity ofa defendant in a
criminal proceeding is never itself suppressible as the fruit of an unlawful UITest, even if it is
conceded that an unlawful arrest. search Of interrogatioJl occurrcd."INS v. Lopez- Mendoza, 468 U.S.
1032 (1984). In New York Y. Ilarris. II () S.Ct. 1640 (1990) the defendant was arrested in his home in
violation of the 4th Amendment. The police had probable cause tor the arrest but didn't get a warrant
in violation of the Payton rule (see "Arrest" section of this outline). HmTis was Mirandized and
confessed at his home; then after he got to the police
station he was Mirandized again and confessed a second time. The first confession was suppressed as
the fruit of the Payton violation but the second was not the "fruif'of the illegal anest. (Not~: this case
is different from Brown v. lIIinois where there was no probable cause for the arrest and Miranda
warnings at the police station didn't cure the "taint"because the confession was immediately tied or
connected to the illegal due to lack of PI(' "arrest. '').
EXCLUS[O~ARY RULE AND T! IE 013.1 ECIWL TEST Many times more than one legal
justification lor a search may exist contempofaneously on a cerlaio set of lacts Must the officer
select the "right" or "best" justification? The United State, Supreme Court suggested the answer is
"NO" in the case of Scott v. United States. 436 U.S. 128 (197)1). Although most of the decision
involved a wiretap issue. it held the court should "examine the challenged search under a standard of
objective reasonableness without regard to the motivation of the oftlcers involved." Thus. you may
think you are making a legal search on an "inventory tht:ory" and the COUlt fules that it wasn't a valid
inventory but if the search can be justified as a "search incident to arrest" or "probable calise search"
the evidence will be admissible. See State v. Greenwald. I 09 ~cv. 808 (Nev. 1(93) in which the
Nevada Supreme COUl1 held that boll1 types of searches "ere invalid on the facts of that case, but
clearly ruled that if police searched or seized unda a warrant exception that police thought was valid
hut that the COUIt deemed incorrect, suppression "ould not ()CCUI if, based on the totality of facts and
circumstances of the encounter there was a valid objective justilication under a different theory for
the police action. In Surianello v. State. 92 Ne\. 491 (1976) the court said that because probable
cause to arrest (or reasonable suspicion to stop) is determined hy objectiVe facts, it was immaterial
that the officer testltied that he didn't think he had enough tact, /,lr an arrest; his action was
nonetheless la\\I'ul if the court determines that the legal justification (RIS for a stop or PIC lor afl
arrest) was present. 13 I. MISTJ\KfS BY POLICE IN SEARCH & SEIZURE 10 real life, there are
times when police make mistakes about the facts pet1aining to a situation and base what we'll call
"4th Amendment type decisions" on erroneous facts. When this occurs. suppression or c\'idcncc is
not always the result, as long as the police and prosecutor can carry the burden or showing that the
mistake was a reasonable one and was not the result of police negligcnce. For example, in Hill Y.
Calitl)rnia, 401 U.S. 645 (1971). police were im'estigating a robbery and developed Hill as a suspect.
They went to Hill"s apat1ment and a man who tit Hill"s description answered the door and admitled
the police. The man said he was Miller. not Hill but the pol icc atTested him anyway and a scar~h
incident to arrest disclosed evidence that \Va5 used to convict Hill at trial. It turned out that the man m
Hill's place was really Miller. The U.S. Supreme Court upheld the search. slating that although "good
faith" alone would not have justified the police action, under the facts of that case, the police mistake
was objectively reasonable. Other examples include a police officer stopping a car based on a
computer entry saying that the driver had an outstanding warrant when the warrant had heen quashed,
but that had not bcen entered in the compuler by the court clerk. Arizona v. Evans. 115 S.C!. I 185
(1995) (error 1101 created by police) See also, U.S. v. Sharc~er 100 P,Jd 1491 (IOlh Cir. 1996) and
'J
U.S. v. Satlta, 180 FJd 20 (2d Cir. 19(9). When rolice entered a residence based on conscn! from a
: c person who, aftcr questioning by the oflicers appeared to have common authority over the premiscs.
but who later on turned out not to have such authority. the police search was held valid in Illinois v,
Rodriguez, 110 S. Ct. 2793 (1990) and Snyder v, Statc. 103 Nev. 275 (1987). (As long as police
make a reasonable effot1 to learn the current racts: "Why can this person give consent')"), The same
rationale upheld a search in Maryland v. Garrison, 107 S. ("1. 1013 (1987) where police had a ,earch
warrant for the 3rd 1100r apanl11cnt at a ccrtain address. In fact. unkno\\n to police, the 3rd noor had
been divided into two separate apartments and both were searched with drugs being found in the
"\\Tong" apartment. The U. S. Supreme Court ruled "no suppression" saying lhat the legality or the
police action had to be based on the infonnatlon available to police at the time of the action: the
mistake occurred dcspite reasonable efforts by police to investigate and learn the correct facts. "f\
policeman's mistaken belief of tilct can contribute to a PiC determination and ean count just as much
as a correct belief as long as the mistaken belief was rcasonabk in light of all the circumstances. ,.
U.S. v. Gonzales. 969 F.2d 999 (11th Cir. 1(92). See also Stuart Y. State (Nevada 1978) and U.S. v.
Alvarez in section on "What Is Reasonable Suspicion). 14 J. "GOOD PAlTll" "Good faith" is a term
1;'
which is oftcn used by police and prosecutors without a full understanding of whether it helps avoid
suppression of evidence. The basic rule eSlablished by the U.S. Supreme COllrt many years ago is that
an ofticer's "good faith" is irrelevant in deciding whether or not there has been a 4th Amendment
violation. There are many reasons for this basic rule, not the leasl ofwhi~h is that it is impossible fix
ajudge or anyone else to read a person's mind. Also. according to thc U.S. Supreme Court. ajudge
2:
deciding a motion to suppress on 4th Amendment grounds must use an objective test. Florida v,
Bostick. III S.C!. 23H2 (1991). Thereillre. "subjective"or "true inner belief" good faith generally
means nothing."fr sui:ljective good faith alone "ere the tcst the protections of the 4th Amendment
would evaporate and people \\ould he secure in their rersons. houses. papers and effects only in the
discretion of the pnlice:' Beck Y. Ohio. 3791.;.S. 89 (1964), I1owcwr. in a few situations. when there
is "objective" or outwardly provable good faith hy a police ot1iccr. the U.S. Supreme Court has used
the term "good faith" to result in admission rather than suppression of evidence. In Michigan v.
DeFillipo. 443 U.S. 31 (1979) and Illinois Y. Krull. 480 U.S. 340 (19R7) police officers made arrests
26 or searches acting pursuant to a state slatute \\"hich was later held bv the courts to be unconstitutionaL
The U.S. Supreme COllrt upheld the police action in both cases bec;lUse of the officer's reliance on
the statute, However, the Court noted that this result would not tl)lIow if (a) the legislature wholly
abandoned its responsibility to enact constitmional Jaws or (b) if a reasonably well trained ofticer
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should have known that the statute was unconstitutional, In United States v, Leon. 468 U.S. 897
(1984) the Court held that iCpolice got a search warrant signed by an impaJ1iai judge and the facts
submitted by the police in the affidavit "ere true (in the sense that they \\'ere not intentionally or
recklessly false) then no suppression would occur even if another judge found a tier the search that
there was not enough PIC. Once again. the Court limited this to cases where a reasonably well trained
ofticer would 110t have realized thattherc \\as insufticient PiC. The I eon case has hcen followcd in
state supreme COUrts on a ratio of about four to one. The Ncvad,1 Supreme Court cited Leon in its
decision in Powell v. State. 113 l\cv. 41 (1997).
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Defendant. charged with bookmaking, had successfully moved 10 dismiss the indictmenl 011 the
grounds that the police and district anorney had a policy not to arrest or prosecute hettors while they
arrested and prosecuted bookmakers, although the ,tatute made it a crime to place as well as to
receive a het. The COLIrt said that based on the record it was dear that defendant was prosecuted
because she was a hook maker and not a hettor, and thus the prosecuting authorities discriminatorily
ent(Jrced the penal code against 11er. lIowever. the court said that the selective enforcement of the
statute was not based on an invidious and unjustifiable standard. The coul1 said that a distinction
drawn on the basis of the ditTercnce in the kind of criminal conduct. even though of equal culpability
under the law, was neither suspect nor im'idious. Stating thar defendant did not assert that she was
prosecllted because of her race. religion. sex. or exercise of First Amendment rights. the court said
that she had thus not demonstrated that absent the announced policy, she would not have been
prosecuted. In People v Winters ( 1959) 171 Cal App 2d Supp 876. 342 P2d 538. the court reversed
the trial COUti'S sua sponte dismissal. hy reason of discriminatory enforcement, of gamhling charges
brought again,t defendants. Thc trial court's basis for so doing was the court's correspondence with
the police chief which indicated that gambling arrests of Negroes were 10 times as numerous as
gambling arrests of Caucasians even though Negroes constituted ani) 10 percelll of the population.
Slating that discriminatory law enforcement will not be presumed. and before it can be established.
proof thereof must be judicially made. the court said that the dismissal of the action was wilhout
pulling intentional discrimination in isslle. In ordering the trial of defendant to proceed. the cOllrl said
that that was without prejudice to the right oftht: defendant. as a matte,' ofdefense, 10 assert and offer
proof that any conviction would deny him cqual protection of the laws because of any proven
intentional or deliberate discrimination. Convkted of various violations of the municipal gambling
laws, the defendant in Davis v United States (1978. Dist Col App) 390 A2d 976. contended that the
prosecution of gambling cases in the District of Columbia was selective and discriminatory in that
there were no prosecutions for possessing socalled "legal" lottery tickets. such as those sold by
Maryland. Stating that in order for a defendant to prove discriminatory enforcement ofa valid statute
there mllst be at least a prima tileie showing that others similarly situated have not genernlly been
proceeded against and that the discriminatory prosecution was based on impermissible
considerations. the cOUl1 said that the defendant did not meet that hurden since he did not allege a
difference in treatment based upon a constitutionally suspect standard but did no more than allege a
failure to prosecute others. Such a conclusory allegation. said the court. was insufficienl without
more. In Creash v State (1938) 131 Flu Ill. 179 So 149. in which defendants were found guilty of
keeping and operating a gamhling house. the ckfendanls complaincd that the arresting officers
exhibited inordinant prejudice against defendants. in that they permitted other "bingo" places to go
unmolested and to run wide open at the time the)' atTested defendants. The COUl1 95 A.!..R.3d ZgO
Page 67 95 A.L.R.3d 280 (Originall~ puhlished in I 'J79) t,' "012 Thomson Reuters. No Claim to
Orig. US Gov. Works. said that even if that was true. it \\as not material to the case In Oakland
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County Prosecuting Attorney v 46th Judicial Dis\. Judge (1977) 76 Mich App 318. 256 l\W2d 776.
defendants. charged with conspiracy to violate the state gambling statute. claimed that they had heen
subjected to discriminatory prosecution because no onc else had been prosecuted for engaging in
activities similar to those in which they engaged. and also that they had been subjected to selective
prosecution because the prosecutor saw tit to dismiss as against two oCthe conspirators, Stating that
seiectivity and the enforcement of laws is not a violation or equal protection unless it is bascd upon
race. religion. or some other arbitrary ciassilication.
the court said that intentional or purposeful discrimination will not be presumed and there must be an
affirmative showing of clear and intentional discrimination, Holding that there had been no sLich
showing on the part of an}' oflhe defendants. Ihe COllrl remanded the cause 10 the trial court. In
People v Shing (1975) 83 Misc 2d 462. 371 NYS2d 322, the court denied defendants' motion to
dismiss the informations on the ground of selective and discriminatory prosecution. Defendants. who
were of Chinese descent. were charged with the crimes of promoting gambling and possession of
gambling dcvices, Noting that defendants argued that they had reason to believe that they wcre being
undulv harassed because of lheir herital!c. the cOllrt said that to invoke the delense of discriminator,
prosc~ution one must prove that the sel~ction of the defendants I()r prosecution was deliberately
based upon their race or religion. The co un said that it \yas not ~nough to allege intentional and
purposeful discrimination. but the defense must present facts suftlcient to raise a reasonable doubt
about the prosecutor's purpose. llowcver. the only allegations were ThaT tlye or more groups of
Asiatic-Amcricans wcre charged with violating the gambling statutes in a 3-month period and that the
defendants had reason to believe that there had not been that same number of prosecutions for those
crimes in the whole borough of Manhattan, Slating that even if that were true. there was no evidence
from which to conclude that the prosecutions were deliberate\) discriminatory. the court said that
mere selectivity in prosecution. in and ofitsclf. created no constitutional problcm. CUMCLATIVE
SUPPLEMENT Cascs: In prosecution /()r bookmaking otTenses of persons involved in operating
neighborhood restaurants and bars. trial court did not abuse discretion by denying defense 1110tion for
discovery of documentary evidence. allegedly possessed by the prosecution. to show discriminatory
law cnt(lrCcment. where defendant did not make prima facie showing of selceted prosecution based
soldy upon geographic or socio-cconomic liletors. Although it was not necessary that the "class"
involved be one against which there has been traditional or historic discrimination. naked allegation
that defendants were members of class of local neighborhood bars did not give rise to rational
inference of selective law enforcement based on condemned invidious criteria. Perakis v Superior
Court of Santa Clara COUIllY (1979. 1st Oist) 99 Cal App 3d 730. 160 Cal Rptr 445. In prosecution
for altempted dissemination of gamhling information, evidence that all of the numerous arrests under
statute in panicular eity had involved defendants or lheir employecs and employers was insufficient
to establish that statute was being discriminatorily enforced. People \' :Vlilano (1979. 2d Dist) 89 Cal
App 3d 153. 152 Cal Rptr 318, 95 A.L.RJd 280 Page 68 95 A.I..RJd 280 (Originally published in
1979) e(:) 2012 Thol11son Reuters. No Claim to Orig. US Gov, Works, Statute which criminalizcd
operation oflottery while exempting players from criminal responsibility did not slippon operator's
claim of discriminatory prosecution in absence 01' evidence of intentional or purpose Cui
discrimination in prosecutions under statute. Commonwealth v Covert (1983) 322 Pa Super 192,469
A2d 248.Selective or discrirninatory prosecution 57 C..I.S. Military Justice 157 To support a defense of
selectivc or discriminatory prosecution. a defendant bems the burden of establishing lhat he or she
has been singled out for prosecution. and that the government's discriminatory selection of him or her
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for prosecution has been invidious or in bad faith. To support a defense of selective or discriminatory
prosecution, a defendant bears a heavy hurden of establishing. at least prima facie. th'lt he or she has
been singled out lor prosecution while others similarly situated have not generally been proceeded
against because of similar conduct, and that the gm'cmment's discriminato!,) selection of him or her
for prosecution has been invidious or in bad lilith. i.e" based upon impCfmissible considerations such
as mce, religion. or the desire to ,",xercist, constitutional rights. I 1J Barc contentions thm others were
similarly liable due to criminal activity. bm not prosecuted, are insufficient [0 bar good-faith
prosecutions. I 2] The conscious exercise of some sclectivity in enforcement orthe law is not in itself
a fcderal constitutional violatioll, [31 Even though statistics might support an implication of selecti vc
enforcement. there must be a further showing that the selection was ddiberatcly based upon an
unjustiiiable standard,\A] [FNl1 CMA~-U.S~ v.Hagen, 25 M.J. 78 (c:.M.A. 1987). GCCMR-U.S. v.
Tatum. 17 M.1. 757 (C.G.C.M.R. 1984). NMCMR--I!.S. \. Garwood. 16 M.J. 863 (N.M.C.M.R.
1983). decision aff'd, 20 yl.J. 148 (C.MA 1985). CJS MILITARY 157 Page 1 57 C.J.S. Military
Justice 157;1,) 2012 Thomson ReUlers. No Claim to Orig. US Gov Works. [FN2] NMCMR-, U.S.
v. Garwood. 16 M..f. 863 (N.MC.M.R. 1983), decisioll aft'd. 20 M..l. 148 (C.MA. 1985). [FN3]
CGCMR-U.S. v. Tatum. 17 M.J. 757 (C.G.C.M.R. 1984). [F\:4J C<iC\-lR-U.S. v. Tatum. 17 M..I.
757 (C.G.C.MR. 1984).
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Uncooperativc witness l.S.-LJ.S. v. Kchm. 799 F.2d 354. 21 Fed. R. Evid. Servo 339 (7th Cir.
1986). [FN21 U.S.-U.S. v. Ramirez. 765 F.2d 438 (5th Cir. 1985). Ala.-Elmore v. State. 445 So.
2d 943 (Ala. Crim. App. 1983). Ariz.- Murray Y, Thomeycroft ex reI. Arizona Highway Dcpt.
Motor Vehicle Division, 131 Ariz. 156.639 P.2d 346 (et App. Div. 21981). Conn.-State v.
Haskins. 188 Conn. 432. 450 A.2d 828 (1982). CJS CRIMI.A W 79 Page 2 22 C.J.S. Criminal Law
79 (C 2012 ThonJson Reuters. No Claim to Orig. US (io\'. Works. (ja.-Lee Y. State. 177 Ga. Apr.
698.340 S.E.2d 658 (1986). l.a.-State \. Coleman. 465 So. 2d 709 (La. 1985). ",1ich.-Peoplc v,
Monroe, 127 Mich, App. 817. 339N.W.2d 260(1983). Neb.-Srate \. Sprague. 213 Neb. 581. 330
N. W.2d 739 (1983). N.H.--State v. Monahan. 125 N.II. 17.480 A.2d 863 (1984). R.I.-SiatC\'.
Ricci. 704 A.2d 210 (R.I. 1(97). S.D.---Statc v. Secrest. 331 N.W.2d 580 (S.D. J983), 22 C..l.S.
Criminal Law 79 Defenses and Circumstances Barring Prosecution or Conviction C. Official
Action or Misconduct 3. Selecti\c Prosecution or Discriminatory En!orccl11cnt. This is seen in
Coughlin gelling arrested for Trespass on 11/12111 whereas Ne\ ada Court Services was not:
http://\\o,;.w.youtube.com!watch?v=NDlcPAbVelg Coughlin filed numerous police reports in this
regard, yet the RPO has not responded in any way. Further. as seen in the attached 22 page letter
regarding NV Energy. WCSO service issues in evictions. the RPD and WCDA selectively prosecutes
in a retaliatory manner against those asserting their constitutional rights. Coughlin reported batteries
commited against him to the RPD in various police reports. yet the RPD refused to investigate or
charge anyone. However. Richard Hill gets Coughlin arrested for jaywalking and OFllccr Look oCthe
RI'D bends over backwards and practically breaks into the jail in a pathetic attempt to serve a TPO
for HIlL and Ilill showed up to the 1/3 I112 Extension hearing on his silly TI'O and. of course.
withdre" it becanse his malfeasance was finally starting to reflect poorly on him. Judge Schroeder
was inappropriate in screaming at Coughlin "Do you want to go to jail'" when Coughlin attempted to
address HIlI's abuse orprocess and bad faith application for a '1'1'0. meant only to prevcnt Coughlin
from asserting his lawtilll'ight to collect evidence incident ((l HIli's wrongful eviction
OfTieers had probable cause to <lITest defendant for robbery; oflicers' receiving units picked up signal
from transmitter from "bait pack" of currency which comaincd electronic transmitting device.

transmitter was located in parked vehicle from which defendant exited, defendant fled to parking
garage when he saw officers approaching vehicle, and one orticer's handheld tracking device
indicated that bait money transmitter was on defendant's person. U.S.C.A. C(}nst.i\mcnd. 4. L.S. v.
Bro\\11. 636 F. SliPI'. 2d 1116 (D. Nev. 20(9).
Sixth Amendment violation can he predicated lIpon counsel's defective representation of defendant in
connection with pretrial plea bargaining. and, under Strickland, prejudice can be established if there
is reasonable probability thm guilty plea would have ensued. U.S.c.A. Const. Amend. 6. U.S. v.
Price. 237 F. Supp. 2d 1 (D.D.C. 2(02).
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i'-Iev., 1973 Assuming without deciding that plaintiff. who \Vas chief accountant of city, was not
required to register as an ex-felon because his Califol11ia conviction had hcen expunged. and that hc
thercf{)rc was not committing a misdemeanor in the prescnce of officers hy not registering, officers
were protected ti'om civil suit for false imprisonment following a f(llse arrest hy statute providing that
no action may be brought against an) peace officer unless an act or omission amounts to gross
negligence or to willful and wanton misconduct. where there was no showing of gross negligence or
wanton misconduct since, inter alia. there \lias no evidence that officers intended to do harm. N.R.S.
41.034, 207.080-207. ISO. formerly 48Ak349(4), 48Ak349, 35k63, I. 35k63(1) Nev, 1972 Officers
who knew that license plates on vehicle containing defendant were stolen acted properly when they
Slopped and approached defendant and his companion. who alleged that only the Highway Patrol had
the duty to enforce statute relating to Iicense plates. and that local police could not investigate when
an evident misdemeanor involvmg possession and use of stolen license plmes was committed in their
presence. N.R.S. 171.124. subd. I(a), 482.545.
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In People v Walker (1966) 50 l\1isc 2d 751. 271 NYS2d 447. the court held that the dcfendant had
demonstrated, hya clear preponderance ot' evidence. that she was singled out for criminal prosecution
. by an intentional. purposeful. and unusual selection process. The court said that the manner of
prosecution was not the same as usually employed and was in sharp contra"t to (he then-existing
pattern of enforcement 0[' housing laws. The court said that the lime all(l\\cd to defendant for
correction ofhollsing violations was so unreasonably short as to make correction impossible and
criminal conviction a certainty. Conduding that the evidence led irresistibly to the conclusion that the
intentional discriminatory prosecution was in retaliation for dckndant's public exposure ot'colTliption
in the department of buildings. the coun held that the evidence reqllired dismissal of the prosecution
on the ground that defendant was deprived of her constitutional right to equal protection of laws. 7[ c]
Invidiousness or arbitrariness of particular basis for seiection[ *]-Vindicti veness toward de I'cndant
[Cumulative Supplement] In the following case. the court held that personal vindictiveness on the
part of the prosecutor to v, arc! the detcnelam would constitute an invidious basis for selection of the
defendant for prosecution. In {Jnited States \ Bourque (1976. ('A I RI) 541 F2d 290. the court stated
that personal vindictiveness on the part of a prosecutor toward the defendant would sustain a charge
of discrimination. However. the coun held that the defendant failed to make a substantial showing
that the prosecutions were not normallv instituted tiJr the offense with which the defendant was
charged, and thus allirmcd his conviction Ii)!' violations of the federal intemal revenue laws.
CUMULATIVE SUPPLEMENT Cases: In prosecution of member of Congress for bribery offense,
motion to dismiss indictment, based upon. in1er alia, allegation of selective prosecution, was properly
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denic'd where plaintiff had mauc J1l\ claim that others similarly situated had not een prosecuted. nor
had he supplied any support for concJusor: allegation that he was "disfavored" kgislator: to shill to
(Jowrnmcnt burden of pro> ing that decision to prosccutc is flcc of discriminatory taint. defendant
must show that. \vhile others similarly situated have not generally been proceeded against because of
conduct of type forming basis of charge against him, he has been singled out lilr prosecution and that
Government's disrriminatory selection of him j()r prosecution has been invidious or in bad faith.
United States v Mycrs (1980. CA2 NY) 6.15 F2d 932. cert den 449 US 956, 66 L Ed 2d 221. 101 S Ct
364. In prosecutions for conspiring to violate civil rights of federal witness (by killing himto prevent
him from testifying against defendallls), defendants' motion to dismiss indictment on ground of
selective enlorcement \\Ould be d~l1ied. despite evidence of various magazine and newspaper reports
and other hearsay statemcnts by individuals who allegedly had spoken with agents of Federal Bureau
of Investigation. to effect that agents had said that they had to remove defcndant from streets. since
such evidcnce would not support defense of selective enforcement in that ddendant had failed to
show that he had been singled out for prosecution. \vhile others, similarl} situated, had not been
prosecuted, and that Govcfllmcnl's determination to prosecute him had been made in bad faith;
further, conseiolls exercise of some selectivity docs not violate defendant's rights. Unitcd Statcs v
Bufalino(1981. SONY) 518 F Stipp 1190.45 A.L.R. Fed. 732 Pag.c4645 A.L.R. Fed. 732
(Originally published in 1(79) r 2012 Thomson Rcuters. No Claim to Orig. US (lov. \Vorks.
Prosecution is not vindictive as long as prosecutor's decision is based upon nonnal factors ordinarily
considered in determining what course to pursue, rather than upon genuine animus against defendant
for improper reason or in retaliation for exercise of legal or constitutional rights. lj .S. v. DeMichael,
692 F.2d 1059 (7th Cir. 1982). In criminal prosecution. defendant's motion to dismiss indictment on
basis of alleged prosecutorial vindictiveness in bringing sccolld charge \\ould be denied since court
found no evidence of actual prosecutorial vindictiveness in response to defendant'S request for change
of venue and record supported fact that prosecution had made initial decision to bring charges in
certain district, instead of in two districts, on basis of convenience. economics and prosecUlorial
resources. and that once case had been transferred, reasons for bringing second charge were
legitimate and did not manifest purposeful governmental retaliation or defendants' exercise of legal
right; given legitimate nOllvindietive reason for returning second indictment, court should not
interfere with prosecutor's c;.crcise of discretion unless determination of actual vindictiveness has
been made. U.S. v. Mulherin, 529 F. Supp 916 (S.D. Ga. 1(81). judgment atTd. 71 () F.2d 731 (11th
Cir. 1983). Selective prosecution and vindictive proseclltion are not defenses on the merits to the
criminal charge but independent assertions that the pro,ecUlor has brought the charge for reasons that
tlw Constitution prohibits. Ex parte Quintana. 346 S.W.3d 681 (Tex. App. El Paso ~009). rch'g
overruled, (Oct. 2R. 20(9) and petition for discretionary review retused. (Mar. 24, 2(10). [Top of
ScctionllEND OF S{!PI'LE.'vH"H] 7[t] lnvidi,)usne,s or arbitrariness of particular basis for
selcction[*J-Raee [Cumulative Supplementl In the folkming casco it was held that if the defendant
were selected lor prosecution on Ihe basis of his racc. the defense of discriminatory enforcement
would he established. In United States v Alleyne (l'ln, SD NY) 454 F Supp 1164. the court stated
that allegations ofselectioJli()r prosecution on the k"is ni"race. if proved, would establish a ddcnse
of' illegal selective cnl(lfccment. The defendant. charged with a violation of la\'5 for the protection
and regulation of navigable waters. contended that he was discriminatoril,. selected for enforcement
because of his racc. The defendant. the only black person in his arca. V'h~ was discharging fill.
suhmitted photographs pOl1raying alleged I} illegal discharge of till into a river b) white people
adjacent to his property. The defendant slated that the other parties in his area who had not been
prosecuted for violations were \\ hile. Those allegations if proved. thc court said, would establish a
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defense of discriminatory prosecution. Accordingly. the court held that an evidentiary hearing was
warral11cd to afford the ddendant the opportunity to substantiate his claim. CUMULATIVE
SlJPPLEMENT ('LiSC,: Trial court erred in refusing ttl apply Virgin lslands habitual uiminal statute
since. absent 45 A.L.R. fed. 732 Page 47 45 A.L.R. Fed. 732 (Originally published in 1979) 1.) 2012
Thomson Reuters. No Cluim to Orig. US Gov. Works. proof that selective enforcement complained
of was deliberately hased on unjustitiahk standard. prosecutor had broad discretion in enforcing
hahitual criminal statute. and n..'cord did not suggeot that either judge or defendant had charged
prosecutor with selective enforcement of statute on basis of race. religion, or other arbitrary
c1assi lication. Government of Virgin Islands \'. David. 741 I .2d 653 (3d Cir. 1984). To prevail on
selective prosecution theory in criminal pro,cculion. ddcndant musl shO\\ that Go\'ernment's
decision to hring action sprang from either invidious discrimination or intent to punish defendant for
exercise of' fundamental right. l;nitd States v Lewis (1981. 'vlD I'a) 514 F Supp 169.
"Discriminatory effect" for purpoSes of a selective prosecution claim, is demonstrated by
establishing that similarly situated individuals ora different race were not prosecuted. lJ.S. Cons!.
Amend. V. U.S. v. Minerd. 182 F. Supp. 2d 459 (W.O. I'a. 2002). To establish a selective prosecution
claim, a defcndant must show that the prosecution had a discriminatory effect and that it was
motivated by a discriminatory intent; this rcquires the defcndant to establish both (l) that similarl J
situated individuals ofa different race v; ere 110t prosecuted. and (21 that the decision 10 prosecute "as
invidious or in had faith. Johnson v. Outlaw. 659 F. Supp. 2d 732 (M.D. ;:J.e. 2009). A prosecutor's
discretion is subject to constitutional constraints; the decision whether to prosecute may not be based
on an unjustitiable standard such as race. religion, or other arhitrary classification. U.S. v. Jeanpierre.
636 F.3d 416 (8th Cir. 20 II). A defendant may bring a selecti\ e prosecution claim based solely on
the race of his victim: to establish a discriminatory effect in a race-of.-the-victim case, he must show
that similarly situated individuals whose victims were of a different race were not prosecuted.
Belmontes v. Woodford. 350 FJd 861 (9th Cif. 2(03). The discriminatory-effect element in a case
alleging selective enforcement of the law requires a credihle showing that a similarly situated
individual of another race could have been. hut was not. stopped or arrested for the offense for which
defendant was stopped or arrested. U.S. v. Alcaraz-Arellano. 441 FJd 1252 (10th Cir. 20(6). African
American inmates who were indil:ted Je)f' alkgcd assault on Native American inmate failed to ,how
that similarly sHuuted indiviuuals of another race wcre not prosecuted. as required to show
discriminatory dfect for purposes of obtaining selcctiw-prosecution discovery, \\ here gowrnment
explained at discovery hearing that il also intended to proseclite )!ative Amet'ican inmates who
allegedly assaulted African American inmate following first alleged assault, government indicted
Native American inmates aftcr District Court ruled on discovery motion. delay in indictment of
Native American inmates did not necessarilv indicate thev were treated
marc favorably. and absence of videotape ~f latter alleg~d assault required more preparation for trial.
U.S.C.A. COnsLAInend. 5. U.S. v. Deberry. 430 F.3d 1294 (10th Cir. 2005). See Uniteu States v
Johnsoll (1991, DC Colo) 765 F Supp 658. S 12. To prove discriminatory effect in race-based
selective enforcement claim. defendant must either make credible showing that similarly situated
individual of another race could have heen stopped /(lr tranic violation. but was not. or defendant
must show discriminatory effect through usc of statistical evidence. U.S. v. Lindsey, 288 F. Supp. 2d
1196 (D. Kan. 2003). A prosccuwr's discretion is subject to constitutional constraints: the decision
whether 10 prosecute may not be ba.sed on an unjustifiable standard such as racc, religion, or other
arbit- 45 A.L.R. Fed. 732 Page 48 45 A.L.R. Fed. 732 (Originally published in 1979) ':0 2012
Thomson Reuters. No Claim to Orig. US Gov. Works. rarl' classiiication. U.S. v. Shaygan. 652 F.3d
1297 (11 th Cif. 2011 ). Fact that white inmate. sentenced to death for commission of aggravated
murders during same prison riot in which Alrican-Amcrican defendant committed murders with
which he was charged. killed both oth"r inmates and prison guards. while defendant killed only other
inmates. did not mean that white inmate "as not similarly situated with defendant. for purposes of
analysis of defendant's claim that he \Vas improperly singled out for capital prosecution based on
3.
race. Stale v. I.aMm. 2002-0hio-2128. 95 Ohio St. 3d 181. 767 N.E.2d 166 (2002). onvictions for
lircarms violations would be at1i1l11cd. despite defendant's contention that he had been subjected to
vindictive prosecution. since vindictive prosecution usually involves retaliatory imposition of
additional penalties against defendant \\ho exercises legal right. and defendant did not allege that
indictments had been ftIed to discourage him from. or punish him for. exercising constitutional,
6
statutory. or common law right. Cnited States v McWilliams (1984. CA9 Cal) 730 F2d 1218.Atier
.,
, reversal by Court of Appeals ofconvictiol1 of immigration inspector on four counts offorging
immigration documents. lIpon reindictment of defendant on original four counts. plus additional
count of conspiracy to forge documents. trial COllrt properly dismissed conspiracy count on basis of
presumption of vindictiveness since superseding indictment. ohtained immediately after defendant's
successful appeal oftirst conviction. created apprehension of retaliation against defendant for
exercising right to appeal and prosecution failed to dispel appearance ofvindictiveness by explaming
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increased charges by reference to newlydiscovered facts or cIidence. United States' Kre7.dorn
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(1983. CA5 lex) 718 F2d 1360. cert den (US) 79 LEd 2d 742.104 S Ct 1416. DDA Zach Young.
Esq. clearly had a hiss)' tit whcn Defendant Coughlin served him with a NRCP 11 21 day safe harhor
,2
sanctions "'lotion. Furthcr. while DPD Goodnight has told Coughlin NRCP II does not apply in
criminal settings. DPD Goodnight quoted the "not based in fact or law language" from NRCI'll
back to Coughlin in citing his justification for fai ling to Iile some "prosecutorial misconduct" motion
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or charge against DPD Young.
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Due to DPD's Goodnight. Hylin. and lesie approach. Defendant Coughlin is being denied his Sixth
Amendment Right to Counsel. though all three of those gentleman are not being denied their healthy
paychecks in any way. nor their benefits packages.
STOP AND FRJSK (INVESTIGATIVE DETENTION): MIDLEVEL

CONTACT
(I) THE TERRY CASE A~D NFVADA STATUTES:
In 1968 the U.S. Supreme COlirt said in Terry v. Ohio. 392 l!.S. I (1968) that
police could stop (conduct an investigative detention where the suspect was not free to
leave) a person based on "articulable and reasonable suspicion" that the person "is
committing. has committed or is about to commit a crime." even where thcrc is not
probable calise for an ancs!.
If there is reasonable suspicion in addition to that which justifies the stop which
causes you to belie\c the suspect may he armed. you can pat down clothing for weapons .
.Just because "stop" is legal and based on reasonable suspicion doesn't automatically mean
that "frisk" is OK too. Sibron I. New York. 392 U.S. 40 (1968).
Terry is coditied in N.H.S. 171.123 as follows:
171.123 Temporary detention hy peace ot1icer of person suspected of criminal
behavior: Limitations.
I. Any peace officer may detain anv person whom ,uch ofticer
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encounters under circumstances \yhich reasonably indicate that such

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person hus committed. is committing or is aboUl to <.:ommit a crime.

2. The oflicer may detain such person only to ascenain the
identity of such person and the suspiciow. circumstances sunounding his
presence abroad. /\ny person so dctained shall idenli(v himself~ bUl may
not be compclled to answer any other inquiry of an) peace officer.
3. No person may he detained i<lOgcr than is reasonably necessary
to cll'ecr the purpose of this section. and in no event longer than 60
minutes. Such detcntion shall not extend beyond the place or the
immediate vicinity of the place where the detention was lirst effected.
(1969. p.53S: 19T1. p.597. 1975).
171.1232 Sear~h to ascertain presence of dangerous weapon: seizure of weapon or
evidence.
I. If any peace oflicer reasonably believes thai any person whom
he has detained Qr is about to detain pursuant to NRS 171.123 is armed
with a dangerous weapon and is a threat to th~ safety of the peace ot1icer
or another, the peace ofliccr may search such person to the extent
reasonably necessary to ascertainlhe presence of such weapon. If the
search discloses a weapon or any evidence of a crime. such weapon or
evidence may be seized.
The question arises as to whether the police. during a "Terry type SlOp" can
lawfully require that the person idenlifv him or her sdf. In Adams v. Williams. 407 U.S.
143 (1972) where the court found that a seizure of the person had occurred. the court
implied that questioning as to the person's identity and a request for identification were
not in violation of the 4th Amendment.
In Brown v, Texas, 443 {l.S. 47 (1979) the police arrested Brown when he
refused to idenlify himself. However. the Court noted that the invcstigmivc stop of
Brown was invalid because police had no reason to stop him. The f'Cqucst for
identitication. refusal and alTest were "fruits of the poisoned tree." In Kolander v.
Lawson. 461 U.S. 352 (1983) a Calif state law required a person lawfully stopped by
police to produce a "credible and reliable id." The Court held that this language was
unconstillitionally vague. Neither case held that it was unconstitutional for police to
require idenli lication from a person in a lawful "Terry Stop."
In Martinelli v. City of Beaumont. 820 F.2d 491 (9th Cir. 1987) the co un ruled
thai officers had reasonable suspicion to stop the person. but the Calif. Statute allowing
arrest if th~ person refused to identify himsel r \\ as unconstitutional. The 9th Circuit Court
erroneously construed the U.S. Supreme Court's decision in Kolander v. Lawson to
justify this ruling even though it is clear that the V.S. Supreme Court has never decided
this question.
In Albright v. Rodriguez. 51 F.3d 1531 (10th Cir. 1995) the co un ruled thaI if
police made a valid Terry stop. and the person refused to identify himself: and if there
was a state statute \\hich allowed police to arrest for failure to identify. thcnthc request
for identification, refusal and anest was constitutionally valid.
In Statcv. Flynn. 285 N.W. 2d 71 (l (Wise. 1979). cen. dcnkd 449 U.S. 846 the
COUIt noted language in Adams \'. William, a stop and frisk case where the Supremc
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Court said that the officer in a brief(validl stop "in order to detem1inc (the suspect's)
identity"may be most reasonable:' The Flynn court noted that unless the oflieer is
entitled to ascertain the identity of the suspect. the TelTY stop can serve no useful
purpose. Same ruling in US v. Basey. 816 F.2d 980 (5th CiL 1987). State v, Landrv.
588 So.2d 345( La. )991),
In U5, v, Vanicromanee. 742 ",2d 340 (7th CiL 1984) the Court held that mere
detcntion is not an arrest: a police oi1iccr mJj, short of an IUTest, detain an individual
brietly in order to determine his identity momentaril) "hile obtaining more
information if the ollicer has articulable facts sufficient to give rise to RfS that the person
had committed or is committing a crime,
The Nevada Supreme Court has not ruled on this issue although a requirement for
identification is in NRS 171, ID, The cases of 13rown v, Texas and Kolandcr v
Lawson do not rule on the identity requirement in NRS 171,123 (see detailed explanation
in Albright \. Rodriguez),
Until the Nevada Supreme Court rules on this issue. police officers should be
selective in arresting for failme to ID with factors slich as the strength of the articulable
suspicion for thc stop and the type of crime suspected. For example if police see a person
continuollsly hanging around a grade school with minor children prescnt a Tcrry stop is
valid. If the person has a prior record for molestation of minor children it would be
devastating for the community if the police otticer was not permitted to request
identi lieation,
A related issue about police obtaining identification during a valid Terry Stop is
whether police can pat down or search the person for documentable lD such as driver's
license. The cases in this area are few and the validity of the practice is uncertain,
In People v. Long. 254 CaL Rptr. 483 (In7). the olliecr had RfS to stop Long in
a har where he was with an under aged girL The otlicer asked for lD and Long stated his
name hut said he didn't have any lD, The officer noted a wallet sized bulge in his rear
pants pocket, again asketl for IHitten lD ant! Long said he had none. The officer directed
Long to look through his wallet. which Long did. and the otricer saw some plastic
haggies containing drugs. The Court upheld the officer's demand tClr writtcnlD, citing
Flynn and Adams Y. Williams. Same ruling in People v. Loudermilk, 194 Cal. AppJd
447 (1987) where an officer had RIS to stop a person suspected of tiring a gun, Pat down
felt wallet but person reflised to lD. and in Harpen', State. 532 So, 2d 1091 (fla. 1988),
In State v. Frazier, 318 N,W. 2d 42 (Miln 1982) an officer stopped a person and
took her purse and reached in to get m and found a gun, The gun was suppressed
because the court ruled that slIch a search was uncon;,titutional without giving the
detainee an opportunity to voluntarily produce lD,
(2) WHAT CONSTITUTES i\ "STOP" AS OPPOSED TO "NONSEIZURE'P'
The Hodari D. case and the Bostick case define the pre-stop or pre-seizure area.
RCl11cl11her a WI erry stop" is a tilrll1 of seizure - the person is not free to go, Drawing the
line between a "Bostick encounter" and a "Terry stop" has to be done on a case by case
basis, Remember. the del".:nsc lawyer "ill tr~ to push thc time of the "Tcrry stop" as
early as possible in the contact when the oflicer has less articulablc suspicion, hoping to
persuade the court that you made an illegal Terry stop and if so, wiping out your case
with a Ii"uit (lfPT argument.
CASE EXAMPLES:
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I. U, S, v, Garcia. 866 F.2d 147 (6th Cir. 1989). an imponant factor in

distinguishing seizures from casual contacts is when the person is asked to accompan\'
the police to a place where the person had not planned to go. An oflicer may approach a
traveler in an airport and ask to speak to him. and continue that conversation until a
reasonable person would no longer feci that the person was free to go. Once that point
has been reached. the otlicer must have a reasonable aniculabk suspicion. or else the
stop or detention is illegal. and fruits of that search must he suppressed. Garcia was not
seizure because "there were only two agents present. no weapon was displayed, he was
not physically touched. and the agent> did not raise their voices 01' threaten him in any
way,lI
2, U,S, v, Glass. 128 F.3d 1398 (10th Cir. 1(97) has some factors that courts usc
in deterntining whether a police-citizen contact is a seizure, These factors include:
(a) Telling a person that he is a suspect for a paJ1ieuiar type of crime
(b) The number of oftieers that are present
(e) Moving the conversation from public to private place or whether the contact
43
is in a public or private place
(d) Whether the person is told that he need not talk to the officers
(e) Whether the person' s egress was blocked
3. U,S, v, Kim_ 27 ],Jd 947 (3rd Cir. 19(4) utilizing essentially the same' factors
in the Glass case ",hich had been rdated in earlier US Circuit Court cases held that none
of these factors alone is determinative regarding whether a 4th Alllendment seil.ure of the
person occurs,
4, i\ few federal cases (pre Bostick) gun: .,trang I\-eight in their analysis or
seizure to a police officer's asking directly incriminating and locused questions. almost to
the point of per se rule lllaking such contacts a seizure. L. S, Y. Nunley. R73 F,2d 182
(8th Cir.1989) U,S, y, Jaramillo. 891 F.2d 620 (7th Cir.1989) However. Nunley was
modified by U.S. v, Perdue, 961 F.2d 723 (8th CiL 1(92) and Jaramillo was reversed by
U.S. v. Ornelas-Ledesma. 16 FJd 714 (7Ih Cir. I (94)(Both post Bostick cases),
5. U,S, v. Cardoza, 129 FJd 6 (I st Cir 1997) Dcfendam was not "seized" within
meaning of Fourth Amendment helore police saw him with contraband, even though
police cruiser turned wrong way up one-way street. making clear oflicer's intent to COllle
into contact \\ith him. and olliecrs asked him what he was doing out at that time;
reasonable person would not have concluded that he was not free to leave. as officers did
not lise flUS/ling lights or sirens. and officers did not ask defendant to stop. or even 10
approach patrol car. The result. thereforc. "i" the dircctiw that police conduct, viewed
from the totalilY of the circumstances. must ohjectively communicate that the officer is
exercising official authorit) to restrain the individual's liberty of movement before we
can lind a seizul'c occurred."
6, U.S. v, Rodriguez-Franco. 749 F.2d 1555 (II th Cir. 1985). held that INS
agents approached a group of "Hispanic looking" persons in a mall and asked question,
about citizenship and asked (nol commanding) tvvo persons to slep ovcr to a beneh there
was no Terry SlOp. (This type of police procedure might arguahly have he en improper
had it been done by other than INS agents. Sec the next case),
In Lopez v. Garriga. 917 F.2d 63 (I st Cir. 1990) an INS agent asked questions of
persons before b\)arding airlines in Puerto Rico. The Court held that INS agents at an
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airport gate may. without violating the Constitution. inqllirc about a prospective
passenger's citizenship and destination. The mere posing of qUl."stions by a government
oflicial is not considered to be a seizure. The Court noted that under federal law. the INS
has authority to ask questions of a person they think may be violating immigration laws.
7. Ozhuwan v. State. 7&6 r.2d 918 (Alaska. 1990). held that a Terr) stop
occurred when an officer partially blocked a person's car with the police car while
activating the overhead lights.
8. U.S. v. Waskal. 709 r.2d 653 (11 th Cir. 1983). held that a Terry SlOp occurred
when police spoke to a person in an airport and took hi.-; ticket and asked him to go to a
44
nearby ol1ice without returning tbe tIcket.
9. [; .S. v. Tayolacci. 895 F.ld 1423 (D.C. Cir. 1990). held no Terry stop where
an officer knocked on a door to a person's train compartment. asked permission to a~k
questions and requested and received a train ticket and personal identification. then
promptly returned them.
10. II .S. v. I'orres-Guevara. 147 FJd 1261 (10th Cir. 1998) Onlccrs
encountered the defendant at an airport and asked for and received her identilication and
an airline ticket. The officers looked at these items returned them immediately and told
her she was not under arrest and could leave.
The oflicers never touched or restrained the woman but asked her twice for
consent to search for drugs. When the ollieer again asked for permission to search her she
did not respond. The ofliccr asked her again and she again did not respond. The oflicer
then told her if she had drugs. she should turn them (l\'\~r.
Another oflieer. asked "you have drugs, don't you?" \Vhen she put her head down
instead of answering. he asked: "don't you')" She responded:"yes." Police 'detained her
and had a female police otlicer search her and found the drugs
The Court ruled that this was a non-seizure encounter stating that asking
incriminating questions does not per sc make this an investigative stop although
accusatory and persistent questioning. display of weapons, or commanding or threatening
tone of voice would amount to an investigative detention.
(3) WHAT CONSTITUTES "RI'ASONABLE SUSPICION?"
"Reasonable suspicion" is a tcrm like "prohable cause" which evades precise
definition. Although the rules for police-citizen contacts are hased on objective
standards. a decision by a court that reasonable suspicion exists depends on the opinion
by tilal judge (or in the case of an appellate court - a group of judges). The same
articulable factors which might be no more than a "hunch" in one coun's mind may
amount to oYclwhelming r~asonable suspicion in another C011l1'S mind. This is a human
factor we all have to live with.
For example. read the Case of U.S. Y. Mendenhall. 446lj.S. 544 (1980).
involving ,m encounter between police and a susrectcd drug courier at an airp0l1. Three
Supreme Coun Justices thought that the contact between the police and Mendenhall was
a non-seizure contact rcquiring no justification. Three other Justices thought it was a
Terry stop. but that reasonable suspicion existed. Three other Jllstiee;, thought it was a
Terry stop. hut was illegal because there was not R;S.
OffIcers should know the \ ic\\ of the \ast majority of courts about the factors that
may indicate R!S and fuctors \Ihich have little or no suppOrt for R/S or PIC.
NERVOUSNFSS
(I) In li.S. \. Wood. 106 F.3d 942 (lOth Cir 1(97) the Court ruled. '"We hale
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repeatedly held thal nervousness is of limited signitlcance in determining reasonable

suspicion and that the gllvel1lment's rcpetitiYC reliance on the nervousness of either the
driver or passenger as a basis for reasomlble sllspicion "in all cases of tillS kind must be
treated "ith caution:'
"It is common kno\\ledge that most citizens. \"hether innoccnt or guilty. whcn
confronted by a law enforcement officer who asks them potentially incriminating
questions are likely to exhibit some signs of nervousness." Same ruling on nervousness in
U.S. v.Peters.IO F.3d 1517. 1521 (10th Cir.1993) and U.S. v. Beck. 140 F.3d 1129 (8th
Cir. 19(8). See U.S. v. McRae. 81 FJd 1528 (10th Cir. 1996) holding that nervousness
along with other objecti vc factors may contribute to IVS,
REFUSAL TO COOPERATE
(2) In Florida v. Bostick. III S.C!. 2382 (1991) in addition to holding that the
police contact was non- seizure. the COUI1 also stated that the suspect's refusal to
cooperate with police (i.e.: answer questions and/or consent to search) \-\-ould not have
given the police reasonable suspicion let alone probable cause to seize the subject or
search his luggage. Same decision by all Federal and Statc COLIrtS: U.S. I'. Pletcher. 91
F.3d 4S (8th Cir. 1(96),l.I.S, I. Torres. 65 F.3d 1241 (4th Cir. 19(5). Karnes v,
Skrutski. 62 FJd 485 (3rd Cir. I c)95) and <iasho v. l:nited States. 39 FJd 1420 (9th Cir.
1994).
TRAINED OBSERV ATIONS
(3) Several US Circuit court cases hold that. "when llsed by trained la\\
enforcement oi'licers. objective facts. meaningless to the untrained. can be combined with
permissih1e deductions from such 1:,ct5 to form a legitimate ba,is
for suspicion." U.S. v. Sholola. 124 F.3d ROJ (7th Cir. 1997) and U.S, \. Lujan. 188 F.3d
520 (10th Cir. 1999).
(4) U.S. v. C0!1ez, 449 U.S. I (1981). dealt with an investigation bI the Border
Patrol into smuggling aliens, Over several months, ntlicers saw sets of footprints, one of
which had a unique pattel1l. coming across the border and ending up near a highway
\\ hieh ran parallel to the border. The tracks led into obstacles \\'hich would have been
visible during the day. The tracks turned eastward at the highway. then dlsappeared after
a shOl1 distance.
The officero set up a vantage point at night. about 27 miles east of thc location
where most of the toot prints disapPl'arcd into the highway. Th<,} estimated it would take
about I y, hours (or a vehicle to pass their location. go to the pickup point and return to
thelr location. They stopped a pickup Ilith a camper shell "hich went past and then
returned in that time frame.
The U,S. Supreme COllrt held: reasonable suspicion did exist on thesc facts to
justify a stop of the trllck. Prosecutors should read and ..:ite this case uftCI\, It contains
language tdling courts that even "innocent" actions when viewcd by police officers who
have knowledge of the modes or paltern$ of certain types of criminal acti\'ity can give
RIS. "A trained officer draws inferences Irom data that might well elude an
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untrained person" "The lest lor reasonahle suspicion is not in weighed in terms of
library analysis by scholars."
(5) L.S. v. Lender. 985 F.2d 151 (4th Cir.1993) officers observed four or five
men "huddled on a corner" in a known drug area. One of the men "had his hand stllck out
with his palm up. and the otiler mcn werc looking down toward his palm." When the
group saw the police. they "kgan to disperse. and the defendant walked away from the
oflicers with his hack to them." Ilased on the hour oCthe day. the group's dispersal upon
seeing the ofjicers. the known character of the ncighbllrhood. and the ofticers' practical
experience in recognizing drug transactions. the court upheld the stop.
(6) U.S. v. Mattar1o. 191 FJd 1082 (9th Cif. 1999) Late at night. an oflieer was
on a dark secluded country road and saw' a pickup truck in the driveway or a fenced
construction storage area. with the gate closed. The truck leli the driveway with a three foot
square crate in the back. At that hour there was no business activity, The otliccr
stopped the defendant.
The ('oUl1 held. "The officer has an objective basis for his susp,cions bascd on all
the circumstances. It is not a matter of hard certainties, but ofprobabilitks. This
requires morc than an oftlcds hunch. but a preponderance 01' the cvidence to show proof
of wrong doing is not required at this stage. RlS therefore can arise from information
different in quality and content and even less reliable than that required for the
establishment of probable cause. The otliccr's training and e~perience arc factors to
consider in dctermining if the or1ker's suspicions wen; rca~onablc.
See section on Basis for Frisk for other part of Mauur10 case
(7) ti.S. v. Quinn. 83 F3d 917 (7th Cif. 19(6) An officer saw three men on a
street corner in a high drug crime arca. Upon seeing the oftlccr. one threw a plastic bag
down and they split up and began to walk (1\\ay. Onc man went one way and the other
two wcnt in the opposite direction. The officer ordered Quinn to stop and saw that he was
carrying a leather jacket "wadded up in his arms."
[Ie ordered Quinn to accompany him hack to thc police car and [0 place the
jacket on the car. As he did so. the otIlcer heard a "thud" sound. He did a pat-down
search IImling no weapons then palled the jacket and felt a hard ohject inside and
remOved a .12 rifle sawed-off and l110dilled into a handuun. )Ie arrested Quinn then wcm
to the corner to retrieve lh~ ;,llspected cruck cocaine.
The Court held the police action lawful. "the dcfendant's prescnce in a high crime
area is an insuflicicnt ground (by itselt) to stop or search. Howcver. COllrts may consider
the defendant's presence in a high crime area as part of the totality of circumstances
confronting the officer at the time of the stop.
DEFINING REASONABLE SCSPICION
(8) U.S. v. Perrin. 45 FJd 869 (4th Cir. 19(5) the court held "reasonable
,uspicion is a less demanding standard than probable cause not only because RJS can be
established with information that is less in quantity than that required to show PIC, but
al<;o from information that is less reliable than necdcd for PiC."
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(9) U.S. v. lIensley. 105 S.Ct. 075 (1985). is important ti1r at least two points.
The lJmted States Suprcme Court held thm the "fellow officer" rule applies to Terry stops
so that the officer actually making the stop could rely on a '\",anted for inve,tigation" Ilier
issued by police in another state so long as the issuing poliCe had reasonable suspicion.
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Also. this case extended the authority to make a Terr: stop beyond reasonable suspicion
that "criminal activity was aloot" (i.e .. a presentl: oCClIn'ing crime) to a serious crime
(armed robber)-) that had occurred weeks earlier.
(10) In Omelas v. U.S .. 116 S.C\. 1657 (1996) police in Milwaukee who wcre
trained in drug interdiction saw a 1981 Oldsmobile with California plates in a motel
parking lot in Decem her. The police checkeo the registered owner through dispatch and
then learned tl'om the DEA that the RIO was ill NADDIS (DEA computer) as a
"suspected" drug trafficker. Police learned ti-om the motel manager that Ornelas and
another man checked in at 4al1\ without reservations. Police also knew that older model
GM cars had large spaces in the doors and other locations.
The U.S. Supreme Court said that these facts constituted RIS. The Court said that
although the mosaic which is analyzed for RIS or PIC is multi faceted and one
determination will seldom be useful precedent for another a court should look at all the
precedents in making a decision. The COllrt should detemline the "historical facts" (ic:
the specitic facts of the case) and thet1111ake a legal decision as to whether the facts
satisfy the constitutional standard.
(II) In State v. Sonllefeld. 114l\e\'. 631 (1998) the Court ruled tim! a deputy
sheriff had reasonable suspicion sufficient l\) make investigatory stop ol'vchic1c hased on
his corrobomtion of bartender's detailed tip to dispatcher that inebriated customer had left
bar and was driving under intluenec: bartender provided color of caL description of
distinguishing roof rack. license plate number, physical description of dri\cr and
direction in which vehicle was heading. all of which were cunfirmed by the officer
thereby establishing RlS.
(12) Other Nevada cases are Wright v. State. 88 Nev. 460 (1972), Jackson \.
State, 90 Nev. 266 (1974). :---Je/son \. State. 96 ';e\,. 363 (1980). and Idcllonso v. State, 88
Nev. 307 (1972). All of these required very little in terms of "articulabk facts" to sho\\'
RlS.
ANONYMOLS AND OTHER TIPS
(13) Alahama v. White. 110 S.C!. 2412 (1990). held that an anonymous tip that a
female would leave a particular apartment complex at a particular time. would drive a
certain descrihed car. would go to a certain destination and would be carrying drugs was
enough for reasonable suspicion when police corroborated the details of the tip and
stopped the car as it neared the de,tination. It made no dillel'ence that all the actions
observed by the police were "innoccnt." Ms. White's subsequent consent to search.
which turncd up the dope, was not the thtit of an unlawfullerry stop.
(14) In U.S. v. Price. 184 F.3d 637 (7th Cif. 1999). the Police received un
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anonymous tip stating that a white Ylel'cury Cougar. "ith a license plate containing the
letters "FLl." would be delivering onc kilogram of cocaine 10 a specific residence in
Milwaukee. The tipster told the police that the car had len Sheboygan at about 9:00 p.m.
( Ahout 60 miles from 'vlilwaukee.) and also stated that Ihe car would contain two black
women. Charlene and Patricia. and one black man named Calvin (also gave last namcs)
Police arrived at the vicinity of the suspecI rc;;idence in an unmarked car at around 10:45
p.m .. The oflicers did not verity who lived at the residence. and did not pcrfornl record
checks of three people named hy the tipste!'.
At approximately 11 :20 p.m .. a white Mercury Cougar arri ved containing two
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black women and two black 111(~n. The drin:r double-parked the car and left the engine
running. The license plate contained the leiters "GJL." All four occupants got out and
approached the residence. Police stopped them at the sidewalk and indicated that they
were investigating a narcotics complaint. SCI'eral ot' the occupants produced lD
conlirming the namcs giycn by thc informant. l.atcr. narcotics were l(lUnd. The ('ourt
held that the stop was based on RIS.( Alabama I. White.).
(IS) In U.S. v. Bell. 183 F.,'d 846 (8th Cir. 1999) Police acted on a tip from Ms.
llalTis. who prolided detailed information that criminal activity was aIClO!.
"Harris was a close acquaintance of Bell who had previously provided accurate
information about him. Harris's tip--that Bell and Ingram wcre dril'ing to Little Rock to
pick up crack cocaine from Linda I3ce--\\as consistent with intCll'lllation received from
other sources less than a month earlier and with more recent information that Bell and
Ingram were ,clling drugs at 2314 Jean Street.
The tip was further corroborated when the officers saw a car matching the
description Harris had provided traveling on u.s. Highway 65 in the direction of Pine
Bluff ,. Considering the totality of the circumstances. we agree with the district court that
the stop did not violate Bell's Founh Amendment rights."
INDIYJl)UAL SUSPICION
(16) YbalTa v. [/Iinois. 100 S.C!. 3,8 (1979). \\as a case whcre police had a search
warrant for a tavern and the bartender. based on probable cause. that he was selling drugs
at the bar. Police entered the tavern during business hours to serve the search warrant,
and patted down the patrons. One of the patrons was Ybarra who had dope in his pocket
which was seized. The United Slates Supreme Court held: illegal search - no rcasonabk
suspicion that Ybarra was engaged in criminal acti\ it)' and.'or that he might ha\'c a
weapon, just becallse he was in the bar. Reasonable ,uspicion and probable cause must
be individualized.
(17) A recent case demonstrates the rule that reasonahle Slhpicion must be
individualii'cd. The difference was whether the I{lS did or did not cover more than one
person. In U.S. v. .Johnson. 170 F.3d 708 (7th Cir. 1999) police were approaching a
residence /()r a "knock and talk." As they arrived. a pcrson exited the residence and was
Terry stop detained by police. The detention and pat down were held to be unlawful
hecause there was no individualized suspicion as to that person.
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REASONABLE MISTAKE OF FACTS
Two cases sho\\ that reasonable suspicion can be f(llll1d in a case where the police
were mistaken about the facts justifying the detention. but the facts believed by the police
were found to be reasonable (ie: the police had no reason to believe that the facts were
incolTcct when the stop was made.
(18) In the case of Stuart v. State. 94 Nc\,. 721 (1978), the ofliccr noticed thut the
trunk lock on the vehicle wa" missing. Alia the stop was effet:tcd. the ofiicer detected
the odor of marijuana and noticed what appeared to be marijuana seeds on the floor in the
front seat ofthc vehicle. The court said "The ofiicer. in this case. had observed the
missing trunk lock. and_ hased upon training he had received at the Highway Patrol
Academy, inferred that the vchicle might be stolen. Lnder these circumstances. we
believe the oflicer's cOllclusion was reasonable and he was justified in storring the
vehicle tor routine questioning and investigation."

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Since the officer had lawfully attained the position from which he observed the
marijuana in open view. and it was in a vehic!": ,,'!lich could be searched without a
warrant he had a right to seize it and the marijuana was properly admitted into evidence.
NOTE: The vehicle was not actually stolen.
(19) U.S. v. Alvarez. 899 F 2d 833 (9th Cir. 1990). an unidentilied caller wid
police that tall Hispanic male would rob certain hank within 10 minutes and had
explosives in trunk of white Mustang. Police saw white ~1ustang backed into parking
space facing bank with Hispanic driver. Car pulled out when police arrived. Police
stopped car and patted down driver. Found gun then searched car and found guns and
drugs in trunk. Before trial. caller \\as idcntiiied and It w'as sho\'m that his "robbery
plan" claim was false. Held: police action OK. Even anon~mous tip can provide PIC or
RIS for Terry stop where police can CCln'oborate all delails of tip. Fact that all of
suspect's actions were "innocent" makes no difference. Police didn't know tip was
false-police had objectively reasonable articulable basis ttlr stop.
(20) [lut - you must be cardul about a stop based 011 wrong information. If the
oi'licer's (or police dcpanment's) negligence causes or produce, the incorrect information
which, on the surface. justifies the stop - later on the court will probabl: say stop is no
good. For example: stop no good where police office called in wrong license number, or
else dispatcher heard it wrong and told officer plates didn't match. l.ater detemlined that
plates did match. Evidence from the stop was mimed, United Statcs Y. Deleon-Reyna.
898 F.2d 486 (5th Cir. 1990) - same result in Ott \. State. 600 A.2d III (Md. 1992),
(Note: this is still true even alier the decision in Arizona v. Evans (see section Oil "police,
mistakes) because there the error was done hy the COlirt clerk's oflice not by the police
departmcnt ).
UNPROVOKED FLIGHT FROM POLICE
(21) In Illinois Y. Wordlaw (decided January 2000) the majority of the U.S.
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Supreme Court held that. although a person standing in an area knO\\ll for heavy
narcotics trafficking. by that fact alone is not subject to a Terry stop. If the person Ileas
from the police presence without provocation. that person can be Terry stopped. Police
did so; did a pat-down because. in the officer's experience it was common lor weapons to
be around drug transactions. and /(llmd a wcapon on Word law. Wllich was held
admissible.
Two fClllowing cases hold that although unprovoked night from police alonc is
not enough for RlS. that the flight along with other factors. can support RiS!
(22) State Y. Stinnett, 104 Nev. 398 (1988). Jlolice "ere on patrol in area with
high incidence of drug crimes and saw several men huddled in front of abandoned
residence. One of the group noticed the police. he ran toward the back of the residence
chased by the police. A fcw minute'S later. police entered the abandoned home and found
suspect huddled in a closet with drugs nearby. Held: The suspect was not detained when
he ran from the police. When the suspect W'as found inside the abandoned house. he was
detained. but alllhc circumstances including his unprovoked night justified an
investigathe
Jet~ntion.
(23) In U.S. v. Jackson. 175 F.3d 600 (8th Cir. 1999) the Court ruled that It was
reasonabk for officer to tackle defendant to effect investigative stop when officers were
responding to call that shots had t>een tlred at address in high-crime neighborhood.
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"If:
defendant was behind area where shots \\ere fired and nenOllsly began 10 nee when
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officers approached in marked ,quad car. officers noticed that defendant appeared In be
clutching something at his side as he ran. und continued to flee after officers announced
that they were officers and told defendant to stop.
(4) 'PROFII.ING"
Quite a bit of confusion exists in police circles concerning "profiling" but modern
cases make the correct legal consequcnces quite clear. In a nutshell. when ofIieers
make a stop based on protiling. thc fact that profiling was used has no legal
signilieance at all. It doesn't help or hurt the validit: of the stop. This was the holding
ofthl' lJ. S. Supreme Court in Soko\cm.
1. In United Stales ,'. Sokolow. 109 S.C!. 1581 (1989). DE:\ agents stopped the
suspect at Honolulu Airport becausc (1) he had paid $2.100 cash for airline tickets. (2) he
traveled under a name that did not match the namc under which the phone number he
used was listed, (3) his destination had been .\1iami \\hich was a "source city". (4) he
stayed in Miami only 48 hours, (5) he appeared nervous and (6) he had no checked
luggage, DEA found I kilo of cocaine in his CaITy-on luggag~ after a trained drug
snifJing dog atel1ell on the luggage and DEA obtained a search warrant. Held:
Reasonable suspicion for a Terry stop existed. Although each factor taken alone was
insuf1icient to justify a stop. when taken together the) amount to reasonable suspicion.
The "profile" factors shown here are "probative" and amount ro reasonable suspicion
even though none ofthcm arc "criminal". The filct that the person lit a "profile" did not
in and of itself equal r~asonable suspicion,
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2.ln Kame'i v, Sknnski, 62 f.3d 4R5 (3rd Cir. 1995) the COUl1 ruled that "the
drug courier profile has little meaning independent of the objectivc facts" prescnted by
the law enforcement of1iccr as sufficient to demonstrate reasonable sllspicion. In other
words. the factors that the law enforcement officer uses to establish PIC or RIS must be
articulated (ie: specified) based 011 the cirCllmstanccs of each case. The profile itself does
not provide any additional support for tinding PiC or RiS, Same ruling in U.S. v.
Malone, 886 F.2d 1162 (9th Cif. 1989). U.S. ", Moore. 22 FJd 241 (10th Cir. 1994) and
U.S. v. S53.082 in US Currency. 985 F.2d 285 (6th Cir. 1993) as well as numerous state
supreme court cases.
3. See the section on "Pretext Stops" in this manual. The modem law based on
the Whrcn case thlm the U.S. Supreme Court and (lama case from the Nevada Supreme
Court make it clear that as long as an otTicer has any objective basis tllf making a stop.
the officer's internal !11oti\'cS are irrelevant. This means that an officer can make a stop
based on a "profilc" hut only so long as there is some other basis l'or the stop. There is no
longer any such thing as an illegal pretext stop.
4. Use of indicators ,1Ich as membership in certain racial groups in drug courier
profiling has been sharply challenged. "Defendant's nationalit) (\1cxican) and his
friends' use of Spanish cannot support reasonable suspicion of smuggling drugs"
according to United States Y. Garcia. 23 FJd 1331 (Rth Cir. 1(94).
(5) WHAT FORMS THE BASIS TO FRISK 'J
The right to frisk is not generally automatic with a \'alid "stop."
I. In Sibron \. New York. 392lJ.S. 40 (1968) and Ybarra v,llIinois. 4441,S.
85 (1979) the U.S. Supreme Court said that the general rule is thaI a "frisk" is not always

?
J
justified because the "stop" is justified, The officer has to be able to point to particular
facts that made him think the suspect "may be" anned,
2, In Minnesota v, Dickerson. 1i3 s,n 2130 (1993). the "plain feel" case.
Justice Scalia's concurring opinion makes it ckar that the right to "frisk" docs not
automatically accompany the right to "stop," (This is the opposite of "search incident to
arrest" rule which does automatically accompany all" lawful custodial arresl.),
3, Adams v, Williams. 407 U,S, 143 (1972). held (hat where a reliahle informant
told an orficer that a person silting in a parked car had a concealed weapon, The officer
asked the person to step from the car. but instead Adams rolled clown the window, Thc
officer reached in the v,indo" to his waisthand and felt. then seil.ed. a gun, I'his was
enough reasonable suspicion for a stop and lrisk.
4, ln U.S, v. Mattarolo. 191 FJd 1082 (9th Cir. 1(99) the Coun ruled that an
officer may conduct a limited protective scarch for concealed weapons if there is a reason
to believe the suspect may havc a wcapon, The officer must choose between being sure
that the suspect is not armcd and jeopardizing his own safety. :\n officer making a stop
0,
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IS
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under the suspicious circumstances of the present case who failed to patdowll the suspect
for weapons within the limited scope of ') erry could he taking substantial and
unnecessary risks." Distinguishing an earlier casc, the Court thalthe stop in that case
was in a bank parking lot during the daylight hours. not on a remote section of road at
midnight. The person stopped was a suspected counterfeiter. not a suspect caught
possibly in the act of committing a nighttime burglary and therefore more likely to be
armed.
In Mattarolo. the defendant got out of his car swiftly and walked quickly toward
the squad car before the onicer had the chance to get out of his car. This caused the
omeer to get out of his squad car quickly so as not to be trapped with the means of
protecting himself consequently limited, Given the totality of the circumst<mces, the
patdown search was fully justified and a provident procedure to follow,
5, In U, S. v. Sinclair, 983 F.ld 598 14th ('if. I(1'13) the Court held th~1 "the
ot1'icer's reasonable belief may derive as much from his experiences in similar cases as
from his knowledge of the dangerous propensities of the suspect at hand,"
6. In U. S, v, GibSon. 64 F,3d 617 (11th Cir, 1995) the Court said that where the
ofllccr had colToborated every item of information from an anonYmous tipster about a
certain suspect. the officer had reason to believe the tipster's statement that the suspect
was armed.
7, In U,S. v, Taylor. 162 F,3d 12 (lSI ('if. 1998) the Court ruled that [n!onnant's
tip that occupants of automobile wcre in possession of crack cocaine and wcapons and
were delivering narcotics exhibited sufficient indicia of reliability to justify investigatory
stop of automobile and fris~ of the occupants: inionnant had provided reliable
information in the past. tip included such details as make and color of car and description
of its occupants. and tip was cOlToborated in significant aspects by the officer.
8, In U,S, v, Campbell. 178 F3d 345 (5th Cir. 1999) the Court ruled it was not
unreasonable for police officer to draw his weapon. order armed bank robhery suspect to
lie on gl'Oulll.L handcuff suspect \\ ith his hands \1ehind his back. and fi'isk suspect during
course of investigatory stop. even though suspect c(lmplied with orticer's orders and
robbery had occurred approximately 30 hours prior to stop: stls[lect matched description
c
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12
co,
,~
?(
of 3nlled bank robber and he was getting into driwr's side of automobile matching
description of getaway car. thcr~ were othcl people in area during SlOp. and there \\cre
only three omecrs to control three suspects.
REMEMBER - A FRISK CAN ONLY BE DONE FOR WEAPONS. NOI FOR i\'iY OTI IER
ITEMS OR CONTRABAND. HOWEVER. IF THE FRISK IS DONE WITH R/S THA T A
WEAPON
IS PRl:OSENT. BUT AFTER REMOVING TIlE ITElvl THAT "FELT LIKE" A WEAPON. THE
POLlCE FIND THAT IT WAS NOT ACTUALLY ;\ WEAPON. TJ IE SEARCII & SEI1URl, IS
STIl.I. VALID
9. U.S. v. Raymond. 152 F.3d 309 (4th Cir. 1998) Police stopped a car for
speeding. Raymond was a passenger and the police ordered him out of the car. He got
out clutching his stomach. The officer palled him down and felt a large disc like object
which he thought might be a weapon. It turned out to be a 7" rock cocaine disk. The
53
court ruled that the circllmstances gave risc to an articulable sllspicion that he might have
been armed with a wcapon. There was a reasonable basis for conducting a patdown
search based on his strange exir jj'olll the car. as ifhe were attempting to conceal
something under his jacket. and the awkward way in which he leaned against the car
while talking to policc.
10. II.S. v. Rahman. 189 F.3d 88 (2d Cir. 1999) the Court held that s..:i/ure of
forged passports by agents was reasonable. \\here agents learned that \chick used in
bombing ofofjicc building in New York City had been rented by person listing his
address as suspect's address. agents obtained warrant to search slIch add res,. agents
observed suspect returning to the building at accelerated pace when th~y entered to
search. suspect resisted being frisked. and agents felt fin11 rectangular object in his pocket
thar they could have reasonably expected lias an explosive de\ice. but turned out to be
envelope containing passports.
II. U.S. v. Edwards. 53 F.3d 616 (3rd Cir. 1995) the Court ruled police were
justilied in conducting Terry protective paldown for \\-eapons and opcning envelope
found in pocket of jacket on ddcndant's lap. Police responded to rep0l1 of credit card
fraud in progress. and were justitiably concerned that small-caliber handgun could be
concealed ill cnI'elope. which measured (our by six inches and felt from outside as if it
held hard. bulky objcct.(found stolen credit cards-OK!.
12. U.S. v. Strahan, 984 F.2d 155 (6th Cir. 1993) the Court recognized the rule
that where un officer is doing a lawful "fr'isk" and feels an object that reasonably appears
to be some sort of weapon. the oflicer can remove that item. and if it turns out that it was
not actually a weapon. but is contraband. the sei/.urc of the contraband is lawtlil. (Bulge
and hard item turned out to be money dip)
13.lnll.S. v. Brown. 188 1'.3d 860 (7th Cir. ] <J9()) the Court ruled that Officer
had articulable grounds for R!S that person in a tranic ,top mighr be armed and
dangerous. tojustiJy an initial pat-donn search: circumsrances included otlicer's
knowledge olTll sur\"eillance of the vehicle as a pl)sslble part oj' a large-scale drug
operation. the smell of marijuana smoke from the car. driver's vcr: nervous demeanor.
his fililure to make eye con1act, his glancing back to the vehicle. where the other
occupants rolled down the tinted \Vindoll s during the trartle stop. and the fact that the
stop occurred in a high crime area where there was gang and drug acrivity and had heen
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recent shootings.
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Nervousness. refusal to make c\e contact or high crime area alone \\"Ill nO! justify
a Terry 5101' and pat-down. hut ~,uch behavior ~ay bc considered as a facto; in the totalil)"
of circumstances.
The Court justilil'd a pat-down search following traffic SlOp which disclosed a
hard object ahout the sizc of a ping-pong ball in suspect's groin area ... It was reasonable
for officer to think object \V3.1 the butt ofa gun. even if officer would have heen more
reasonable to think the object was drugs:
14. U.S. v. Campbell. 178 F.3d 345 (5th Cir. 1999) Court held removal. during
54
course of invcstigatory stop. of contents of suspected armed bank robber's pocket was
reasonable and within scope of permissihle Terry frisk. when: police officer had not ruled
out possihility that large bulge, formed by over $1.400 in currency and cardboard box
containing gold chain. was a weapon.
Note: Ol1icers should be aware that an item encountered and lawfully removt;!d
during a '"frisk'" does not generally give the right to open the item unless it might
reasonably contain a weapon. Otherwise. if it is opened. evidence will he suppressed
unless there was justification. (Remember: R!S is enough to get weapons hut PIC +
consent or a S/\V is needed to uct contraband or evidence. Beware of a pretext arrest to
gct authority to search) '"The need to discover weapons cannotjustif} opening the
matchbox'Pace \.. Beto, 469 F.2d 1339 (5th Cir. 1972. same ruling regarding small
pouch People v. Martinez. 801 P.2d 542 (Colo. 1990) and cigarette case in C.H. \.
State. 54R So.2d 895 (Florida. 1989)
Pleasc refer to the "Plain View section in this mannal under subject of Immediately apparenL' for
discussion on single purpose" containers.
The theoretical distinction between "SlOpS" and "frisks" (that each requires its
separate justification) is sometimes blurred. although the COut1's decision is correct. for
example:
15. In Ruslin:; y State, 'l6 Nc\,. 778 (1980). a police ofticcr saw a person \\ ith a
car parked in the road. trunk and door open. walk across the street to a truck where a
rubber hose led from the gas tank to a gas can. The suspect tled and the officer broadcast
a description. Another of"ficcr stopped the suspect (based on matching description and
location) about one hour later. The sllspect was patted down and a gun was found.
Defendant was charged with possession of a firearm by ex-felon. On the pat down issllc,
the court said:
"The officer need not be absolutely ce!1ain that thc individual is armed ITerry).
The otlicer had reasonable grounds to anticipate danger to himself or the othcr otlicer.
The suspect met the description oronc who \Vas possibly engaged in aulO theft. The
suspect fled and was hiding. The stop occurred late at night. All these factors led the
officer to conclude reasonably that the sllspect was involved in criminal conduct.
Thercforc. it was not improper for him to infer the possibility of a concealed weapon."
Certain Types of Crime Do Justify an 'automatic' Frisk
Many. but not all. courts hold that certain types of criminal acti\ ity arc commonly
associated with weapons. thereby justifying a frisk for weapons if there is reasonable
sllspicion ortha! type of criminal activity.
For example. high lc\'er' drug dealing has been vkwed this Wa\ in the following
cases: U.S. v. Brown. 9()) F.2d 540 (8th Cir. I~90). People v. Lee. 240 Cal. Rplr. 32
2
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18
20
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(1987). U.S. v. Peay. 885 F.Supp. I (DC D.C. 1(95). U. S v. McMurray. 34 F.3d 1405
55
(8th Cir.1994) and U.S. v. Salas. 879 F.2d 530 (9th Cir. 1989) LS. \'. Price. 184 FJd 637
(7th Cir.1(99).
Violent domestic disputes can qual if)'. Peorlc v. Barber. 537 N.E.2d 1171 (III.
1989). State \'. Vasquel. 807 1'.2d 520 (Ariz. 1991).
Armed robbery: U.S. \. Abokhi. 829 F.2d 666 (8th Cir.I9R7) and t:.S. Y. Lang,
81 FJd 1405 (8th Cir. 1994).
Burglary: U.S. \. Walker. 924 F.2d I (I st Cir. 1991). U.S v. 1-,\oore. 817 F.2d
1105 (4th Cir. 1987).
(6) "PLAIN FEEL"
Minnesota \'. Dickerson. 113 S.C!. 2130 (1993). is the so-calkd "plain feel" case.
Uniformed police were on patrol at night ncar an apaItment building known to thcm as a
hotbed of drug dealings. Police had serwd seveml drug search \\arrants at that building
and had citizen complaints of drugs being sold in the hallways. [)i~kcrs()n \\as observed
leaving the building and walked toward the marked police car. Lpan seeing the police.
he turned and abruptly walked the other \\ ay and entered an allev.
The of'ficers made a "Terry stop" on Dickerson and also "frisked" him. Whik
"frisking" Dickerson. one otllcer telt something in his pocket \\'hich the of1icer slid
around and manipulated. then removed a plastic bag containing 1/5 gram of rock cocaine.
(The legality of the "stop" and the decision to "frisk" were not an issue before the United
States Supreme Court. It was assumed. but not directly held by the Court. that they wcrc
valid.i The issue is whether and when "plain teel" would alIO\\ ollicers to legally seize
items other than suspected weapons.
The Court held as follows: assuming that there is a legal stop and a legal frisk.
and during the frisk the orticer feels an item that is not a suspected weapon. then if it is
immediately apparent from the mass and contour that the item is probably contraband. the.
ollicer can legally seize it (without haying to arrest the person and rely on search incident
to arrcst).
In Dickerson. the Court ruled that the rock cocaine v\ould have to be suppressed.
because the officer continued feeling and frisking attcr the officer already concluded no
weapon was in the pocket - i.e .. plain feel means immediately apparent.
In U.S. v. Proctor. 148 F.Jd 39 (1st Cir. 1995i police had lawfully entered a
premises and seized a large package of marijuana. About 15 minutes later. Two persons
knocked on the door and wcre admitted entty. The onicer patted them down and felt
what he thought was a plastic bag cOlllaining marijuDnil. The Court uphdd the ti'isk and
also the sei~ing of the marijuana based on tbe otlker's experience and the fact that the
persons entered a drug house just after the drugs anivcd.
In State Y. Conners. 116 ~e\. ___ . 994 P2d 44 (Feb 4. 2000) an oftlcel' la\\ fully
stopped and frisked Satan Renee Conners. After ruling out a weapon the officer changed
his grip on a pocket to determine what an object was and removed a small \ ial of
methamphetamine. The item was suppressed based upon the Dickerson rUling.
Westlaw computer research discloses thal many j~deral cOllns have followed the
56
rule estahlished by Minnesota v. Dickerson and that 1110re than 90% of State Supreme
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Courts which have dealt with the issue have adopted the same rule.
(7) WHAT LlMITS EXIST ON THT' SCOPE AND INTF\SITY OF
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2d
THE STOP')
The General Rule
In U.S. v. Sharpe. 105 S.Ct. 1568 (1985). a DEc\ agent de\dopcd reasonable
suspicion that olle of two \'chicles traveling in tandem on a highway \\a, smuggling
drugs. The agent gO! help frolll a state trooper and a passenger car W'lS plllled mer. The
pickup tl1lek suspected to contain the dl1lgs could not be pulled over for several miles.
The police units lost radio contact and the pickup truck and its drivcr \\crc detained aboLlt
15 minutes beloIc an agent arrived. smelled marijuana and developed probahle cause.
The criminal claimed that this time delay converted the "stop" into an "anest" and since
there was only reasonable suspicion and not probable cause. he claimed there was an
unlawful arrest. The Court held: no arre"t until after the sniff of marijuana - scope of
Terry stop was OK. The (ouli said a Terry stop was a temporary detention (as opposed
to an arrest) and that the scope was lawful as long as the police diligently pursued a
means of investigation that was likely to confirm or dispel their suspicions quickly.
NOTE: In Sokolow, the United States Supreme Court held thai the investigative means
used by police to conlirm or dispel suspicion do not have to be the least intrusive means
possible - only that they be "reasonable" means.
\J .S. v. Owens. 167 FJd 739 (I SI (ir 1999)50 minute detention of driver and passenger
after stop of automobile for speeding was not so long as 10 com'eli ilwestigative stop into
de facto anest. Length of detention was reasonable under the circumstances: driver did
not have valid dri\ er's license. need 10 determine II hether passenger had authority to
drive the automobile. and of/ieers' diligenl pursuit or means or investigation that mlUld
dispel their "uspicions.
"The permissible scope of the detention depends on the facts and circumstances of
each case, but in every case il must be lemporary anJ lasl no longer than necessary to
effectuate the purpose of the stop:' L.S. v. Sandoval. 29 F.3d 537 ( 10th Cir.1(94).
This rule is the same as set forth in Nevada Law. But. note that Nevada places an
absolute limit of 60 minutes lor a Terry stop. Sec also Washington v. State. 94 Ncv. 18 I
(I 97X).
N.R,S. 17 1.1231. Arrest if probable cause appears. At any time after the onset
of the dckntion pursuant to N RS 171.123. the person so ddain.:d shall be arrested if
probable cause for an arrest appears. It: aftcr inquiry into the circumstances which
prompted the detention. no probable cause Ill[ an'cst appears. such person shall be
released.
fL in the course of the detention. further intormation comes 10 the ~110\\ ledge of
57
the officer which amounts to"P/C" to anest (i.e .. more facts than needed for reasonable
suspicion). then you can arres!. In report writing. be surc to differentiate initial stop U'i
investigatory detention and when and ho\\' it escalated into an arres!.
NOll-Search Examination
In liS \. Martin. 806 F.2d 204 (8th Cif. 1(86). \\here an oflicer looked throul!h
the window of a suspect's pickup truck and saw nwchine gun parts -- he could ~,cize them
witiwut warrant. or in Texas v. Brown. 460 U.S. 73fJ (1983). "here police shined a
tlashlight into a person's car which was stopped at a routine tranic check point and sa\\
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white powder and balloons,

This rule was applied in State v, Herbert Wright, 104 Ne\', 521 (1988'),
Temporary Seizure of Items
Reasonable suspicion can support a temporary sci/life (without a search) of
personal items such as the suspect's suitcase in U, S, v, Place, 462 U,S, 696 (1983)
(although in Place, the 90-minute detcntion of the suitcase was too long for an
investigative seizufe with RIS, but without probable cause),
An onicer's removal of a suitca-;e Irom a baggage area convevor bell. squeezing
the bag and then sni11ing the bag ",as neithc;; s~arch nor a s~i7.Ure, U,S, v, Garcia, 42
FJd 604 (10th Cir. 1994) "The temporary moving oi'unattendcd luggagc from one area or
a bus to another to facilitate a dog snitTis not a seizurc."U.S. v. Graham. 9R2 f.2d 273
(8th Cir. 1992) "The defendant's-only interest was that the airline would place his luggage
on the next airplane, The police process of taking the luggage from a cart to an olrice
and having the dog snilTit \\as completed prior to the time the luggage would ha\'c been
placed on the airline. There was no scilllre of the luggage until after the dog alerted,"
U,S, v. Furukawa, 99 FJd 1147 (9th CiL1996) Same resuh in U,S, \, Ward, 144 FJd
1044 (7th Cir. 1998).
Conducting a one-on-one at the sccne or elsewherc,
NOlI::,: NRS 171.123 says in Nevada the "one on one" must be at place \vhere
suspect detained,
Although no emergency exception is listed in "evada statutes. probably it would
be OK to transport the suspect (assuming RIS) to the victim ifthc victim couldn't be
transported,
A 39-minutc detention of2 sexual assault suspects. including transp0l1ation to a
hospital to be viewed hy the victim, was valid where based on R!S, At least 25 minutes of
the detention was due to completion of the victim's treatment at the hospital before
viewing thc suspects, Police were acting diligently to pursue a means ofimcstigation,
namely. display of the defendants to the victim \vhile her memory was still fresh. which
was likely to confirm or dispel their suspidon quick I) . and this means of investigation
58
obviously required the reasonable detention orthe defendants." State
A.2d 1017. Conn.1986),
y,
Mitchell. 507
(8) USE OF \VEAPO:--;S OR HAN[)CUFFS IN OETE:\[ IO~
Numerous cases have held that display or weapon or handcufting suspect does not
in and ofitsdfconvert a "ddcntion" into an "arrest" (although these things knd to push
in the direction or arrest-see "levels or contact" factors) hut vou must be able to
m-ticulatc whv these means were cmploy~d (things sllch as suspicion directed at crime of
violence. detection occurred at night. isolated area. otlicer alone, risk oftlight).
Hanucuffs okay, lJ. S, v. Bautista. 684 F.2d 1286 (9th Cir, 1982), Smnc result in U.S, \,
Blackman. 66 F.3d 1572 (11th Cir. 1995) and also in LS, v. Tilmon. 19 F.3d 1221 (7th
Cir. 1994)
Placing suspect in police car did not cqual an arresl. Swte '., Braxton . .195 A2d
273 (1985), Same result in U.S. v. Cannon, 29 FJd 472 (9th Cir. 1994),
In U, S, \. Merritt. 695 F.2d 1263 (10th Cir, 1(82). the Court held that pointing a
gun at a suspect stopped on a reasonahle suspicion of criminal activity docs not
necessarily tum the encountcr into an arrest requiring probable cause. A pickup truck
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believed to contain <llllurder fugitive and 2 other persons \vas surrounded b} at least 12
otlicers. and as many as three pointed guns at the suspects.
ll,is show ofl,)rce was not unreasonable. considering the potential danger faced
by the officers. One of tile persons beliewd to be in the truck was wanted I"r murder.
and the police had been advised that he was dangerous and heavily arlllcd. Also. the
police had just been to a house \\hcrc the suspect was thought to reside. and observed a
large assortment of deadly \\'eapons and ammunition. The same circulllstances supp0l1cd
a "frisk" of the pickup truck for weapons.
Merritt has becn tollo\'.ed in nUI1l.:rous other cases: U. S. v. Hardnett. 804 F.2d
353 (6th Cir. I(80)(C/I said 4 armcd men were in car): U. S. v. Roper. 702 F.2d 984
(11th Cir. 1983) (bail jumper): U. S. \'. rerate. 719 F.2d 706 (4th Cir. 1983); U. S. v.
Jones. 759 F.2d 633 (8th Cir. 1985); l;. S. y. Trullo. 809 F.2d lOS (1st Cir. 1987). U.S. ,.
Alvarez. 899 F.2d 833 (9th Cir. I99()) (possible bank robbery and explosives); U.S. v.
Taylor. 857 F.2d 210 (4th Cir. 1988) (RIS stop and police knew person had been
convicted for assault with 1I1tcnt to murder and robbery); li.s. v. Ti Imon. 19 FJd 1121
(7th Cir. 1(94) (RiS stop or bank robber who thrcatened Lise of' explosives: U.S. v. Calc.
70 FJd 113 (4th Cir. 1995) (police suspected car occupants had a large amount of drugs
and might be armed).
In Houston v. Clark Count\'. 174 FJd 809 (6th Cir. 1999) the Coun held that it
was valid for Ihe o11icer. after a RIS stop w handcuff a suspect in a serious violent crime,
but the length and manner of the officer's conduct must be related to the initial basis for
the stop: Samc ruling in l'.S. v. Campbell. 17& FJd 345 (5th Cir. 1(99) valid tor officer
(wi th RIS for the stop) to draw gun and handcuff the suspect who was in a car with the
license numher ofa recent armed robbery.
In U.S. v. NavarreteBaron. 192 F.3d 786 (8th Cir. 1999) the Court held that
59
police ofi1cers did not exceed scope of Terry stop when th~) handcuffed occupants of
automobile and placed them in separate patrol cars while oilicers searched automobile:
there were two suspects and only two officers at scene, detention did nOllast for
unreasonably long lime. and in light of dangerous nature of suspeclCd crime or drug
trafficking and good possibility thar driver or passenger had weapon. their contlncmcnt
with handcuffs in back of patrol cars during search was reasonably necessary to maintain
status quo. protect officers. and allow them to conduct search immediately and without
interference.
In U.S. v. MazaCorrales. 183 F.3d 1116 (9th Cir. 1999) Drug enforcement
agents' temporarily detaining dcfendalll with the use ofhandcuff.~ for 15 to 30 minutes
while questioning him. \\a5 reasonable and did not escalate into a rullblown arrest. given
relatively small number of officers present at scene. fact that weapons had been found
and more weapons potentially remained hiddetl. Ilccing persons were on the loose.
uncooperative persons were insidc the residence. an armed lookout \\a5 outside and blew
a car horn \\ hen 0 EA came.
The COUI1 held that "intrusi\e and aggressi\'e police conduct will not be deemed
an aITest in those circumstances when it is a reasonabk response 10 legitimate safety
concerns on the pal1 of the investigating olliccrs. When we make such judgmenls,
common sense and ordinary human experience rather than bright line rules sen'c as our
guide. and wc recognize that "we allow intrusive and aggressive police conduct without
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deeming it an arrest in those circumstances when it is a reasonable response to legitimate

safety concerns on the paI1 of the inyesrigmillg oflicers."
See same case in "protective sweep" section immediately following
(9) EXTENDING THE FRISK TO A RESIDENCE
[t should be noted that all COU!1S hold that a person's home bas an extremely high
expectation of privacy and warrantkss entries are viewed dimly. (Sec t()!lowing sections
on emergency and search warrants.) However, in some limited circumstances a
"protective sweep" 01' a premises can be made on reasonable sllspicion.
In Maryland v. Buie. I to S.C!. 1093 (199(). the court allowed police to make a
protective sweep of a residence alier lawful entry with an arrest warrant as long as there
was reasonable suspicion of danger to police to justify the protectiw sweep. Items in
plain view during the protective sweep could be seized. This autl10rity is in addition to
the right to conduct Q tilll search of area immediately adjoining area of arrest. (SIT A).
U. S. v. lIoyos, 868 F.2d II) 1 (9th Cir. 1989). In this case Iloyos attempted to
escape arrest by entering the house. Also. the onieers were aware that several suspccts
had not yet been arrested and could possibly he in the area of the residence.
The Court ruled that thc protective s\veep exception to the requirement of a search
warrant 10 enter a residence may apply if the arrest occurs outside. "This is not surprising
because the distinction is logically unsound. If the exigencies to SUpp0l1 a protective
swcep exist, whether the arrest occurred inside or outside the residence does not affect
60
the reasonableness of the orticer's conduct. J\ bullet Jired at an arresting officer standing
outside a window is as deadly as one that is projected from one rool11."
lj.S. v. Hem), 48 F.3d 1282 mc Cir. 19(5) Police acted reasonably in
conducting protective sweep of defendant's apartment alicr his arrest just outside
apartment's open door. where police infnnllant had previously advised l\lliccrs that
defcndant v,ould have weapons and that defendant's "boys" might be "'ith him in
apartment: sweep did not violate defendant's Fout1h Amcndmem lights.
'The officers' awareness that Henry had a previous weapons conviction and could
be dangerous did not itsell'tIirectly justify the sweep. Once Henry was in custody, he no
longer posed a threat to the poliCe. But the infonnant's advice coupled with the arrest just
outside the op~n door. was sufficient to lead a rea~onably prudent policeman to fear that
hc was vulnerable to attack.
While it is true that the officers could not be certain that a threat existed inside the
apartment, this does not impugn the reasonableness of their taking protcctive action. It is
enough that they "hayc a reasonable basis for believing that their search will reduce the
danger of harm .... "
In U.S. v. Meza-Corralcs. supra, the Court held that U.S. Drug Enforcement
agents had justification to conduct their initial protective sweep (a search warrant had not
yet been obtained) of defendant's residence to ensure that no potcntially dangcrous
persons were hiding inside residence. (See facts of case)
'Mc/.3-Corralcss argument that Bridges's soundin(! orthe horn of the Blazer. the
discovery of loaded handguns. and th';: sighting of fleeing people. all had absolutely no
connection with what was going on inside the residence and with the people who lived
there. simply because they all physically occurred outside the residence, is patently
ridinJ!olls ...
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In Hayes v. State. 106 Ncv. 543 (1900). police arreskd sllspect outside of his
residence. Suspect shouted l<J inside of house "the cops are here" and police had some
reason (Ii'om 01) to believe the arrestee had guns around. The co un said the protective
,\\eep (which discovered dope in plain view) was unlawful since in the court's opinion
the police could have withdrawn with the suspect who was arrested for a non-violent
felony. The court did recognize and agree with the Maryland ,'. Buie concept but helu
that the facts in I layes were not sufficient to allow such a sweep. This was a split uccisioll
by the Court.
In U.S. v. Burrows. 48 L3d 1101 (7th Cir. 1995) police had an arrest \\arrantlor
Burrows who lived in a housing project having an established reputation I'or violence.
The arrest warrant was lor a violent crimc . When police arrived at his apartment. they
saw movement in an upstairs window and the occupants refused to let thc police enter.
Police entered with a pass key from the manager and found and arrested RUITOWS in one
room Then, because there were other occupants and the: previou,ly stated circumstances.
the police did a protecti"e sweep in less than 5 minutes. during which they found a gun in
a closet. The Court upheld the protective s",eep undl'[ these facts.
61
Other cases also upheld protectiw sweeps
U. S. v. Richards, 937 F.2d 1287. 1291 (7[h Cir.1991 ) (noting that an "am hush 111
a contined setting of unknown configuration is more to be feared than it is in open, more
fami liar surroundi ngs ").
lJ, S. 1' . .lames. 40 FJd 850 (7th Cir. 1')94) (finding no 4th Amendment violation
where officer quickly scnrched bedroom closet and jacket located therein. Officers had
~ncountcred multiple individuals in the dwelling. arrested one suspect just outside the
bedroom. unJ had found a semiautomatic rine in the bedroom.)
U. S. \. Barker. 27 F.3d 1287 (7th Cir. I(94) I-leld ol1icer had reasonable belief
that area swept harbored dangerous indi\'iduals because a second olliccr's prior dealings
with delendant indicated that tireanns and multiple individuals could be present.
lJ. S. v. Mendoza-Burciaga, 981 1'.2d 192 (5th Cir.1992) noting that otlicers.
who had arrested two narcotics coconspirators in high-speed chase and t\\O more just
outside a house, "would be in great danger" if additional armed indiviuuals remained
inside the home, and finding that oftlcc:rs' warrantless entry and protective sweep
constituted "minimally necessar:- steps to secure the house" for purpose, of ensuring
sa let) and safeguarding evidence.
U. S. v. Kimmons, 965 F.2d 100 I(11 th Cir.1992) Ok'd S\\CCr in case involving
bank robbery consJliracy where t"o p3I1icipants were arrested away li'om the premiscs
and had ordered defendant out of his house and arrested him. but were unsure of the
whereabouts of a fourth coconspirator.
(10) WHERE IS 1'1 IE 1.1l\E HI:1WLFN A "ST(W A,\D A\:
"ARREST')"
1. In Hayes\'. Florida, 470 U.S. 81 1 (1985) the U.S. Supreme Court said that
although there is no "bright linc rule" to answer this question. at some point in the
investigation police procedures can becomc so qualitatively and quantitati\ely intrusive
regarding a suspect's freedom ofmo\cm~1ll and privac) that an "arrest" occurs. The
Court said this occurs when the police. without PiC or a warrant. forcibly require a
person to go to a police station where he is detained even briefly Ilx investigation.
- c" -
11
16
2b
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/8
helieved to contain a lllurder fugitive and 2 other persons was surrounded by at least 12
oftlcers. and as many as three pointed guns at the suspectS.
This show of force was not unreasonahle. considering the potential danger faced
by the ofl1cers. One of the persons believed to he in the truck was wanted for murder.
and the police had been advised that he was dangerous and heavily armed. Also. the
pulice hadjllst been to a house v.herc the suspect \\as thought to reside. and observed a
large assortment of deadly weapons and ammunition. The same circumstances supported
a "frisk" oftlw pickUp truck for weapon'>.
Merrill has been rollowed in numerous othcr cases: U. S. v. ! !ardnctt. R04 F.ld
353 (6th Cif. 1(86)( C/l said 4 armed men were in car); l}. S. \'. Roper. 702 F.ld 984
(11th Cil'. 1983) (bailjumpcr); U. S. v. Perak, 719 F.2d 706 (4th Cil'. 19H3); U. S. v.
Jones, 759 F.2d 633 (8th Cir. 1985): l,'. S. Y. Trullo. 809 F.Ld 108 (1st Cir. 1987). U.S. y
Alvarez. 899 F.ld 833 (9th Cif. 1990) (possible hunk rohhery and explosives); U.S. v.
Taylor. 857 F.2d 210 (4th Cir. 1988) (RIS stop and police knew person had been
convicted for assault "ilh intent to murder and robber): U.S. v. Tilmon_ 19 FJd 1221
(7th Cir. 1994) (RIS stop of bank robber who threatened use of explosives; U.S. v. Cole.
70 F.3d 113 (4th eir. 1995) (police suspected car occupants had a large amount of drugs
and might be armed).
In Houston \'. Clark County. 174 F.3d 809 (6th Cil'. 1999) the Coul1 held that it
was valid for the officer. uncI' a RlS stop to handeufT a suspect in a seriolls violent cnme.
but the length and manner of the officer's conduct must be related 10 the initial basis tor
the stop; Same ruling in L S. v. Campbell, 178 F.3d 345 (5th Cir. 1(99) valid for officer
(with RfS for the ,top) to draw gun and handcul'fthc suspect who V.:lS in a car with the
license number of a recent armed robbery.
In U.S. v. Navarrete-Baron_ 192 F..ld 786 (8[h eir. ]9(9) the Court held that
59
police officers did not exceed scope of Terry srop when the\ handcul1ed occupants ofautomobile and placed them in separate patrol cars while ofllccrs searched automobile;
there were two suspects and only two officers at scenc. detent inn did not last i()r
unreasonably long time. and in light of dangerous nature of suspected crime of drug
tra(ficking and good possibility that driver or passenger had weapon_ their confinement
with handcuffs in back of patrol cars during search was reasonably necessary to maintain
status quo_ protect officers, and allow them to conduct search immediately and without
interference.
In U.S. v. Maza-Corrales. 183 FJd 1116 (9th Cil'. IlJ99) Drug enforcement
agents' temporarily detaining ddendant with the use of handcuffs for 15 to 30 minutes
while questioning him. \\as reusonahlc amI did not escalate into a full-blown arrest. given
relatively small number of officers present at scene. fact that weapons had been fClUnd
and more weapons potentially remained hidden. fleeing persons were on the loose,
uncooperatiw persons were inside the rcsidenee. an armed lookout was outside and hlew
a car horn when DEA came.
The Court held that "intrusive and aggressive police conduct \\ ill not be deemed
an arrest III those cIrcumstances \,'hen it is a reasonable response to legitimate saiet\'
concerns on the part urthe investigating onicers. When we make such iudgments ..
co~nl11on sense and ordinary human experience rather than hrigbt-linc r'uk; serve as Ollr
gllloe. and wc recognize that '\w al1o" intrusive and aggressive police conduct without
- 24 -
under arrest". Factors such as sho\\' of authority. involuntary restrai nt or movement and
passage of time arc important.
Dunaway v. New York. 442 L .S. 200 (1979). police lacked probahle cause to
arreSl -- went to suspect's neighbor's home and asked him in a compulsive \\ay In go to
police station where he was placed in inh:rrogation room -- \\"asn'l told he "as Iree to go - the trip Ii-om the residence to the police station was several miles and took I hour-Held -- although he wasn'llOld he was under arrest and wasn't booked -- this was same as
an "arrest". because the police told him hc needed to go to the police stalion. he
acquiesced. and the trip took an hour and went many miles lrom his residence. His
subsequent confession to a crime \\as suppressed as a "fruit" of the "arrest" without
probable cause.
Florida v. Royer. 460 L.S. 491 (19B3). police slrspectcd ddendant as drug
courier. approached and asked to speak to him and requested to ,ee his tickel and driver';;
license--notcd lhal names didn't match -- asked him to go to nearby room while retaining
his ticket and license. Held -- this constituted a ";;cizure" 15 minutes afier initial :;top he
consented to search of suitcase. Court ruled that this police conduct clTectiveJ~
constituted an "arrest" and requin:d probable cause. Since there \\as no I'.'c. (although
there was RS) the illegal "arrest tainted the consent.
3. NEVADA CASES
Prohable cause to make a \\arrantless arrest exists if the facls and
circllmstances known tllthc officers at the moment of the arrest would warrant a prudent
64
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man in believing that a felony had been committed by the person arrested. Thomas v.
Sheriff, 85 Nev. 551 (1960).
The "probable cause" test is based on the totalitv of the circumstances
known to the officer. Minor v. Statc. 91 Nev. 456 (1975).
4. STANDARD FOR PROBABLE CAUSE
Basically, thc same standard (quantit) of proof) is needed for arrests as for
searches. so the Illinois v. (jates. 462lJ.S. 213 (1983). total it} of the circumstances test
applies - i.e.: a fair probability. but not Ill'cessarily a certainly.
In U.S. v. Ornelas. 116 S. Ct. 1657 (1996) The Court ruled: Articulating
prccisely what "reasonable suspicion" and "probable cause" mean is not possible. The}
are common sense. n011lcchnical conceptions that deal with" 'the factual and practical
considerations l)f cveryday life on which reasonable and prudent men. not legal
technicians. act.' " As such. the standards arc "not readih. or even usefullv. reduced to a
neat sct of legal rules.". \Ve have described reasonable s'uspicion simply ~s "a
particularized and objective basis" f()r suspecting the per,oll stopped of criminal activilY,
and probable cause to search as exislin~ where the kmmn facts and circumstances arc
sufficient to warrant a man of reasonable prudence in the belief that contraband or
evidence ofa crime \',ill bl' found. We have cautioned that these two legal principles arc
not "finely-luned standards." comparable to the standards of proof hc)"ond a reasonable
doubt or of proof by a prepondcrance of the evidence.
ln [;.S. v. Covarruhias. 65 F.3d 1362 (Jth ('ir.1995) the COlirt held that "Police
have piC to arrest if at the moment of the arrest the facts and circumstances within their
knowledge of "hich lhe\ had reasonablv trustworthy information were sufficient to
warrant a prudent perso~ in believing th~t the su;;pe~t had committed an ofTense. While
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PIC requires more thal1l11ere suspicion. we do not require it to reach the level ofvil1lJaI
certai nty:'
In Brinegar v. L .S .. 338 U.S. 160 ( 1(49) the Court held. "PiC requires Jess than
(the ,Ul1ount (1) evidence that w'ould .iustil~ a convietion hut more than mere suspicinn."
and in Spinelli v. U.S .. ~9:l II.S. 410 (1909) the Cour! held that "onl: thc probability and
not a prima facie sh,)\\'ing of criminal acti\ it: is the standard of PiC." Also. in licrstein
\'. Pugh. 420 U.S. 103 (1975). in ruling on a magiS1l'atc's determination of PiC alia a
warrantless arrest. tbe Court held that "a PIC determination does no! require the line
resolution of cont1ictinl! evidence that a reasonahle douht or preponderance (marc than
50% probability) demands"
In Greene v. Reeves. 830 F.3d 1101 (6th Cil'. 1996) police an'esteu the parents for
promoting sexual performances hy a minor based on their sending of a postcard with a
photograph of the genital area ofth~ir unclothed minor daughter. The Coun upheld the
arrcst stating that. >. the PIC standard docs not mean that the ( cvidence of tlK suspected
criminal act) is more likely than not.'
65
In U.S. v. Mathnay. 895 F.2d 1418 (9th Cir. 1'<)90) "The test for probahle cause is
"hether the facts and circumstances \\ ithin the arresting otlicer's knowledge arc
surticient to warrant a prudent person to belicve a suspect has committed. is committing.
or is about to commit a crime." i\ court may consider hoth the c'(pericnce and collective
knowledge of all officers involved in the im-cstigation and their respective levels of
expertise .. A court may also consider any r~asonable inferences drawn 11'0111 the oI"iicers'
collective knowledge.
In ll.S. v. Ocampo. 437 F.2d 485 (9th Cir. 1991) the Court held thm"PiC
evaluation depends 011 the lotality orthe facl'; (of the casel evcl1 though there is an
inl10cent explanation for each facl."
Note: In Terry v. Ohio, 392 U.S. I (1968) the police detective \\ ith morc than ~o
years experience saw Terry and his partners walk from a street corner to look in the front
window of a jewelry store without entering to shop about a dozen times in tweIve
minutes. Even though this action was (superiicially) innocent, the Supreme COUl1 agreed
that under all the circumstances there wa;, RIS that they \Vcre casing the store for an
amled robbery.
Although Terry involved RIS. Ocampo and Ilumerous oth~r case, hold that
"obvious criminal" behavior (pointing a gun at a victim)is not required ttlr PiC.
5. SOURCES OF PROBABI.E CAl.:SE
Rd iable Contidential Intclrnlum
Sec the section in this manual on search warrants to learn factors that make an infonnant reliable.
r'vlcCr3y v. Illinois. 386 C.S. 300 (1967). A strong prO\'cn reliable informant with
tirst-hand information is enough for probable cause. "The Court has never required a rule
of compulsory disclosure of an inform am where the issue is the preliminary one of
probable cause. and guilt or innocence is not at stake" [v'en an infOlmum of lesser
reliability can be enough if the informant predicts future actions and details. Draper v.
United States. 358 U.S. 307 (1959)
Inl!. S. v. Fixen. no F.2d 1434.( 9th Cir .. lC)86). the Coun held the arrcst was
lawltd and based on PIC. "Thc inforiller. enlisted b: the pohce. mc\ ,,ith the del'cndant to
arrange delivery of some cocain~: he then told police thatthc source of ,uppl: \\as a
Latin male hom Los Angdes. '1 he defendant was surveilled traveling to Los Angdes
where. in a series of moves apparently designed to dis(,'ourage detection. he appeared to
obtain a brown paper bag tj'Olll a Latin male. Upon his arrest. cocatne was found in the
bag." Although verificmion oft~lct' li'tllllti1e inf(lrmds story \Vas largely oj"innocent"
behavior. credibility \vas enhanced by the aecurac: and detail of the infomlation given.
(ienerally. police/D/\ arc not required to di>cl(lse inl(lI'lllant's idcntity
Defendants always want to know the identity of an informant for obviolls reasons
66
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12
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such as threats to make the intormant chanl!e his ston or to lic about information given to
police. and sometimes more drastic rncan,.'Thc follo~'ing cases e~plain the view 01'
federal COUl1, on the issue of inlonnant disclosure.
[n U.S. v. Fixcn (supra) The trial court refused identilying the Ul and the 9th
Circuit upheld that ruling. "A proper balance depends on the particular circumstances of
each case. consideration of crime charged. po,sible defelbes. possible significance of the
informcr's testimony. and Olher relevant iilctors."
Although the infonner's pri\ ilege must gIve way where the disclosure of the
informant's identity "is rdevunt and hdpful to the defense of an accused. or is essential to
a fair determination of a cause." the burdcn is on the defcndant to demonstrate tht.: need
lor the disclosure.
A trial coun need not require disclosing the identil~ ora rdiable inl()ft11311l where
the sole ground for seeking that information is to eSlablish the existence of probable
cause lor arre,t, rixcn's request I\)r disclo,urc expresses his concern there may not have
been an informant or that police lied as to the inl(lnnation related to them. An in camera
hearing (without presence ofdel'cndant or his lawyer) could have served to allay these
lears:
Through disclosure ofthc inl(.lrlner's identity to the trial judge, and such
subsequent inquiries by the judge as ma: be necessary. the (im crnment can be protected
from any signilicant. unnecessary impairment ofsecreey. yctthe deCendant can be saved
Irom what could be serious police misconduct.
Nonetheless. a district court need not conduct an in camera hearing \.\ heneyer the
identity of an intormant is requested.
In U.S. v. Gordon, 173 r.3d 761 (10th Cir. 1999) the coun held that a ckl't:ndant
seeking to force disclosur~ of an illl()I'll1ant's identity ha, the burden to show the
,
informant's testimony is rele\3nt or essential to the fair determination of defendant's casco
"""here it is clear that the inl\)fJl1ant cannot aid the delen,e. the go\cmmel1l" interest in
keeping senel the inf(Jrmant's identity must prevail Dyer the defendant';, asserted right or
disclosure."
The inf()rmant's role in Gordon's arrest was extremely limited. He did not detain
(Jordon, and dId not participate in or witness Gordon's detention or the transaction in
which Gordon purportedly agreed to transpc)rt cocaine in exchange for money. \Ve have
refused disclosure in similar cases where the infolll1ant hus limited information, was not
present duri I1g commission of the onensc, and cannot proY'ide .my evidence that is not
cumulative or exculpatory.
In U.S. v. Ilickman. 151 F.Jd 446 (5th Cir. 1998) (Reversed on other grollnds in
179 !'.3d 230 (5th Cir. 199R). the COllrt held thm it was I1Lltnecessary to lllsclose the
identity oj' an inlorl11ant."This circuit has craned a three-pan test to detemline whcther
;:
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disclosure of a (Clrs) idcntitv is necessarY. We examine: I) the informant's del!ree of

, .
involvement in the crime:~) the hcJpfulnc" of the disci(lsllre 10 the delens,;: and 3) the
Government's interest in non disclosure. /\5 to the first prong.. \\c have held that mere
"tipsters" are not so ciosci) related to a crime as to require the disclosure of their identity.
~
67
)2
27
In U.S. v. Mangum. 100 L3d 164 (DC Cir. 1996) Mangum argued that he
needed to interview the (C/I) in order to determine whether the C/lillight haw planted
the gun in the knapsack ill order to help secure an arrest and curry hn or with the
government. He never cited an) specific tacts supporting his motion to disclose the
identity of the informant. hut merely wantcd to interview the ((:il) because the (C/I)
might possess inj(Jfmation that could exculpate him.
The court found that the defendant was not entitled to know the (O!"s) identity
"because there is no evidence in the record supporting the Dctendant's speculation that
the (etl) actively participated in the offense." He failed \0 meet his burden by "showing
that the informant's testimollY is necessar: to his deli:n,>e S,) as to justii:, placing the
informant's ,>afety in jeopardy."
"Mere speculation that the (el) may possibly be of some assistance is insufticient
to meet this burden. To overcome the public interest in rrotcction'ofthe (CIl)." the
defendant must sho\\ that the (CI) was "an actual participant in or a \,itness to the
oftense charged." and identity is "necessar) to the defense."
U.S. v. Fields. 113 F.3d 31:; (2d Cir. 1997) Government i, not generallv required
to disclose the identity of (CI s). Ib interest in protecting anonymity of (C/I' s) who
I'urnish illiorm<ltion regarding violations of law is strong- withholding a (urs) identity
improves the chance, that the person w ill continue prO\iding intotlnation and encourages
potential (CTs) to aid the government.
The defendant bears the burden of showing the need for disclosure of a (e l ]' s)
identity. and must establish that. absent ,uch disclosure, he will be deprived of his right to
a fair trial.
Even if. as the defendants claim. the in)(mnant's inlofm3tion was uncorroborated
and constituted the bulk of the probable cause upon which the police relied. the district
COUlt's in camera interview ofthc (01), conducted \Iith a view to matters dclcnsccounsel
identified in writing as potential I} relevant. adequately protccted defendants' rights. An in
camcra intcrvic>\ ofa (ClI)that tlnds no (suhstantial) inconsistency with police testimony
can mitigate any concern that the (CTs) testimony would in fact be useful to the defense
U.S. v. Kimc. 99 F.3d 870 (gth Cir. 1996). Kimc argues that the disclosure of
crs identity wa, necessary to test the ,cracity of his or hcr information and the quantum
of probable cause behind the aftldavit oft;;rcd in SLiPPOlt of the appl ication for the
interception of \\ ire and oral communicatiolls. But Kime oners no basis other than bald
speculation for his assertion that such a disclosure and an opportunity to interview CI-I
would allow him to impeach Cl-I', affida\it kstillllHl). The mO\ ant'> burden" requires
more than mere speculation that the testimony of the iniormant might prove to bc helpful
to the defense."
Infc)rmation trom Victim or Witness
Gates. held that citizcn-inftlrlllant is presumed reliabk unlike a criminal CI
In I:aston Ii. City of Boulder Colorado. 776 F.2d 1441 ( 10th Cir 19H5)
The COUll held that "when examining informant evidence used to support claim of
68
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,-
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probable cause for "arnmt It)r arrest. or warrantless arrest. skcpticiwl and careful
scrutiny w>ually found in cases involving informant:;. sometimes anonymolls. ti'om
criminal milieu. is appropriately relawd irinformant is identified victim or ordinary
citi,cn witness.
lkcause citizen witnesses arc prcsumptivdy reliahle. the orncers in this ,;ituation
had no duty to examine tlll1her the basis of the \\itness' knowledge or talk with any other
witnesses. The proposilJoll that private citilen "imesses or crime \ ictims are pre'l1l11ed
reliabk docs not "dispense \\ ith the rc,!uirement that the iuformant ... tiJrnish underlying
facts sutlicicntly detailed 10 cause a reasonable person 10 believe a crime had heen
committed and the named suspect was the perpetrator." (Just as police need to state facts
learned by them tojustify R!S or P'C)
US v. Butler. 74 F3d 916 (9th CiL1996) Court held "you look at the totality or
the circumstance, to ddermine PIC "P!C can he hased on heat'sa) ... or on information
relayed through oniciai police channels ... and through thc collective knowledge of police
officers involved in an investigation even ifsome of this inltlnnation was not known by
the arresting ollieer (and) if an unquestionably honc,t wizen comes forward with a
report of criminal activity which if fabricated would <;ubject him to crilllinalliability we
have found rigorous scrutiny of the basis or knO\\ ledge unnecessary.'Tang\\ all v. Stuckey, 135 F.3d 510 (7th Cit'. 1998) Court hdd that "\Vhcn an
olliecr received his ini(lrInation from some person--normally th~ putative victim or eye
witncss--wl!o it secms reasonable to believe is telling the truth: he has(PiC)," No deepseatcd
logic or rationale underlies this principk. (PIC) is a common sense detcrnlination.
measured under a reasonablencss standard.
Sharrar 1'. relsing. 128 fJJ 810 (3rd Cir. 19(7) Court held that "ben irthe
ofticcr heard the victim' s claim that another person attacked her it \\as reasonahle for the
oniccr to a<;sess her dellleanor. tind her story credible. and rely on her subsequent
identification orher husband as the attacker. When an otftccr has received a reliable ID
hya victim of his or her attacker. the police ha\'e PIC to arrest, Same ruling Lee v.
Sandberg, 136 FJd 94 (2d Cir. 1'197).
Official Channels
Whitley v. Warden. 401 U.S. 560 (1971) (Fellow officer rule). An of1icer who
does not personally possess sufficient inf(mnation to constilute rronablc causc may
nevertheless make a valid ancst if he acts upon the direclion or as a result of a
communication from a fellow ofliccr and the police. as a ,,hole. possess sufficient
information to constitute probahle cause, People v. Freeman. 6681'.2d 1371 (Colo.
1983 ).
In Dolcman \', State. 107 l\ev. 409 ( 1991). police arrested a murder suspect based
on information from an int(mnant and citizen witness (jae!S arc somewhat complicated).
Even though the arresting officer may not have been aware or each and everV' fact
included in the probable cause. colle~tivelv he and the other (lfticcrs il1\'olv~d in the
investigation did possess probable cause a;ld this made the arrest valJd. This decision
69
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I!xknds the" fellow ofliccr" rule to its Jhlll's!.

Personal Oh,ervations by police
This is the most common ingredient ofprobablc cause - \\hut >ou sec. hear. smell.
,
1
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!1
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teel Dr taste m<lj giw pwbable calise hv itself or as corroboration of information rcceived
from inlnrmant.
Di,crepancy between infimnation recci\cd and suspect conti'onted
This docs not automatically mean that there is no prohahle cause Some
discrepancies normal due to human nature. Brown \'. U. S.. 365 F.2d 976 (D.C. Cir.
19(6). where policc had dcscriptillD of robber as black male. driving maroon 1954 Ford
and about a mile away. minutes later. police ,av. car which was 1952 Jllaroon ford and
had occupant with different clothing and height was 6" ofT -- lIeld: probable cause
existed. despite the discrepancy to stClP the car and aITcst occupant.
U.S. v. Tilmon. 19 FJd In 1 (7th Cir.1(94) Polit'e had PiC 10 anest Tilmon for
bank robbery once he stepped Clut of car and olliecrs could compare him \\ith description
of rohher. due to fact that police already identified his distincti\'ely marked car; although
defendant \\ore different clothes fWIl1those described by robber} eyewitnesses. and two
hours had passed since robhery.
Lallcmand \'. U. R. I. . 9 FJd 214 (151 Cir. 1993) Affidavit which set /,][th
victim's vcrsillll of rape and followed it \\ith description ofvictill1 selecting arrestee's
photograph Irom picture array and positively identil~'ing him as the man \\ho wped her
provided probable cause \i)r arrest. C\ en though therc were discrepancies bdv.een
arrestee's appearance and description of the pcrpctJ'alOr.
U.S. v. Valcz. 796 b.ld 24 (2nd Cir. 1986) Observing onict'i"s ue,criplion (lr
cocaine seller was adequately delaikd. despite his silence on matter oj' seller's facial hair.
1Uld delcndanl. who was in immediate area or drug transaction. sufficiently fit description
to give anothcr officer probahle cause to arrest dei'cndant within short space of time
following transaction.
6. NO NEED TO "PRrSERVF" PROBABLE CALSF
Frequently an olficer stops (or arrests) a person t,)J' a small offense and then
continues the investigation and linds PiC tor a milior crime. In such cases, the officer
often doesn't "charge" the person \I ith the initial. sometimes pettv. otTense. In the past
sonw judges bave ruled that this makes Ihe entire arrest bad because the officer didn't
"preserve the pmhablc cause." This is not the law. In Scott \'. State. 110 Nev. 622
(1994) the dcfendant was in a car stopped lilr an improperl: am,Xed license plate. After
the stop it Iva, determined that Scott was an cx-felon and had a gun. He was arrcsted for
that. but no citation was issued. The l'icvada Supreme Coun said this made no difference
in the validity orthc stop. In I'.S. \. Woody. 55 F.3d 12:;7 Oth Cir. 19(5) the court said,
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"An arrest ma) be perfectly rcason,lble c\ en if the police ot1iccr ultimately docs not
charge the suspect with the of!",nse giving rise to the of'ficer's probable cause
determination.
7. WJ[EN WARRANTNEEDE!) IN ARREST SITU.HION
The Supreme Court said in Ii. S. I. \Vatson. 423 U.S. 411 (1976). that IOU don't
need an arrest warrant for a lawful arrest in a public place --probable c~usc is enough.
even ifyoll had time to get an arrest ",arranl. Same ruling in Florida Y. White. 526 U.S.
559 (1999). LS. v. Levine. 80 F.3d 129 (1996). U.S. \. Snov\. 82 FJd 935 (10th
CiLI996). and numerous other cases.
"The Supreme Court has refused to attach ,ignificanc~ tll the tilct that the police
had ample timc to get an arrest "arrant out dc'ciined w do w. For an arrest in a public
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place ." the onl) rC<juircme!1\ is probable cause:' l.'.S. Y. DeMasi. 40 F.3d 1306 (I st
Cir.1994).
There arc two situations where a warrant nlU5t be obtained in alTest situations
(unless policc can provc an emergency or consent (,ception exists) hOlh imolving entry
into premises to arrest. These arc the "PA YTON IUJI.E" and the "STL\GALD
RUI .f:."
(a) DISCUSSIO\ ON P.\ YTON RUE
Payton v. Nc" York. 445 U.S. 573 (1980Lthe court held that police cannot make
a warrantless nOll-consensual cntry into a suspect's home [(J make an arrest unless exigcnt
circul11stances exist.
In Payton. police developed pic to arrest suspect filr murder occurring two days
earlier. Police went to suspect's home where lights wcre on and mllsic playing. When
nobody answered knock or door. police made entry. Pa)l0n wasn't home but shell casing
to murder weapon was in plain \'ie\\ ami" as scit.cd.
The \;.S. Supreme Court ordered this evidence suppressed stating that the privacy
interest in a home was very high and police needed either an arrest \\arrantlllr Payton (or
a search warrant for his home) to enter his home.
Although the U.S. Supreme Court ha, not decided all possible sub-issues Ihat
arise after Payton - the Illilowing rules 11<1\ " been applied h) hlgh ranklllg State and
Federal courts.
(I) If police are otherwise lawfull) in a person's home, lor cxample. with a search
warrant, and probable cause to arrest appears it is OK to arrest without arrest warrant.
Mahlherg v. Mentzer. 90R r.2d 772 (8th Cir. 1992). Jones v. City ol'Denvcr. R54 F.2d
1206 (10th Cir. 1988).
(2) In People v. \Vhite, 512 N.E.2d 677 (III. 1987).the court held that \\'hether a
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place is "home" depends on thing" lik~ length or stay. regular usc. relationship to other
occupants. storing possessions then~ and payment of rent.
(3) The Payton rule ean be violated c\en ifpoliec don't physicall) enter the
home, so held in Walters v. State. 106 ,,"c\,. 45 (19901. Walters became it suspect in a
lllurtkr case. The next morning. without obtaining a warrant. police used a helicopter
and bullhorn and ordered him out of his home. He complied. I\as arrested. and was given
Mirandu warnings and gave an incriminating statement during the 100 mile dri\ c to the
police station. The Court held the statt:l1lcnt should he suppressed since Walters was
technically arrested in his home (b~ surrounding it \\'ith police and ordering him out)
without a warrant and the confession I\as the "fruit" of an illegal I,arrantless ancst.
(Note: This was overruled aner the LS. Supreme Coun decision in New York v. Han-is.
I I () S.C!. 1640 (1990) holding that even alter Payton dolation police giving Miranda
alia), from residcnce or at pol icc station OK' s interrogation 1.
Other courts have ruled the same in "surround" or"bullho111" cases. U. S. V.
AZLflWY 784 F.2d 890 (9th Cir..19R51. U. S v. Macz. 872 F.2d 14-1-1 (IOlh Cir. 1989), I!.
S. v. Morgan. 744 F.2d 1215 (6th Cir. 1(84).
(4) The Payton rule applies to the suspect's place of business as well as his homc.
(5) Most eOllrts hold in addition 10 the watTant requirement police also need
"reasonable belief' (not prohahlc causc) to believe a parlicular premises is that of the
suspect and that the suspect IS "home" al the time ,)!'policc entry, U.S. \, Risse. 83 F.2d
"J
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212 (8th Cir. I 996j"ofTieel'5 cxc~uting an arrest warrant must haw a 'reasonabk hclicl'that
the suspect resIdes at the place to be {'mercd ." and have reason to believe that the suspect
is present' at the til11e the warrant is executed. rhc 'llSpect" s home mcans he has common
authority or some othcr signilicant relationsbip to the premises even iClhe premises is
owned by a 3rtl person" "Reasonable beliet'o ruling tilllowcd in C.S. \'. iauter. 57 !'3d
21 C (2d (ir.1995) U.S. v. \1agluta. 4-t F.3d 1510{ II tll Cir.1(95)U .S. \. Route. 104 F.3d
59(5th CiLI (96).
In Valdez v. [,heters. 172 FJd 1220 (10th Cir. 19(9) Couli held that thc proper
inquiry is whether there is a reasonable belief that thc suspect resides at the place to be
entered ... and whether the officers hav'C reason (0 belicv'c that the suspect is present. 1n
U.S. v. Edmonds. 52 FJd 1236 (3d Cir.1(9) although "the information available to thc
agents clearly did not exclude the possinilit) that the SllSpect was not in the apartment.
the agents had rcasonabk grounds fm concluding that he \Vas there.
In Lnitcd Staws v. Albrckt:;en, 151 1'.3d 951 (9th Cir.19(8) the court recently
cited with approval both Route and Risse j()r the proposillOll that ofllcers cxecuting an
arrest warrant must llave "some rcason to believe thatlhe dcfcnd~lI1t mightliYc flt and he
prescnt within the premises" enterd. ma~ing no mention oi' an) higher slUndard of
knm\ ledge.
(6) '10 need to have WRlTant in IKmd. Whenever possihlc "mCe1S should have a
cop; of the arrest WaJTal1l. hut ,]> long as a IdloVv officer conlinns that the written signed
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warrant is in existence this IS slll'ficiem. U.S. ". Munoz. 150 FJd 40 I (5th Cir. 1998).
(7) Misdemeanor "anants. Whenever possible officers should not make a forced
home entry to scrve a misdemeanor arrest warrant. Hov:cvcr. NRS 171.138 appears to
contemplate a h\)\\sc entry to make arrest on a misdemeanor WUlTanl. See also. Jones v.
State. 513 So. 2d S (Ala. 1986). Lyons v. State. 7871'.2d 460 (OklJ. 19R9). The l\evada
Supreme Courl implied in Hatley v. State. 100 :--Jcv. 214 (1984). that police could make
an in hDn1c alTest on a misdemeanor \,arrant as long as it was not a pretext to gain
evidence reference an unrelated felon) investigation.
(8) Use of Ruse. NOTE: You cannot lise a ruse to gain cnlr) into a premises to
ayoid the Payton warrant requirement. l~l()wever. the majority of cases on this isslle hold
that you c,m usc a ruse to get the subjcct whom you wish to arrest ("ithout a warrant) to
exit the residence.
The rationale these cases is rock-solid. The purpose of ih" I'a:ton rule is to
prewnt warrantless police entries into a residence to arrcst. 'linec police can legally
arrest outside a residence y,ith probahle calise and without a warrant. what dillerence
docs it make if police usc a rusc to get the 'lispeet to kaw the premiSeS instead of
waiting Llutsidc until the suspect lett on his own q The ans\\cr is obviolls . no difference
and no Payton violation.
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The /()llowing cases upheld use of a ruse to get person out of premises:
In L.S. I'. Rcngito. 8S8 F.2d SOO (I st Cir. 1988) A govcnlment agent's telephone
call to defendanb' motel room warning them that there had been 'problems" "ith a
cocaine deliYerv and that it \\ould he hest if they left the roOl\\ and the area did not
improperly aI'oid requirement fllr an'cst warrant bv artiJiciailv creatin~ exigent
circumstance.
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[n C,S. v, Vasiliavitch. 919 F, Supp, 1113 (:-.iD Illinois. 19(6) The Coun held
that" courts have t()lmd no constitutional violation when police "llieers usc tactics of
mi~infllrlnation to solve crimes. Most prominent is the Supreme Coun's 1969 decision in
Frazier v, Cupp. 394 U.S. 731 (1969) in which Justice Map,hall held that an of1icds lie
to the defendant that his co-conspirator had conksscd was lI1sufficient to make an
otllcmise voluntar'Y conf\'ssion inadmissible, '1 he ruse at issue III Frazier Ivas
substantially more serious in ils scope and its consequence than the ruse here, The
defendant in Frazier was tricked into making a lull confession."
In this casco the officer's usc of tricker; only obtained Vasiliavitchious' arresL an
inevitable consequence since the officers had prohable cause, Unsurprisingly the COLlrts
have upheld the use of subterfuge to trick a defendant into leaving his home on many
occasions under circumstances vcry similar to the ones here. People v, Witherspoon.
576 ~,E.2d 1030, (tHinois, 19(1) ("The usc of deception 10 lure a defendant from his
home in order to cffcctuate all arrest without a warrant has been held not to violare
fundamental fairness.")
(b) DISCUSSION 01- STEAGALl) RULE
Steagald v, United Stales. 451 U,S ~04 (1981). held that while an arrest wan'ant
does permit entry into the suspect's own home to eilect the arrest. it does not allow police
to enter a third person's home in search of the suspect. Absent either consent or exigent
circumstances. police musl have a separate search warrant authorizing them to enter the
third person's home.
(I) The search warrant will require nOI only a showing Df probable cause that the
suspect is inside thc third person's residence, but it sh(lI\ ing of \\"hy it IS reasonable to
seck the search warratl1 and make the entry to arrest as opposed to waiting for suspect to
depart and arrest elsewhere,
(2) The Slcagald mlc also applies to b\lsiness offices and other area, where there
is a high reasonable and legitimate expectation ofprivac)'.
Civil Liability
In addition to suppression of evidence. police and/or District Atlol11cys may be
civilly li"ble for l'aYlOn-Stcagald violations,
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In Pcmbaur v. City of Cincinnati. 106 s.n, 1292 (1986), Pcmbaur, a doctor.

'''1S indicted hy grand jury for welfare fraud. Suhpoenas \lcre issued for 1\VO of'his
employees and when they laikd to appear, warrants for their arrest issued, The two
employees were loeuted UI the Pcmbaur's clinic, but he. l'embauL refused to admit the
oflicers serving the warrant. The o!licers callcd the District Attorney who advised the
oflicers to "go in and get" the tl\"() employees. They complied. Pcmbaur jiled a suit
undcr 42 lJ.S,c. section 1983 alleging a violation or his rourth and Fourteenth
Amendmcl1t rights, lie sued the County. the officers and the District Attorney for 20
million dollars,
The U, S, Supreme Court Held: The DA lVas implementing "oflicial policy," In
this case. the DA had the tinal authority in ,uch mattcrs. thcrc!'m:. the nmniclpalit)
"officially" sanctioned the unconstitutional and tortious conduct. Therei'Jrc. the Count\
is liable. (lmrortant note: County and police poli<:y lI'oua!iy resultcd in District Attorne\
making these decisions and a state law granted the District Attorney the authority to gi\'e
such legal instructions.)
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G. PRETEXT ARREST
for cases on pretexttranic stop, please sec section on Automobile SlOpS and Searches in this manual
Since the United SWtes Supreme Court in Whren \. U.S .. 166 S.C1. 1769 (1996) and the
Nevada Supreme Coun in Gama v'. State 920 P.2J 1010 (1996) have adopted the no
such thing as pretext" rule for stops. the status ol"the rule f"r arrests is unclear. The
Court"s decisions say that a police of1ieers motive or subjective thoughts are irrclel'arH if
the ot1icer has a legal basis j()f the stop.
At the prcsent time there are no clear cut CILses Irom federal OJ sWte deei:;ions on
the issue 01" a pretext arrest. ie: a valid arrest bascd on PIC where the arresting police hli\"C
an additional subjective reason for making the arrest.
.
Some pretext arrests lead to custody' and/or interrogation for the other' (usually
greater) aime, while others arc used to justify a rolice search nt' a premises or vehicle.
The cases on this subject are contlicting. Some say that as long as there is a legal
basis for the arrest. the additional subjective police reason is not improper hut other cases
disagree.There arc not enough cases in this subject for the author ul"tbis manual to give
directions or opinion on the v'alidity of pretext arrests. The following cases have different
results, often based on complex factual and legal factors.
In lJ. S. v. Willis. (, I FJd 526 (7th eiL 19(5) th(; court said that if an an-est is used
merely as a pretext to search I(,r cvidencc. there is a 4th Amendmel1t \iolation.
In Terrell v. Petrie. 763 F. Supp. 134] (ED Virginia. 1991 )The Court held that.
It is clearly established that an arrest eilectetl as a pretext for an otherwise unlawful
search is constitutionally defective"
The arrest was ostensibly based lIpon a state-issued warrant for failure to pay $60
in court costs in 19R2. Plaintiff. who works for the IRS claims the am'st was a pretext to
search lor illegal drugs. IRS employees \\110 conducted the search or were supervisors.
conceded that they suspected Terrell of drug activity. This court finds the anest to be
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prctextual in violation of the 4th Amendment.

In Hatley v. State. 100 Ncv. 214 (1984) the defendant vvas arrested on J
misdemeanor bench warrant He claimed that the police \\"(:re nC\'crthc!css using it us an
impermissible "pretext" to an'est appelluJll 011 tbe hurglw', cbarge ... rbi, contention. it"
tnte, would at least arguahly entitle appellant to relief See Tagl,wore v. U.S .. 291 F.2d
262.265 (<)th Ci1".I%I) ("here police of/icers use misdemeanor warrant as a pretext to
arrest a defendant f(,r a felony narcotics offense and to search tbe defendant for narcotics.
both the arrest and the ensuing search arc illegal).
In U.S. v.lludson, 100 FJd )409 (9th Cir. 19(6) the Court stated: An arrest may
not be used as n pretext to search tt)r evidence without a search warranl which would
ordinariI) be required b) the 4th amendment. but \\ent on 10 uphold a fCiony arrest with
an arrest warrant at a residence v,here the federal police thought that the arrestee might
have contraband. In making the arrest. l(o,kral police did a search incident to anest,
lound some methamphetamine and a gun. Qot a search warrant and obtained more
contraband and evidence.
This case is all example "rthe confusion that presently exists concerning pretext
arrests.
In United States v. Cause). 834 1 .2d 1179 (5th Cir. 1987) police suspected
Causc~ in a ballk robbery hut had no Pi(" to arrest and question him on that easc. Police
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did have a bench warram ror hi:, fTA on a petit larceny charge and arrc,ted him on that.
He was Mirandized and con l'c:iscd to the rohber\'.
The Court said that decision:; oi'the U.S. Supreme COLIn make it ekar thal the
officer" s subjecti\'c intent or motivation is irrdcvant. Whal COllnts is whether there was
an objecti\(' basis f()f the oniccr's actions.
In \;nited States I'. Trigg. 878 F.2d 1037 (7th Cir.19g9), the Court concluded.
"We believe that the rensonablcne,s "fan ,lITest depends upon the existence of two
objecti vc lactors. First. did the arre:;ting otlieer have probable cause to believe that the
defendant had committed or was commilting an offense. Second. was the arresting ot1icer
authorized hy state and or municipallu\\ to effect a custodial arrest fur the particular
oflellsc. Ir these two factors arc pre,ent, we believe that an atTest is reasonable under the
Fourth Amendment. [n other I\ords: so long as the police are doing no 1l111l'e than they
are legally pcrmitkd and objectively authorized to do. an arrest is constitutional. Same
ruling inti.S. v. Kordosky, 878 F.2d 991 (7th Cir. 1991)
[n Holland v. City of Ponland. 102 r .3d 6 (1 5t Cir. 1996) Police subjecti ve
motives in arresting motorist. as alleged pretext. to investigate more seriou,> crime did nllt
affect validity of arrest hased on motorist's admitted statutory violation in refusing to
provide identifying information (license) to policl'.
In Scarborough Y. State, 621 So ld 996 (Ala. 19(2) the COUll upheld the arrest
ot' a person suspected of murder based on a misdemeanor arrest warrant.
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0'1 HER FOURTH ;\ vlE'<DME)')T I)')TRL'SIONS (SL\RCI 1&

ENTRIES)
A. SEARCI I L',CIDE;\T ro ARREST "SlTA"
(I) In Gcncral
A "SITA" is a "policy justi1ied" search in the sense that it does not require its own
justification in terms llfprobablc cause or reasonable suspicion. All that is required is a
lawfu[ cW;lOdial arrest and a SlTA can occur.
In Illinois v. LaFayette, 462 U.S. 640 (1983), the U.S. Supreme Coun said, "The
authority to search the person incident to a lawful custodial arrc:;t, while based on the
need to disarm and to discov'er evidence. docs not depend 011 what a court may later
decide was the probabillt~ in a panicular arrest situation that weapons or evidence
would in fact be fOlmd on the person of the suspect ... the arrest heing lawful means
the S!TA re4uircs no additional justilication."
In United States v. Robinson. ~ 14 U.S. 218 (1979)1 he Court said all custodial
arrests from murder to traffle violations are equal in justif~ ing SITA.
(2) Scope of SITA
Since the SIIII is automatic with a hmful custodial arrest. the legal issues in this
area all involve the scope oflile SfTA f!lm :.;oon l1lust it nceur': I It", far can it gil in
terms of area and imfll'iion 0 The folloyying cases provide some guidclmes but officers
should realize that the 1110re (I) time goc;, bJ and (2) the 1(lnher away from the exact
place of the arrest and (3) the harder it would be for the arrestee to get into the area
searched. the less likely it yvill be a \'alid SlTA.
(a) Time
The general rule is that the SITA must be "conkmporaneous" with the arrest. It is

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axiomatic that a SITA cannot precede an arrest in providing the justification for the
arrcq, hut if the justification exists already tie - police had I'/C before the SITA) then the
fact that the formal arrest immcdiatel\' t(11Io\'.cd the SITA madc no dilTerence. Rawlings
v. Kentucky, 44~ U.S. 98 (1980),
Although the search must be contemporaneous. COlH1S provide police a brict'
cushion of time until they have gaincd complete control of the situation. U.S. v.
$639.558 in t:.S. Currency. 955 f.2d 712 (D.C. Cir. 1992) There is no prohibition
against a reasonable delay between the 101 imination of danger and the search. lJ .S. \'.
Han, 74 FJd 537(4th Cir. 1996) A scarch incident to arrest must be contemporaneous
but not necessarily immediate. U.S. 1'. Willis. 37 r.3d 313 (7th Cir. 1994).(flillcrent
77
person Irom l:.S. v. Willis in pretext arrest).
In C.S. v. Johnson, 114 FJd 435 (4th Cir. 1997)Applying Han to the facts at
hand, no douht exists that the car was within Johnson's immediate control at the
beginning of his encounter with the oftlcers: the search was conducted at the scenc ofthc
arres\' aller the officers moved the car to the front of the ,;hopping center mall into a
better lighted area: and the delay betwecn the elimination ofthc danger--Johnson-- and
thc search was not unreasonable.
(b) Place scurchcd
In Chimel v. Calilimlia. 395 U.S. 752(1969) the U.S, Supreme Court beld that
police coulc1not search areas inside a house outside the immediate control of the suspect
at the time orthe Imd'ul atT"S\. Police ale not allowed to simulate circumstances
justifying a SITi\ merely by bringing the item they "ish to search into the area near the
person arrested or vice versa. U.S. \'. Perea, 986 F.2d 633 (ld Cir. 19(3) However, iflhc
suspect voluntarily asks to move about his premises (to get a coat or other clothes, etc.),
the ol1Jecr can monitor the arrestee's movements and SITA may be \alid at another
location. Washington v. Chrisman, 455 U.S. I (1982).
Items "immediately associated with the person" can be searched incident to the
arrest of the person including a woman's shoulder hag r,'gardlc5' of \\ hethel' on her
shoulder or on the ground a few teet u\\'ay. l) .S. v. "elson, 102 LJd 1344 Hth Cir. 19(16)
In L.S, v. Cotnam, 88 F.3d 487 (7th Cir. 1(96) OK to search arrcstcc'sjacket laying a
few reel away at arres\. [,;.S. v. Ortiz. 84 FJd 977 (7th (ir. 19(6) OK to push button on
pager found on dclendant at time of arrest revealing numeric messages.
Some C01ll1S alia\'. a SI rA of a locked area or container, 1).S. v. Gonzales, 71
F.3d 819 (11 th Cir.1996) and Clemons v, U.S., 72 F.3d 128 (4th Cir. 1995). However. if
the arrestee is handeulTed and in police custody and has no chance of unlocking and
opening the container. it seems that searches of locked containers require a search
warrant or other exccption.(such as inventory search or consent).
In U.S. v. Tarazon, 989 F.~d 1045 (9th Cir. 1993) police could search a desk
dnmer where defendant '\as sitting at time of anest cYCn though he was handcuffed.
Same ruling in U.S. v. Hudson. 100 F.3d 1409 (9th ('ir. 1996) OK to search rifle case at
feet of person arrested c\ en though he was removed Irom the room 3 minutes earlier.
Same ruling in U.S. v. I'lorne, 4 F.3d 597 (8th ('ir. 1993) search of scat where he \Vas
arrested even though handcuftcd.
(c) Arrestee Handcuffed
EvelY case decided in SITA Jaw ,3:-S thal it makes no difference that thc person
\,..,/
was in handcuffs at the time of the SITA as long as the other SfTA requirements are mel.
Chime] v. California, United Slates v.lfdmsetter. 56 F. 3d 21 (5th Cir.1(95) (Sec
ca,cs above).
78
(d) AUlomobiles:
Sec section on automobile stops and searches 1lllhis manual
AH'JRMATION
I declare under penalty of perjury under the laws of the State of Nevada that the
7
foregoing is true and correct and that this document does not contain any social security
numbers, pursuant to NRS 239B.030, an affirmation to that effect this herehy is.
DATED lhis 13th of Fehruary. 2()12:

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lsi Z~~h Coughlin

Zach Couglllin, Esq.
Hcfcndant! Co-Counsel to Goodnight

;:
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PROOF OF SERVICE
0:'-1 this date. I causeu a COpy of the t()regoing Motion for Sanction, to be ser\'ed upon the following
bv sending to their reglstercd email addre,s and tllX number as found on -----,-----"'- and by
\\ I\w.mbar.oru.
.
placing a true and correct copy of the i(He~oing dO(lUl1enl in the I :.S mail addressed to:
~
Zaehmy N. Young. Esq.

Washoe County DA
I South Sierra P.O. Box 30083
Reno. NV 89520
Phone Number: 775-328-320Q Fa~ number: 775-325-6703
Email: zyoung@da.washoecounty.us
Biray Dogan. Esq.
Washoe County Public Dd"cnder's Office
P.O. [lox 30083 Reno, NV 89509
Email: bdogan((;washoecounty.us
. "
'"
. ,
; "
] ')
"I
Joseph W. Goodnight. Esq.

Washoe County Public DeICnder's Oftiee
P.O. Box 30083 Reno. "iV 89520
Phone Number: 775-337-4839 Fnx number: 775-337-4RS6
j good nigh t@washoecounty.us
JEREMY T. 130SLER. Esq.
Bar No. 4925
One California Ave
Reno. 1\'V 89509
(775) 337-4800
Attorney fllr Defendant
DATED this l)th of FdmJarY. 2012:
-r-- -
;, '.'
-.'" -~-""'-:-c,---
Zach Coughlin.

INDEX TO EXHIBITS
1. COLLECnO:"l PERTINENT nOUiMENTATlON
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RE: FW: State v. Zachary Coughlin, DA #432068

From: Goodnight, Joseph W (JGoodnight@washoecounty.us)
Sent: Fri 10/07/11 3:28 PM
To:
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RE: Libby refused to do the competency evaluation

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RE: libby refused to do the competency evaluation

Sent: Tue 10/11/11 12:39 PM
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RE: I will call at 230

From: Goodnight, Joseph W (JGoodnlght@washoecountyus)
Sent: Wed 10/12/11 2:01 PM
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RE: I will call at 230

From: Goodnight. Joseph W (JGoodnight@washoecounty.us)
Sent: Wed 10/12/11 215 PM
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RE: standard of care/claim preculsion/res judicate/holistic

approach
Sent: Thu 10/20/11 8:16 AM
To:
zachcoughlin@hotmail.com
Zoch.
This week hJS been busy and J haven'! rad a c:hanc:;. to respond to your emad. i s!1()ulJ Le ;lbi& to get to 11
tomorrow mornmg as I'm m cour ali day today FIrst. tt'e COrrlOerency e'181ti8 110f1 carne back \,\'IU1 a fJnO!llg of
competoncy and we can proceed as per USual vilth YO:.,H (~$e Seco[1(j, I\;e bn~':fly beei) "Jbh) 1::.' open SCrr'8 of thp,
malenals you've researched on box net I don'! see cnyttllng on probable r::8Usr~ to Ci''-esl 1'1 YJU( reseJrC"1
Hemernber, thIS wil! be the Crux Df YOll! defefl5'~
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k1any Of y::-:vr tOPICS below se<:'l'l to be Clvd and
111 ,1Gr1!eSS 2JC'.1 snn or; i==r;diJY (;ood 11F:EI on Ihn g!;1nO
larceny vs petit larceny doHa! arnouill hOV'i\~Ver, lbi.1t !aw dldn t ta~,::. effect d:'~!i Oc:ol:;;er 'I 2G 1~ and l.jOuldr'1 effect
the officer's probable ca~!se 10 3rfer.j delernioaholl
Slnce(ely.
Joe Goodni9ht
*****************~************************************ ****
Joseph W. Goodnight

(775) 337-4839
jgoodnight@washoecounly.us
** Notice** This message and a~companying documents arc covered b~ the ekctronic
Communications Privacy Act 18 U.S.c. ~ 2510-252 L and may contain conJidential
information intended t()r the specified individual (s) only. If you are not the intended recipient
or an agcnt responsihle for delivering it to the intended recipient. :-:Oll 3rc hereby notified that
you have received this document in error and lhat any review. dissemination, copying, or the
taking of any action bas.:d on the content, of this inl(mnation is ,;(rielly prohibited.
From: Zach Coughlin [mallto:zachcoughlln@hotmall.comJ
2/14!2012 1:10 I'll
Sent: Fnday, October 14, 2011 9:23 PM

To: Goodnight, Joseph W; Novak, Eva
Sllbject: standard of care/claim preculslon/res )udlcate/holistlc approach
Whals Up Chief!
Just to give you an idea what 1 have been up to outside of this (though it
ar,guably relates contextually), I havc been before Judge SfelTazza quite a bit
lately:
https:!!skydrive.live.eom/?cid=A3084638n2f5f28& id=4 308463 SF3 2F5F2S' 357
r was reading some recent NY S. Ct advanced opinions and came across

something indicating "grand larceny" \vas now for stealing something with a
value of $650 or more, up from 5250:
http://www.hkimlaw.com/aggregatorlsourecs/2
" Grand larceny consists of intentionally stealing property, owned by
another person, having a value of $250 (now $650) or more. NRS
20S.220(1)(a).(2] "Value" in larceny cases is statutorily defined. Drawing
on section 223.1(2)(c) of the Model Penal Code, NRS 205.251(1)
provides: "The value of property involved in a larceny offense shall be
deemed to be the highest value attributable to the property by any
reasonable standard." While the provision's purpose "is to put the
transaction in a higher rather than a lower category where anyone of ..
several possible criteria of value justifies the higher classification," Model
Penal Code and Commentaries 223.1 cmt. 3(b), at 141 (Official Draft
and Revised Comments 1980), the burden remains with the State to
prove value as an element of the crime. Thus, the State must "prove by
evidence beyond a reasonable doubt that the value of the property, by
any reasonable standard, exceeds [the statutory threshold amount]," h"
I believe Cory Goble's phone was an iPhone 3g ... maybe a 3gs .... they
come in a few different incarnations, the more memory, presumably,
makes them a little more valuable ... 8gb of memory is not as good as
16gb (memory can come onboard the phone .... an or via a memory card
slot one can add to the phone) ... Regardless of how tricked out his phone
was (I suspect, not that much), the value for third generation iPhone
(much less used ones) began quickly plummeting in April 2010 with the
7on7
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introduction of the iPhone 4 or 4G:

http://www.bgr.com/2011/09/16/pla n n ing -on -picki ng-u p-a n -i phone5-better-sell-your-old-iphone-now/
I would think there could be some hay to be made with the outrage
incident to the police and DA charging people with very, very serious
crimes, crimes that could ruin reputations and careers based upon
valuations that any reasonable amount of diligence or man on the street
common sense would reveal are completely unsupportable. Best
defense is a good offense. What is your offense on this? Do you need
to keep a good working relationship with the DA7 I don't say that
sarcastically, it may be a valid consideration ... but I think they may respect
you more for going strong to the hoop and being willing to flash some
Rule 11 fangs (and, yes, Judge Sferrazza, Rule 11 most certainly applies
in all legal proceedings, hell, it may even apply to retailers having
computers, er, paralegals, send out million of form litigation demand
letters from Utah or Florida each year to anyone accused of shoplifting
by mega retailers like Lord and Taylor, Home Depot, and Wal-Mart:
http.//online.wsj.com/articie/SB120347031996578719.html
So, these two law firms, one in Utah, one in Florida, send out, literally, millions
of these civil recovery litigation demand letters a year to accused shoplifters.
Remember, it is seeking a settlement for a civil claim, doesn't have that much to
do with the criminal case that mayor may not have resulted in a conviction, or
even a prosecution (Clark County has a program that seems to just get everyone
to do community service, at least first time olfenders). However, some people
don't just respond to these form letters by paying or ignoring them. Some go'on
the offensive. Best defense is a good offense, some might say. Funny thing is,
all those cases settle real, real quick:
Civil Results
Case
7 Palmer. Reilier & ASSOCIates (dfl)
uldee
8 Palmer. Reifler & ASSOCiates. P.A. (dfl)
110[1" (Yc;i)841 470 06/26/200801/1]12010

gandce 1 2(lOS Cy"(iiJl.P 360 11/02/2005 10110/2006
9 Palmer. Relfler & Associates, P.A (mov)
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890 12/22/2004 01/24/2006
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Civil Results
10 Palmer, Reifler & Associates, PA. (mov)
gandee 1 :::;.:1',;.,-0230.,2 360 11/01/200510/31/2006
11 PALMER, REIFlER & ASSOCIATES, PA rdft) losdce
] ,:(1(.;
(.j
(J(I16S 890 02/07(200703(13(2007
12 Palmer, Reifler and ASSOCIates, P A. (dft)
mledce 2.2j))': '.Yc_~9_~87 360 02/28(200610/31/2007
13 Palmer, Relfler and ASSOCIates, PA [dftl
mledee 22:.'; c' 1~,::3 890 05/17(200707/31(2007
Joe, I hope you get signed up for Pacer.gov, and utilize the legal fde shanng plug-In that 15 RECAP, which helps,
sometImes, get around paying 8 cents a page for copies of the actual pleadings on file
case starting
In
In
pretty much any federal
2000 or so Lots of nICe defense motions to crib from on there, pretty sure Some attorneys at
places like your ~tandard PublIC legal AHi law finn would go years WIthout ever really filing any real badass motions
If, for whatever reason, they left their mothership firm, they wouldn't really have much to pOint to out In the private
sector to justify charging healthy fes
How about this. Think of some Issue in this case you like .. Iike plain feel doctrine. See one of my attached AlR
articles on plam feel doctnne ... ftnd a more recent case ..sign up for a pacer-gov account (2 minutes tops) and
download
a summary judgment motion from that case that concerns that Issue, copy and paste, and Bam! Everyone
knows Joe Goodntght is nots to be effed With even more than they already did.
Speaking of the holistic approach your office takes, not to mention any malpractice concerns. what is the claim
preclUSion/res judicata landscape like 1!1 cases like these 7 Not that I would necessarily want to rock the boat like
this, but would a subsequent 1983 act/on or wrongfuJ arrest or defamation
suit be barred were you
or f to fall to
allege it in this matter? Are those compulsory cQuntercJaims ... are they perrni-;,slw 7 If permIssive, would Bosler (who
had the good sense not to hire mei let you bring them, assumrng you wanted to' Oh, wait that's right, those types
of matters don't just depend on If the lawyer wants to litigate them, they are kind ofwithrn the ellen!'s discretion,
aren't they?
Have you ever filed an offensive motion agamst the DAf Have you even once filed a Rule 11 motion. Could you cite
me a speCific example with a case number so r can review It? Anything related to prosecutorial misconducF
Sometimes you gatta throw a few 'bows to let them boys know that paint belongs to you,
I hear you about the other Side of the coin too. though A deter and dismiss IS not something to sneeze ilt and you
don't want to wake a sleeping tiger. yln9 yang .. Shake and Bake.
However, what could be done With this new $650 reqlllrement for a grand larceny el1arge' Any offensive motions' I
listened to the cd you copied me on Nothing jumped out too much except the kid, Goble, I believe, IS clearly and
aggreSively heard saying "[ am going to reach rnto your pocket right now and get my phone" .. he comes off kind of
like a w!1lny suburban skater who, allegedly, would leave a smartphone on a ledge unsupervised in the middle of a
downtown Reno skate park, amidst citizens In a County dealing With an unemployment fight hovering around 15%
for three and a half years straight, then not think tV.Jice about accosting a stranger and demanding the stranger open
up their clothing to a search so this skater can ascertain whether hiS iPhone IS in that stranger's possession
He can
barely focus. long enough to anS'vver a professional ~ounding 911 operators baSIC questions, making the operator
repeat himself around 4 trmes within a minute and a half. Goble seems to, several times, make statements that he
and his friends saw the accused take the lPhone right off the ledge where he set it It would seem there is a wealth
of evidence and testimony to show that that IS plainly false and a recliess defamation on Goble's part. That offends
some people greatly, He got a lICensed attorney charged With a felony. The attorney wound up spending 6 days
III
Jail and sustaIning grave injury to his professional reputation and business concerns. And what repercusSions does
Goble and his accomplices face?
On the other hand, the accused can clearly be heard makmg his own 911 cal!s, supporting hIS contention that he was
assaulted and battered and falsely imprisoned
In
a precarious sitl.Jatlor on a bridge, and close to oncoming traffiC,
while on () bicycle and with hiS Pekmgness dog in tow on a lease The accused clearly express that he has been '
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made to feel scared and threatened by a mob of skater youth, whose wlture and attitudes he does not necessarrly
understand
The eVidence shows a gleefUl display of at least one of the skater youths seeming to exclaim that he IS
a "minor" at 17, and therefore, car. do reckless and Irresponsible things to CoughlIn, In the facE' of Coughlin
reminding the aggresive mob that a 13 year old had recently killed 25 year old Stephen Gale on California avenue
during the struggle for a purse incident to an attempted armed robbery.
How is 01 Eva dOing? What is his expo~urE' here, what;., mot1\fatlng him? 1t~ a start to get the 911 tapes from the
Incident How about the 911 tapes from the days foHowing the P'Kldent wherein the Inve<;tlg.ator was assaulted and
battered (cited by Incident or case number in the onlme polICe report the accused filed and copied you on, involving
Officer Durio and Officer Barners, who appears In a 1983 case one can find on pacer-gov, litigated by Andrew Boles,
Esq, as dll of them seem to be, that Involves Officer Barners, and Officer Hartshorn, v'lho seems to make quite
frequent appearances III cases as a 1983 defendant. wherein a guy with a femur pOKing through his skin or
something after cop case saw the cops do some fme "boxing out" of the pararnedics on the scene, apparently so
they could get some good attempts at coerCing a confession ro consent to search out of the plaintiff
Anyways, 01
Officer Barnes refused to do much at all whefl one of the Investigators compiling som' of the audio and video
evidence in this case was assaulted and battered and subsequently saw hiS attacker at the same skate park the Goble
Incident occurred at. Officer Barnes couldn't even be bothered to query the early 20's female Hispanic attacker
about whether or not she punched a retreating irwestlgator in the back of hiS head while saying "1 don't give a fuck"
in response to statements like "I don't think a judge is going to appreCIate your attacking me physically".
Has Evo
gotten around to gathering those 911 (alis, What Investigation has been done regarding the subsequent police
report with RPD that the accused, your Client, copied you on Perhaps If the police have to push tl bunch of paper
and respond to a bunch of icky requests they won'l mind to much If the
DA loses some interest in pursuing a
conviction here, some might say. Sure would be good, and maybe required by the standard of care, to get any and
all other audiO or Video created on the night of the arrest in any way related to the matters before, during, and after
the arrest This might Include sending subpoena duces tecum to some of that horde of suourban skateboarders, all
seemingly equipped With iPhone to help them tweet out that they "just got some good weed and want to get Anne
Franked tonight, n.:ltgga" as seen in the collection of SOCial media postlngs gathered and which should be In your
possession by now. Why, IS It obVIOUS \\'hy Officer Duralde woudl so readily find credible that collectton of Anne
Franking skateboarders over the statements of a licensed member of the Nevada Bar' And that he would be so free
to antagonize such a person? Does that indicate he Isn't much scared of what the PO's office might do with a fact
pattern like this? Have you ever heard the saying, "sometimes you have to get some people down the steps Just for
rep .. "7 What does that mean'
Za('h Cou:;:hlin. E"'q.

121 /live!' Rock St.
Reoo, "'V 89;0 I
775JJS HI18
Licensed in Nevada
*It
,\loticl'**
fhi" nll'Ssilge and al.:l'OlTlra!1: ing dIlCl,m~lH:-. iJr~ L(lV':1 cd b: {he dcr.:twnk CpmmuniciltiollS Pri \'iJi':~ Act, 1Xl, ,S.C
** 2510-2521. and may ~on{ain conlidcmi:tl in!~ml1ati{ln intcndt.'c lor thc :.pccirkd indl\'iJutll (,,) onl~, lr:ou arc not tht;
inl(.'l1dcd r~('irlcnt or an ,~~cnl ri.'~pPII~il... k 101' lkll' "-'filiI-!
111\)
lhe intcmkd rr.,.'ciricnt. ~ \IU
dfl'
l'cccin:d (hi') document in errol' and lhm an) re, !~\\-, ,,-h";"l.'mm~Hi\l11. copying. or the luting
h':I~'h: nOli Ik'd lhal ~'Oll Ilu\ c
l)(
an~ action ha.;~d on th..: conh:nl:-, nl'
tht:, int(lrmnlion i'i '>[ril'lly rrohihitcd,
CONFIDeNTIALITY NO TlCe
This message is confidential, intended only for the named recipient(s) and may contain information that is privileged,
attorney work product Of exempt from disclosure under applicable low. 1/ you ore not the ;ntfmded recipient(s), you
are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the
loorn
2i14i20 12 I: 10 P\l
! lotnmi! Print Mcs<;agc
http: /by 1-18\\.bn) 1
'lJII.llvt!.comfrna! !iPrlntiviessag.:s.usp.\ '?cpids--9;1.
\,~,
contents of this information is prohibited and may be unlawful If you receive this message in error, or are not the
named recipient(s) , please notify the sender, delete this e-mail from your computer, and destroy any copies in any
form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
iRS Circular 230 D;sc!osurt? To rmsure compliance with requirements imposed by the Internal Revenue Service, we
inform you that any U,S, federal tax advice contained in this (ommunicot;on (including any attachments) was not
intended or written to be used, and cannot be used, by any person for the purpose ,of (iJ avoiding tax-related penalties
or (ii) promoting, marketing or recommending to another person any transaction or matter addressed in this
communication,
RE: standard of care/claim preculsion/res judicate/holistic

approach
Sent: Sun 10/23/11 5:30 PM
To:
Cc:
Hylin, Carl (CHylin@washoecounty.us)
Dear Zaer,
I've ;1cklie5sed the lliZljOllty of YOUl COf:!men\s '::JBio'N In C/.\,PS Hen1emD8:, \rli:~ 8C()~G ()~ n)y fepresen~atloll Dn
behalf of the> PUblic Offender's Office is s,)leiy Jni3u~d t~J your cr:m!nai defenSe
jI"
R::':R'I; Ge3:}:11 ar~d ! \'/Ili not bE:
Q1vmg YOtl any adVice on CIVI! 01 potPl'1ial {;;)!!aU:r{.';i rnmters, i e., how t~~js Gas\} n,ay a;-[ec; Y0W HC9'iSe b practice
law, You r'lay con1acl the State 1331 Gf Nevada If yo:.'
r:ie
cOr'cemed aboL,j eoUatedi consequ(;"'ces related ~o a
convlctiol1 in thiS c.aso OU! nexi ~~2a;if,~1 IS Tuesday. OctJbe( 26, 2011 of 1,J 00:1 rn PleiJs am\!8 15 to 30 JTIJI)utos
early
Smckrely.
Joe Goodnight
From: Zach Coughlin [mailto:zachcoughlln@hotmall.comj

Sent: Friday, October 14, 2011 9:23 PM
To: Goodnight, Joseph W; Novak, Evo
Subject: standard of care/claim preculslon/res Judicate/holistic approach
Whats Up Chief?
II 01'77
2:14/20121'10 P\-I
HOlllwil Pi lilt tvle-.,<;agc
hUp:!!by 1.:t8w.bay 1
mil.live.com'lllai):'Print\1c')sages.asp\ ';cpids-l..J(j .
'--'
Just to give you an idea what I have bcen up
to
outside of this (though it
arguably relates contextually), I havc been before Judgc Sferrazza quite a bit
latelv'.
https://skydrive.live.com/,icid=43084638f32f5f28&id=43084638F32F5F28!357
JG
1/--IIS J\?fJEARS TO Bf:;.\ CIVIL Su:f lH- rVVF.EN YOU AND YO'.,R l AJ.J~)l ORO
: DON'f BELIEVE IT Hf\S
ANY Bl:!\F~ING ON 'lOUR CRIM!NN_ CASL
I was reading some recent NV S. Ct advanced opinions and came across

something indicating "grand larceny" was now for stealing something with a
value of $650 or more, up from S250:
hltp://www.hkimlaw.com/aggregator!sourcesi2
"
Grand larceny consists of intentionally stealing property, owned by
another person, having a value of $250 (now $650) or more. NRS

205.220(1)(a).[2] "Value" in larceny cases is statutorily defined.
Drawing on section 223.1(2)(c) ofthe Model Penal Code, NRS
205.251(1) provides: "The value of property involved in a larceny
offense shall be deemed to be the highest value attributable to the
property by any reasonable standard." While the provision's purpose "is
to put the transaction in a higher rather than a lower category where
anyone of several possible criteria of value justifies the higher
classification," Model Penal Code and Commentaries 223.1 cmt. 3(b),
at 141 (Official Draft and Revised Comments 1980), the burden remains
with the state to prove value as an element of the crime. Thus, the
State must "prove by evidence beyond a reasonable doubt that the
value of the property, by any reasonable standard, exceeds [the
statutory threshold amount]," h"
JG - .A,S i STA Tl~D RFFORE, TH!S :':r{b}\JGE iN 11 L ,:\W '=;:8 f\:~): GO 1.\-;C [fH- CT UN': !L .t..clTR YOUR
ARRi~ST AND WOiJl 0 NOT CHANCE 'NIlE: Il1t H THe. OFrlCcK HAC ?HOBAeLE CAUSE: TO ;\Rr<ES 1 yQLJ
12 "fn
2ilif/2012 1:10 PI'.1
I !olmai I PI int Mes!l.age
http:'{by148"" bay I
'ail.1 i\.t~>com/mail:.Pl.lntVless3g.C.s.aspx . )Cljid. -tla ...
I believe Cory Goble's phone was an iPhone 3g ... maybe a 3gs .... they
come in a few different incarnations, the more memory, presumably,
makes them a little more valuable ... 8gb of memory is not as good as
16gb (memory can come onboard the phone .... an or via a memory card
slot one can add to the phone) ... Regardless of how tricked out his
phone was (I suspect, not that much), the value for third generation
iPhone (much less used ones) began quickly plummeting in April 2010
with the introduction of the iPhone 4 or 4G:
http://www.bgr.com/20 11/09/ 16/planning-on-picking-up-an-i phone5-better-sell-your-old-iphone-now/
I would think there could be some hay to be made with the outrage
incident to the police and DA charging people with very, very serious
crimes, crimes that could ruin reputations and careers based upon
valuations that any reasonable amount of diligence or man on the street
common sense would reveal are completely unsupportable. Best
defense is a good offense. What is your offense on this? Do you need
to keep a good working relationship with the DA? I don't say that
sarcastically, it may be a valid consideration ... but I think they may
respect you more for gOing strong to the hoop and being willing to flash
some Rule 11 fangs (and, yes, Judge Sferrazza, Rule 11 most certainly
applies in all legal proceedings, hell, it may even apply to retailers
having computers, er, paralegals, send out million of form litigation
demand letters from Utah or Florida each year to anyone accused of
shoplifting by mega retailers like Lord and Taylor, Home Depot, and
I) of77
21141]0121:10 pVI
Ilolmail Print Messnge
~ail !i\'~,com,'!llaiI/P!inl\1cssagc~,a~p'\',)crid~ 9a"
http,' hy14Rw,bayI
'-""
Wal-Mart:
http://online. wsj.com/article
/SB120347031996578719.html
J(J
t\GAIN, Ci'jIL L~Epnf:SEN fA';'I()N !S Ou 1 SI:JI::- n!F. SCOPE O~: i'.:V R!:YhESI-_N 1/\ r ION OF YOUR
CRiMIN!\~ CASE,
! WILL I\JOT ANSVVER
OUE:STiOt~S REGc.;::DI\JG CIV!L fv1ATTERS
So, these two law tirms, one in Utah, one in Florida, send out, literally, millions
of these civil recovery litigation demand letters a year to accused shoplifters.
Remember, it is seeking a settlement for a civil claim, doesn't have that much to
do with the criminal case that mayor may not have resulted in a conviction, or
even a prosecution (Clark County has a program that seems to just get everyone
to do community service, at least first time offenders). However, some people
don't just respond to these form letters by paying or ignoring them. Some goon
the offensive. Best defense is a good offense, some might say. Funny thing is,
all those cases settle real, real quick:
Civil Results
7 Palmer. Reitler & Associates (dl'f)
uldce
:;-2001LI
8 Palmer. Reiner & Associale,_ I'.A (dft)
9 Palmer, Redler & Associates_ P.A.
14 (lf77
(Illo\,)
Ihdce
Date
~()S
Court
Party Name
Date Filed
890
12C212004 01124/2006
Closed
cll 1-' 7-l
470 06/"6/2008 01111/201 ()
360
I I :02!~005 1011 012006
"'14:2012 I-Ill 1'\1
HOlnHlil Pnnt I'vlessage
htlp:r:bj I 48w.bay 1
)D.i 1.live,l,(Hll Jllai!il l rintivlt.::-.sage-:..aSp\',\:ptd::. 0')\1..
Civil Results
Court
Part) Name
Case
P.;\. (dn)
Vate
Closed
JoO ll!O I/2005 IOJ] 112006
10 Palmer, Reiner & Associate" P.A. (mo,)
II PALMER, RHFLER & ;\SSOCIATFS,
NOS Date Filed
in,dec
1)007~
890 0::'/07/200703/1312007
12 Palmer. Reifler and ""ocia!"" I'.A. (dti)
360 02i28-l006 10/31/2007
13 Palmer, Reit1er and '\ssocia!cs, P.!\. (elm
890 OS!i 712007
om 1;2007
Joe, I hope you get signed up for Pacer.gov, and utilize the legal file shanng plug-in that IS RECAP, which helps,
sometimes, get around paying 8 cents a page for copies of the actual pleadings on file in pretty much any federal
case starting in 2000 or so. lots of nice defense motions to crib from on there, pretty sure, Some attorneys at
places like your standard Public Legal Aid law firm would go years without ever really filing any real badass
motions. If, for whatever reason, they left their mothershlp firm, they wouldn't really have much to pOint to out in
the private sector to justify charging healthy fees.
.IG - NO COMMEN I
How about thiS. Thrnk of SOfTl Issue In this case you Ilke... llke plain feel doctrine. See one of my attached AlR
articles on plain feel doctrine ... find a more recent case .. sign up for a pacer.go'l account (2 minutes tops) and
download a summary Judgment motion from that case that concerns that Issue, copy and paste, and Bam'
Everyone knows Joe Goodnight is nots to be effed with even more than they already did.
JC - NO COMME'NI
Speaking of the holistic approach your office takes, not to mention any malpractice concerns, what is the claim
precluSion/res Judicata landscape like
In
cases like these? Not that 1 would necessarily want to rock the boat like
thiS, but would a subsequent 1983 action or wrongful arrest or defamation SUit be barred were you or I to fail to
15 of 77
~,1412012
1 10
P~l
Hotmail Print \1essagc
http: fb~' I48w.ba) 1.4"
'(lj!.!i\'c,cont'mail.'Pnntv!essagc~.asp\'.)cpiJs'-9a ..
allege it in this matter? Are those compulsory counterclaims ...are they permissive7 If permisSIVe, would Bosler
(who had the good sense not to hire me) let you bring them, assuming you wanted to' Oh, wait, that's right, those
types of matters don't JUst depend on If the lawyer wants to litigate them, they are kind of Within the client's
discretion, aren't they?
J;"') - OUTSIDE: I H~ SCOPE Or- c;:.;;!t';j;Nf",L KE;:HESc::\rIA;TJ~~
Have you ever filed an offenSlve motion against the DA7 Have you even once filed a Rule 11 motion. Could you
cite me a specific example with a case number so J can review it? Anything related to prosecutorial mISconduct'
Sometimes you gotta throw a few 'bows to let them boys know that paint belongs to you,
JG ' IRRELEvANT fO YOUR CR!\.11~v4.l GEFENS;:'
I hear JOU about the other side oflbe coin too. though, A defer and dismiss is nol something to sneeze at
and you don't want 10 wake a steeping tig~r...) ing yal1g: .... Sha~c and 8ake.
JG - THE STATE HAS NOT YET OFFICIALLY MADE US A 'DEFER AND DISMISS"
OFFER IF THEY DO, I WOULD ADVISE YOU TAKE IT NO MATTER HOW
STRONG OF A DEFENSE ONE HAS, THERE ARE NO GUARANTEES THE
COURTS WILL AGREE THE MAJORITY OF YOUR CORRESPONDENCE SEEMS
TO CALL FOR IMMEDIATE FILINGS OF MOTIONS TO DISMISS I DON'T SEE
THAT AS A PRUDENT COURSE OF ACTION IN YOUR DEFENSE AT THIS TIME
AS I STATED EARLIER DOING SO PRECLUDES ANY CHANCE OF RESOLVING
THIS MATTER THROUGH NEGOTIATION,
However, what could be done with this new $650 requirement for a grand larceny
charge? Any offensive motions? JC SiC I {\8()VE RE CH/,NC,' Ii', I MJ ',OT YET IN [FFECT [\ T
TiMF OF ;IRREST I listened to the cd you copIed me on, Nothing Jumped out too much except the kid, Goble, I
believe, is clearly and aggresively heard saYing "J am gOing to reach into your pocket right now and get my
phone" ... he comes off kInd of like a whiny suburban skater who, allegedly, would leave a smartpnone on a ledge
unsupervised In the middle of a downtown Reno skate park, amidst citizens 111 a County dealing With an
unemployment right hovering around 15% for three and a half years straight, then not think twice about accosting
a stranger and demanding the stranger open up therr clothing to a search so this skater can ascertain whether his
IPhone IS in that stranger's possession,
He can barely focus long enough to answer a professional sounding 911
operators basic questions, making the operator repeat himself around 4 times WIthin a minute and a half. Goble
seems to, several times, make statements that he and hiS fnends saw the accused take the IPhone right off the
ledge where he set it. It would seem there is a wealth of eVidence and testImony to show that that is plainly false
and a reckless defamation on Goble's part, That offends some people greatly. He got a licensed attorney charged
With a felony. The attorney wound up spending 6 days In Jail and sustaining grave injUry to hiS profeSSional
reputation and busilless concerns, And what repercussions does Goble and hiS accomplices face'
JG ~ INCONSISTEi'1('::Il=S IN TESTlf\~O\lYiSTA'rFr\-1p,jTS 0;-- i)!FcE'<::::,'rr I.Vl rNE:SSES MAY OR MAY NOr
ChUS~: fHF T!<IEr~ GF
rhCT T:':: D1SCRED(T SUC~ Tf:STHvlONY THE COUR r ~~ECOONIZFS THAT TV'JO 01::;;
MORE' PI,RSONS WITN[ SSING A~J iNCID!:!,;T ~,',LY SC:E 0" HEA'~ IT 8Y I U,b!\ TlY ;\N iNNOCENT
MISPECOl LlCTION UKr r:;:',lLUHf: TO PfCO:.~.f(~T IS N01 W,\j Ui,,::::Of,H,H>N ;:x"F>~:;:-N(;t~ 11'\ WEiGHlt\G
THe: AFFECT
or A OISCRf~PANCY, l-Hf" C8u~n CCli:)10::::RS ',\'HETHER !' f/f ~Tf\I'\~~
j -:) f!.,
i\AAl TE~~ UF
IMPORTANCl. OR AN UNIMPD!{ rA~n CE:~;',lL ANC f/; ""h-!b< THE O;S~>::';F.:F;d\;CY HESU ..J S Fi-":()M
1601'77
~i14/:2012
I I() P\1
e--------------~-'.111, 1i\'~.l.'orn, Inall IPrmt '1c~~ages,Jsp'\,.lcpid"-"l)(l.,,
Ilotn''lail Print '-'1cssage
INNOCENT ERROR em WILLFUc r-AlSCHOOD. THUS, 'NE UN A"GUE 1HAT HiE CONFllcr,N3
STAT EMf'NTS Ptr"AINI 0 A ~/AnE::R 0;; IMPORTi\NCL
nils STILL ONLY GOES TO THE
i\~ll ~PE NOT
v'vEiGHT OF TI-i!ll -fLST:M'JNY
lt~
SIf,lPLY 'NNOCFNT EF<ROR [lUT
AfThCKl\:G THE
OF~"ICERS
PROBABLE
CAUSE TO ARRES T VvF'l L HAVE: TO GET THe TERRY PAT-DO\flfN !\ND SU6SE~UENT HAND ON THE PHO~l:
SUloPRESSED. L"AVING THE COURT v'lITH ONLv lief' 'Nil NESS STATEMENTS .\ND BUZZING PIfONF
F()f~ I\, PHOtl,c,Hl E C/,USr- fJ~"Tt:RMINATi()N, [Vf::~ THEN -'1[ 1,-:':OUHr M/:..,Y fiND THE ~Jr f~ICf-P i-1AU
u:r";
PI~OB!~8LE
CAUSE" "f 0 ,t.HRE:ST Y!)U AND T~iE D!SCOVERY CC Tr- P'-~ONE IN YOUR peCKET RECOM:::S
INEVITABLE: AS
r", SEARCH
INC1Dt:NT TO .::..':.zPES"t
On the other hand, the accused can clearly be heard making his own 911 calls, supporting his contention that he
was assaulted and battered and falsely imprisoned
In
a precarious situation on a bridge, and close to oncoming
traffic, while on a bicycle and with his Peking ness dog In tow on a lease_ The accused clearly express that he has
been made to feel scared and threatened by a mob of skater youth, whose culture and attitudes he does not
necessarily understand. The eVidence shows a gleeful display of at least one of the skater youths seeming to
exclaim that he IS a "minor" at 17, and therefore, can do reckless and Irresponsible things to Coughlin, in the face of
Coughlin reminding the aggresive mob that a 13 year old had recently killed 25 year old Stephen Gale on California
avenue dUring the struggle for a purse Incident to an attempted armed robbery.
JG - ThE ~J11 OF YOUR vOlet: COUI.O t)()SSi8LY Hf- USH) 10 U0LSTEf, YOL:::: \~Ht:DIGILI',-Y NUn. YOL:
TO TESTIFY HOV/EVER. THE h::::~!It.,INDER
is
IRR~-~
FVANI TO yOUR CR!L.'1'Nf..._ ~)EFENS[
How is 01 Eva doing? What is hiS exposure here, what IS motivating him' Its a start to get the 911 tapes from the
incident How about the 911 tapes from the days follOWing the incident wherein the Investigator was assaulted and
battered (Cited by incident or case number in the online police report the accused filed and copl2d you on, involVing
Officer Durio and Officer Sarners, who appears In a 1983 case one can find on pacer.gov, litigated by Andrew Boles,
Esq., as all of them seem to be, that involves Officer Barners, and Officer Hartshorn, who seems to make quite
frequent appearances in cases as a 1983 defendant. wherein a guy with a femur poking through hiS skin or
something after cop case saw the cops do some fine "bOXing out" of the paramedics on the scene, apparently
they could get some good attempts at coercing a confession ro consent to search out of the plaintiff.
$0
Anyways, 01
Officer Barnes refused to do much at all when one of the Investigators compiling some of the audiO and video .
evidence In this case was assaulted and battered and subsequently saw his attacker at the same skate park the
Goble Incident occurrec at Officer Barnes couldn't even be bothered to query the early 20'5 female Hispanic
attacker about whether or not she punched a retreabng Investigator
give a fuck"
In
In
the back of hiS head while saying "I don't
response to statements like "I don't think a Judge IS gOing to appreciate your attacking me
physically". Has Eva gotten around to gathering those 911 calls. What investigation has been done regarding the
subsequent police report with RPO that the accused, your client, copied you on. Perhaps If the police have to push
a bunch of paper and respond to a bunch of Icky requests they won't mind to much If the OA loses some Interest
In
pursUing a conviction here, some might say. Sure would be good, and maybe reqUired by the standard of care, to
get any and all other audiO or video created on the night of the arrest in any way relatec to the matters before,
during, and after the arrest. This might include sending subpoena duces tecum to some of that horde of suburban
skateboarders, all seemingly eqUipped with iPhone to help them tweet out that they "just got some good weed and
want to get Anne Franked tonight, n#gga" as seen in the collection of SOCial media postlngs gathered and which
should be in your possession by now. Why, IS it obvious why Officer Ouralde IVoudl so readily find credible that
collection of Anne Franking skateboarders over the statements of a licensed member of the Nevada Bar' And that
170f77
2,'14/20121:10 pl'vl
! lotmail Pfll\! Me~sagc
http:
:oJ 148w bay 1
wil.1 ive.com/mai L'Printtylessagcs.asrrx?cpids=9a .. ,
, "
~
he would be so free to antagonIZe such a person? Does that indicate he isn't much scared of what the PD's office
might do with a fact pattern like this? Have you ever heard the saying, "sometimes you have to get some people
down the steps Just for rep ... "? What does that mean?
J(; - AS
fOl.D YOU BEf ORE Wi ARE.' IN THE PPOCf:SS
O~
SSU'NG SLJCPOENi',S
rUI~
ANY AULIO
RECORDINGS M;\DE BY'I HE POLlCt' E' i HEF, ON THE'K P"RSCNAL RECCRDcRS iN T'iEIR CAi<S.
Zach Coughlin, Estl.

121 I{h'cr Rock St.
Reno, "\' 89501
77;; ,\38 8118
Lict'II.'1cd in I\evada
** Notice*" I'his 1TIt::-',>(1~..:anJ
acc(ltl1rnn)ing dOl'uJllCnh all.' ~('\,::rcd
b) \h..: d":(.'lr<mir CorwnuniC;:Hion-;. Pri"lCY Act. IX U.S C.
~* 2510-2521. and may I.onfain ~onlid~ntinl inrOrmJlion imcnJl"d !(lr the ~rccified individual h) (,nl~'. If:- ou arc not the
intcnd..:d reCipient Of all il!!l.'nl rcsponsihk li)r ddi\ ~1 illg. il (\) lllL inlcmkJ rc(;iplt.:nl. ~ (It! ,In:, hcr(:h~ n()tlfkd thaI ),011 ha'1.!
r~c~i\ ~d this d(l~umcl1l in error and that all;' rC\lt.'w. db,,~nllnati(ln. l:Op~ mg. or Ill.:: takmg ()fall) Jl:!ion bU"l.:d on 11K' I.:l)ntcnt:-. oj'
Ihis in/(WIllHtion IS ')11 idl>' prnhihill..xI.
CONFIDENTIALITY NOTICE:
attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(sj, you
are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the
contents
of this information ;$ prohibhed and may be unlawful. If you receiVe this message in error, or are not the
named recipient(s), please notify the sender, delete this e-maU from your computer, and destroy any cop;es in any
form immediately. Receipt by anyone other than the named recipient(s) is not Q waiver of any attorney-cljent, work
I
product, or other applicable privifege.
IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the Internal Revenue Service, we
inform you that any U.S. federal tax advice contained in this communication (including any attachments) was not
intended or wdtten to be used) and cannot be used, by any person for the purpose of OJ avoiding ta)(-related penalties
or (ii) promotjn!J) marketing or recommendin!J to anothe-r person any transaction or matter addressed in this
communication.
Hearing Date
Sent: Mon 10/24/11 4:07 PM
To:
Zach,
18 of 77
2114120)2 LIO PM
f lotn13i! Prln{ 1\:lesc;agc
http'! hy 14!Sv..bay 148.frf' : 1 live c()ITl!fl1ml/Prinl:Vl(;-:.,>~gcs
a~p\ ':cpld' ()~\..
'-....,r
In my last correspondence to you I wrote that your next hearing was Tuesday, October
26. This is incorrect. The hearing is this Wednesday, October 26,2011 at 10:00 a,m,
in Reno Justice Court
Joe Goodnight
~**********************~*****~************************ ****
Joseph W. Goodnight
Oeputy Public Defender
(775) 337-4839
jgoodnight@washoecounty.us
** Noticc*' This message and accompanying documents are cO\wcd by the electronic
Communications Privacy Act. 18 l),S.c. ~~ 2510-2521, and mav contain conlidential
information intended 1'01: the specified ind'i~idual (s) only. II' YOl; are not the intended recipient
or an agent responsible for delivering it to the intended recipient. }OU are herehy n(\tified thaI
you have received this document in error and that any rnic\\, dis,crnination, copying, or the
taking of any action based on the ctlntcnts of this infiJrmation is strictl~ prohibited.
RCRII-063341 - certain rights of Defendant

Sent: Mon 10/24/11 5:44 PM
To:
zachcoughlin@hotmaiLcom
lach
in a cnnw'.:,.! CJse with appomled couns01 y(x: i'l~we Hi(~ u;Jimale (lutliOJlty o,;pr th-2 fOi'Qv'lIng V,'f1e!h6f to plead guil1y,
whether to V/t!lve a j;Jry (!n a teiony,'gross m:2.{;ernea'iN context), whet~el to les:!fy en your own tJehalf, and whether
to appeal. :Lor!~2_Y.~n;lrne~~, 463 U S. 47~ (1983) s;J~LsQ, ~{~_!.QY.llLhty, ~IJS~l 433 U,S 72 (~977). You also have
the final say In raising an insanity defense. ,.>.:;r.'..!'ls::?11 v St<..~le, 1~ 7 Nev 1:33: 20C~ ~ :\P 0:11er i(1cttcal dec!slons are
up to your counsel nh.YXjf~Y.:~;;tatp, 118 :\Jev 1 ',2002:
You also have the nght t~j Waive C::J:I!'lSE:1 CIne! iepI8sent yourse:f f:-i?fe.tla v C..j[i.~::DI~L 4:::::: U S 8e6 (1975) S~e
alse ~GVt1d3 Supreme Cour! F~uli~ 2::;3
Slncer~ly.
Joe Goodnlgt1i
Joseph W. Goodnight
(775) 337-4839
jgoodnlght@washoecounty.us
** Notice** This message and aceompan: ing documents are covered by the electronic
Comlllunications Privacy Act 18 USc. ~~ 2510-2521, and may contain confidential
19 of 77
ilotlllail Pnnt j\,lessagc
Imp; , by 148~\,bny J 48.ft"
'I
I1r,;-.com;mail/Prinl,v!cssnges,a!:.{)\ ?cpid:.;. ')a, ..
'-..../
information intended for the spccilicd individual (s) only. If you are not the intended recipient
or an agent responsible f()T delivering it to the intended recipient. you are hereby nOli tied that
you bave received this document in elTor and that any re\'k\\. dissemination. coPYlIlg. or the
taking of any action ba,,,d on the contents of this inlllrll1atioll is strictly prohibited.
Trial Strategy meeting

Sent: Wed 10/26/114:35 PM
To:
Mr. Coughlin,
I am available to meet next Tuesday, November 1. 2011 at 3:30 p.m. Can you meet at
the PD's office at that time?
Sincerely,
Joe Goodnight
*******************************************~~***********~*
Joseph W. Goodnight
(775) 337-4839
** Notice** Tbis m~ssagc and accompanying documents are covered by tbe electronic
Communications Privacy Act. 18 U.S.c. ~~ 2510-2511. and may contain confidential
information intended forthe specified individual (s) only. If you are not the intended recirient
or an agcnt responsible for deli\ering it to the intended recipient. you arc hereby notified that
you have received this documcnt in error and tbat any rc\ie\\. dissemination, copying. or the
taking of any action based on the contcnts orthis information is strictly prohibited.
RE: Trial Strategy meeting

Sent: Mon 10/31/11 9:54 AM

To:
loch.
So
ale
yo;; ava!lable 0'1 Friday. NOVE'!~lber 4 to
111E:2f)
:'.isc_ ;"jre )'ou :;fl!c!;JII'i lB,ecung the State's offer?
Sincerely
Joe GOOCrllg!lt
200f77
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llotillail Prim \1cssage
hltp:. 'by 1~8w.bay 148.1'''' ., 1

ive,\:om 'maiIWrillt~'lc~~agc:-'.iJsp:\ '.\:pids;;:;9a. ,
\~'
*******************************************************y**
Joseph W. Goodnight
(775) 337-4839
** Notice** This message and accolllpanying doculllents me covered by the electronic

Communications PriHlcy Act. 18 USc. ~ 2510-2521. and may contain confidential
intormation intended felr the specilied individual (s) only. If you arc not the intendecl recipient
or an agent responsible tor delivering it to the intended reeipH:nt. you arc hereby notitied that
you have received this document in error and that any review. dissemination. copying. or the
laking o(",my aclion based on the wntents of this int(wmation is strictly prohibited.
From: Zach Coughlin [mailto:zachcoughlin@hotma,l.comJ

Sent: Wednesday, October 26,2011 11:35 PM
To: Goodnight, Joseph W

Subject: RE: Trial Strategy meeting
Mr. Goodnight,
1 am booked til Friday, November 4th. Please prepare a draft of a
Motion to Dismiss and a Motion for Sanctions against the prosecutor
for my review. If you refuse to, please provide a very, very detailed
explanation of why and legal and factual support in writing. Please do
not communicate about my ease with anyone at the Public Defenders
Office or the District Attorney's Oftlce outside my presence. Please
provide a complete copy of my entire file. Today you admitted that
my file lack any sort of documentation (such as the Client
Memorandums that you seem to do quite regularly) from Mr. Hylin,
despite the fact that Mr. Hylin felt so ensconced in this case that he set
in motion a chain of events leading to my being ordered to have a
Competency Evaluation done. There are reports that Judge Sferrazza
was furious to have had a bill for this Competency Evaluation
submitted to his Court, and that he intends to redirect the bill to the
Puhlic Defender's office. Please indicate why Lake's Crossing was the
entity I was ordered to use for this evaluation and why I \.vas told r
could not have another professional conduct it.
Please provide any writing, oral attestations, or otherwise that
"lof77
2"4/20121.101'\1
HOlnmil Print
~vle,,<.;agc
hltp;/;by J 48w.bay 148.1' " 1ive.comlmail!Print;'vlessage'. <ll,f)\'?Cplds--9,1. .
supported Mr. Hylin's contention that arguing for a Competency

Evaluation was in order. Mr. Hylin indicated that it was the Publ ic
Defender's Office's contention that he sought such an Order for
Competency Evaluation because, it is alleged, J "kicked fumiture in the
Public Defender's Lobby." I am placing your office on a litigation hold
notice with regard to any materials in any way related to that event or
my case in general. Further, I would like a written and signed
explanation of these accusation, which seem defamatory in that they
simply are not true. Please interview Jessica the receptionist in this
regard and report, in writing, as to her account of that day and how it
jibes with Mr. Hylin's attestation's, especially in view of the dictates of
NRCP II. I did not ask you to stand up in court today and make a
motion or divulge any information related to any alleged discussion of
having a co-counsel an-angement on this case. Task that, in the future,
you be much, much more careful. Counselor. The DA has in its
possession exculpatory video and audio evidence, in addition to audio
and video evidence which shows material witnesses not only
completely contradicting themselves, but also seeking to dissuade
other material witnesses from testifying. Further, other material
witnesses can be seen in this audio and video evidence assaulting and
battering an investigator asking questions related to exculpating the
accused in this matter. Why any of you are not seeking to wash your
hands of this case immediately is so very curious to me.
Tn the United States Supreme Court case of Buckley v. Fitzsimmons,
509 U.S. 259, 113 S.Ct. 2606, 125 L.Ed.2d 209 (1993), the petitioner
alleged the prosecutors and police conspired to link the boot print at
the murder scene with his print by witness "shopping." "At the time of
this witness shopping the assistant prosecutors were working hand in
hand with the sheriffs detectives .... " ld. at 272, 113 S.Ct. 2606. The
Court held the prosecutors \vere not entitled to absolute immunity,
stating: A prosecutor's administrative duties and those investigatory
functions that do not relate to an advocate's preparation for the
initiation of a prosecution or for judicial proceedings are not entitled to
22 of 77
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hup:','by 14S".bay 148.]' " Ii\c.cntn Illai I:PnntMes";agcs.as[)\ '-'cpid::;" !Ja..
absolute immunity. Id. at 273, 113 S.Ct. 2606.

Contrary to any indication in court today, the DA does not play with
some sort of special safety net the rest of the attorneys in the state fail
to have:
Nev.,2000, Office of Washoe County Dist. Atty. v. Second Judicial
Dist. Court ex reI. County of Washoe, 116 Nev. 629. 5 P.3d 562. The
DA absolutely is subject to NRCP 11, and so is Mr. Hylin and the rest
of the WCPD's Office. "In a ease brought by the district attorney to
enforce a Washington child support order in Nevada, the district court
imposed NRCP II sanctions against the district attorney for failing to
discontinue enforcement of the support order after the district court's
previous lUling that Washington had continuing exclusive jurisdiction
to adjudicate the arrearage amount." District attorncy's office, as a
non-party in underlying proceedings to enforce out-of-state child
support order, did not have right to appeal district COlIli's order
imposing Rule II sanctions against the office, and thus writ of
mandamus was an available remedy. Office of Washoe County Dist.
Atty. v. Second Judicial Dist. Court ex reI. County of Washoe. 2000, 5
P.3d 562, 116 Nev. 629. District judge abused his discretion in
imposing $2,500 sanctions against city manager and city attorney for
their alleged failure to participate in good faith in settlement
conference and, therefore, petition for writ of mandamus to prevent
district court from enforcing sanctions would be granted; sanctions .
levied did not fit purported violations at issue. City of Sparks v.
Second Judicial Dist. Court In and For County of Washoe, 1996,920
P.2d 1014,112 Nev. 952.
See Gentile v. County of Suffolk, 926 F.2d 142 (2d CiL 1991) (holding
that a county district attorney's long practice of ignoring evidence of
police misconduct and sanctioning and covering up wrongdoing could
n
01'77
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make the county liable); Claude H. v. County of Oneida, 626 NYS.2d

933 (App. Div. 1995) (holding that district attorney's command that
plaintiffbc unlawfully arrested could support action against county for
false imprisonment).
Nevada Rules of Professional Conduct, Rule 3.8. Special

Responsibilities of a Prosecutor.
" The prosecutor in a criminal case shall: (a) Refrain from prosecllting
a charge that the prosecutor knows is not supported by probable cause;
(b) Make reasonable efforts to assure that the accused has been advised
of the right to, and the procedure for obtaining, counsel and has been
given reasonable opportunity to obtain counsel; (c) Not seek to obtain
from an unrepresented accused a \vaiver of important pretrial rights,
such as the right to a preliminary hearing; (d) Make timely disclosure
to the defense of all evidence or inf01111ation known to thc prosecutor
that tends to negate the guilt of the accused or mitigates the offense,
and, in connection with sentencing, disclose to the defense and to the
tribunal all unprivileged mitigating information known to the
prosecutor, except when the prosecutor is relieved of this responsibility
by a protective order of the tribunal; (e) Not subpoena a lawyer in a
grand jUlY or other criminal proceeding to present evidence about a
past or present client unless the prosecutor reasonably believes: (I)
The information sought is not protected from disclosure by any
applicable privilege; (2) The evidence sought is essential to the
successful completion of an ongoing investigation or prosecution; and
(3) There is no other feasible alternative to obtain the information; (f)
Except for statements that are necessary to inform the public of the
nature and extent of the prosecutor's action and that serve a legitimate
law enforcement purpose, refrain from making extrajudicial comments
that have a substantial likelihood of heightening public condemnation
of the accused and exercise reasonable care to prevent investigators,.
law enforcement personnel, employees or other persons assisting or
2.+ ofn
:/14/20121:10 P\-I
V'
II()t","i I Print \k;sage
hitI':
:hyl~~\\'.ha:
14g
livc.com!mai!iPrinl\lcssngcs.asp''cpids <)il ...
associated with the prosecutor in a criminal case from making an

extrajudicial statement that the prosecutor would be prohibited from
making under Rule 3.6 or this Rule."
Under Brady v. Maryland, 373 U.S. 83, 87 (1963), "the suppression by

the prosecution of evidence favorable to an accused ... violates due
process where the evidence is material either to guilt or to
punishment...."United States v. Shaygan, 661 F.Supp.2d 1289, 1325
(S.D. Fla. 2009) (judge reserved the right "to impose any further
sanctions andior disciplinary measures as may be necessary against
[the federal prosecutors] after reviewing the results of the Justice
Department's investigation."); United States v. Jones, No. CR
07-10289- MLW, 2010 WL 565478 (D.Mass. 2010) (court determined
that imposition of sanctions against AUSA or government for failure to
adequately train AUSA based on failure to disclose plainly material
exculpatory evidence were neither necessary nor appropriate where,
since violation disclosure. AUSA, US Attorney's Office and DO.!
officials took actions such as participating in discovery training
programs, which obviated need for sanctions).
Sincerely,
Zarh Coug.hlill, Esq.

121 Rh'el' Rock St.
Reno, ,'\IV 8950 I
t<l: 7753388118
fa" 94966 1 7402

Lkenscd in
,'\;('v(lda
** Notice'" 1his Jnt;,,<,.agc and m:..::nmpulI) ing dOl.. umtm~ .lIe ";O\l..'r",d
P: Ih\.' ('h:';llllni..; l..'ommuni.,;alion, PII\ a..:) ,\('\. ! X L.~ (',
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(:-0)
l~nl). I r) (Ill arc ni)\ [h\.'
inll.!lldcd [('cipimt or an agent r..... pon..,ibk 101' Jl.:b~'ring it 10 !h~ illll.:nJ~~1 !'c . . ir<..:nL )lllj ,1[:: h.:rd"> nOlitloJd thaI you hd\t: .
n:cL'i\ cd thi .. documen1 in
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and lhal ~Hl) I\!~ i..;\\. db..,>:mil'Ull~)n ...,I]1;'lng. or lh" Wkillg of -ttl> <lclion ha~..:d on tile COllt('nt\ 01'
2,'14,'2012 1.10
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,IiI c,comimall!PrintMcssages,aspx"cpllh"'Ja "

'-./
good for meeting

From: Goodnight, Joseph W (JGoodnight@washoecounty,us)
Sent: Thu 11/03/111:23 PM
To:
1 attachment
Coughlin_Letter_ll_1_1Lpdf (173 KB)
Zach
! Ilave next TUi~sday 11/8111
w 11 :()(: a m
of those limes? 1put the attached Jeter In
Of HhJfsday 11/10;1: (.1: 3 :'~(j;-; rn ,;,'ji;llidh;e to nl(;et

jrh?
CElli yO-J do either
rn3,1 \flO Oiii!~: oal' and wart 1:'J t"lake sure you receh'8 it ShOldrl your
address change, please l10tlfy this office so we can update ou' H::;\lrds
Sincerely,
Joe Goodnight
****************************************************** *~**
Joseph W. Goodnight

(775) 337-4839
jgood night@washoecounty,us
** Notice** This message and accompanying documents are covered by the clectronic
Communications Privacy Act. 18 {jSc. 2510-2521. and may contain confidential
information intended for the specified individual (s) only. If you are not the intended recipient
or an agent responsible lor delivering it to the intended recipient. you are hereby notified that
you have received this document in error and that any review. disscmination, copying. or the
taking (Jfany action based on the contents of this information is strictly prohibited,
From: Zach Coughlin lmallto:zachcoughhn@hotmail.com]

Sent: Wednesday, November 02,20111:51 AM
Subject: need file before meeting foia request, thiS week IS no good for meeting
please do not set anything with me for Friday, thanks,
Zach
Cou~hlin,
Esq.
121 River Rock St.

Reno, X\ 89501
775 338 811~

Licensed in :'\1'\-llda
** ;"IIoticc"'*
Thi~
m..:,,,ug . .' am! accomr,m~ 11l,~~ d~KlJIn-:n~!'o ar~ ..:\)\\.'[\.'d h,I' lh~ .:kC!f\lnir.:: C(lflHllUnil..'atinns PI h <Icy \d, 18
(I, i..;.C
~~ 2510-2521. and m;l~ t:;)lllain c!'Tllidcntlal inl~mn(lii\lJl in:\:;,dl..'d lbr tht: :.pcl.:i fir..'J inJh i{hw] (:-1 ll!ll~ r r) Pll an.: nIH Ihe
inh.;mi-:d r. .'1.:ipicnt N <111 Ufent f..:~pnn..,jhk tor dl'liH:1 ing. 11 to th.: inH.:ndt:d rl"Ciri~ni. ~ nil .HI.: hr:rd': llll1i Jkd 1hal ~ ()u h:.nc
'27 01'77
,/1;1:'1111, I
In rH
II olll1alll'rtlll Message
r~cLi\cd thi:-.
document inl.!rror and thaI an) rcvk\\, disscminminl1. c('pying. Of the takil1g oLmy acliP!1 h'L'.~d onlh!.: ,;om . . . nb 01'
[lib mi"orm:.Hioll i') :micti) rrohihitcd.

CONFIDENTIALITY NOTICE
attorney work product or exempt from disclosure under applicable law. If you
afE'
not the intended recipient(sj, you
are notified that any discfosure, copying, distribution or any action taken or omitted to be taken in reliance on the
contents of this information;s prohIbited and may be unlawful. If you receive this message in error, or Ofe not the
named recipient(s), please notify the sender, delete this email from your computer, and destroy any copies in any
form immediately. Receipt by anyone other than the named redpient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
IRS Circular 230 Disclosure: To ensure compHanee with requirements imposed by the Internal Revenue Service, we .
inform you that any
u.s. federal
tax advice contained in this communication (including any attachments) was not
intended or written to be used, and cannot be used. by any person for the purpose of OJ avoiding tax-related penalties
or (H) promoting, marketing or recommending to another person any transaction or matter addressed in this
communication.
Trial Strategy meeting

Sent: Thu 11/10/11 3:45 PM
To:
Mr, Coughlin:
I'm writing to again attempt to arrange a meeting with you at my office to discuss your
case, I was disappointed to not hear from you after my last offer to meet and seeing
you on the street. I'm available next week at the following times: Monday 11/14 at 11
a,m. or 1:30 p.m. OR Friday 11/18 at 11 a,m. Please let me now as soon as possible
so I can reserve a meeting room.
Sincerely,
Joe Goodnight
******************************~**************.***.**T*****
Joseph W. Goodnight
(775) 337-4839
2S
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2d4.'2012 1:10 I'M
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li",c.col11/rnail!Printrvlessar.es.asp~ '?cpid:,-- t)a ...
.
.
',j
-
! lotl1lail Prill! f\1cssagc
** Notice** This message and accompanying documents arc covered by the electronic
Communications Privacy Ac!' 18 USc. *~ 2510-2521. and may contain confidcntial
inlonnation intended ie)r the specitied individual (s) only If you are not the intended reciplcnt
or an agent responsible for deliv'cring it to the intended recipient, you are hereby notitied that
you have received this document in error and that an:, review. dissemination. copying. or the'
taking of any action based on the contents of this intonnation is stricti: prohibited.
RE: Trial Strategy meeting

Sent: Fri 11/11/11 2:39 PM

To:
Mr (;oug!~lin.
I've already explained
bli! the blilk Of Q,ir
~Ty
posItron
diSCUS-SlOt)
WII!
~eg8rlilnq
fOCt;s
Of)
your
'eq~!est
.;ef(-;1'dlng
Aga!n ;!e can riiscuss
yeuf case F' l e3se
Ir~t
~he
Issue
:::-'m~ny a~
Ot:r nleetlng
me 1\'10\\' 11 yeu can meet on Monday or
.'xt
FlI~~ay of next week dt Cfie of tnt: trrnes I di;~Hgnated Othi.w.vlSt;,!'!i SBB yOll at (lur n-:. 1e:ir:nq on NOlJernber 28,
2011 al 8 30 a
['lIP
Repc Justice Court.
SU"lcerely,
Joe Goodn'ght
Joseph W. Goodnight

(775) 337-4839
** Notice** This message and accompanying documents ~lrc covcred by the clectronic
Communications Privacy Act. IX l:SC. ~~ 2510-2521. and m3) contain confidential
information intended fllr the specified individual (s) only. If you are not the intended recipient
or HIl agent responsible j(lr delivering it to the intended recipient. you arc hereby notificd that
you have receivcd this document in error and that any review. disscmination. copying, or the
taking of any action based on the contems of this information is strictly prohibited.
From: Zach Coughlin [mallto:zachcoughlin@hotmail.comJ

Sent: Thursday, November 10, 2011 4:14 PM
Subject: RE: Trial Strategy meeting
Please respond to my FOrA request in writing and provide a copy of my entire

file, including all conespondences with anybody.
29 of 77
,'1'1;,0121:10
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'-../
Zach Coughlin, Esq.

121 RiHr Rock St.
Reno, 1\'V 89501

7753388118
Licens{'d in I\evac\a
*,~ Notice'
* rhis mc\",afl~ and <'1C1.'ompan.\ 109. dllCllm~nh lire ~'(l\~lcd
h~ tilL" I.'kctrnnit: (. 'nmrnunicati(ll1\ Prh (ICY '\c\. IX (I.S.(.
*~ 251O-2)~ I. and nwy contain elmlitkiltialillfurmarioll imcn.[ed i'llr tilt: ~pccilid indiviJual (\) on!~. If you (lrt' nN the
in\~'ndcd
recipicnl N an agent rc\r{)ll~illk j()r dl.!li, cring: il 1(1
\Ile
inlclllkd I'cdpknL. ) (lU ~\rc hCI'l.::h~ not i!icd lhat ~ (Ill have
rcccin:d thi,; documcnl in error <lnd that Jny rc"ic\\. di ...:-.c:minatioll. cop~ :ng. or thc lilJ...ing 01'.111), action ha'icd nn the conlt.:nt-; of
Ihi:-. informatIOn is <;(ricti y prohihited, This message;s confidential, intended only for the named recipient(s) and may
contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recip;ent(s), you are notified that any discfosure, copying, distdbution or any action taken or
omilte>d to be taken in reliance on th~ contents of this in/ormation is prohibited and may be unlawful. If you receive
this message in error, or are not the named recipient(s). please notify the sender, delete this e-mail tram your
computer, and destroy any copies;n any form immediately. Receipt by anyone other than the named recipient(s) is not
a waiver of any
attorneyclj~nt,
work product, or other applicable privilege.
Subject: Trial Strategy meeting

Date. Thu, 10 Nov 20111545:26 -0800
From: JGoodnight@washoecounty.us
To zachcoughlin@hotmalLcom
Mr. Coughlin:
I'm writing to again attempt to arrange a meeting with you at my office to discuss your
case. I was disappointed to not hear from you after my last offer to meet and seeing
you on the street I'm available next week at the following times: Monday 11/14 at 11
a.m. or 1:30 p.m. OR Friday 11/18 at 11 a.m. Please let me now as soon as possible
so I can reserve a meeting room.
Sincerely,
Joe Goodnight
*************x************************~******x************
Joseph W. Goodnight

(775) 337-4839
jgood night@washoecountyus
** Notice** This message nnd accompanying documents arc covered by the electronic
Communications Privacy Act. ]8 C.S.C. s 25] 0-2521. and may contain contidenlial
information intcnded for Ihe specified individual (5) Oilly. If you are not the intended rccipicnl
or an agent responsible for delivering it to Ihe intended recipienl. vou arc hereby notified thai
you have received this document in elTor and that any review. dis~cl1lination. c~jlying. or'the
taking of uny action based on the COI1lCI1lS of this information is strictly prohibited.
Wof77
214'2012 1.10 P~I

....../
'
http:',b, 14S",bay
14RJ~\LCOm!mail'l'rint~
kssages,aspx',"pids=<)a"
'-'"
RE: temporary address change and instruction to pursue a

continuance
From: Goodnight, Joseph W (JGoodnight@washoecountyus)
Sent: Tue 11/22/111:39 PM

To:
\1r. ()I[gillin.
't h~ pre-Ilial h. .'aring: h I1C$ l\.l{\l1d~!>. 'l)h'mh.'r ~X, 2{J: 1 ;)[ ~'~() <un !)~'-:(l,",'" (H! i~ e al r: J ~ tUll. I'm ::'01'1'.\.
but I uon'! S~C ~.o{ld ('.Ill'l' f~)r a cl.l!ltinu~lllct..' .md (an'l r-.:qu ..'sf Olh.' \\ ilhnut slItll You \\\..'It.: !H1!;!1ed l)frh~
hearing ill CP!!!~ tJfl OCI()h:'1 26 b~ tCHr-ou! and ;'g~ll!l {\O '\.qn:mh:.'r i i h:- '-Iliad 'Your (irculllstallct.:"!) lip
not wflrranl a contilH!dIH..'I.' a:-. ) I)\{\C pl~)l. id('{\ Ih~ !\'il'...(lil \\ h~, :',)U ca!lilnt ~ll\~tld (n('II.
Regarding :I)ur doc\!In\'~111 reqllc'it: "gain. 11k!i~\t..' I ha\"~' prP\'j(kti :Oll \\i1.ll \"\':".'f.\1hlll);! in )$111' tik Ihat
-' Ill!
an.: en! ItJcd to,
Silll'LrLI~ .
Joe (io()cini),!ln
**********************************************************
Joseph W. Goodnight

(775) 337-4839
** Notice** This message and accompanying documents are covered by the electronic
Communications Privacy Act, 18 lJ.S,C ~~ 2510-2521. and may contain confidential
information intended for the spccitied individual (s) only, If you are nOl the intended recipient
or an agent responsible for ddivering it to the intended recipient. you arc herehy Ilotilicd that
you have received this document in error and that any revie\\'. dissemination. COpyIng. or the
taking of any action based on the contents of this inJofll13tioll is strictly prohibited.
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, November 21, 2011 3:44 PM

Subject: temporary address change and instruction to pursue a continuance
Dear Mr. Goodnight.

I have been evicted and perhaps subject to an illegallockout and unlav;ful rent
distraint by Richard G. Hill. Esq., who is withholding my state issued
J 1 01'77
2/1420121:10
P~l
llotmdii Pnnt \-lcs5age
indentification, wallet, and all materials necessary to my law practice. J am .

instructing you to pursue a continuance of the upcoming hearing, r cannot even
access when that hearing is. Please contact DDA Young in writing to request
one, and failing his assent file a Motion for Continuance with the court.
Dear R.JC, Ms. Stancil:
Please note that my tcmporary address for now is:
Zach Coughl in, Esq.
elo Silver Dollar Motel
817 N. Virginia St., Unit # 2
Reno, NV 89501
Richard G. Hill, Esq. is withholding my phone as wcll. Email is the best way to
get ahold ofmc.
Further contributin(] to the need for a continuance is vour failure to provide the
o
.
materials I requested of you in writing and in a FOlA request.
Sincerely,
Zach Coughlin, Esq.

121 River Rock St.
llenl>,lW 89501
775.1388118
Licensed in Nevadn
H ,'otit'-t'''* rhi,,> llle~.,Dg\! and 'h.'L'\'ITlf)nn~ ing {h::umem" <lIe l\JI. .... rcd b) the (.'k":lronic (
~9 2510~2521.
nmrnllnll"ltinn,. Pri\':J() At;L 1g ll.,'., C.
and nut) (ontain COIII\h:nli:d inlorrnmjoll :1l1t:nd",'I] t;,1 tile '>p('cilil'd indi' idu,lI h) (l1l1~.It':Oll an; J1t11 {he
intendeu recipient or an agent rc"poJ1:.ir,k-
recein:d thi:-; Jocumenr tn <:rror and tl1m
I'M
ddivl..'ring
iln} f\.."\
It to the inlcmkJ rccip;(:nr. :' Ull ar..: Ilerel!~ nOlllicJ Ihat )()U 11,]\ G
il."'~, lli:-::.er:linalion. l'()P~ illg. or the taking ill' J.1l\ ddi,ll\ bav.:d on dh.' ~onll.:nh nf
lhi.., infnr'lllalioll is "lrll.'li) rlOhilmd. This meSSOje is confid>ntial, intende-d only for the named recipient(s) and may
contain ;n[ormaUon that ;s privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recipient(s), you are notIfied that any disclosurl!, copying, distribution or any action taken or
omitted to be taken in relianel! on the contents of this information is prohibited and may be uniawful. If you receive
this message in error, or are not the named recipil!nt(s), please notify thl! sender, delete this e~mail from your
computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not
a waiver of any Qttomey~cUent, work product, or other applicable priviles>.
3~
01'77
2/14'2012 1'10 PM
Hntmni! Print ,Ivtessagc
http'i-by t ~8w,hay 148 '

live,comilllaiIfPrint\.lesc;agcs.asp.\'.'cpids:c-()a ..
'-..../
Client meeting ~ Trial strategy

Sent: Mon 11/28/11 3:53 PM

To: zachcoughlin@hotmail.com
Mr. Coughlin,
We are available to meet at the date/times listed below. Please choose one and I'll
reserve our conference room for the meeting.
Friday, 12/2111 @ 10 a.m.
Friday, 12/2/11 @ 11 a.m.
Monday, 12/5/11 @ 11 a.m.
Friday, 12/9/11 @ 10 a.m.
Friday, 12/9/11 @ 11 a.m.
Sincerely,
Joe Goodnight
****************************************~************* ****
Joseph W. Goodnight

(775) 337-4839
** Noticc** This message and accompany ing documents are covered by the electronic
Communications Privacy Act. I S USc. ~~ 2510-2521, and may contain conlidential
infom13tion intended Cor the specilJed individual (s) only. 11' you are Ilot the intended recipient
or an agent responsible lor delivering it to the intended recipient. you 3rc hereby noti1ied tha't
you have received this document in CI1"or and that any revie\\'. disseminaTion. copying. or the
taking of allY action based on the contents or this information is strictly prohibited.
FW: Coughlin - DA#432068

Sent: Tue 11(29/1112:31 PM
To:
rvlr. Coughlin.
Below is the offer that was tendered by the State in October and that I prOVided to you
on October 26,2011. At that time YOLI expressed that the offer was unsatisfactory In
13 OT 77
lot mail Print \'Ie~s(lge
Iivc.(om: mar I, Print.\ks'>'lges .aspx.'cp Ids 9a ..
passing yesterday, DDA Young stated that he wouid re-open the offer if you wished to
accept it within a reasonable amount of time, Ii you would like to accept the offer at
this time, it appears that you may do so Howev;;I', DDA Young WII! not keep the offer
open forever. Until I hear otherwise from YO'J, I will proceed as if it is still rejected and
we are going to tnaL Please let me know what you deCide
Sincerely,
Joe Goodnight
****************************************************** *~*~
Joseph W. Goodnight

(775) 337-4839
jgoodnight@washoecounty,us
** Notice'* This message and aCCOll1pan~ ing documents arc cOI'cred by the electronic
Communications Privacy Act, 18 U,S,c. ~~ 2510-2521. and may contain confidential
ini(H'!11ation intended for the specified individual (s) only. If you arc not the intended recipient
or an agent responsible I(lr delivering it to the intended recipient. you arc hereby notified that
you ha\c received this doculllent in error and that any review. dissemination. copying, or the
\8k ing of any action based on the contents of this information is strictly prohibited,
From: Young, Zach

Sent: Tuesday, October 25, 2011 8:35 AM
To:
Goodnight, Joseph W
Cc:
Spencer, Darcy
RE: Coughlin - DA#432068
Subject:
Sorry, got caught up with a pretrial

Mr. Coughlin can get mental health eval and if counseling is recommended and
medications prescribed, he can plead gUilty to Petit Larceny as charged. set
sentencing out 6-8 months (or thereabouts) and if he obeys all laws, abstains
alcohol/non-Rx drugs, takes Rx meds as prescribed, and abides by
counseling/medication recommendations (with updates provided and final letter from
counselor saying he is dOing well. etc,), State Will allow him to withdraw his plea and
dismiss the case with prejudice, An informal diversion If you will,
If no counseling is recommended or if Mr Coughlin chooses otherwise, he can plead

guilty to Disturbing the Peace, stlP 180 days WCJ sIs, mental health eval follow recs,
abstain alcohol/non-Rx drugs, obey all laws, take Rx meds as prescribed,
I am CC'ing Darcy, who is covering file for me tomorrow afternoon.

Zach
Hotmail Print tvle..,..,age
'.Iive.com 'mail;Prinli\ lcssagcs.asp>. ?cpld:,"'9a ..
From: Goodnight, Joseph W

Sent: Monday, October 24, 2011 5:54 PM
To: Young, Zach
Subject: RE: Coughlin - DA#432068
Friendly reminder
Thanks.
Joe
to send that offer over.
Sent: Monday, October 24,201111:19 AM

To: Young, Zach
Subject:
Coughlin - DA#432068
Zach,
Please call me when you have a chance, I'd like to discuss negotiations in this case,
Thanks,
Joe
*****************************************************~ ****
Joseph W. Goodnight

(775) 337-4839
jgoodnight@washoecountyus
** Noticc" This message and accompanying documents are covered by the electronic
Communications PrivacY Act. 18 USc. '~~ 2510-2521. and mav contain contidential
"
,
inrormation intended ttlf the speciticd individual (s) only. If YOli are not the intended recipient
or un agent responsible ror delivering it to the intended recipient. you are hereby notified that
you have rccciv cd this document in error and thut any revicw, dissemination, copying, or the
taking of any aClion based on the CDntents of this information is strictly prohibited,
~
FW: Client meeting - Trial strategy

From: Goodnight, Joseph W (JGoodnighl@washoecounty,us)
Sent: Thu 12/01/1111:34 AM
To:
Mr. Coughlin,
I'd like to address several topics from your email on 11129111, First, I had already
requested the audio recordings of the hearings and can provide you with a copy.
Second you can bring a friend to the meetmg, but must understand that doing so may
3S 01'77
2!1-!f20121:IOP~1
110In1l1ill'rint ~1CSS3gC
http::/by1.!8w.bay 148.
li\ e.colllmail;Prilll\icssages.asp' ?cpid\~0:l ...
'--./'
jeopardize confidentiality as the attorney-cilent privilege would not extend to that

person, The pnvileg~ is yours to waive If you wish to do so. Lastly, our conference.
room is the best place for tills meetina to occur as we'll ilave plenty of room, whiteboards to use In brain-storming, and audio-visual equipment to review the videos, I've
included the possible meeting times again below and encourage you to respond In a
timely manner so \ can make the necessary arrangements
Sincerely
.Joe Goodnight
********************~***~******************~~********* ****
Joseph W. Goodnight

(775) 337-4839
** Notice" This message and accompanying documents arc covered by the electronic
Communications Privacy Act. 18 U,S,C 2510-2521. and may contain confidential
infol111ation intended for the specilied individual (s) only. If you arc not the intended recipient
or an agent responsible I(lr delivering it to the intended recipient. yo 11 are hereby notified that
you have received this document in error and that any revle\\'. dissemination. copying. or the
taking of any action based on the contents oflhis in/lmnation is strictly prohihited,

Sent: Monday, November 28, 2011 3:53 PM
To:
'zachcoughlin@hotmail.com'
Subject:
Client meeting -
Trial strategy
Me Coughlin,
We are available to meet at the dale/limes listed below. Please choose one and I'll
reserve our conference room for the meeting,
Friday, 12/2/11 @ 10 a,m,
Friday, 12/2/11 @ 11 a.m.
Monday, 1215111 @ 11 a.m.
Friday, 12/9/11 @ 10 a,m,
Friday, 12/9/11 @ 11 a,m,
Sincerely.
Joe Goodnight
*********************************~*~************~***** ****
Joseph W. Goodnight
')6 ur77
liotl1laii Print \1ess3ge
(77 5) 337-4839
jgoodnight@washoecounlyus
** Notice** This message and accompanying documents arc co~crcd by the electronic
Communications Privacy Act. Ig L.S.c. ~ 2510-2521. und rnay contain conlidential
information intended J()!' the specitied individual (0) only. If you arc not the intended recipient
or an agent responsible I()f del ivcring it 1O the intended recipient. you are hereby noli lied that
you haw received this document in em)r and that am rcvkw. dissemination, copying. or the
laking of any action based on the contents oflhis information is strictly prohibited.
Recend documents received

Sent: Wed 12/07/11 2:36 PM
To:
zachcoughli n@hotmail.com
2 attachments
Coughlin.Amended.Complaint.pdf (66.4 KB) , Coughlin.Discovery Received.llJO.ll
.pdf (561.3 KB)
<: <CQ..::~'::l i :1 __AiC:::k(_ C~)::';:-; .... ':":-:t pj~ :> '> ~,-: ::.:::,1':.1.'11 i r: _ D.: 3 C;-.' \;e ::1' :; i.Y~i'.;:: -:n~i : : . ' (I . 11
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RE: can you meet next week

From: Goodnight, Joseph W UGoodnight@washoecounty.us)
37 of 77
:'14i2012110PM
. livc,comhnail'Print\1e:;sages.l1sp'\\:pids~9a ..
http: lh) 148\\',ba) 14R.
~~/
Sent: Wed 12/14/114:51 PM

To:
Mr Cougtllm.
We C-<Hl nh~t-}t next Mon..J3y C! I~,esrj;:r!' aherno,),~ 8t 4 f):J i~ f~ (p;~:i~:",;jJIV -..'eSG~lV~
me ,1;111 LOSIIr. ann Fvo NO'",",k
.'~Il
of
Pa:t:t..:{O<1nrs wollln::::ludp yr:i!,
)t'~:(.(l i:lrr,: !~"jerf:(l unrl(\( ;y!:rYfli"'/ ~~iI(.i~j :lrl'./ik?~;(;)
Aq8IP. you are l:vulGo(')f' 1(:, t'.!: Ell:Jst re~ltz;:: [1m: :" (' at1Grrk~y
C;,(:f'lt ;)P'/lit);}f:
9"Jrdt';
/d~::
you /)llllglng ..111'lor't!)
d(~e~; ;;:,'; ("y.;el:l to thai
petson
win be
Here IS what you can expect fr::;m this nieeling \ve
discussjng rl1C n)~!lon tD sJPpress thaI we'll hie in you
case and review tnal strategy:" JPuaros to the ev'ornee we ca', expect !h~ St,lle w'ill try 10 pI ('sent \lVe'!lIGVleW Hie
[:ludlo eVidence
wt)
I':j\sh to present and 2:Jrlpar8 l: 10 the w:wess ~lc:tel;1ents a'ld pcJ!{~'e report, dtscusstn~! how to
best pli~sent the jlscrepancles bet\','een the tw,~ 10 disc edt;: the State's wllnesses and ~a\'.' enforcr:mer,t \l'Ve'\\ ge\
an updiJtc ffern L~v[) as to tt1e iJ;U~lrc% (,f fliS ~nv8s:lgfl!i0!1 '/Ile (';1n ',:;;cfly 30-jrcss sarrle C'f y()~lr other conO:1I1S ~.,n(l
liemands. bur the majonty of thE- Pl0i::':il;19 Will bG cledicatec to tl:oi prep.a1il: 0;1
Lastly IS the address DIOVldGd beio'v your curren: sddl!;ss') ! haw: lhe
d;::~rel~t
where to send them as ttm; is
nJl: iJudlo heanngs fOf you but I'm no! sur~
if ;)Pl the lalE:'st adaress we nave on file
Smcerf;IY,
Joe Goodnight
Joseph W. Goodnight
(775) 337-4839
Jgoodnlg hl@washoecounly.us
** Notice** This message and accompanying documents are con:r~d
hy the electronic
Communications Privacy Act. I XUSc. ~~ 2510-2521. and m,J\ contain cnnticicrniaJ

information intended for the specitied indivIdual (s) only. If you are not the intended recipient
or an agent responsible for del ivcring it to the intended recipient. you are hereby notitied that
you have received this document in en'or and that any revielV, dissemination. copying. or the
taking of any action based on the contents of this information is strictly prohibited.
~
>
From: Zach Coughlin [mailto:zachcoughlin@hotmatl.comj

Sent: Wednesday, December 14, 2011 3:21 PM
To: Goodmght, Joseph W
Subject: can you meet next week
when would be a good time to meet next week?

Zach Coughlin, Esq.
817 N. Virginia St. #2

Rello. NV 8950 I
2,14120121:10 PM
1lotmail Prim lvlessage-
l1ttp:J,b~
'.li\c.com:'11l3i I, Prillt\ lcssilgl's,asp\'~\.:plds - lid"
148\\ ,bay 1-l8
V
lei: 775 2296737
fax: 949 6677402
Zac hColigh Ii 11 fgi hO\m3 i I.colll

Nevada Bar No: 947.1
lllcs~lge
Idt
l\'otice** Thb
9~
2510252L ,mli
1l1a~
,mJ w,:l:ompan) ing drn.:umcnh art: cOH'rt'd h~ the I!k..:mmlc C)mnllJl1lcali\\n~ Priv:.lc) Acl. J 8 U,S C
contain cOllliJ..:nlialinfoflnalilHl inktitl!d j()r the ;-.p.:t:iticd Indi\ iJll:Jl (..,) onl). It yOll arc not the
ill1cndcd rcciri.:nt or an agenL rC"Jlnl1~ihlc I~)r ddivcrinr it tl) thl! inll!mkd r~ciri(.nL ~ I'll are hcrehy 1l{l[iJiL'd that you hen t:
n:t:dvcd [hi:-. dm;lHn,,:.n\ in
tlli<.> inji)rnwtion
i~ 'it! i...'Lly
~fmr :lJ)l\
I\),)t UI1) r..:\ i~'\'\. dh'oc-mm;\lion, wp> 1nt:'. nr I\h' \:oll,...in)l ()f'.ln> d.;\j\,n
ha~\.:d nil
the c~\nh:n\" n\
rl'llhihikd. This message is confidential t intended only for the named recipient(s) and may
contain information that is privileged, attorney work produ(t or ex-empt from disclosure under applicable law If you
are not the intended recipjent(s)t you are notif;>d that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawfuf. If you receive
this message ;n error, or ore not the named rE'cipient(s), plE'ose notify the sender, delete this e-mail from your
computer t and destroy any copies in any form immediately. Rece;pt by anyone other than the> named recipient(s) ;s not
a waiver of any attorney.cHent work product, or ather applicable privilege.

t
RE: I respectfully request a jury trial

Sent: Fri 12/16/111:30 PM
To:
3 attachments
NRS_175_011.rtf (94.7 KB), 99_Nev_806.rtf (114.2 KB),

nevada_supreme_courtJule_25.rtf (91.2 KB)
Mr C()lI~hIIC.
ft.,s Judge Sferu.uza explaine:L Vie ~r;'l'~ ~a\"0 d I!gtlt!O a Jury tfia! )" yOU( caSl:. n,e peftlner:r statute IS NHS
175,0:1 8~1~ the case hE:;!s lll(ely' rde"I:lg to's SiQ!ej SOJlli~" 99 Ncv 80G j v(~ ,~ttachdd tJOlfilO tillS emilil
Because rnlsclemeancis are' petty-" l~fteriSes. tOle rtgnt!.o a jury tllal :Joes nct attacfl
Ad;:HlOna:!y I've attached Suprm:'l(O Court R:;!e 253 it IS clear :!,at yet.; are unsatisfied With 'low I am handling
your case despite my numerous atren'pls to 8'"lanve a meeting with you to disc:JSS thA motions you are suggesting
~md consult wl~h you in preparation 10( tr1d! "fleWl. yo,! have the ngnt to represent yo~,lself Piease let me knov! if
you Wish to do so
SIllCele!y,
Joe G~odnjgt1t
**********************~**~*.******~***********************
Jr)
01 77
HOlnmil Print \less.lge
hilI', 'by 1-18\'. bd)' 148."
J .livc.(om:malj!Prim~les$ages.asr\:'~cpids~f)a
,....,/
Joseph W, Goodnight

(775) 337-4839
** I\'otice** This message and a~companying dOClll11~Jlts arc cmwccl by the t:iectrDnic
Communications Privacy ACL I R USC ~~ ~51 0-25~ L and may contain conJidcntial
in/clrmation intended IClr the specitied individual (5) only, If you arc not the intended recipient
or an agent responsible for delin:ring it to the intended recipient. you are hereby notified that
you have received this docllment in error and that any review. dissemination. copying. or the
taking orany action based on the contents of this in/clrInation is strictly prohibited.
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Friday, December 16, 2011 7:04 AM
To: Sferrazza, Pete; Goodnight, Joseph W; Young, Zach
Subject: 1 respectfully request a jury trial
I have made clear previollsly thai I wanted ajury trial and strenllou,l, objected the the serting that
occurred before JlIdge Pearson rccentl, and ask that I he aftl1fed mv rig.ht to aJurt" trial. especiallv to the
extentlhnt Mr. Goodnight continues 10 reruse to file an) oCthe motions I ask himlo tile. Motions III
Limine. Motions to Dismiss. to tak.e nn) depu:;itions.
Dr
othen\l-;e In an: thmg that would seem 10 result ,n
Lealously advocating onmy behalf. Addilional". Mr. Le,lie ordered Mr. G()odnlghtnot to speak atlhe last
hearing.
RULE 38. JURY TRIAL OF RIGIIT

(a) Right Preserved. The right ortnal by jury as dedared by the Constitution orthe State or as given
by a statute (lfthe State shall tx: preserved to Ihe parties inviolate.
(b) Demand, An) palty may demand a Irial by jury of nny issue triable of righl oJ ajury by serving as
required by Rule 5(b) upon the other parties a demand [herefor in writing: at any time alier Ihc
commellcement oflhe actioll and 1l00Iater than the time ofth,' elltr) of the order tirst sening the case I<H'
trial.
[As amended: dleclive .Ianua,y 1.2005,)
(e) Same: Specilication ofl,sucs. In the demand a pany may 'p,'<'i(, the i'5ues \\hich the rnl1)
wishes so tried: otherwise the part) shajJ be deemed 10 have demanded trial by jur) 1,,1' all the issues so
triable. Irthe party ha:-. JC'JJland~d lrial by Jury for onl: ..,om~ of the iss,lIe:;. any other part) \\ithin 10 day,;
2/14.'2012I,IOPM
rlotlllali rrinr \1cssage
http::byl-l3w.bajl-18.
'lhe com.'l1IlJiI;Prill[\1c'i:.agcs.nsp)o,')cp1ds 9n.
\or"
ancr service oCthe demand or such lesser time a:; the eOllll 111(1: order, may serve a demand for trial hy jury
of any other or all of the issues of fact in the action.

[As amended,
en~cti,e
January I. 2005.J
(d) Waiver; Deposit of.Jurors' Fees, The failure of<! party 10 sene a demand as required by Ihis rule
and 10 file il as rCl.lUired by Rule 5(d) constitutes H waiver by Ill:.: p8rt~ of trial b) jury Unless the district in
which the action IS pending has adopted a local rule pursuant to Rule 83 d~clarillg otherwise, at the time a
demand is tiled as required by Rule SId), the party demanding the Irial by jury shall deposit with the clerk
an al110unt ofmoncy equal 10 the fe'es 10 be paid Ihe Irialjurors for Iheir services fl,r the t,rst day "flrial A
demand for trial by jury made as herein provided may be withdrawn only \\'ilh Ihe consent of the panies.
or for good caLise :,hown upon '::illch terms and conditions as the c()urt ml} fi.\.
Zach Coughlin. Esq.
817 I\. Virginia St. #2

Reno, 1\\1 8950 I
tel: 775229-6737
fax: 949667 7402
ZacItCoughlin@hotmail.com
Nevada Bar No: 9473
*" Notice"'* This ml..!s">agt; tllld
** 2510-25:21. :Jnd
illl~ndl.:ll r\.~ipi~nt
ma~
a.;compall~ in~ liOI.:umcllh
tll": >':O\'crL'd hy tho: ckctrlulil
(Ofllil111f1i~'d!I{)II~
. . IlIlWill cOlllid(,lllial inl(lrIllmi011 inh.'IlLkd lnr thL' spl..' . . lIkd indi\ il~UJj
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nr an a~em rcspons,ibk for d..:.li\.:ring i\ 1n the inlCntkd fl'l:lPI"::n\. >o\.} Jr..:: h":ld,: l)<)\ilicd lhil't ;()\llmvi.:
rIo!CL'i\'lXI [hi .. do(;ulrI.:n! ill error and thal an}
fl,\j :w.
Jj;;~c!1ljrl;:)tinll, coP.\ illg. nr rh . ., taking III an} a..:li(lll hased nn th..: l'()Il!t.:rlJ~ (lr
thi:-, inlixmaliol1 i'l sln~tl~ prohihitcd. This message is confidential, intended only for the named recipient(s) and may
are not the intended recipient(s), you are notified that any disclosure, copying. distribution or any action taken or
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From: i:;iUtm~v'$JIU'~ (JGoodnight@washoecounty.usj
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From: Goodnight, Joseph W (JGoodnight@washoecountYcusj
Sent: Mon 12/19/11 10:49 AM
To:
Mr Cough!irl,
I've cleared t~e 4 00 P In time sIc: fo:- ;hs 'Nednes:..iay if yO'J wou:d
Joe CoorJnlgrn
Dr..0
to meet
Joseph Wc Goodnight
(775) 337-4839
jgoodnlght@washoecounty.us
** Notice** This message and accompan> ing documents arc covered b) lhe electronic
Communications Privacy Act. 18 (icS.C 'i~ 2510-252 Land ma) cnntain confidential
4501'77
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information intended for the specified individual (s) only. If you are not the intended recipient
or an agent responsible for delivering it to the intended r~cipient. you are hereby notified that
vou have received this dowment in error and thal ,In\ rc,iIC\\'. dissemination. copying. or the
;aking orany action based on the contents of this inl~rmali()n is stricti: prohibited.
From: Zach Coughlin [ma,lto:zachcoughlin@hotmail.com]

Sent: Friday, December 16, 201111:18 PM
To: Goodnrght, Joseph W
Subject: RE: I respectfully request a JUry trial
Hey Joe,
Lets meet next week, how about Wednesday? Does a time on
Wednesday work for you?
Thanks,
Zaeh
Zach Coughlin. Esq.
817 N. Virginia SI.
#]
Reno. NV 89501
tel: 77S 229 .. 6737
fax: 949 667 7402
ZachCough Ii n~{~hotlT1 ai I. co III
Nevada BHr No: 94i3
1<*
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contain information that ;s p,;vileged, attorney work product or exempt from disclo5ure under applicable low. If you
are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents 01 this information is prohibited and may be unlawful. If you receiv'e
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this message in error, or are not the named recipient(s). please notify the sender, dele~e this emaiJ from your
computer, and destroy any copies in any form immediately. Rpceipt by onyone other thon the named recipi~nt(s} is not
a waiver of any
attorney~cI;ent,
work product, or other applicable privile1.
Subject: RE: [ respectfully request a JUry trial

Date: Fri. 16 Dec 201113.30'02 -0800
From. JGoodnight@washoecounty.us
To: zachcoughlm@hotmail com
Mr CDU9~\\i\"lt,
.As Judge Sfenazz~1 explained we dor;t have a {'gnt to a Jury in,J' in your case
175011 anc the r.(lse
f)(;
is like~y f'3fcrnng t~ is S~~1tt; v Smlth. 99 ~('v S06
!'Jf::
The Oeri!l18nt statute is NRS
allach:'c bot!) to this emC:ill
[3ecausd I)llsderneanurs arfj "petty" offf'r'~'(':; tt1e fight to,~ JWY [rIn) do.';'s 110t at1dch
Additionally I've attaChed Supel::e Co~ri Rule 253 Ii IS clear tbat you art: llnsa~!sh~d with tlo,,", ! am hand:mg
your case despite my )'urr.efOUS Jtemp'is U: ;J:-range a meeting wllh you tc d:scus:s [he:: motions you are suggesting
and consult with yOU in proDaraLon for trial ~\gain you [lave Hie rl9ht to lepresent yoursE-ljf Please Jet me know If
you wish to
fjO
so.
SlnC8!('iY
Joe Goodrllght
*********~************************************************
Joseph W. Goodnight

(775) 337-4839
** Notice** This message and accompanYlIlg documents arc covered by the electronic
Communications Privacy Ad. 18 USc. ~> 2510-2521. and may contain confidential
information intended lor th" specified individmi (s) only. It'YOlI arc not the intended recipient
or an agent responsible for delivering it to the intended recipient. you are hereby notified thal
you have received this document in en'Ol' and that any review. dissemination. copying. or the
taking of any action based on the contents of this inl()fmation is strictly pmhibitcd.
From: Zach Coughlin [ma,lto:zachcoughhn@hotma,J.comj

Subject: I respectfully request a jury trial
I hav..: made cleHr previous.ly that I wanted a jury trial nnd 'itrclHh)tls\y ohjectcd tile the setting thai
occurred bdo,." Judge Pearson recently and a5k that I be aj]('r~d 111~ right to alurty trial. especially to Ihe
extent that MI'. Goodnight c(lntinu~s to refUSe (0 fite any of the motion". l a~k !,im lo file. Motions in
Limine. Motions to Dismiss. to lake any depositions. or otherWIse do anything that would seem (0 result in
47or77
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IlolllJail Pr illt iv1cssage
zealollsly advocating onmy behalf: Additional). iVlr. Leslie ordered Me. Goodnight not to speak at the last
hearing.
RULE 38. JURY TRIAL OF RIGHT

(a) Right Presened. The right of trial by jllry as Jecilired by the Constitotion ofthc State or as g"en
by a statllte of the Stale shall be preserwd to the parties i,,, iolate.
(b) Demand. Any part) mao demand a trial by jllry of an) isslie triable of right by il jury by scrv illg as
required by Rule 5(b) upollthe other panic, a demand therclor in writing at any time after the
commencement of the action and notlakr lhall the time oflhe ciltry oflk order ~rst setting the case
tri<ll.
IAs amended: effective Janllal'
I,,,
I. 2005. J
(e) Sallie: Spccilieation of Issues. In the demand " parl~ Illay specify the ISSUeS \\hieh the party
wishes so tried: otherwise the parly shall he deellled to have demanded trial by jUlY lor all the issues so
triable. If the party has demanded tt ial by jUt" (or only some of the isslies. an) other party" ithin 10 cia) s
after servicc of the demand or such ksser time as the cOlin may order. nHI) sen e a demand lor trial by jury
of any other or all ofthe issllcs of fact in the action.
[As amended: effective Januarv I. cOOS.]

(d) Waiver; Deposit of ./urors' Fces. f'he fllliurc of a parly to se"e a demand as required by this rule
and to IIle it as required by Rule 5(d) eonstilutes a waivcr bv the party oflrial b) jury Unbs the districl in
which the action 1\ pending has adopted a local rule pursuant to Rule 83 declarin~ otherWise. at the tillle a
demand is filed as required by Rule :i(d). Ihe party demanding the trial bY jUlY ,hall deposil with the clerk
an amount ofmone)" equal to the tees to be paid the trialjulws for their ,>,rvicc; li]r the first day of trial A
demand for trial by jury made as herein provi(kd Illay be withdra" n only" ith the consent oflltc parties.
or for good cause shown upon such lei ms and condilions as the collrt may Ii,
Zach Coughlin, Esq.
817 N. Virginia S1. #2

Reno. NY 8950 I
tel: 775 229-6737
tax: 949667 7402

Z:.lchCough Iill(l)hotrna i I.com
Nevada !lor No: 9473
48 of 77
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Lor> lng. l)f the whing ()f<lny (I(:li(111 ha"t:d on Ihl.': o,;()nlr:nl.., or
plOh'lbikd. This message is confidential, intended only for the named recipient(s) and may
contain information that ;s privileged,
attorn~y
work product or exempt from disclosure under applicable taw. fl you
are not the intended recipient(s), you afe notified that any disclosure, copying, distribution or any action taken or
omitted to be taken ;n reliance on the contents of this information is prohibited and may be unlawful. If you receive
this message in error, or are not the- named recipient(s), please notify the sender, delete thls emaH from your
computE'" and destroy any copies in any form immediately. Rece;pt by anyone other than the named recipient(s) is not
a waiver of any attorney-cuent, work product, or other applicable privilege.
RE: meeting
Sent: Wed 12/21/11 3:41 PM

To:
Mr Cougnlll1
The follov'o'II19 mepting tilTleS are avaliabj nG.:(f loved',
ThulSday. 12129111 a\ 3"45 p.m

t-nday, 12/3011~1 at 10'48 8.m or 245 p rn
Sincerely
Joe GoOdnlgl1/
From: Zach Coughlin [mailto:zachcoughlin@hotmall.com]

Sent: Tuesday. December 20. 2011 10:46 PM
To: Goodnight. Joseph W
Subject: meeting
Dear Mr. Goodnight, this confirms our discussion durin" our chance meetin!!
'"
~
today in Reno Justice Court. Alas, my Hearing today resulted in an Order th,;t
will make any mceting during 9-5 on either this Thursday or Friday an
impossibility. Further, this Wednesday is similarly unavailable. Do you have
any availability next week? I notice Mr. Jim Leslie was in court during my
hearing today before Judge Sferrazza. [s there some rcason why Mr. Leslie
would feel it necessa'ry to attend a hearing of the sort held today" In all
4l)of77
2114/20121:10 P\/
hap:, b: \ 4fh... bay; Inailllve,com:maiL'Pri\\t:-'ks:-.ages.3s.p\'!cP\th, .ihL

""-'!
likelihood, I will be bringing an agent with me to the meeting with you.

Sincerely,
Zach Coughlin. Esq.

Reno. NV 8950 I
lei: 775 229.6737
Ii,,: 949 6677402
lac he'0 II gh Iin(it halmai I. CO!11

Nevada Bar No: 9473
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contain informatron that is pr;viteged, attorney work product or exempt from disclosure under applicable low, If you
are not the intended recipient(s), you are notified that any disclosure, copyiny, distribution or any action taken or
omitted to be taken in reliance on the contents 01 this information ;s prohibjted and may be un/awful. If you recpjve
this message in error, or are not the named recipient(s) , please notify the sender, delete this e-maif from your
computer, and destroy ony copies in any form immediately. Receipt by anyone other than the named recipient(s)
is not
a waiver of any attarneY'cfient, work product, or other appficab/e privilege.
RE: meeting
Sent: Tue 12/27/11 9:10 AM
To:
Mr Coughlin,
Let's metl at 1045 a rn eil Friday DC:C8i;;r.:e: 30 20i 1 at O-'e PutljlC [)r;Lencjw's ottlC!;1 :350 S Cef'ter 5t, 5tn floor
Below I've mciuded, for the thIrd tl,-ne wk::: jOt: can eXDcct from H~e lT1f.'C'ill":J
Smcereiy,
Jot) Goodnight
50
or 77
;cok i,";~'jj3;d to It
! \Olmai! rrint
Message
I1Hp, ,1.1) 141hv,b:ly !

1ai l.Ii\'C'.com:rnail:Prllll\'lcs"a!!<;.'s a,>px'\:pilb-(}a
'-./
(EXCEf~PT FROM PkF:VIOUS t::MJ\\LS'J
Panicipants will indudc )OU_ me_ Jim l.eslie_ and E\'o NO\ak (all of\\hich are covered under attorneyclient privilege). Are ,YOll bringing anyone? Ag.ilIl. }Oll arc \VC\cOfll~ to, but must realize that the altorJle~'~
client privilege probably doe, not ,,'tend to Iha1 persoll.
Hcr~
is what you can c:-..pt:ct from this meeting. \Vc will be discussing. the Illotion to suppress that we'll
tilt:: in your case and r~\'ie\V trial strategy in r~gard~ to the evicknce Wt:' call e,\pect the State will try to
present. Vv'e'Jj r~view the audio evidence we wish to prcsr;n( and compare it to the witness statements and
police ,cport. discussing ho\\ to best present the discrepancies between the IWO to dlScreditlhe Stale's
witnesses and law entorcement. Wc'll get an update from [yo as 10 the progre" of his investigation. We
call bridly address some ofyollr orher concerns and demands_ blilihe m~jorilY of the meeting will be
dedicated to trial preparation.
Lastl). is the address provided bclo\\ your current address': I have Ihe R.lC audio hearings for you bul
I'm nOI surc where to selld thcm as this is difTerenl from the lalcst addre" we have on fi!c.
********~**************+**********~***********************
Joseph W, Goodnight
(775) 3374839
** Notice** This message and accompanying documcnts arc covered by the electronic
Communications Privacv Act. l8l".S.C. ~~ 25102521. and may contain confidential
'"
. ..
.
information intended for the specified individual (5) only. IfyOll are not the intenuccl recipient
or an agent responsible for delivering it to th" intended recipient. you arc hereby notiiled Ihat
you have received this document in emJr and that any review. dissemination. copying. or the
wking of any action based on the contents of this inlormation is strictly prohibited,
From: Zach Coughlin [mailto:zachcollghhn@hotmail.comJ

Sent: Salurday, December 24, 20111'57 AM
To: GoodnIght, Joseph W

Subject: FW meeting
Hi Joe,
Lets meet Friday I will bring one or more of my entourage WIth me, What do YOll want to talk about? You seem to
have done nothing on this case and Mr. Leslie seems pretty intent on your cO('Itinlllng to do nothtng, so What is
weird is Mr. Leslie showed up to my Motion to Contest Personal Property Lien hearing before Judge
Sferrazza on December 20, 2011 ... why? .. help me our here, why do you want to me, again?
Zach Coughlin, Esq.
Reno. NV 8950 I
:i I of77
2/\4:20121:10Ptvj
IIOlmail Print Message
hl1p:'iby 1.j,~\V.bay I,,.
113; I.lil'0.com'mad f Print\ bsage5,asp,\'?cpilb--')a ..
>J
tel: 77S 229-6737

fa>.: 949667 HOc
Zac he ough lin (,{~lhotl1l aiI, com
Nevada Bar No: 9473
lit<
Notice;'* I hi:- mc~:-;ag!.) anJ
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iug docllnH:IH~ .Ire t'o\crcd hy the dl.!Clronil.: (:I)!VOluni.::mi(lfb Privacy A(;I. 11\ U.s c.
and may contain C'onfi~kntial in/t)! mat/on inwndcd fi)r [he ~p,"'citicd Indi, iJu;JI IS) ()111~. If) Oll arc not [he
inli.:mkd fcdpient or an <.lg :nt n:sroll$lbk I()f lId:\ ~ring it 10 the inLcmkd f1,,'ciricrll. ) Ill! 1n: hcn..'h) lw!i/lcd th'll you have
l\\.\.:i\cu
this d()(,;umcnl III error and that 311)
fl'\
i('w. Ji . . s..:lllinati(1f]. COp: ing. I,r 111.' wkll1g. t)(rJ1):' ~lCllon bused on the L'"onlcnl" of
thb inlotnwtion is sIdell) prohihitr.:d. This message ;s confidential, intended only for the named recipient(sj and may
contain in/ormation that is privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recipient(s), you are notified that any d;sc/osure, copying, distribution or any action taken or
omhted to be taken in reliance on the contents of this information ;$ prohibited and may be unlawful. If you receive
this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your
computer, and destroy any copies jn any form jmmediately. Receipt by anyone other than the named recipient(s) is not
a waiver of any
attorney~c1iept)
work product, or other applicable privilege.
From zachcoughhn@hotmail.com
To: jgoodnlght@washoecounty.l1s
Subject RE: meeting
Date' Sat, 24 Dec 2011 01:S3 22 -0800
Hi Joe,
Lets meet Friday. I wili bring one or more of my entourage with me What do YO'J want to talk about? You seem to
have done nothing on this case and Mr leslie seems pretty intent on your continuing to do nothing, so help me
our here, why do you want to me, again?
Zoch Coughlin,
tSQ
8 I 7 N. Virginia 51. #2
Reno. NV R9501
leI: 775 229-6737
til>': 949 667 7402
Zac hCo LJ gh Ii n(n~h()ll1la iI, co III
http::' h)-I~8w.ba~ !
riil,livi.:.col11/nmil 'Printv1e::.,>agt:s.llspx'\:pid.s- ()a.
'-./
I-iot!lwil Print \1cssagc
Nevada Bar No: 9473
*-;: :\oti('~**
fhi;.; mcs\agr..: and {Kt.:()n'ran~ ing document-:- <I:\! (;()~..:r..:-J b~ til!.' dCdt'OllK COnlmunicmioll<. Pri\ u(: AcL. I g I I.S C.
~ 2510-2521. and ma: C()FlI.1in \"'~lnIiJcntia! infi)rmali~\O imend.;J Itl!' Ill\..' :-.p..:~i lied illJi\'ldoal (.-.. I onl:. If: Ol! an: nol rhe
jnh::nd~u J-,,':clpicnl 01 ,m ag.':1l1 rI..':c.[)t\f)'>lhk
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the I.:(lllknl~ of
Ihis infO! m,lliol1 b 5>Lri ... tly rrohihilCd. This m@ssage;s confidential, intended only for the named recipient(s) and may
contain information that;s pdvifeged, attorney work product or exempt from disclosure under applicable low. If you
are not the intended recipient(s), you art! notified that any disclosur'2, copying, distribution or any action token or
omitted to be token in reliance on the contents of this information is prohibited and may be unlawful. If you receive
this message;n error,
Or
are not the named recipient(s}, please notify the sender, delete this e-mail from your
computer, and df!stroy any copies in any form immediately. Recerpt by anyone other than the named recipient(s) is not
a waiver of any attorneyclient, work product, or other applicable priVilege.
Subject: RE: meeting
Date Wed, 21 Dec 201115'41:47 -OBOO

From. JGoodnight@washoecounty LIS
To' zacilcoughlin@hotmailcom
Mr. Coughlin'
The ;o!lowlng meetlf~g times nrE' 3V!Jl!8t:!f~ next WEek

'I hursday 12129;; 1 at :lA5 pm
Friday, 12/30/11 at :O'4S a tn. or 2'tt5 [1 rn
Smcere\',
Joe Goodnight
From: Zach Coughlin [mailto:zachcoughlrn@hotmad,com]

Sent: Tuesday, December 20, 2011 10:46 PM
Subject: meeting
Dear Me Goodnight, this confirms our discussion during our chance meeting
today in Reno Justice Court, Alas, my Hearing today resulted in an Order that
will make any meeting during 9-5 on either this Thursday or Friday an
impossibility_ Further, this Wednesday is similarly unavailable. Do you have
any availability next week') I notice 1\,.11'. Jim Leslie was in court during my
hearing today before Judge SfelTazza, Is there Some reason why Mr. Leslie
would feel it necessary to attend a hearing of the sort held today? In a1\
53 of 77
2!14I20121,IOPfvl
http:'! b) j48v.' hay!
HOlmail Print \:1es~agc
likelihood, I will be bringing an agent with me to the meeting with you.

Sincerely,
Zach Coughl;n Esq
817 N. Virginia SL #2
Reno, i'\V 89501
lei' 775 229-6737

fax: 949 66 7 7402
Lache 0 ugh 1
in(ivhot l11ai I. com
Nevada Bar No: 9473
".1<
:'lotice""" Thi~ m.:s<.:ag(; and acc:ompanying dncumcrH" arc "::0\ cn:d hy the t;1;,x:1ronic (\)mmW)iC31i{)ll~ Pri\ <lI.'Y Ad. I R I j, ~.( ,
g~
2510-2521. and TI1(1) rom:]in connJCll1la: Information in!endcd lor the .:..pccifl;.::c "IflJi\ itlll<ll hi l)f11~ 11')llU arC not Ihe
intcm.kd ro.:ipi<.::t1t or an
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thb dUClllllent ill . . . rror and [hal an~ rc\ let\. dl;;:-:::mln:l!ioll. copying, or lhl' taking of any ,lCtiOIl ba:.cd on Ihe con1enl.., 01
[hi" inrornwtioll b 'mi-.:lly prohihit~d. This message;s confidential, intended only for the named recipient(s) and may
contain informat;on that is privilesed, attorney work product or exempt from disclosure under applicable law. If you
are not the> jntended redpient(s), you are notified that any disclosure, copying, distributjon or any acODn taken or
omitted to be taken in reliance> on the contents of this information is prohib;ted and may be unlawful. If you receive
tMs message in error, or are not the named recipient(s), please notify the sender, delEte this tmei! from your
computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not
a waiver 0/ any attorneY-client, work product., or other applicable privliege.
RE: meeting
From: Goodnight. Joseph W \JGoodnight@washoecounty.us)
Sent: Fri 12/30/11 9:18 AM
To:
-rnat's fIne '11 he make:'> you unC0!1\ror:20:e GP dCt;;:n t need TO b prBs(:r~t
}../is r:::''2SF)'IC(~ was ';lten(jed to nrDVlrJe
me a resource as (L;ca~lor;ally you :cisk q<..leS;'O;lS ;1"-;:;~ i don't h{lVC:; ;;;\'( ()nS"'.If';f for and i !((.JlJS,bt M: LGSlle c:)dl!J be ot
HSslsta'lei:..' rl{~ W8sn'f gOldg :0 O~: any of the talK'ng ;OdiJY :'dl~ess , !lac :1
a rn today">
Joe Goodnight
54 of 77
qUt::d:C r ,
for hr,'TI. An:: you cor-ling
3\
1045
2:14:20111:101''v1
*~************************************y*******************
Joseph W. Goodnight
(775) 337-4839
jgoodnig ht@washoecounty.us
** Notice*" This message and accompanying documeills arc covered by the electronic
Communications Privacy Ac!. 18 U.S.c. ~~ 2510-2521. and may contain conlidential
"
"
.
inicl1mation intended tllr the specified individual (5) only. If:-ou arc not the intended recipient
or an agent responsible for delivering it to the intended recipient. you are hereby llotified that
you have received this document in error and that any rcvic\\. dissemination. copying. or the
taking orany action based on the contents orthi, inl()Jlllation is strictly prohibited.
From: Zach Coughlin [maitto:zachcoughlin@hotmai!.com]

Sent: Friday, December 30.20119:11 AM
Subject: RE: meeting
I don't really want Jim Leslie ther~, he is not my attorney. {want you to unleash
the Kracken! Jim Leslie Hied to silence the Goodnight Kracken, and for what?
New address for me, please note:
Zach Coughlin, Esq.
NV Bar No: 9473
1422 E. 9th St. #2
Reno, NV 89501
Tele: 775-229-6737
Fax: 949-667-7402
~* NOlke*'" Thi::. I1lc'):.agl and i:lCC()111p<ln~ ing d~ycw1h.'nt" arc cov..::red hy Ilh.: ~k":lrt1nic COfnmun;l.::ltinn<, Pri\ [11':;- !\ct. 18 L
J,S.c.
~~ 25 J 0-2521. and Illa~ CtHHain ~\)ntidcnti(:lJ inl(lrmali,)]1 i tllcnJcd fix Ihe sp;;dljl,.'d inJi, iJual b) lml). Iryou art: on! the
imended r..;-cipicf1\ or an a~(.nt r~~ronsihk ftlr (kllv(!flllg iT
11)
the intended r~'clri('rll you
1m..'
helch) I1nlitkd tha! you hu'rc
n;-::ci\cd !hj~ documcnt ill L'rrurunJ tlwI (In; rL'\j .... \\', Ji"'''CfnllHllion. ('()P~ ing. or lh<..' taking tlran~ action ha... .:d nn lilt: conlt::nb or
tIll" inll.mnutioll is strictI} prohihifCd This message is con/idenc;al, intended only for the named recipient(s) and may
contain in/ormaOon that is privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recipient(s), you are notifid that any disclosure, copying, distribution or any action taken
Dr
omitted to be taken ;n reliance on the contents of this information is prohibited and may be unlawful. If you receive
5501'77
\ {O\ITI,lil Prin!,
t\'lcs,sag~
this message in t>rror f or are not the named recipient(s), please not;fy the sender, delete this e-mail from your
computer, and destroy any copies in any form immediately, Receipt by anyone oth~r than the named recipient(s) is not
a waiver of any attorneY-cfient, work product, or other applic<lbfe privi/ese.
RE: update please and confirmation of next meeting

From: Goodnight. Joseph W (JGoodnlght@washoecounty.us)
Sent: Mon 1(23(12 2:04 PM
To:
Mr, Couq)1110,
fhe daie for our nex! meeting
t'!as
.Januar)' G, ?G~2 You failed to
meeting OP 121'30 and YOu aH:-cC to m"')8~ (/-
t!(J
apf)":;dl
\Nc; d;-2,c'J:;s~:d
HilS dd18 81 mll ViOl
'
s'al'ng you fleO B [ra!ni:~9 O'~ 1/5 (sorrH~Ul;ng at,out b8nkrLJplcy
fllmg! believe) Let me know Ii y~)U wDvd Ll;:,e Ie) n~(\t.)t again bl~fGfe 11,a! ;')(lj "vi) r;an ')y to sCGPdu!e something
hAve tar,cn your C(Jlnne:lts regcliding t/'0 Mot:Of' 10 Su~ress d: aft: p:";-w C0~1 Y()'..1 ,:..,t~> ;:;Cl!1S GC;(1tlcn and 'N:I! br illwq
the mOllon In the near future:
fhe (t:\s: d;;\'f Tn\
;:F8-tna' mot,ons \S 15
tJf-)'():(;
('tal (see NH'S 174 125)
11 hAl:; 0(;(,[1 brOf)gtt to ny attetl!orl lh<:l: 'Sin~~e y~hu -':lues! 111 ReR 1! -00334" f)~1 :'":c,v;j b8t'n arrested or p~,i 1[;
custody an aJ'(i!tio[",ai five t lYles the: rnost ;9cer1i of which lor an ai!egocj G!oss M,.sde~~v?anOl offense rillS is
cnncerping And IWJ'C<1tlv8 of SOPleone v,,'ho truly nee(is some ne!p, Are yo;; d'.\lafe of thE' SOLACE progmm offered
through ~he Slal~ Bar cf NevadA')
f :ere:s
a i<l~k tf ',/,,)\\ are \!jtBfesh::d hljp
9)9;GQ.n.t~nlJsO@GG_..l)ppon
program
Sincerely,
Joe C;oozinight
From: Zach Coughlin [mailto:zachcoughlin@hotmall.com]

Sent: Tuesday, January 17, 2012 8:54 PM
Subject: update please and confirmation of next meeting
Mr. Goodnight,
My notes indicate you were to get back to me regarding another time
for another meeting in your office. I do not have any record of a date
set, is this your understanding as well or do you have a meeting on you
calendar for us. Please keep me alerted. in real time as closely as
practicable, to when something is filed in this case by anyone. I
believe the deadline to file the various motions I request you file is
close to running, if it has not already. Please seek a continuance in the
ease as r am not satisfied with Evo's contribution or the level to which
)6
or 77
2'14i2012 1:10 P.\I
Hlil.ll\'e.com!maiJ.'Print\ 1cssages.llsp.\ )cp,d:'='i),j .
hup ,'by 14R\\.bay J
Hot!llaill'rinl Message
"-"
the defense in this matter has been worked up.

Sincerely,
lach Coughlin, Esq.

1422 E. 9th St, #2
RENO, NV 89512
wi: 7753388118
Illx 9496677402
ZachCough Ii n@hotmail.colll
Nevada flar No: 9473
ha~cJ on Ih.-; Cllllll'nts (Iflhl" hllmll1:HI~H1 h ,>,'v,.lh \lfuilltnl.:..[
contain information
~hat
nus message is confidentla',
jn~ended
only for the named reclpient($) and may
is privileged, attorney work product or exempt from disclosure under applicable law If you ore not the'"
intended recipient(s), you o(e notified thot ony diSclosure, copying, distribution or any action taken or omitted to be token in
reliance on the contents of this informatIon is prohibited and may be unlawful. rf you receille this message in error, or ore not the
named redpient(s}, piease notify the sender, delete this
e~mail
from 'lour computer, ond destroy any copies in any form immediately
Receipt by anyone other than the named recipient(s) is not a waiver of any ottorn(>yclient, work product, or other appficable
pri'Vilege.

Sent: Mon 1/23/12 2:14 PM
To:
t'v1r Coughlin
\~/hy do
YOLI thmk a jury ~rla! IS In yml:
Joe C;oodn!flht
5701'77
2114120121.10
p\1
laj I,Iive.cnm 'lllall:Print\.-1cssl1ges,'lSp\ ?cpids - 9ti_ .
Ilolll1uil Print :vlessag,c
******************************************~*~*************
Joseph W. Goodnight
(775) 337-4839
** Notice** This message and accompanying documents are covered by the electronic
Communications Privacy Act. 18 U.s.C. ~ 2510-2511. and may contain confidential
information intended for tile specified individual (s) only. IfyOll arc nOllhe intended recipient
or an agent responsible for delivering it to the intended recipient. you are hereby notified that
you have received this document in elTor and that any review. dissemination. copying. or the
laking of any action based on the contents ol"this infonllation is strictly prohibited.
From: Zach Coughlin [mailto:zachcoughIJn@hotmail.com]

Subject: RE: I respectfully request a Jury tnal
Regardless of YOn! interpretation of the cases you referenced below

and statute, I wish to preserve for appeal my demand for a jury trial.
lach Coughlin, Esq.
1422 E. 9th St. #2

RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
ZachCough Iin@hotmail.com
Nevada flar ~o: 9473
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In
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prIVilege.
SUb)EKt RE'1 resoectfully reque':>t a Jury tnal
Date: hi, 16 Dec 201113.30'02 -0800

From' JGoodnight@washoecountyus
To zachcoughlin@hotmailcom
fAr. Ccughli".
As Judge Sfen(lna e:<p\alnec, we don't have a ~;ght 10 a JUry trl:::'\
your ::aSB The. per1I;,cmt stRtute IS NRS

175011 and the c~se he IS likHly ref~~fJin9 to IS ~t~te v S.ff1.lth. OD r\tV A06 1\/(-7 attacl18C bOH1!O this email.
8ec<)use n11sdellloanors are "pet{' offenses. the light to <?l Jury trio! Goes not .3~l.ach
Additionally l've attached SUf,':rerr,EI C'Ju!i Rule 253 It '5 c;ear that you are Ln;;ailsf!ed wilh now \ 8m hanc\\ing
your C<1se despite my numerous ,~tempts to arr:mQi? <.1 mee!II'g \tnrl lDU to ()i}:;l,S:s' ttlr~ rno1!0ns you are suggos ti n9
<.il1d consult \Vitll you in prcparatlJn for tlJ3i AgEH1, YOtl have the r,qhr to repi8s-ent youfself Please Ie! me knm', If
In
YDU wish to GO SO
Smcerely,
Joe Cuodnighl
************************************~*********************
Joseph W, Goodnight

(775) 337-4839
jgoodnight@washoecounly us
** Notice*" This message and accompanying documents arc co\ ered by the dectronic
Communications Privacy Act, 18 USc. ~~ 2510-2521, and may contain confidential
information intended for the spccilicd individual (s) only, If you are not the intended recipient
or an agent responsible for delivering it to the intended recipient, you are hereby notifIed that
you have received this document in CITor and that any revicv" disseminntion, copying, or thc'
taking orany action based on the contents oJ'tilis information is strictly prohibited.
From: Zach Coughlin [mallto:zachcoughlin@hotmail.comj

Subject: I respectfully request a JUry trial
I have made clear previously that I wunh"d ujury trial and strenLiolbly objected the the selling that
oc~urred bcf(m:: judge Pearson rccen\l~ and a~'" 1hm I be atTorl~d rny righl to a jUl1y trial. especially to thL'.
extent that Mr. Goodnight continues tn fefuse to tile an~ orllle motiolls I a~'" him to tile, Irv1otj{)ns jn
Limine, ~'lotion.s to f)i~mjss. 10 ta~e [my dep(}:-.ilion~. or otbJ;;'f\vlse do anvtllilH.: that \\Quld seem to result in
zealollsly advocMil1g
59 of 77
(11111)
behalf Additional)" Mr. Leslie ordaed Mr.'(joodnight not to speak
al
the laSI
:>/t4ilOt21.IOPVI
-~-._/I
hearing.
IUJU: 38. JURY TRIAL OF RI(;HT

(>1) Right Preseneu. The right of trial by jury 85 declared by the Constiltltion of the Slate or as given
by a statute of the State shall be preserved to the parties inviolate.
(b) Bemand. Auy part) may demaud a trial hy jury of any issue triable of right by a.Jury by serving u>
required by Rule 5(b) upon the other parties u dellland theref('r In \\'ritinf! at any time after the
cOlllmcnccmenloflhc action and not later than the time of tile entry of the order first setting the case for
trial.
[As amended: efleetlve January I. 200S.]

(e) Same: SpeCification of Is~ues. In the demand a party Illay spccity the is>llcs which the party
"lshes so tried: otherwise the party ,hall be deemed to haw demanded trial by j\ll"\ for all the issues so
Iriable. Iflhe party has demanded trial by jury for only some of the issues. any other part)' within 10 days
after service of the demand or such lesser time as the court may orMr. may serve a demand for trial by,iury
of an)' olher or all "fllte issocs of tact in the action.
lAs amended: effective January I. 2005.J

(d) Waiver; f)cposit of .Jurors fees. The failure of a party to serve a demand as required by Ihis rule
and to file it as required by Rule 5(d) constitutes a waiver by the pill!)" oftri,,1 by.iul'). Unless the district in
"hich the action is pending has adopted a local rule pursuant to Rule 83 declaring othen, i,e. al the time a
demand is tiled as required by Rule 5(d). the party demanding the trial by jury shall deposit \\'ith the clerk
an amount of money equal to the fee, to he paid thc trial jurors ((11' thcir lef\ ice, for the first day of trial. '\
dcnwnd for trial by jury made as herein provided mav be \\ ilhdrall n onl,' II' it h the consent of the parties.
.
.
or for good cause shown upon such terms and conditions as the COlll1 Illay fl,\:.
Zach Coughlm, Esq

RellO. NV 89501
tel: 775 229-6737
fax: 949 667 7402
ZachCoughlin@hmmail.com
Nevada
GO 01'77
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9473
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ttli..; illftumalioll i~ strictI) prohibitt:d. This message is confidential. intt?nded only
lor the named recipient(s) and may
arf! not the intended recipient(s), you are notified that any disclosure, copyins, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive
this message in error, or afe not the named recipient(s), please notify the sender, delete this e-mail from your
computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) ;s nat
a waiver of any attorneyclient, work product; or other applicable privilege
RE: please confirm trial date

Sent: Mon 1/23/12 2:28 PM
To'
Cc:
Novak, Evo (ENovak@washoecounty.us)
Mr Coughlin.
The currp.nt Inal di3tp.IS FDbr~fmy 79 2012 a18:30 a m III HellO J:,S{IC Caurl You have preViously been provided ~
copy of the docurnents you requps!eo. ftle time deadlines you are looktng for can be fO:Jlld In the NeVtlda ReVised
Statutes hee NRS 174 125 174 23:5-174 295} and th~: ,Justice COlI! HuieS of Reno Townshi~t
Joe Goodmght
**********************************************************
Joseph W. Goodnight
(775) 337-4839
** Notice** This message and accompanying doculllent<; are co\wcd hy the electronic
Communications Privacy Act. 18 USc. ~ 2510-2521. and may comain conlidential
information intended for the specified individual (s) onl\". If you arc not the intended recipient
or an agent responsihle for delivering it to the intended recipient. yOU arc herehy notiticd that
you have received this document in error and that any rcvie\\. dissemination. cop~ ing. or the
taking of any action based on the contents ofthi, inl(mnation is strictly prohihited.
From: Zach Coughlin [mallto:zachcoughlin@hotmail.coml

To: Goodnight, Joseph W; Novak, Eva
61 of?7
2i14.'2012110P"1
Hotmail Print Message
hl[P','!by 148w.ha
~ .mall,1 j\'e.J.:Ol1l i rnail
'Prinl1'-1ess;)ges.Jsp\:"J cpl ds'-9a..
"-.i
Subject: please confirm tnal date
Dear Mr. Goodnight,

Will you please confirm in writing the trial date for this matter, case
number, provide a copy of all pleadings/orders on tile in this matter
(please do not mail it, I am living with domestic batterers right now
who I believe arc destroying some of my mail, please email these
documents or fax them to me at my fax number 9496677402 ... 1 wanl
every thing in the court record for this case please).
Further, will you please specify in writing the relevant deadline for all
major nIles related to discovery, pre-trial motions, for filing a Motion
to Dismiss, for production of Trial exhibits, etc., date by which a jury
trial must be demanded (regardless of your interpretation of whether
this case is entitled to a jury trial, r will remind you JCRCP 106 used to
say tenants in an eviction were not entitled to a jury trial, however, that
is not the case now, as tenants absolutely are entitled to a jury trial
where properly demanded.)
Sincerely,
Zach Coughlin, Esq.

1422 E. 9th 5t #2
RENO. NV 89512
tel: 775 33S 8118

fax: 9496677402
ZachCoughl in@hotmail.com
"cvada Bar ",,: 9473
62
or 77
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\1cs~age
contain information that
IS
privileged, attorney work product or exempt from disdo$ure under applicable law It you orr;! not the
intended recipient(s), you are notified thot an;' diSclosure, copying, dlstrriwtion or any action tllken or omitted to be token
reliance on the (.ontents of this informatio/l is prohIbited ond may be unlawful. 1/ yoo receive this message
In
In
error, or ore not the
named (ecipient(s), please notify the sender, delete this e-mcHI from your computer, find destrcyy .any copies in any form immediately_
Receipt by onyOfle other than the named reClprent(s) is not a waiYer of any {1ttorney~lient, work product, or other applicable
privilese,
Continuance and meeting

Sent: Mon 2/06/12 12:31 PM
To:
zachcoughlin@hotmall.com
Cc:
Novak, Evo (ENovak@washoecounty.us)
Mr. Coughlin:
I am available to meet thiS week at the following times:
Tuesday (2/7) at 3:00 pm. or 4:00 p.m.
Wednesday (2/8) at 3:00 pm. or 4:00 p.m.
Thursday (2/9) at 1:00 p.m.
Friday (2/10) at 1:00 p.m. or 2:00 p.m.
Please let me know when you'd like to come in to discuss your case further. As for
your continuance, how far out would you like to continue your case? Again, we'll have
to present "good cause" for the cOlltilluance and I'm no! certain our request will be
granted. lastly, DDA Young has indicated that he IS willing to re-open negotiations in
your case in an attempt to resolve both the misdemeanor in RCR11-063341 and the
gross misdemeanor in your new case. Are you interested In re-opening negotiations?
Sincerely,
Joe Goodnight
**********************************************************
Joseph W. Goodnight

(775) 337-4839
jgoodnight@washoecounty us
** :\fotice** This message and accompanying documents are covered by ,he ekctmnic
Communications Privacy .Act. 18 U.S.c. S: 2510-2521. and 111a) contain confidential
inCormation intended for the specified indi\ idual (s) only. IfjoU arc not the intended recipient
6} 01'77
2/14/20121:10 P,\I
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or an agent responsible for deliwring it to the intendcu n:cipienl. you are hereby notified that
you have rccciveu Ihisuocument in error and that un)' review. dissemination. copying. or the
laking of any action based on the contents of this information is strictly prohibited.
Motion to Suppress
Sent: Wed 2/08/12 6:15 PM
To:
1 attachment
Coughlin_suppression_motion.pdf (2227 KB)
Mr. Coughlin,
I'll be filing the attached motion by the end of this week. I took many of your comments
into consideration and used the ones Jfelt were appropriate.
Sincerely,
Joe Goodnight
CoughJin_suppression_motion.pdf
*************************~*******************~******** ****
Joseph W. Goodnight
(775) 337-4839
Communications Privacy Act, 18 USc. :510-252l. and rnay contain contidential
information intended for thc specified individual (s) onl~. If you are not the intended recipient
or an agent responsible for delivering it to the intended recipient. yOU arc hereby notified that
you have received (nis document in error and that any revic\\'. dissemination, copying. or the
taking of any action based 011 the contents of!his information is strictly prohibited.
RE: Motion to Suppress

From: ;~rUIM**v.tnIA. (JGoodnlght@washoecounty.us)
Sent: Wed 2/08/12 10:12 PM
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communication.
Subject
Tnal Strategy meeting
Date' Wed, 26 0ct 201116:35.21 -0700

From: JGoodnight@washoecocnty.us
To: zachcoughlin@hotmall.com
Mr. Coughlin,
I am available to meet next Tuesday, November 1. 2011 at 3:30 p.m. Can you meet at
the PO's office at that time?
Sincerely,
Joe Goodnight
**********************************************************
Joseph W. Goodnight

(775) 337-4839
Communications Privacy Act. 18 lJ.S.c. 2510-2521. and may contain conlidential
information intended for the spccili~d individual (5) (lilly. If you arc not th~ intended reclpil:nl
or an agent responsible ror delivering it to the intended r~ci)1ient. )ou are herdl)- notilied that
you have received this documcnt in error and that any re\ ic\\. Ji,seminution_ copying. or the
laking or any action based on th~ contents of this mi()f]nation is strictly prohihitcd.
RE: need file before meeting foia request, this week is no

\
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From: Goodnight, Joseph W (JGoodnighl@washoecounty.us)
Sent: Fri 2/10/12 3:41 PM
We just called you. Can you talk?
******************************************~*********** ****
Joseph W. Goodnight
(77 5) 337-4839
** l'Iotice** This message and accoll1pan) ing documents are covered by the clcclronic
Communications Privacy Act 18 USC. 2510-2521. ami may contain confidential
information intended li)r the specified indi\'idual (s) only, If you arc nOl the intended recipioll
or an agent responsible for delivering it to the lDlcnded recipient. you arc hereby notified that
you have received this document in error and that any review. dissemination, copying, or the
taking of any ~ctiOti hased on the contcnts of this information is strictly prohihitcd,
750fn
cI4!20L'I:101''v1
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http> by! -J.8w ~
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148.mu! I.livC'.com 'mail Pri nt\1cssaj..'.c~.a~rx')cpld~'- 9a.,
Motion for Continuance

From: Goodnight. Joseph W (JGoodnight@washoecounty,us)
Sent. Sat 2/11/12 5:06 PM
To:
1 attachment
Coughlin_Continuance,PDF (81.4 KB)
Mr, Coughlin,
Contested motions for continuance must be accompanied by affidavit. Please review
the attached document and let me know if there IS anything in there that you do NOT
want me to share with the Court or the Prosecution Try to get back to me by this
Monday a,m, please,
Sincerely,
Joe Goodnight
Coughlin_Continuance,PDF
*********~********************************~****~****** ****
Joseph W. Goodnight

(775) 337-4839
** Notice** This message and accompanying documents are CO\ ered b) the electronic
Communications Privacy Act, 18 t S,C ~~ 2510-:521, and may contain conlidential
ini(wmatiol1 intended for the specified individual (s) only, IfyOll arc not the intcnded recipient
or an agent responsible for delivering il to the intended recipient. you are hereby notilied thai
you have received this document in error and that any rC)'iew, dissemination. copying. or the
taking orany action based on The contents or this int(lrmmion is strictly prohibiTed.
Continuance and Fifth amendment

From: Goodnight. Joseph W (JGoodnight@washoecounty us)
Sent: Tue 2/14/12 11:42 AM
To:
zachcoughlin@hotmal!.com
Mr. Coughlin,
Please respond in a succinct constructive manner to the questions regarding the
affidavit supporting the continuance you want. I won't file It until I hear from you,
76of77
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'"r'
In regards to your Fifth Amendment questions. I think you are focusing on something
called Doyle Error.
DOY.Le '" _Q.hio _426 U _S. ()_10 ,,:U_S19(6) This occurs when a prosecutor tries to impeach a
defendant at trial with their silence and invocation of their Fifth Amendment right. This
type of impeachment at the trial level is most-often Improper However. the analysis for
a probable cause determination is different and the officers and court can consider the
"totality of the circumstances" including your responses to the officer's questioning
when determining whether probable cause existed to arrest you. We can object during
the hearing, but I don't see a basis for a motion at this pOint. I'm not finding anything
that says otherwise, but if you do, please share it.
L
Joe Goodnight
PS - The State rejected our counter-offer
~~********************************~***~****************~**
Joseph W. Goodnight
(775) 337-4839
** Notice" This message and accompanying docum~nls arc covered by the electronic
Communications Privacy Act. 18 11.S.C ~ 2510-2521. and may contain conlidenlial
information intended for the specified inJi"idual (s) only. If you arc not the intended recipient
or an agent responsible for delivering it to the intended recipient. you are hereby notitied that
yOU have received this document in error and that any review. dissemination. copying. or the
taking or any action based on the contents ol'this information is strictI) prohibited.
77 ()f77
2/14/20121:10
p/\,,]
To; 7cJf21e9-fcc8-461a-SeOf-lea559b
1-15-11
fcom; zichcoughl1n
5:01pm
p. 1 of 1]
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12 FE311 M18:G8
Document Code:
Zach Coughlin,F.sq.
Nevada Bar No: 9473
1422 E, 9th St., i!2
Td:77S 338 &1l8
Fax: 9496677402
lachCoughlin@hotmail.com
Reno, NV 89512
IN THE .n.:STICE COlJRTOF REN(\ TOWNSHIP

IN AND FOR THE COUNTY OF WASHOE. STATE OF'iEVADA
,f.' STATE OF NEVADA;
) CASE ;-.JO: RCR1I-063341

)
Plaintill
12
) DEPT NO: 2
)
Vf-;:.
) RPD RPll-OIG399
ZACHARY COUGllLIN:
Ddendant.
l4
10
------------)
13
NOTICE OF APPR-\RA'iCE AND St:PP],F,ME'IT TO MOTION TO ACCEPT PRE

TRIAL 1\10TIO.\S WHERE lJNTI;\,IELY
2C
The undersigned hereby fiks this Notice o~ Appe~nmcl;! to app<!aI vn hl.s own b~half 8::; cc-counsel i:lJong With
21
DPD Joe Goodnight E'iq. It 1S la\\' of the CfL')c that the underSigned rr:ay do so. as Judge Sierrazza pre\'lOuc;ly!;,o ruled
22.
.%3
26
27
.\OTICt OF APPEARANCt A1'iD SVI'J>LBlENT TO MOTION TO ACCEPT PRE TRIAL

;\'JOTI01'iS WHERE V.\Tl"U:LY
10' 7cltl1e9-!ccB-4fila-BeOt-lea\\9b
l-1fi-12
From: ,.chcoughl!n
1:01pm
p,
1 of 2J
",-"
AFFIR'vIATIO:-';
2
I d~clare under penalty of perjury under the laws of the State of:--ievada that the foregoing is
tnte and correct and that this document does not contalll lUI)' social security Illunbers. pUrsUlUlt to
KRS 239B.030. an affimlation to that effect this hereby is,
6
DAnD this 16th of February. 2012:
{l/
Is! tach Coughlin

1(:
Zach Coughlin, ~:sq.

Defendantl Co-Counsel to GO(Klnight
11
12
14
15
16
13
2f
28
J\OTlCE OF APPEARA:\'CE AND SliPPU:MENT TO MOTlO" TO ACCEPT PRE TRIAL

MOTIONS WHERE jl:STIMF,LY
1-16-11
from: laeheoughlln
ldf11e9-fccH61a-BeOf-lea559b
5:01pm
p. 3
of 13
PROOF OF SERVICE
ON Ihis date. I caused a copy of the foregoing document (0 be serwd upon the following bv sending
to their registered email address and fax number as found on www.n.ool erg. anJ by placmg a 1ru< and
conect copy ot the
1 'J
I1
10
J 1
16
18
1';'
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21
tor~oJng dOClffilent In the
U S mall addressed to
Zachary);. Young. Esq.

Washoe County DA
1 South Sierra P.O. Flox 30(j83
Reno, !\V 89520
Phone :-':umber: 775-328-3200 Fax number: 775-325-6703
Email: zyoullg(G)da. washoecoullty.u>
Joseph W. Goodnight. Esq.

Washoe Connty Public Defender's Office
P.O. Uox 30083 Reno. "'V 89520
Phone :\umber: 775-337-4839 Fax number: 775-337-4856
Jgoodnlght@washoeCOlltlly.l1s
JEREMY T. BOSLER. Esq.

Bar :-.io. 4925
One Cahfomia ;\ ve
Reno. l\V 89509
(775) 337-4800
DATJU.l this-.l,~th of February. 2012:

-----
~,
'~-
------ - -_. ~~
-------"
t,ic!ff;;t~n
DEFEN))A!\T
22
27
28
"
1\01'lCI': OF APPEARANCE AND SUPPI,EMENT TO MOTIOI\ TO ACCEPT PRE TRIAL

M01'101'\S WHERE l';\TII\II':LY
To: 7clfI7e9-fcc8-467a-8eOf-le.559b
Fro.' ,achrough!!n
1-1H1
5:01pm
p. 4
of 13
INDEX TO EXHIBITS
1 Exhibit 1: letter to Court Administ .....tor Tuttle :md 12/21111 Order ill REY2011-001708 alld
other materinls
lC
1:
12
:5
1-6
17
18
19
21
2S
::-:8
- 4 -
N(YnCE Of APPEARANCE AND Sl'PPLEMENT TO l'vIOTION TO ACCEPT PRE TRIAL

~fOTIONS WHERE lINTIMELY
To: 7cJr17 e9 -fceS -461 a-SeOf -1 ,,5 59b
From: zachcoughlin
Hotmail Print Message
/-16-12
5:01pm
p, \
Page 1 of 13
RE: cases being randomly assigned in RJC FW: attempt

to file prior to Spm denied
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent Thu 2/16/12 4:58 PM
r0 stuttle@washoecounty.us
1 attachment
ex 1 CVll03628-2658302 (Exhibit 21.00: JOdi :1851 KBj
Dear Court Administrator Tuule.
I red that you have misllllderstood mv Import. Please consider that yuu and others in the court
arc only human, whtlrca~ Richard G. Hill. Esq. is clearly a lycan, who has also somdlOw
managed to fa,hion himself and his hrethren into a sophisticated commercial law linn capable
of distorting reality in Y<ays not commonly seen ahsent the ildministration of extremelv potent
psychotropic drugs, lnere were no "assertions regarding "Judges Sferrazza. Clifton and the
Court', integrity" in anything [ wrote you. There IS a ditTerence between ill! "appearance" and a
"reality". however. [think you will find that "appearances of impropriety" are gIven
considcrable attention in the Rub of Professional Rcsponsihilit\. the Code of Judicial
Conduct. and the "'lodel Code ofCnnduct for .ludicial Emplow~s in the State of:.ievada.
Further. I think you will find that, contrarY to vour retaliatory assertions. 111\' duty to my client
includes making a reasonably diligent dIor! to attempt to access justice, and any subsequent
excusable ncglcd analysis may, in fact. call for making an attempt to inquire "ith court
personnd or Sheritl's Deputies in an attempt to address my concem, vis a vis the doors locking.
While you Illdicate the videos are the property of the Sherifj'('1l1lte a bit nfpower for the Shenff
alolle to own those videos) you do not make clear how it is that you are able to review them.
while at the same time, seemingly disclaiming any liability li)r the negligent hiring. training. or
supavision of tile various Deputies you 8UperYisc and or work with at the RJC. especially, vis a
vis their propensity to tell litigants that tl10:> will have obj<'c!' !()rc'ibly in,crted Into their anuses
should such litigants in any way question the cold. hard. authority of these SheriJl's Deputic's
jackboot.
What is not clear is why Judge Clilton would handle all the other cases 011 the stacked doekd of
2/13112. beginning at 8:30. but then, after Chief llailitT Sc,-1on came into the Court Room with
BailitIReyes (whom! have been forced to lile lix a Prokction Order agarnstjust reccntly) and
made some phone calls, Judge st".:rrazza replaced Judge Clifton. Further. while Judge Sfeo'azza
e:-.-plained the non-appearance of Judge Lynch by Illdicating that Judge Lsnch was instead
scheduled to do traffic court that day. Chid' Civil Clerk Stancil indicated today tJlat. in fact,
.fudge Lyllch was hearing matters on a criminal cal~ndar'
Regardlc,", I certainly have not impugned the crcdihility of any of the fine judges of the R,lC.
However. your lumping to being "insulted" and taihng to ask Ille anything about these incidents
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From: zachcoughlln
{-10-1?
I:D1pm
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p. 0 of?J
Pa(1e 2 of 13
"'
involving thr~al' to in,en objects inside of my anlls leaws a bit to be Msired. in my humble
opinion, from the perspective of a member of the publi~ appearing in your ~ourt as a litigant.
You wrotc "You were not denied by this Court your right to lile the.s" documents yesterday.
You were. however. denied bv Washoe County Sheriff ... Court Se"lritv Dlllt acce" to the
building afier closing time; th~ same as anyon~ else would be denied. \'ou were not here before
5:00pm and trying to gain access into the facility by coming through an "exit only" door is not
permi"ible. "
1 don't agree with your assessment, but 1 apologize for Ille annoyance thi, 'eCIIlS 10 hayo caused.
1 hope you wtll cOl15ider that the date on which thi, occurred was Ihe last day to jik a pre-trial
motion (under NRS 174.125, such motions. including a "motion to suppress" the fntits of an
unlawful search by law enforcement) in a matter for which I am a cftminal defendant, and for
which a conviction could result in me being disbarr"d as an anomey. in addition to fairly
substrunial criminal penalties, induding incarceration. There are a 101 of things that can go
wrong on the way to an innocent man being convicted of a crime. One key area inn)I",)s the
failure 10 preserve lor appeal impottant issues. Such 1I'0re the content of the documents! sought
to filed on February 14th, 2012. Additionally. only )\:stcrdav \Va, I finally inlormcd by the RJC.
criminal division. that [may file by fax. I hav~ previously been told that I may not tile by fax.
Further, today Ms. Stancil, Chief Civil Clerk.. informed me that I mH) also fik by fax in the
Civil Divisio~. I am quil.: certain [haw requested pcnnission to do this before in both the ci,'il
and criminal divisions and hav~ heen told I may not ewry singk lime lllis relates to your
recent commentary on "favoritism" and appl, ing the rules evenly to ailliligants. I am sure \
have heretolore b.:cn disallowed Irom filing by fax. lndecd_ I have spent countkss hours of my
time travelling out of my way. down to the Reno Just;':e Court. to Jik each and every document
that 1 have tiled in the few cases I have had in your court (and most any lawyer will tell you that
their "time" is the only tiring a lawyer is much able to sell to anVOIl" for the purpose of makmg a
living, something which_ I assure, has been an enonnous struggk for me thts past few years).
You are aware Of.lU51 how enormous th~ file is in RJC RC"2011-00 1708. I guess S0111e would
say that is my fault though I would counter that the law is rath~r dear that NRS 40.25.1',
summary eviction proceedings are forbidden against commercial tenants where the non paymollt
of rent is neither alleged nor ?-Jotice of su~h is posted or s.::r\'Cd. as here.
Mr. Tuttle. you know as wdl as I do that there is a turnstile that only turns one" ay that would
obviously prc'Scnt any such attempt to gain access. Further, the door you are referring to is not
mark~d "exit only". and your a""ltions that [was "trying to gain aCcess to the facility" is so
transparent that it is disturbing considering your position with the court. I c1earh' kno~ked on
the window and waived to Deputies III an attempt to ask them my questIOns. Surely, the video
you ret".:rence easily show this. Additionally, you do not mention exactly what time "after 5 pm"
the video showed. and I Itnd that curious. Further, ) 011 do nol mention anv system in place 10
assure that the time stamping on the video is in accord with the olTt~iaJ United Slates time at
www.time.goy. Indeed, the RJC or the Sheriff arc not the onil one's in the this world \\ ith
cameras and clocks, and it might be very interesting to see a documentary of se"eral days worth
oftootage of just whon exactly the doors lock. synced to a \'isua! time stamping verilied to be
acwrate vi, a vis www.time.gov. Ifsuch a video did exist YOU don't sound like vou would be
too intereskd in seeing it Please correct me if I am wrong ..'
.
You further wrote: "Because vour actions could be cons.ider trcspa')sin2. is the reason wh\'
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Justice Court Chief Bailiff Michael SeJl.1on agam asked you to leave, Fair and equal access to
justice applies not only to discrimination, but also to favoritism. Allowing one party to file
documents after a deadline is unethical 'Uld without questton unfair." Your interpretation of tlle
crime of "lrcspassing" is ink-resting I guess. under your approach, Richard G. Hill. F.sq. would
he guilty "ftrespassing where. at the 12/20i11 Ikarin on Tenant's Motion to Contest Personal
Property Lien, aftcr the Tenant invoked the Rule of Exclusion, and Judge Sferrazza ordered Hill
and other prospectiw witn')sses to leave the court room, where Hill surrcpttously snuck back In
the court room, found time during a recess to announc~ to myself Bailiff Reyes and Chid'
I3ailiff Sexton that Hill too would like to "put his boot up Coughlin's ass". and then manage to
sneak back into the court room during the proceeding, and have I3ailiff SC>,10n pass post-it notes
from behind !"he Bar to a Struggi111g Casey Baker, Esq., whom waS anemptillg to apply and
unlawful rent distraint under the guise of "reasonable storage" eXP<lnses.
At S30 a day for "reasonable storage" expenscs. Judge sternazza', Order was more in line with
what one gets in a room at !"he Sand's for a da\", complete with the full use and occupancv orthe
room_ heat, plubming, light, and premium cab!,; television, and wi-Ii access. $30.00 ada\" Il)r
"reasonable storage" of that which could fit in a 10 hy 30 foot storage shed (which tvplcallv cost
Sl25 per month. or about I;Rth ot'what Judge SferraZla nllcd would be a reasonable dailv
storage charge, in the great Reno area). This $30.00 a day storage charge is made all the more
questionable by the fact that the 10cal1ons where all these items were being "stored" (and for
which a bill for $1,060 to "secure" this "storage" was med with the RJC) was actually
hurglarizcd on J)ecemha 12th, 2011, while lUlder Ilill ami Baker controL and many valuable
were stolen, though neither Hill nor Baker ever provided an}1hing close to a reasonable detailed
inventory of what was fIIere prior to the burglary and what remained after the burglary. The did
manage to notice that a 62 inch Television was missing, though.
I agree with your assessment that it would be unethical and without question unfair for the
criminal division tiling ofTice to a$k a "red headed step child" litigant "who is calling" on the
phone when they inquire with court personnel as to whether the court will, in fact. remain opcn,
all the way up to the posted Spm closing time, and then for the do,Jr's to the court to, ever sa
cUflously, be locked prior to 5 pm when said redhead presents to access justice, and even more
so where 11 court Jlhninistrator and Chi"r Bailiff then arrange a \crsion of the facts to explain
away their actions and decisions, replete ",ith menacing allusions to retaliatory prosecution, etc.,
etc. You are right about that, Sir.
You further wrote "lnfomling Chief Bail iff Se".ton of)our intention to wait outside for Reno
Justice Court employees to leave so you could force them 10 take your tilings is a t"onn of"
harassment and needs to stop immediately. If thiS aggresslvc bd1<.vlor continues. the Court will
consider a protective order against you, which will result in your ahility or privilege to access
Reno JlL,tice Court." Well, it does seem somewhat untoward that yOU are now threatening to file
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~w J;, tl,,court's doors focking pnor to 5 pm. This is particularly troubksome where you make
accusations of such a litigant engaging in "aggressive behavior" when, in fact. it is your own
Chief Bailiff Sexton and Bailiff Reyes who have both engaged in bUllying behavior towards
litigants, replete with the ever so professional threats to forcibl} insert objects into a litieants
anus, and o!"hcr menacing commentary rdated to a litigants "ass". particularly whc'fc such
commentary occurred while said litigant wa, attempting to access justice in the most ba,ic way
(by presenting documents to b" filed with !"he tiling office, during hours j()r which the COUIt
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To: lclf11e9-fccB-467a-B.Of-Je.559b
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From: mhcoughlln
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Page 4 01'13
holds itself out as open for bU&iness).
You further wrot.:: "In addition. I have looked into your assertions of sexual assault by the Reno
Justice Court Bailin;. and found these allegations to be ",ithotn merit." However. in your
"looking into" these "assertions of se:-.'U.I assault" you have neither met wIth me nor intcrvlc"ed
me or otherwise conducted an)thing close to a reasonably dilIgent inquiry. something whIch
you may have a dUly to perf0TI11 WIth respect to anv negligent hiring. training. or supervision
daim or other 42l.fSC Sec 1983 daim a member. or a class of members orthe public may havc,
But you seem to suggeslthat you do not bare any responsihilitv for the actions or the WCSO
Court Security linit's actions. Howewr. if that is th~ cas~. one must wonder why you would
have "Iooked'into your assertions of sexual assault by the Reno Justice Court BaIliffs" or why
you ref"r to said Bailiff's altemative1y as "R"no Justice COllrt 13aililTs". while elsewhere using
the designation Washoe County SherifT - Court Security Unit.
You wenl on to write in another recent correspondence: "I) Th~ locking of the lfont doors to th~
Courthouse is the responsibility of the Sheriffs om,c. so all your questions regarding this Issue
will need to be directed to them. However, I will stale that the surveillance videos, which are
dakd and time stamped, dearly shows that you were here after 5:00pm on 2: 14;20 12 " Well, th~
videos may technically show I was "here after 5 pm". bUI it is curious you do not write that the
videos show tlla( I "did not aniw until alier 5 pm"",or otherwise get vcr\' spccifk
Please be aware Ulat this correspondence place, vou on a LITIGATIOl\' HOLD NOTICE with
to any and all recordings made in conjunctJon with this matter. and [,.rthcr. with regard
(0 any recordings made conceming me whahoe"er. PLEASE PROVIDE ME WI1ll A COPY
OF THE VIDEO YOU REFERENCE, CmfPLElE WllH THE TIME STA111'1"G ANI);\
WRITTDI ATTESTATIO;'; AS TO THE PRACTICE I\, PLACE TO ASSURE THE
ACCURACY OF THE TIMESTAMPING,
r~spect
You go on (0 write: "3) I am not sure what your question is regarding your 11/16111 filingMotion to Contest Personal Property," By all m~ns.let me elucidate tillS maner for you more
clearly Please sec the anached I i5, 12 Reply to Opposition in the appeal ti'om this malter, in
CVI1-03628 wherein the RIC's liability for failing to appropriaklY carry out the dictales of
black lener ~evada law found in NRS 40,253(7)-(8) IS quite clearly pronounced. Further. I W'LS
neWr provided or served a COPY of (ul1tll the filing (lfthe Record on Appeal. well after the 12115
aIld 12!17iJ I entries in the docket, which preceded the I2!20!l1 Hearing on Tenant's Motion to
Contest Personal Property Lien) the two statements the RJC se~mingly order Deputy Clerk .
Jocelyn Jonas ,md Chief Civil Clerk Karen StanCIl (0 place in Ihe tile in RJC REV20I 1001708.
In that Reply. in page 7 of24. one' finds the following. 4, FUlillY thing ahout the Reno Justice
Court: when it comes to sdting a hearing withIn 10 days ofmv l11ing :o.lotion to Contest
Persollal Property Lien on November 16th. 2011. the RJC is all "oh. we needed your
pennission, :Vir. Coughlin. to set sllch a hearing. its VOllt' fault that we couldn't g~t it on withll1
the!O days required by statme under '\RS 40.253(7-8): h,mel'er. when Coughlin \\ent in to lik
somethmg on ;;ovember 3. 201 I at 4:58pm. RJC tiling olliee Chief Clerk Karen Stancil didn't
nr>f'ci no nf':ml1""ion to
"I"T'Vi"
Of>rc.()t1:1lh: nn ('otlohlin ~otH't> of:1 ll'~;lrino to tak." nIM...... on
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C[om:
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zechcQugh11n
/-16-12
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Pllgc 5 of 1.1
~~01:d~y_ :\ovember 7, 2011. Well, actually. allegatheticaUy, another clerk (Deputv Clerk
. lfIstme Erickson) had to sneak that NOlice oftll. Hearing on Novemher 7, 2011 ';nto a st.ok of
paper.; she slIpped Cmlghlin when she was pretending to he helplill li)r a change, ralller than
sullen. and overly opllilOnated tor someone who cares so linl. of tne import of the Whitman,
Donoho. Bvrant, and Sullivan decisions of the Nevada Supreme Court with r<spectta court
employees legislating from the tiling office desk and refusing 10 accept filings because they just
aren't fcdillg it that day.... You seo, somebody allhe RJC figured out that it probably was 11~\
legal to hold on to Cougiliiniasl $2.275 on ~arth if il was not granting him a stay (especially
where NRS 40.385 entitles Coughlin to one. for his posting a bond as Utile as S250 (instead the
RJC kept Coughlin's $2,275, and ifyau believe Htll, did not grant a sta~) as. in Judge
Sferrazza's wordK ilIa! would be "conversion". So. ho\\ again is il Mr. Hill's outrageolls
allegations of Coughlin living here or there during this or that period (something which Hill
never bothers to support with anything other thall his own hluster. hot air. and conjecture. and
apparent willingness to to incur NRCP Rule J I sanctiolls if it me'IIIS milking a "illful
neurosurgeolJ good and dry in the process) are reasonably b'Lscd in fact or taw and therefore nol
worthy oDlRCP 11 sanctions')
Regardless, the RJC did set a Hearing on Tenanl's :vlolion 10 Conlest Personal Property I ,;e11,
and Tenant dId show up for it, in face, he checked in with Chief !:latliff Sexion prior to that
Hearing, which was set for November 22,2011. However, Tenant "as the oniy one who
showed up. Should that not yield a default victory')
However, more troubling is the RJC's conduct in forcing two ofig filing office personnel to
sign unswomed "statements", one month after some 'lIkgcd conversation incident to a litigants
visit to the filing ollice, and further. where Deputy Clerk Jocelyn Jonas was called to leslify by
Judge Sferrazza. would conducted a leading examination ofth~ Court's witness, Ul i\ matter
where the Court was not even a party. Most trouhling of all. however, it the faclll1al Ms. Jones.
OJ] cross-examination had to admit matters that show here stalement of December 15th, 2011 to
be misleading, at best and wholly deficient in fnlfilling Ihe RJC's dtny 10 maint;lin an
appearance of impartiality towards all litigant~. It is simply impermiSSIble for the RJC to have
Ms. Jonas sign and unsworn "statement" (truly a new one to me, heing neither a notarized
AHidavit, nor a Declaration made under "penalty of perjury" in lieu of an Allidavi!. However.
when Ms. Jonas did get sworn in at the 12/20, II Hearing. a few ImpleaS<lnl tnlt]" emerged,
One, Ms. Jona; was forced to admit that she did recall having a dlSCtlssion with Tenant
Coughlin in RJC REV2011-00I708 about the requiremelJt that the R.JC eomplv with :-;RS
40.253(8) which reads;
"NRS 40.253(8): Upon the filing of a motion pursuant to subsection 7. th~

court shall schedule a hearine on the motion. The hearing must be held
within 10 days after the tiling of the motion. The coun shall affix the date of
the hearing to the motion "lid order a cony sen'ed upon the landlord bv the
sheriff, constable or other process server. Atth" hearing. the court may:
(a) Detemline the COSIS. ifallv. claimed b~ the landlord pursluI111 to ;\RS
I 18A.460 or 11SC.230 and any accumulating daily cosLs; and
(b) Order the release orlhe tenant', property upon the puv'ment or the
char"", delennined to he due or ifno charp" are ddermincd 10 be due.
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One thing you may notice about the jurisdiction granted to the Court. ahove. in J\RS 40 253(R),
is that there is decidedly not any language allowing for an Order "Rcsol\'ing" \[otion to Contest
Personal Propel1y Lien like that Judge Sfcrrau.a .:Jllered on 12.2 J /11. and for "'hidl the RJC
tiling office has refused to allow me to file a Nuticc of Appeal for. and I"" f,.rther reflLscd to
even mark as "rccciwd" my auempts at so filing Such a Notlec Appeal and Motion to Proceed
on Appealln Forn1a Pauperis (to the exlent thai would eYen be nec,,;sary considering the
previous IFP status given the Tenant in that matter. RJC RE V20 ]-(JO !708). That 12/2!; 11 Order
is included following this corrspondence.
Coughlin is also the Defendant in this criminal matter, which is also before Judge Sfen-azza.
RCR11OG3341 ... .Judge Sferrazza is now seemingl~ being placed onto another landlord t,mant
matter where Coughlin i, a named party. desplle JCRRT 2 calling for a random assignment of
cases (Judge Lynch was randomly assigned to the ease originally. RJC20 12074408, Coughlin
v. Par~ Terrace HOi\. and. also. Judge Sferrazza is no .... sct to also take jurisdlctioll O\'d the
unlawful detainer matter that shall soon be filed upon Coughlin tiling a Tenant's Af1idavit upon
the proper service of a 5 day Unlnw!,,1 Detainer ?\oti,e to Quit). TIli, is not about impugning
Judge Sterrazza as a jurist. Its about cnticizing and seeking redress tOr the appearance of
impropriety creat~d wh~re WCSO B'liliffs engag~ in ~ondu,t thaI IS imp<rTnissiblc (threatening
to forcibly insert objects up a litigants anus) and th<n ~reate an undulv suspicious appearance of
"judge shopping by Bailiff' (Wh\' these Bailiffs seem to want to insult an estwnedjuristlike
Judge Sferrazza, one who has an e),,1raordinary depth and breadth of experience throughout all
three branches of gowrnment in Wa~hoe Counh. is puzzling and unfortunate). It would not
take much for these Bailiffs 10 gather an opinion on which judges 11a\'e which approach on
landlord tenant matters. It would be Imp<rmissible to allow Bailil],s go gmdgc based judge
shopping to retaliate against litigants asserting their conslllrtional rights, "" Coughlin clearly
does, much to their totalitarian dismay. Judge Sferrazza has an approach to landlord tenants
matters that is his own. as all judges invariably will. That does not make him and impartial
arhiter or imply any impropriety. HO"~\'Cr, to allow RJC Bailiffs to "gerrymander" "hat is
supposed to be a random a'lSigning of cases. would clearly be i11lpemli"ible. Ewn if that is not
what is occuning here, a reasonable person could concluded that the appearance of such is
evident. TIlis is pilfttwlarly lrue where Judge Clillon "as 011 the bmch and heard every other
case set for the 8:30 stacked docket in court room "B" on 2l3il2. \Jr. Tuttle did not get where
he is by being foolish or dim. He must work day ill day out with these BailitlS. \1r. Coughlin is
but a minor occasionallitigant'attomey in the Reno Justice Court. Reasonabk minds may reel it
would he filOlish for Mr. Tutlle to lake any action which "ould appear to undern1ine ~is belief
in the reasonableness and justness or these Railift's actions. particularly "here these hrave men
arc calkd to pcrtorm the heroic in tmly dangerous circumstances (ct times. That is "INrc mles
get to be the "bad guy" rather than judges \)r administrator.;. KRRT 2 is the had guy here, and it
is only appropriate for Judge L)llch to hear botll this new Complaint for llnlawful Intemlption
of Essential Services. in addition to anY Summary Eviction and or linlawful Detainer matler
that may arise hetween those parties m;d within Ii conunon nexuS of circumstances and facl~.
Also: "The Justices' judgment obligation to pay anome),s' fees is based (I) on their having
followed a procedural mle (JCRCP 106) enacted by this court and (2) on their having made
several erroneous judicial decisions." Lippis Y. Peters. 112 )iev. 1008. 021 P.2d 124R (l\eY. Aug
16.1996):
Wallace. Inc. v Eighth Judicial Disl. Court oJ'Stalc. ex reI. County "fClark.
262 P3d 1115.1140". 127 ;,rev. Adv. Op. 64. 64, (Nev. Oct 06.2(11) (\i0. 5677:1)" H"i
2,3,4 (P.2d) 2 Schneider v. Elko County Sherilfs Dept.. 17 F.Supp.2d 1\62.1165 (D.Ne\'. Aug
06,1998) ()\O. CV-N.96-548-ECR) Mentioned J Cheung Y. Eighth Judicial Dis!. Court ex reI.
n.c.
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Count v of Clark. 1241'.3d 550. 552. 121 :-;~V. 867. 869 leicv. Dec 15.2(05) (1\0. 42212) lIN:
1 (P.2d); "42 U.S.C. 1988 (1991).'111is federal statute pennits the statc courts to award
attollleys fecs to successful civil rights lihgants III civil righL' actions brought in the statc courts
under 19K!. 111e cited code provisIOn. section 1988. nllows for an award of fccs to Ihe
"prevailing party" when that party ha.s sued 'to enforce a pro\'ision of .. , 42 l,SCS J9R 11983." Ewn if we were to recognize the tenants a., the "prevailing party" in this litigation. it is
more than dear that this action wa.s in no way designed or pklldcd ',0 cnJoree a proviSIOn of .,
42 uses 1981-19&3." In their points and <luthorities in support of their application for
1015 attorney's rees the tenants agree that "[iJn order 10 statc a claim under 1983, PlaintJt1s
must allege a pet>on has deprived him or her of a federal right and the person so depriving actd
under color ofslalc law" In no instance did plainlifTtcnanl' ever "allege [that] a person has
deprived him or her of a federal right." Lippi' v', Peters 112 \ev II)OR. 921 1',20 1248,
Sincerely,
Zach Coughlin, Esq.
1422 E, 9th SI. #2

RENO, NV 89512
tel. 775 338 81 18

fax: 949 667 7402
ZachCoughlin(qiholmail,cotn
Nevada Bar No: 9473
... NoUcc..... ThG me~a.e:e 3Tl(\lIccompan}'1ng OOCIlmetlB ale L'O'rU-eJ ny the e\ectl,mIC Comrl1lJnt(dlwfI" Pm'll"), ACL i& U S,C ~s 2~\ \)2:;11.
and may contain confidenual IOformaium imended for tht spccltled mll"Hilal \~i ulIl~ [1' ~ou arc 1131 1M lIltendcd recipient or an al!:cnl
responSIble for dehvC1in~ It 10 the Intended reClplctlt. you art herevy nonned !hat ~ou have reCCI\OO C.htii document in error and tllsi any rC"tCII,
drssemmstkm, copymg, Of the taking of any action oa<;ed Oil the ~onteng \1f Ill!.., InformDllon i~~!t h:tl) prohltwed This Inessogt' is
intt'nded only for th, n(Jf1J(ld fu;pient(sj and may conto;n mformation that is privileged, attomey work
product or exempt fr<lffl disclosure utllkr cpplkabfr faw. if you art' not the IIltfnth'O reciplfnt(S}, you aft' notified thot
0"1 disclosure, copying, distribution or any action lattn or omittrd to tit' taken In "lIonc, on the contents of this
informotjon is prohibitfd and may be unlawful. Ifyro receive this messo'j(> in trror. or are not tht nOfflfd rt'cipient(s),
please notify rht sender, de/trf!' this f''ffloi/ 'rem your computtr, and deHroy any copies in ony {orm inTntdiately.
Receipt by anyoot!' ortler than tht nametl recipit!'ntfs) is not a waiver of any atrorney-cUtnt, work product, or other
applicable privilege.
confidentiaf,
Subject: RE: cases belllg randomly aSSigned in RJC FW: attempt to file prior to Spm denied
Date: Thu. 16 Feb 2012 09:46:45 -0800
From: stuttle@lwashoecounty,US
To, zachcoughlin@hotmail.com
CC psferrazza@washoecounty.us
1)
Questions regarding clocks - asked and answered,
hllp:m,y 148w.bay I 48.mail.livc.cmnfmailii'rintMcs.agcs,"'px?cpidFh02d3 508-a656-4a96"
2; 16; 20 I 2
To, lclfl1eHcc84fih8eGf-l ..119b
/1611
fr ... , zachcoughlin
Bonnail Print M~ssagc
Hlp.
"-"'
p, 12 of 23
Page 8 of 13
2)
Assertions of a countywide conspiracy are unfound and Insulting,
3)
Case judge aSSIgnments are random, but hearing ludge assignments arE at the discretIOn of
the ccurt and cases will be moved for a variety of reasons. mostly to ensure continUIty and
caseflowefficiency,
4)
5)
Statements regarding your "ass" - asked and answered,

Assertions regarding Judges Sferrana, Clifton and the Court's integrity are unfound and
,"suiting,
Steve TlIttle
Court Admini'tralor
Reno Justice Court
From: lach Coughlin [mailto:zachcoughlin@hotmail,comj

Sent: Wednesday, February 15, 2012 10:29 PM
To: Tuttle, Steve; Lynch, Patricia
Subject: cases being randomly assigned in RJC FW: attempt to file prior to Spm denied
Dear Mr. Tuttle,

Would you please confirm that the clocks in the court are accurate,
and indicate how the doors are locked, and how they were locked
yesterday. It is my position that I was there prior to 5 pm, further
the appearance given by the fact that the person I spoke with on the
telephone from the criminal division filing office (she made sure to
ask for my name, as though that would affect the content of her
answer to my questions-contrary to your a
ssertions, I am seeking no special privilege, but rather, seeking to
avoid any special prejudice) made sure to ask my name, and it was
provided is troubling when viewed in conjunction with the events
before my 2113/11 Hearing in the RJC in Coughlin V. Park Terrace
Townhomes HOA. As you know, JCRRT Rule 2 requires cases be
assie:ned randomly. However, thoue:h Jude:e Lynch was assie:ned to
htlp:!!by 14Rw, hay 148,mai1.ljvc,corn/maiIiPrjntM~ssagcs,asp.x?cpjds~M2d3 508.a656.4.01i
) i 1{;i1fl 1~
To: 7cJfI7.9-fc,8-461.-8.0f-lea519b
From: zachcoughlln
Holmail Print !.kssagc
2-16-11
"-"
5:01pm
Page 9
p. 13 of lJ
or 13
hear my Complaint for Interruption of Essential Services, shortly

before the hearing, the court room was popuplate by two different
Deputies who have both made menacing statements to me involving
my "ass", one of which involved forcible putting an object up my
"ass". Chief Deputy Sexton entered the court room and made a
few caUs, and he is one of the two Deputies to which r refer when
mentioning this "ass" situation. Next thing r know. Judge
Sferrazza is hearing the case, and now I am told Judge Sferrazza is
"attached" to the case instead of Judge Lynch. While hearing the
case, before it was continued, Judge Sferrazza apparently granted a
license to practice law to a property manager on behalf of another
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should be heard by Judge Lynch. This is not a statement against

Judge Sferrazza, it is a statement with respect to the appearance
created by the above facts. This, combined with the unexplained
October 19th. 2011 fax to Judge Clifton seeking an ex parte Order
allowing inspection of my law office by Casey Baker, Esq. of the
Law Offices of Richard G. HIlI, Esq., despite Judge Clifton not
being Chief Judge at that time in consideration of JCRCP 84.
Sincerely,
Zach Coughlin, Esq.
Zach Coughlin, Esq.
1422E. 9th 51. #2
RENO, NV 89512
tel: 775 338 8118
fax: 9496677402
ZachCoyghlin@hotroail.com
Nevada Bar No: 9473
From: zachcoughlin@hotrnail.com
To: stuttle@washoecounty.us
Subject: RE: attempt to file prior to Spm denied
Date: Wed, is Feb 2012 22: 15:02 -0800
hllp :!/by 148w.bay148.mail.live.com/mailfPrint~lessages.aspx""l'ids~b02d3 508-a656-4a96.. 2, 16/201 2
To, 7-df11e9-fccB-461.-8eOf-1e.119b
l-/olmaii Print Message
/-16-11
From, lachcoughl1n
i
"--"
'
'\.....--
5'01,.
p. 14 of 13
Page J 0 of J:1
Dear Mr. Tuttle,

Your correspondence contains numerous inaccuracies that r am too
presscd for lime to counler al this point. I appreciate your response
though. Can you confinn that the clocks in your court are correct')
Deputy Sexton agreed to get a supervisor and it was agreed r would
wait outside to speak to one. You, of course, have been infornled
numerous times previously ofWCSO Court Security efforts to deny the
access to justice prior to the 5pm closing time. I am still waiting for
some response from you regarding the various statements concerning
my "ass" by those you have some supervisory position over. Further.
can you please indicate why J was, apparently. provided some demand
whereby I would perform the duty placed upon the WCSO incident to
my IlI16/11 filing of a Motion to Contest Personal Property Lien vis a
vis the service and scheduling dictates found in NRS 40.253(7)-(8).
especially considering the holding in Lippis and NRS 42.
Sincerely,
Zach Cough"n, Esq.
1422 E. 9th SI. #2
RENO, NV 89512
tel: 775 338 8118

fax: 949 667 7402
ZachCoughlin@hotmail.com
Nevada Bar No: 9473
~A NotJce Ttll~ mes<;age and "ccompan}11l8 dOi.:umcnts arc covO"ed br we e!ectronlc ("omJ!'llIIlC!l.tJO,IS Pr.\'acy All J g (J S C 5~ ~5 JI)-~3 21.
and may con~run confidentIal mfm:nal.ion mlcnacd for 1)le ii'tclfie(1 mdivldual t SI lll!ly If) QU arC" flOl the mtended :"{'ClPletlt or an agent
respon~lble lor dchvenn,g It to the mtcndc:d reCIpient. )'1,.'\1 are hereby nOtified that you ha'rC recClved tlm; document In erfllr Mid thar any rel-Jew,
~h'S,;;e~\in\\.\i:"l\. 1::'Pymg, (~r 1\1, \aking l)f ...ny l\C\\Oil bm.~ll)}1 \he tI.lJl\enh 01 thiS informatwll h ~U Itll)' prahltll\cd This messeSI:" is
confrdffltia/, mt(>nd(>d only for the namtd r(>cipi(>nt(s) and m<lY cootClm mfOI7fflJt1on that is prfvil(>sed, ottom(lY work
product Qf f'nmpt (run disclosure unde( applicable law. If you O(f' not tilt> intt'nded fecipient(s), you ore notifird that
any discloS(Jre, copying, distribution or any action taQon or omfrtf'd to bt taken rn reliance on tilt contents of th6
information IS pronibtted 'lAd may ~ onl'lwftjl. If you rf'criw thi$ mf'$sQi!' in t'ffor j or Oft' not tht' namt'C r~cipjfM(s),
please notify the sender, d~J't(' this ('-mail {rem your computer, and destroy any copi('s in any form immM;otlly,
R('cf'ipt by anyone other tlKm the named recipient(sJ is not a waiver of {Joy attomt'y~dittnt, work product, or otht'r
app{icable privi/~e.
U
http:'/hy148w.hay J 48.mail.liv"_comjlllail!PrintM~ssag,,s.aspx?cpids=b02d3508-a6 56.4a96 .. _ 2; J6120 12
To: :'cJ!lleHccS-461a-SeCf-lea\\9b
'1m.: lachcoughlin
1-1~-\1
1:01pm
p, 1\ of lJ
Page II of 13
Holmail Prinl Message
Subject: RE: attempt to file prior to 5pm denied

Date: Wed, 15 Feb 2012 15:57:32 -0800
From: stuttle@washoecounty,us
To: zachcoughlio@hotmaU,com
CC: JGoodnight@washoecounty,us
Mr. Coughlin:
The documents that you emailed and faxed to Reno Justice Court at 0:40pm 00 "ebru.ry 14, 2012 were
filed staMp With today's date (February 15, 2012) and placed In 'he hie for the Judge's reView, It Will be
noted tha: these documents were received by the Court after normal business hours on February 14,
2012.
You were not denied by this Court your right to file these documents yesterday You were, however,
denied by Washoe County Shern!' - Court Secuflty Unit access to :he building after clOSing time; the
same as anyone else would be denied. You were not here before 5:00pm and trying to gam access mto
the facility by' coming through an "exit only" door
conSider (fespasSing
IS
IS
not permi.lslble. gecause your actions could be
the reason why ~eno Justice Court Chief BaMf MIChael Sexton agam "sked you
to leave. ~air and equal access to JU5tice applies not only to dlSCflrllndtlon, but also to fdvorltlsm.
Allowing one party to file documents after
a deadline IS unethICal and w"hout question unfaJ(,
Informing Chief Bailiff Sexton of your intention to wait outside for Reno Justice Court employees to
leave so you could force them to take your filings IS a form of harassmene and needs to scop
Immediately. !f this aggressIVe behaVior {ontlnues, thE Court will conSIder a protective order against
you, which will result in your ability or privilege to acces'S Reno Justice Ccurt
In addition, I have looked into your assertions of sexual assault by the Reno Justice Court Bailiffs and
found these allegations to be Without ment.
Lastly, your practice of filing hundreds of documents on Multiple cases and then repeatedly asking for
copies of the case files "free of charge" Will no longer be granted by the Court. Reno Justice Court will
proVide you one free copy of your angmal case files and Doe free COp~f of any future flllng~, bur you will
be charged appropriately for all additional ccples.
Steve Tuttle
Court Administrator
To: 7.cJfZle9-fccH67a-ieOf-7ea559b
H6-11
From: zachcoughlin
Hotmail Prinl Message
'-
5:01pm
p. 16 of 13
Pagc12of13
Reno Justice Court
From: Zach Coughlin [rnallto:zachcoughlin@holmail.com)

Sent: Tuesday, February 14, 2012 6:40 PM
To: Tuttle, Sieve; C..oodnight, Joseph W; Young, Zach; RJCWEB

Subject: attempt to file prior to 5pm denied
Dear Reno Justice Court Administration and RUng Office, DDA Young and DPD Goodnight,
Helio, I am emailing and faxing the document and one exhibit you will find herein as I was denied my
right to file it today. I presented to the court prior to Spm today but was prevented from filing this
document (and today is the last day to file these pretrial motions absent receiving leave of court to do
so prior to the February 29th, 2012 Trial in Department 2 before Judge Sferrazza. Judge Sferrazza has,
in the past, expressed displeasure with regard to any attempt to file by email, and 1 do not wish to upset
Judge Sferrazza here, and accordingly am not copying him on this correspondence. However, r believe
the "excusable neglect"/"deprivation of rights under (olor of law" analysis may dictate that r promptly
attempt to make some record of my attempt to file and in that regard 1 am submitting this to you noW.
Incidentally, I did call the criminal division RJC filing office today shortly before Spm alerting them to my
imminent attempt to access justice and received confirmation that they would not close prior to Spm.
Hawver, the doors of the court house were locked prior to Spm. r have witness timers/clocks In the
court to be set approximately 5 ninutes fast in that past. I attempted to ask a supervisor about tllis by
alerting Chief Deputy Sexton, and while he initially refused to get a supervisor, he then finally indicated
'he would, however, no supervisor ever appeared. Chief Deputy Sexton, along with another Deputy has
sexually assaulted me in that past, and as such, of course, the was a very unusual and uncomfortable
situation.
Add~lonal1y,
I had another landlord tenant hearing involving
myse~ on Monday,
2/3/12. AS per JCRRT
my Case was randomly assigned to Judge Lynch. However, JUst prior to my case being heard, Deputy
Sexton entered the court room, made some calls, and Judge Sferrazza appeared to hear my case.
Judge Sferrazza then proceeded to grant a property manage a license to practice law on behalf of Park
Terrace Homeowners Assodations (PTHOA). 1, of course, am very uncomfortable having the Oeputy
who sexually assaulted me appear in the court room at ali my appeances, as Deputy Sexton seems to do
(in fact, he glowered over me at the 12/21/12 Hearing on my Motion to Contest Personal Property lien)
in such a menacing fashion that I was unable to think clearly, much to the detriment of my case.
Further, I am uncomfortable at the appearance given off by the curious changing of the Judge assigned
to my hearing after Deputy Sexton entered the court room and made a few calis. It may be
inappropriate to give off the appearance that Deputy Sexton is able to control the assignment of Judges
to certain cases rather than having cases randomly assigned pursuant to JCRRT. I believe this filing and
one exhibit you find herein should be accorded a filing date for 2/14/12, as 1 was prevented from
appropriately accessing justke, and in that regard, I don't believe this is a request to "bend" the rules or
allow a special exception, though I do believe One is able to file a motion seeking such an exception for
cause. Deputy SExton has sexually assaulted me in the past in similar situations where I attempt to use
all of the hours available to filing accorded to any other member of the public.
Zach Coughlin, Esq.
1422 E. 9th SI. #2
RENO, NV 89512
http:!tbyI48w.hay 148 .maiLliv~.com!mail;PrintMcssagcs.aspx'!cpids=b02d3 508a656-4a96.. 2;) 6:20 12
To: 7cJfl7e9-fccH67a 'BeOE-7.a559b
lIotmuil Print
M~ssag~
From: zachcough11n
1-16-\1
Ulpo
p, 17 ,f 13
Page 13 01' !3
"
tel: 7753388118
fax: 949667 7402
ZachCoughlin@hotmail,com
Nevada Bar No: 9473
** Notice-- ThIs message Mel accompanYing documents lre (overed by the electronic CommuntcatlOns Pnvacy Act, 18 U.S.C.
~ 2SiO-2Slt, and
may contain c{)nftdentla! mforrnatH:m jnt~Med for the weclfleQ lOO\l\dual (s) only. If you are not the u'\tende<l
reCIpient or an aJent responsible for delrvenng it to the Intended recipient, you are hereby notified that you have received this
document In error and that any review, diSSeminatIOn, copying, cr the taking of any action based on the contents of thiS
information 15 sbictly prorublted. This message is confidential, intended only for thi' namtd fPcipienr(s) and may contain
mfonrration that;s privileqed, attorney work product or exempt from d;sclosuft under applicable law. If you are not the
intended rt'dptfnt(s), yoo are' notified that any disclosure', copying, dlstdbution or any (lction tax,n or omitted to be
taken in fetionce on the contmts of this information is prollibited and may bf' unlawful. If you rea/v!' thJS message in
error, Of art not the named reopient(s), please notify the ~nder, defett this e..moil from your computer, and destroy
any copies in any form imnediate(y. Rt"ceipr by anyone other than the MJlJ1lId recrpient(s) Is not a waiver of any
attom,yc(itnt, work product, or other applicable priVl/'9 p
htlp::'/by 148w,bay 148,maiL livc,comimailiPrinlMcssagc"aspx?cpids=b02d3 508-a656-4a96."
2! 16/20 12
To. lcJfl7e9-fccH61 ,-BeOf- 7ea559h
from: rachcoughll'
1-16-11
.'
\.
5.Dlpm
p. 18 of IJ
F I LED
Electronically
01-20-2012:02:35:37 PM
EXH IB IT 2
'j
I
,
EXHIBIT 2
Joey Orduna Hasllngs

Clerk of Ihe Court
Transacflon#2711293
10: )clflle9-fcc8-461a-8eOf-)e.119b
1-16-11
froo' zachcoughlin
I:Ol?m
-II
; I
p. 19 of 13
rD
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11 OEC 2 I Plm I 7
2
3
COUNTY OF WASHOE, STATE OF NEVA DA
Case No. REV 2011001708

Dept. No.2
ORDER RESOLVING MOTION TO CONTEST

PERSONAL PROPERTY LIEN
14
15
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HaYing considered the evidence presented to this point and the parties having
17
agreed to allow the Court to enter an order based on said evidence, the Court finds that $480.00
18
is fair and reasonable compensation for storage of the personal property of the Defendant for
19
the period of November 1,2011 to November 16,2011.

Based upon the foregoing, the Court hereby enters the following Order:
21
1.
That the Defendant, Zachary Coughlin, shall pay the sum of$480.00 in
22
certified funds to the Plaintiff at the Law Offices of Casey Baker on or before Wednesday,
23
December 21, 2011 at 4:00 p.m.
24
2.
The Plaintiff shall have the right to videotape the premises from 9:00
25
a.m. to 5:00 p.m. on Thursday, December 22, 2011 and said video shall include personal and
26
real property; however, they shall not identify any personal information of any clients of the
.I.
To: JclfI7e9-fcc8-467a-BeOf-7ea559b
Fro.: ,.chcoughlln
1-16-11
5:01pm
p. 10 of 1]
Defendant's law practice. In addition, the Plaintiff, by his attorneys or other authorized
2 representative, shall have the right to videotape the property following the removal by the
3 Defendant of his personal property, which shall occur on or before 5:00 p.m. on December 23:
4
2011. The purpose of the video is to determine whether then; is any damage to the real or
5 personal property of the Plaintiff, which shall include all fL'ttures and appliances that belong to
6 the Plaintiff. In addition, the video shall be used to verify what properly, if any, is left on the
7 premises by the Dcfendant.
S
9
10
3.
Anything and everything left on the property after 5:00 p.m. on Friday,
December 23, 2011, may be disposed of by the Plaintiffin his sole discretion.
4.
Defendant shall have access to the property from 9:00 a.m. to 5:00 p.m.
lion Thursday, December 22, 2011, to videotape, if he desires, the real and personal properly and
12
to remove his property from the premises. In addition, the Defendant shall have from 9:00 a.m.
13
to 5:00 p.m. on Friday, December 23,2011 to videotape and remove his property from the
14
premises. Access will be provided by a representative of the landlord, who will unlock the
15
property at 9:00 a.m. and lock the property at 5:00 p.m. on both days.
16
5.
The Landlord shall have no liability for any injuries suffered by
17
Defendant or anyone else during said removal process, except for an intentional tort committed
18
by the Plaintiff or his representatives against the person of the Defendant and, likewise, the
19
Defendant shall have no liability for any injury to the person of the Plaintiffor his agents,
20
except for an intentional tort by the Defendant. Further, anyone the Defendant authorizes to be
21
on the premises during the period Thursday, Deccmber 22"d, from 9:00 a.m. to 5:00 p.m. and
22
Friday, December 23", from 9:00 am. to 5:00 p.m. shall sign the Release of Liability, attached
23
hereto as Exhibit A If any third party is on the premises without signing the waiver, they shall
24
be trespassers and the Plaintiff or his agents can have them removed by l~w enforcement.
25
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6.
The Defendant shall not cause any damage to the real propcrty or
personal property of the Plaintiff located at 121 River Rock, Reno, :-levada, from this date
2.
:0.
.
,
, '.
'lcJf21e9-fccB-461a-8eOf-lea\19b
from: zachcoughlln
/-16-11
1:01pm
p. II of 13
I
forward. The Court will retain jurisdiction over the issue of any damages caused to the real
2
property or personal property oCthe landlord during the removal process.
7.
4
The Defendanl shall have no claIm for damages with respect to missing
or uamaged personal property at 121 River Rock, except for property identifled by him. in
5 Wnting, by 11 :00 a.m. on Thursday, December 22, 2011 by email to).1r. Baker, with a copy to
6 the Court. The Defendant reserves any other claims he has that may not involve his personal
7
property located at the premises to the extent legally allowed by statute or case law.
8.
The Plaintiff reserves all claims of any nature including, but not limited
9 to. additional storage fees from November 17,2011 up until December 23.2011, damages to
10
the property allegedlY caused by the Defendant, disposal costs of any property left behind.
l!
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13
.'
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15
16
17
18
19
20
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22
23
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25
26
.3 .
To" ldf21e9-f,cS-461 a-SeUHea159b
From, ,achcouqhlin
1-\6-12
"Ulp.
p. 12 of lJ
RELEASE 0 F LIABILITY
By signing below, your agents hereby release Dr. Matthew Merliss, the Matthew J.
Merliss Living Trust, the Jaw finn of Richard G. Hill, Chanered, Richard G. Hill, Esq., and
Casey D. Baker, Esq., in advance, from any and all injuries, from any source and of any kind,
~ri~in\l 11111
I1f nm or th~irllr~~~n~~ I1n
lh~ llmrlr.T1Y
M I? 1 Riv~r Ro~1< R,nn
;,.. 'hfl ~'"'T''' (MMll"i'''e fnt"rt, ,,,,,1'1 ...,,,,1\';,-,1\ f...., l'\fI\'\v,).

tort
,/'It"'"'}"
N~var1a
tnnayor
,hMr, t'.ri.,;,.,e ,*M' !of "\'1 ;,0,' 1''''l~''''\''1\1
by either pany against the other. You, personally, agree to indemnify the above from any
such loss, cost or damage, including fees.

By signing below, you agree to all of the foregoing.
Dated this ___ day of December, 2011.
Exhibit A
-_._----------
------------------------
10' 'loJfl1e~-fcc8-l61a-8eQf-lea55~b
From: zilchcoughhn
Hfi-l2
Hlp.
p. 2J
2
3
Lori Townsend, certifies: (a) she is a citizen of the United States, ovcr 18 years of
age, and not a party to the within action, and (b) that affiant served a copy of the attaehed on the
5
6
cktM ' 4tv~....u
LORI To\VNSEf.;D, Secretary to

PETER l. SFERRAZZA, lustice of the Peace
9
10
11
12
13
Name:
Address to which
mailtxlidelivered;
14
Richard G. Hill, Esq.

Casey D. Baker, Esq.
652 Forest Street
Reno, NY 89509
December 21,2011

date plaeed in eounty interoffice mail.
dale placed in county mail jog system for postage
transmitted via facsimile to 775348-0858
Name:
Address to which
mailed/delivered:
Zachary Barker Coughlin, Esq.

8l7l\orth Virginia Street
Reno, NV 89501
22
December 21,2011
23
December 21,2011
dale hand delivered.

date placed in eounty interoffice mail.
transmitted via facsimile to 949-6677402
15
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Dccember21,2011
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18
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20
21
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25
26
ot 1)
.. ",4
.1

Plaintiff,
6
7
v.
DEPT:

Defendant.
8
9
RCR2011-063341
----------------------------/
MOTION TO STRIKE FUGITIVE DOCUMENT
10
11
COMES NOW, the State of Nevada, by and through RICHARD A.
12
GAMMICK, District Attorney of Washoe County, and ZACH YOUNG, Deputy
13
District Attorney, and hereby moves this Honorable Court for an Order
14
granting the State's Motion to Strike Fugitive Document. This Motion
15
is based upon the attached Points and Authorities and any oral and/or
16
documentary evidence that may be presented at a hearing on this
17
matter.
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19
20
21
22
23

The undersigned does hereby affirm that the preceding
document does not contain the social security number of any person.
DATED ,hi,
a\:s,l;-
day
Of::3 \:>'~1l2
,2012 .
RICHARD A. G ICK
District Attorney
Washoe County, Nevada
24
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Attorney
,
'J
,
"
'I
2
3
I.
Statement of the Case
On August 20, 2011, zachary Barker coughlin (hereinafter
I
i
.i
!
j
"the Defendant") was arrested by the Reno Police Department. He was
charged, by way of a Criminal Complaint, with a misdemeanor count of
Petit Larceny. Subsequently, an Amended Criminal Complaint was filed
alleging a second misdemeanor count of Possession of Stolen Property.
From the inception of this case, the Washoe County Public Defender's
Office was appointed to represent the Defendant, and Deputy Public
10
Defender Joe Goodnight (hereinafter "Mr. Goodnight") was assigned to
11
the Defendant's case. Among other things that Mr. Goodnight has done
12
in the course of his representation, he filed a Motion to Suppress on
13
February 13, 2012. '
14
Throughout the course of the instant case, the Defendant
15
has personally sent several emails and faxes to the undersigned, Mr.
16
Goodnight, and this Court. On February 15, 2012, the undersigned
17
received, by way of fax, a "Motion to Dismiss, Motion to Suppress,
18
Motion in Limine, Motion to Examine Police Personnel Files, Motion
19
for Sanctions, Motion for Continuance or Extension of Time, Notice of
20
Appearance of Co-Counsel, Notice of Ineffective Assistan [sic] of
21
WCPD Defense Counsel; Request for New Counsel." This purported motion
22
was not file stamped when received by the undersigned. Later on
23
February 15, 2012, Steve Tuttle (hereinafter "Mr. Tuttle"), who is
24
the court Administrator for the Reno Justice Court, emailed the
25
Defendant, Mr. Goodnight, and the undersigned stating that certain
26
The State is currently draft'
~ng an
Oppo
,
sit10n to sa~d Motion to Suppress, wbich will be timely filed.
documents - purportedly the aforementioned "motion" - will be file
stamped February 15, 2012.

While the State has not yet received a file-stamped copy of
3
4
the purported motion, the State files the instant Motion to strike
FUgitive Document in an abundance of caution due to Mr. Tuttle's
I
1
email stating that such document would be filed and given to this
"1
Court for review.'
1
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,
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II .
ARGUMENT
"If the defendant elects to have counsel, he has no right
9
10
to represent himself." Layton v. State, 91 Nev. 363, 366 (1975).
11
While a criminal defendant has a constitutional right of self-
12
representation, he does not have a right of "hybrid representation",
13
where a defendant has an attorney representing him and represents
14
himself at the same time. Wheby v. Warden, 95 Nev. 567, 568-569
15
(1979) (overruled, on other grounds, by Keys v. State, 104 Nev. 736
16
(1988; also see Rhyne v. State, 118 Nev. 1, 8-9 (2002) (citing a
17
California's court denial of a defendant's request, opposed by
18
counsel, to act as co-counsel). The Nevada Supreme Court has
19
"previously determined that although a criminal defendant may have
20
both a right of self-representation and a right to assistance of
21
counsel, this does not mean that a defendant is 'entitled to have his
22
case presented in court both by himself and by counsel acting at the
23
same time or alternatively at the defendant's pleasure.'" Wheby, 95
24
Nev. at 568-569.
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26
The undersigned has received several other pu~rted motiOns. signed by the Defendant throuNh-.t the
course of this case Until now the St t
'
".~"
filed This M
'.
'
a e ""as not made aware that any of the prior "pleadings'" had been
Defendant
otl.~~ while specifically addressing the aforementioned purported motion filed by the
, equal y applies to any other fugitive documents personally sent or filed by the Oefendant.
In the instant case, the defendant is represented by Mr.
Goodnight, a deputy with the Washoe County PUblic Defender's Office.
As such, the Defendant is not - at the instant time - in a position
J
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,
to be representing himself, and any documents filed or otherwise
submitted by him, rather than Mr. Goodnight, are fugitive documents.
Such documents should not be considered by this Court, and the State
should not be required to respond to such purported filings.
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Allowing a hybrid representation poses several practical

problems. " [W]hile the client may make decisions regarding the
10
ultimate objectives of representation, the trial lawyer alone is
11
entrusted with decisions regarding legal tactics." Rhyne, 118 Nev. at
12
8. A defendant and his attorney, if acting as co-counsel, may reach
13
an impasse as to certain legal tactics, such as what questions to ask
14
and what evidence to offer (if any), thereby negatively impacting the
15
representation of the Defendant. Should the litigation go off in
16
different, possibly oPPosite, directions, the question arises as to
17
who will make the ultimate decision: criminal defendant or his
18
attorney. If there is a disagreement between "co-counsel" that cannot
19
be resolved, should the presiding judge become involved in conflict-
20
resolution? See Rhyne, 118 Nev. at 9 (finding that the district court
21
should not have attempted to resolve a dispute between a defendant
22
and his counsel) .
23
Further, what happens if either the Defendant or Mr.
24
Goodnight believes that his "co-counsel" is acting unethically or
25
against the best interest of the Defendant's case? Who gets the final
26
say and should one report the other for any unethical or otherwise
4
improper behavior? And if one person acts unethically, is the "co-
counsel" responsible for any such misconduct? Moreover, where a
defendant truly representing himself in proper person is barred from
subsequently claiming he was denied the effective assistance of
counsel, does the same hold true for a defendant acting as co-counsel
,1
with an attorney? Also, what sort of canvasses should be conducted by
the presiding court regarding all of the above concerns? Finally, as
;1
is true in the instant case, "co-counsel" may be filing duplicative
and redundant pleadings, Which begs the question which pleading
1
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10
controls so as not to unduly burden the court and the State.'

In sum, the Defendant should not be allowed to act as co-
11
12
counsel with Mr. Goodnight in the instant case, and consequently, any
13
pleadings filed by him should be stricken as fugitive documents. Of
14
course, should the Defendant wish to represent himself, such a
15
request should be raised before this Court, at which time a proper
16
canvass can be administered, pursuant to Faretta v. California, 422
17
U.S. 806 (1975), and Nevada Supreme Court Rule 253. 4 Until such a
16
request is made, and potentially authorized by this Court, the
19
Defendant should be prohibited from filing his own pleadings. As
20
previously stated, the Defendant can represent himself or be
21
represented by an attorney, but he is not entitled to a hybrid of
22
both.
23
24
Additionally, the purported motion filed by the Defendant

includes one exhibit, which the Defendant titles, "Collection of
25
26
:f~~~~~~t'fU~~~::Vi~~!it stated,
.. To the best of the und:rSi
::.
gn
tiled a Motion to Suppress on February 13, 2012, while the

the Defendant includes reference to a "Motion to Suppress."
ledge, the Defendant has not yet asked to represent himself.
fi~ by
,
,
:j
Correspondence Between WCPD Joe Goodnight, Esq and Zach Coughlin,
Esq.; Two Hundred and Twenty six (226) Pages." By the very title of
I
,
the exhibit, it appears that the Defendant is waiving his attorney-
client privilege, as he has taken it upon himself to provide to the
undersigned and this Court correspondence he has had with his
attorney. If this is the Defendant's intent, such may turn out to be
an ill-advised decision; if this is not the Defendant's intent, then
the State should not have to respond to the aforementioned motion as
i t incorporates, by way of attachment, a document which arguably
10
should not be reviewed by the undersigned.
11
III.
12
CONCLUSION
The State respectfully submits that any motions or other
13
documents executed and signed by the Defendant himself that are filed
14
with this Court, including but not limited to the Defendant's "Motion
15
to Dismiss, Motion to Suppress, Motion in Limine, Motion to Examine
16
Police Personnel Files, Motion for Sanctions, Motion for continuance
17
or Extension of Time, Notice of Appearance of Co-Counsel, Notice of
18
Ineffective Assistan [sic] of WCPD Defense Counsel; Request for New
19
Counsel" should be stricken as a fugitive document. Accordingly, the
20
III
III
III
III
III
III
III
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State hereby respectfully requests that this court grant the instant
Motion to Strike Fugitive Document.
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DATED this
ZI5\-'day o~6~
, 2012.
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RICHARD A. GAMMICK
District Attorney
Washoe County, evada
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0217RCR20110633414
Cr.>j'>"h
~rti,~,.
FILED
"'}
JEREMY T. BOSLER
BarNo. 4925
One California Ave
Reno, NV 89509
i
I
(775) 337-4800
IN TIlE JUSTICE COURT OF RENO TOWNSHIP

6
THE STATE OF NEVADA.

Plaintiff,
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v.
Dept. No.2
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ZACHARY BARKER COUGHLIN.

Defendant.
----------------------~/
MOTION TO CONTINUE TRIAL DATE
15
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN. by and through his
16
attorney of record Joseph Goodnight, Deputy Public Defender, hereby files this Motion to
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1S
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Continue the Trial Date for sixty (60) days. This Motion is made and based upon the following
memorandum, affidavit of counsel and all papers and pleadings on file herein.
STATEMENT OF THE CASE
20
This case stems from an arrest made on August 20. lOll. The Washoe County Public
21
22
Defender was appointed and the parties appeared for a Pre-Trial Hearing on September S, 2011.
23
A Competency Evaluation was requested and a Competency Hearing was set for October 12,
24
2011 and then continued due to a delay in obtaining the evaluation until October 26,2011.
25
After a
fin
ding of competency, the case was re-set for a Pre-Trial Hearing to occur on
26
November 28, 201 L The parties appeared for the Pre-Trial Hearing whereupon the State
1
requested leave of the court to amend the criminal complaint. The case was then set for Trial to
occur February 29, 2012. During this time period, the Defendant has been subject to numerous
personal hardships including fmding a new residence, custodial arrests, and being the victim of
domestic violence to the extent that the Defendant had to seek a Temporary Protection Order
5
6
from his co-tenant. Further, his power was shut off and has yet to be restored leaving him with
no electricity, heat or hot water. All of which has made it difficult for him to prepare for his
upcoming trial. The Defendant has asked his counsel to seek a continuance of the trial date in
light of his current situation.
10
MEMORANDUM
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12
The Justice Court Rules of Reno Township (nJCRRT") provide direction to this Court
in granting continuances. JCRRT 12(A) states "[n]o continuance of a trial in a case shall be
13
granted except for good cause. A motion or stipulation for continuance shall state the reason
14
15
therefore and whether or not any previous request for continuance had been either sought or
16
granted. The motion or stipulation must certify that the party or parties have been advised that
17
a motion or stipUlation for continuance is to be submitted in their behalf and must state any
18
objection the parties may have thereto." (See Also, Criminal Rules of Practice for the Second
19
Judicial District Court of the State of Nevada, Rule 10. Continuances.)
20
The Defendant moves this Court for a continuance of sixty (60) days to allow him
21
sufficient time to stabilize his Iiving situation, address the personal hardships he has endured,
22
23
and prepare for trial with his counsel. He has been advised that this request will be submitted
24
and he has no objection to it. The defense submits that the following Affidavit establishes good
25
cause and moves this Court to grant the Motion for Continuance.
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1//
v
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AFFIDAVIT IN SUPPORT OF MOTION TO CONTINUE TRIAL DATE
State of Nevada
} ss.
County of Washoe
I, [Joseph Goodnight}, do hereby swear under penalty of perjury that the assertions of
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this affidavit are true.

1. 1 am an attorney, duly licensed to practice law in the State of Nevada, and that I, in
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my capacity as a Deputy Public Defender and representative of the Washoe County Public
Defender's Office, represent defendant, Zachary Barker Coughlin, in the criminal matter of the
10
State of Nevada vs. Coughlin, RCRII-063341.
11
2. That I am familiar with the facts and circumstances set forth in the Motion for
12
Continuance, and know the contents to be true, except to those matters stated upon information
13
and belief, and as to those matters believes them to be true.

3. I make this affidavit in support of a Motion to Continue the trial in State v. Coughlin,
15
16
Case No.: RCRIl-063341.

4. I base the facts set forth in this affidavit upon my persona! knowledge, information
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19
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obtained during the course of my representation. and review of documents provided by the
Defendant This affidavit does not set forth each and every fact learned by me or others during
the course of my representation.
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5. On January 17, 2012, the Defendant contacted this affiant and requested a
22
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continuance because he felt that the investigation performed by the Public Defender's office
24
was insufficient in preparation for trial.
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III
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III
"
v
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6. On January 24. 2012, the Defendant again contacted this affiant and requested a
continuance citing the following hardships: being the victim of domestic violence, being
wrongfully arrested, and a "variety offactors."
7. On January 24,2012, the Defendant provided this affiant with a scanned copy of a
5
!
,
,
Violence, and an Order For Hearing To Extend Modify Or Dissolve The Protection Order. The
latter two documents are me-stamped January 23, 2012 and signed by Deputy Clerk Joey
Hastings. A "Certified Copy" stamp and signature also appears on both documents.
,!
"
Temporary Protection Order application, a Temporary Order For Protection Against Domestic
10
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8. The setting date for the Hearing To Extend Modify Or Dissolve The Protection
Order is February 28, 2012 at 8:30 a.m.
12
9. On February 9,2012, this affiant spoke with the Defendant who explained that his
13
power had been shut off and was not yet restored, leaving him with no electricity, heat or hot
14
15
16
water. Also on this day the Defendant confirmed that he still sought a continuance and had no
objection to submission of this motion.
to. Prior to filing this affidavit, undersigned counsel, in good faith, contacted Deputy
17
18
District Attorney Zach Young via telephone to request a continuance in this matter. Mr. Young
19
declined to stipulate to the continuance.
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11. Based on the above facts, undersigned counsel respectfully requests that this Court
21
grant his Motion and continue the trial date for sixty (60) days.
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(II
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III
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II/
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III
v
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RJRTHER AFFIANT Sl\ YETH NAUGHT

-~
Dated this 3L day of t - I : . 2012.
,
By:
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SUBSCRffiED and SW~RN to before me this
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day Of~012.
\.laJu~&~JtkA~
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u
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DATEDthis ..... \
Day of
.2012.
JEREMY T. BOSLER
f~~
By
1J,~~
JOSEPH W. GOODNIlIT
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forwarded a true copy of the foregoing document through inter-office mail to;

DATED this
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~,
Day of
F~
,2012.
~frAdJi
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FILEO
JEREMY T. BOSLER
BarNo. 4925
One California Ave
Reno, NV 89509
(775) 337-4800
I
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9

Plaintiff,
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v.
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13
Dept. No.2
Defendant.
________________________
~I
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MOTION TO APPOINT CO-COUNSEL

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attorney of record Joseph Goodnight, Deputy Public Defender. hereby files this Motion to
Appoint Co-Counsel. This Motion is made solely at Mr. Coughlin's request and based upon
the following points and authorities and all papers and pleadings on fIle herein.
STATEMENT OF THE CASE
This case stems from an arrest made on August 20. 2011. The Washoe County Public
22
Defender was appointed and the parties appeared for a Pre-Trial Hearing on September 8, 2011.
23
A Competency Evaluation was requested and a Competency Hearing was set for October 12.
24
2011 and then continued due to a delay in obtaining the evaluation until October 26, 2011. At
25
the October 26 hearing the Court addressed whether Mr. Coughlin would be representing
26
himself or through the assistance of counsel. The Court told Mr. Coughlin that he could be
1
-.
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1
2
appointed as co-counsel if he wished to represent himself. At the time, Mr. Coughlin declined
a co-counsel arrangement and did not seek to represent himself. Recentl y, Mr. Coughlin has
3
4
set to occur February 29, 2012.
,!
changed his position and wishes to appear as co-counsel in his own defense. Trial is currently
POINTS AND AUTHORITIFS
A defendant in a criminal case has "two constitutional rights with respect to his legal
representation, [ ... J[h}e may choose to be represented by professional counsel, or he may
knowingly and intelligently elect to assume his own representation." People v. Hamilton, 48
10
Cal. 3d 1142, 1162,774 P.2d 730,740 (Cal. 1989) (citing Paretta v. California, 422 U.S. 806
11
12
(1975. "An accused who chooses professional representation rather than self-representation,
has no right to participate as co-counsel." l!L However, the Court may authorize this
13
arrangement if there is a "substantial showing... that in the circumstances of the case the cause
14
15
of justice will thereby be served and that the orderly and expeditious conduct of the court's
16
business will not thereby be substantially hindered, hampered, or delayed." Id. (citing People v.
17
Mattson 51 Cal.2d 777, 797, 336 P.2d 937 (1959.
18
CONCLVSION
19
Over the objection of counsel, Mr. Coughlin requests to be appointed as co-counsel.
20
Counsel suggests a pre-tial hearing to determine the merits of Mr. Coughlin's request.
21
If/
22
III
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/11
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II/
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/II
v
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j

The undersigned does hereby affmn that the preceding document does not contain the
CERTIFICATE OF SERV'Irn
1, JOSEPH W GOODNIGHT, hereby certify that I am an employee of the Washoe
forwarded a true copy of the foregoing docwnent through inter-office mail to:

DAlEDthis
2/
Day of
F&v".........
3
,2012.
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tb1di:i
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~ ~'t~~~-'f'.
ORiGiNAL
v
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CODE 2592
JEREMY T. BOSLER
BAR #4925
WASHOE COUNTY PUBLIC DEFENDER
P.O. BOX 30083
RENO, NY 89520-3083
(775) 337-4800
~J:~
{:OS '3c
FpLED
lU'l FEB 23 AM 10: 3
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9

Plaintiff,
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12
vs.
CASE NO. RCR2011-063341
ZACHARY BARKER COUGHLIN

Defendant.
DEPT. NO. 2
I
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14
NOTICE OF WITNESSES
15
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attorney of record, JOSEPH GOODNIGHT, Deputy Public Defender, and hereby gives notice of
17
witnesses the Defendant intends to call in his case-in-chief, pursuant to NRS 174.234:
18
(
j
I
PROSPECTIVE WITNESSES:
19
1.
Robert Dawson, 4775 Summit Ridge Dr. #1052, Reno, NY 89523;
21
2.
Colton Templeton, 6366 Everest Dr., Reno, NY 89523;
22
3.
Nicole Watson, (775) 233-0367.
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AFFIRMATION PURSUANT TO NRS 2398.030
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Social security number of any person.

DATED this 23rd day of February, 2012.
er
BY'4~~~~ ;=-"'J
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EPHGOOD
i" .
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Reno, Washoe County, Nevada, and that on this 23 RD day of February, 2012, I forwarded
copies of the foregoing documents through, but not limited to, inter-office mail, addressed to:
ZACHYOUNG
DEPlITY DISTRICf ATTORNEY
1 soum SIERRA STREET
RENO,NY
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I
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MISHA BAYNES
IN THE JUSTICE COURT OF
IN AND FOR THE COUNTY OF WASHOE;; .____ "'_ ~tfll~rr~~A

v,
* * *
Plaintiff,
RCR2011-063341
v.
DEPT:
7
8
Defendant.
10
OPPOSITION TO MOTION TO SUPPRESS
11
12
GAMMICK, District Attorney of Washoe County, and ZACH YOUNG, Deputy
13
District Attorney, and hereby opposes the Defendant's Motion to
14
Suppress. This opposition is made and based upon the attached Points
15
and Authorities and any oral and/or documentary evidence that may be
16
presented at a hearing on this matter.
17
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document does not contain~e social security number of any person.
DATED this
dS
day of
'\..R kwM&
'
2012.
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RICHARD A. GAMMICK
District Attorney
24
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Attorney
I.
FACTS l
On August 20. 2011 at approximately 11:27 p.m., Reno Police
Department Officer Nicholas Duralde (hereinafter "Officer Duralde")
and other officers was dispatched to the plaza at 10 N. Virginia
Street, Reno, Washoe County, Nevada, regarding a report of a larceny
of a cell phone. Dispatch characterized the scene as a loud
disturbance, with possible fight. Upon arrival, Officer Duralde was
hailed by a group of people on the Center Street Bridge at 1 N.
10
Sierra street and contacted Zachary Barker Coughlin (hereinafter "the
11
Defendant H
12
people also pointed out the Defendant.
13
),
who fit the description of the suspect. The group of
Officer Duralde advised the Defendant that if he had
14
somebody else's phone, he could just give the phone back and the
15
issue may resolve itself. The Defendant responded by saying that
16
there was not enough information for a "Terry stop". Officer Duralde
17
again asked the Defendant if he had the phone. The Defendant
18
responded by asking if he had the right not to answer Officer
19
Duralde's question.
20
The Defendant was wearing baggy clothes that could conceal
21
a weapon, at which time Officer Duralde conducted a pat-search for
22
weapons. As Officer Duralde reached the Defendant's left front shorts
23
pocket, he felt an object resembling a phone at the same time the
24
Defendant yelled loudly that Officer Duralde had grabbed his penis.
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1 The facts recited herein are taken from Officer Nicholas Duralde's Report and
dispatch records, full copies of which have been provided to defense counsel.
2
The Defendant was trying to make a scene and was very hesitant to
follow Officer Dura1de's directions, and was placed in handcuffs.
Officer Duralde further spoke with Cory Goble (hereinafter
"Mr. Goble"), the owner of the phone. Mr. Goble stated that he
learned the Defendant was in possession of his phone. Mr. Goble
confronted the Defendant and asked for his phone back, but the
Defendant denied having the phone. Mr. Goble used a friend's cell
phone and called his number, and observed the screen of his phone
light up in the Defendant's left front shorts pocket. Officer Duralde
10
also spoke with Nathanial Zarate (hereinafter "Mr. Zarate"), who
11
stated that he observed the Defendant put Mr. Goble's phone in his
12
left front shorts pocket.
13
Officer Duralde obtained Mr. Goble's cell phone number and
14
called the number from another phone. Officer Duralde heard a
15
vibrating noise coming from the Defendant's left front pocket and
16
touched the outside of the Defendant's shorts where he had previously
17
felt the phone and could feel the phone vibrating. Officer Duralde
18
stopped calling Mr. Goble's cell phone and the phone in the
19
Defendant's pocket stopped vibrating. At this point, Officer Duralde
20
placed the Defendant under arrest for larceny and retrieved the phone
21
from the Defendant's pocket. Mr. Goble was able to verify his
22
ownership of the phone based on the password for the phone and calls
23
that had been made in the previous hours.
24
II.
ARGUMENT
25
The Defendant, by and through his attorney, recently filed
26
a Motion to Suppress, claiming that his Fourth Amendment rights were

3
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,
violated. Specifically, the Defendant first argues that the pat-down
search of the Defendant for weapons was not supported by controlling
law. Second, the Defendant contends that Officer Duralde's subsequent
touching of the outside of the Defendant's left front pocket
constitutes a search and was unsupported by controlling law. Finally,
the Defendant claims that the plain-feel doctrine did not support
Officer Dural?e's seizure of Mr. Goble's phone. The Defendant asks
this Court "to suppress the evidence and the fruits thereof".2 The
State of Nevada (hereinafter "the State") respectfully submits that
10
the Defendant's arguments are without merit,
11
A. The Pat-Down Search of the Defendant's Person Was Proper
12
The Fourth Amendment protects individuals against
13
unreasonable searches and seizures. NRS 171.123, which essentially
14
codifies Terry v. Ohio, 392 U.S. 1 (1968), allows for a peace officer
15
to detain a person when there is reasonable suspicion to believe that
16
he has committed, is committing, or is about to commit a crime. NRS
17
171.1232, also essentially codifying Terry, provides that a peace
18
officer may search a person detained pursuant to NRS 171.123 if he
19
reasonably believes that said person is armed with a dangerous weapon
20
and is a threat to the safety of the peace officer or another. To
21
justify a pat-dOwn search for weapons, an "officer need not be
22
absolutely certain that the individual is armed; the issue is whether
23
a reasonably prudent man in the circumstances would be warranted in
24
the belief that his safety or that of others was in danger. The
25
26
Although the Defendant does not state specifically what evidence he is seeking to
suppress. the State responds to the Motion under the belief that he is seeking to
suppress Mr. Goble's phone,
4
reasonable basis for the pat-down arises from the circumstances
surrounding the stop as well as the specific facts of the citizen's
reaction." Rusling v. State, 96 Nev. 778, 781 (1980) (upholding a
pat-down search because all factors led the officer to reasonably
believe that the defendant was involved in criminal conduct, and it
was not improper for the officer to infer the possibility of a
concealed weapon).
8
9
In the instant case, the pat-down search of the Defendant

was proper under the totality of the circumstances.) Prior to
10
arriving, Officer Duralde learned that the scene involved a loud
11
disturbance with. possible fight, thereby immediately raising the
12
concern of weapons and the safety of all those present. This is just
13
one factor for this Court to consider. upon contacting the Defendant,
14
he became uncooperative and challenged Officer Duralde that there was
15
not enough information for a detention. Thereafter, in response to
16
Officer Duralde's inquiry whether the Defendant had Mr. Goble's
17
phone, the Defendant asked if he had the right not to answer the
18
question. While the Defendant arguably can choose not to answer such
19
a question, this response, along with his general attitude, demeanor,
20
and reaction, certainly can be considered by this Court when
21
addressing the reasonableness of Officer Duralde's concern for his
22
and others' safety.
23
III
24
I II
25
26
3 The Defendant does not claim that his detention itself was improper; as such, the
State does not address such.
5
It is important to note that there were multiple people on
scene, any of which could be subjected to injury or death if the
Defendant had a weapon. Upon arrival, the Defendant and a group of
people (including Mr. Goble) were on scene, and with the allegation
that the Defendant had stolen a phone belonging to a person of said
group, emotions were high and a physical fight could have erupted.
Again, such factors should be considered by this Court when
determining the reasonableness of the pat-down search.
Moreover, the Defendant was wearing baggy clothing that
10
could conceal a weapon. This is yet another circumstance to consider
11
in ruling on the validity of the pat-down search. Also, Officer
12
Duralde's contact with the Defendant and the group of others occurred
13
shortly before midnight. At such a time, the quality of lighting
14
surely was less than in the middle of the day, adding to the concern
15
that a concealed weapon may not be immediately visible.
16
Additionally, Officer Duralde's training and experience led
17
him to believe that a pat-down search of the Defendant was proper,
18
under the circumstances. A sworn law enforcement officer, who
19
presumably has had numerous contacts with countless people in the
20
course of his profession, felt a concern for the possibility of the
21
Defendant possessing a weapon. such should not be overlooked, when
22
considering the reasonableness of a pat-down search and based on a
23
trained law enforcement officer's judgment.
24
Finally, it is important to note that officer Duralde
25
completed a brief, cursory search of the Defendant's outer clothing
26
just to assure his safety, as well as that of others. Accordingly,

6
the State respectfully submits that this minimally intrusive search,
based on all of the above-listed facts and circumstances, was clearly
justified and proper under Terry and NRS 171.1232.
B. The Touching of the Defendant's Left Front Pocket Was Not a Search
Later in the contact with the Defendant, Officer Duralde
called Mr .. Goble's cell phone number and heard a vibrating noise
coming from the Defendant's left front shorts pocket, exactly where
Officer Duralde had been advised the phone was located. At that time,
Officer Duralde briefly touched the outside of the Defendant's shorts
10
where Officer Duralde had previously felt the shape of a phone with
11
his hand, and felt it vibrating. The Defendant argues that such
12
touching constitutes a search. The State respectfully submits such is
13
not the case.
14
Officer Duralde merely touched the outer portion of the
15
Defendant's clothes, underneath which was a phone. Officer Duralde at
16
no time reached his hand into the Defendant's shorts pocket (until
17
later during a search incident to arrest). The brief touching of the
18
exterior of the Defendant's clothes was so innocuous and minimally
19
intrusive that it could hardly be construed as a "search."
20
Alternatively, even if this Court finds that such conduct
21
constitutes a "search", suppression of the evidence is not warranted.
22
As stated, the touching of the outside of the Defendant's clothes was
23
so harmless that suppression is a disproportionate penalty.
24
Suppression, which precludes the introduction of evidence at trial,
25
is too harsh a response to such non-offensive and harmless conduct.
26
III
7
C. The Plain Feel Doctrine Is Inapplicable to the Instant Case
The Defendant claims the plain feel doctrine, articulated
in Minnesota v. Dickerson, 508 U.S. 366 (1993), does not permit the
seizure of the phone from the Defendant's pocket.' The plain feel
doctrine provides that if an officer feels an object during a Terry
search and it is immediately apparent that said object is contraband,
the officer may seize the object without a warrant, arrest, or
consent. The Defendant's argument is inapposite to the instant case.
Here, Officer Duralde did not seize the phone pursuant to the plain
10
feel doctrine. It is important to note that Officer Duralde did not
11
reach into the Defendant's pocket or seize the phone during his pat-
12
down search, nor did he do so when he innocuously touched the
13
Defendant's outer clothing. Rather, he collected the phone after
14
placing the Defendant under arrest for Larceny of the phone. Such a
15
search was justified as a search incident to a lawful arrest rather
16
than the plain feel doctrine.
17
Of course, because Officer Duralde was justified in
18
conducting a cursory pat-down search of the Defendant's person, he
19
may consider the fact that he felt a phone during said search when
20
making the decision to arrest. This is just another factor supporting
21
the probable cause to arrest the Defendant, as further discussed
22
below.
23
III
24
III
25
26
Also see State v. Conners, 116 Nev. 184 (2000), which is the Nevada authority on
the plain feel doctrine.
8
1
2
D. Assuming, Arguendo, That the Defendant's Fourth Amendment Rights

Were Violated as Alleged in His Motion, the Phone Was None-The-Less
Properly Seized During a Searcb Incident to Arrest
Even accepting all of the Defendant's claims for purposes
of argument, Mr. Goble's phone should not be suppressed as it was
obtained during a search incident to a lawful arrest based on actions
which are not challenged in any way by the Defendant. Probable cause
to believe that a crime occurred, thereby justifying an arrest, is
determined by objective facts. surianello v. State, 92 Nev. 492, 497
(1976). "Probable cause to conduct a warrantless arrest exists when
10
police have reasonably trustworthy information of facts and
11
circumstances that are sufficient in themselves to warrant a person
12
of reasonable caution to believe that an offense has been or is being
13
committed by the person to be arrested. Doleman v. State, 107 Nev.
14
409, 413 (1991).
15
Here, even excluding all of the challenged actions that are
16
set forth in the Defendant's Motion, there is clearly ample evidence
17
supporting the arrest of the Defendant. Officer Duralde responded to
18
a specific location in reference to an alleged theft of a phone. Once
19
on scene, he met with the alleged victim and witnesses, who provided
20
a consistent sequence of facts. Both Mr. Goble and Mr. Zarate were
21
still on scene, hailed down law enforcement for assistance,
22
identified themselves, and reported their knowledge of the
23
Defendant's criminal actions to law enforcement. Neither Mr. Goble
24
nor Mr. Zarate had anything to gain by falsely accusing the Defendant
25
of taking Mr. Goble's phone; to the contrary, making a false police
26
report is a crime itself. NRS 207.280. As such, to the best of

9
Officer Duralde's knowledge, there was no reason for either Mr. Goble
or Mr. Zarate to be untruthful about the Defendant having Mr. Goble's
phone. See State v. Sonnenfeld, 114 Nev. 631, 634 (1998) (citing,
with approval, a case which found a witness to be a "reliable citizen
witness" due to "the exigency of the circumstances and the apparent
lack of an ulterior motive"). Mr. Goble and Mr. Zarate provided very
specific information regarding the Defendant being in possession of
the phone, including that it was in the Defendant's left front shorts
pocket and they had seen the phone'S screen light up when they called
10
11
it.
As part of Officer Duralde's investigation, he then
12
obtained Mr. Goble's cell phone number and called the same. upon
13
doing so, he heard a vibrating sound coming from the very location
14
Mr. Goble and Mr. Zarate said the phone was located. This, in and of
15
itself, provided Officer Duralde with probable cause to believe that
16
the Defendant was unlawfully in possession of Mr. Goble's phone. On
17
top of these facts was the Defendant's uncooperative demeanor upon
18
being contacted by Officer Duralde, further supporting probable cause
19
for his arrest. Upon his arrest, Officer Duralde conducted a search
20
incident to arrest, locating the phone. See Carstairs v. State, 94
21
Nev. 125, 128 (1978) (holding that "in the case of a lawful custodial
22
arrest a full search of the person is not only an exception to the
23
warrant requirement of the Fourth Amendment, but is also a
24
'reasonable' search under that Amendment") .
25
Including the challenged facts of the Defendant's Motion,
26
as the State respectfully submits this Court should do as set forth

10
above, further bolsters the probable cause justifying an arrest.
However, even excluding that which the Defendant challenges, Officer
Duralde clearly possessed reasonably trustworthy information of facts
and circumstances that are sufficient in themselves to justify the
Defendant's arrest, and the subsequent search incident to arrest and
the fruits thereof - specifically, the phone - are fully admissible.
7
8
9
10
11
12
13
III.
CONCLUSION
The State respectfully requests that the Defendant's Motion

to Suppress be denied.
document does not contain ate social
DATED this
~2)\
day of
of any person.
~~~~~~~____ '
2012.
14
15
RICHARD A. GAMMICK
District Attorney
,
16
17
18
19
Attorney
20
21
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23
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0223RCR20110633414
11
- - - - ._-- - - ,
. ,
CERTIFICATE OF FORWARDING
I hereby certify that I am an employee of the Washoe County
District Attorney's Office and that, on this date, I forwarded a true
copy of the foregoing document, through the Washoe County interagency
mail, addressed to:
6
7
JOSEPH GOODNIGHT, PUBLIC DEFENDER

PUBLIC DEFENDER'S OFFICE
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DATED this 2
----
day of Februa
~
, 2012.
"
.'
r.;;: n
,- r t
ZOl2 FEB 27 PH 2: 55
IN THE JUSTICE COURT OF RENO TOI4N.SHI,!:, 7

" i ,')
IN AND FOR THE COUNTY OF WASHOE,
\.
~._
r;~::~~;'
* * *
3
4
. c;:)
' " ~:'J
l<, I ~

Plaintiff,
RCR2011-063341
v.
DEPT:
7
Defendant.
8
9
_________________________1
10
OPPOSITION TO MOTION TO CONTINUE

TRIAL DATE AND MOTION TO APPOINT CO-COUNSEL
11
12
13
GAMMICK, District Attorney of Washoe County, and Zach Young, Deputy
14
District Attorney, and hereby opposes the Defendant's Motion to
15
Continue Trial Date and Motion to Appoint Co-Counsel. This opposition
16
is made and based upon the attached Points and Authorities and any
17
21
III
III
III
III
III
22
III
23
25
III
III
III
26
III
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19
20
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.;
v
1
2
I
I
oral and/or documentary evidence that may be presented at a hearing

on this matter.
5
6

DATED this
j day ofr:~b-Y(J==
, 2012.
7
8
RICHARD A. GAMMICK
District Attorney
Washoe County, N vada
10
11
By____-+~~+_------------
ZACH
12
Depu
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14
15
16
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19
I
I
20
21
22
23
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25
26
ict Attorney
v
1
I.
Statement of the Case
On August 20, 2011, Zachary Barker Coughlin (hereinafter
"the Defendant P
misdemeanor count of Petit Larceny, by way of a Criminal Complaint,
on or about August 24, 2011. The Defendant was arraigned on the
Criminal Complaint on August 25, 2011. On or about December 5, 2011,
an Amended Criminal Complaint was filed, also alleging a misdemeanor
count of Possession of Stolen property. There have been multiple pre-
was arrested for Larceny. He was charged with a
10
trial hearings set in this matter: September 9, 2011; October 12,
11
2011; October 26, 2011; and November 28, 2011. On this last date, the
12
Defendant elected to exercise his constitutional right to trial.
13
Accordingly, the matter was set for trial, scheduled to commence
14
approximately three months later on February 29, 2012. All of the
15
witnesses for the State of Nevada (hereinafter "the Staten) have been
16
subpoenaed for said court date, and arranged their work schedules
17
accordingly.
18
On February 21, 2012 - just eight days prior to the
19
scheduled trial, the Defendant, through his attorney, filed a motion
20
requesting a continuance. On that same date, the Defendant, again
21
through his attorney, filed a separate motion requesting that he be
22
appointed as co-counsel. The State now opposes both requests.
23
III
III
III
III
24
25
26
v
1
II
ARGUMENT
A. The Trial Should Not Be Continued as the Defendant Has Failed to

Establish Good Cause
As the Defendant points out in his Motion, a court may
continue a trial, at the request of one of the parties, when good
cause is shown. The State respectfully submits that the affidavit
filed by the Defendant's counsel, Deputy Public Defender Joe
Goodnight (hereinafter "Mr. Goodnight"), fails to establish good
cause.
10
The instant case has been languishing in the Reno Justice
11
Court since the Defendant's arraignment on August 25, 2011 - more
12
than six months prior to the scheduled trial. Further, despite
13
numerous pre-trial settings, the State and the Defendant have been
14
unable to resolve this matter through a plea negotiation. The trial
15
date was known to both the State and the Defendant for approximately
16
three months, giving both ample time to prepare. In that regard, the
17
State issued subpoenas to its witnesses, all of whom have returned
18
their subpoenas and arranged their work schedules to attend. Despite
19
a full three months to prepare for trial, with full knowledge of the
20
scheduled date, the Defendant waited until February 21, 2012 to file
21
his Motion to Continue - a mere eight days prior to the trial date.
22
The State respectfully submits that the bases for a
23
continuance submitted by the Defendant do not rise to the "good
24
cause" threshold. His claim that he was "wrongfully arrested" is a
25
completely subjective belief; the case for which he was arrested is
26
active and pending. Further, the fact that he is a party to

4
protective orders has no bearing on the instant case. If the
Defendant, in fact, is the person who sought and applied for such
protective orders, that provides even less of a basis to continue, as
it is the Defendant himself who initiated such activity.
Moreover, the State does not understand how his claim that
he is a victim of domestic violence supports his request. While the
State is sympathetic to any victim of domestic violence, the
Defendant fails to show how his alleged victimization impacts the
instant case, Mr. Goodnight's representation of the Defendant, or the
10
Defendant's ability to assist his counsel. Similarly, the State is
11
unsure how the fact that his power was shut off has any effect on
12
this case or a continuance thereof.
13
As such, the State opposes a continuance of the trial
14
scheduled for February 29, 2012.
15
B. The Defendant Should Not Be Allowed to Act as Co-Counsel
16
The State incorporates, by this reference, its Motion to
17
Strike Fugitive Document, which was filed in this case on February
18
21, 2012. Specifically, and as set forth in that pleading, nlf the
19
defendant elects to have counsel, he has no right to represent
20
himself." Layton v. State, 91 Nev. 363, 366 (1975). Further, in the
21
instant case, Mr. Goodnight expressly objects to the appointment of
22
the Defendant as co-counsel. See Motion to Appoint Co-Counsel, p. 2,
23
line 19-20 (Feb. 21, 2012). Such a circumstance was addressed in
24
Rhyne v. State, 118 Nev. 1, 8-9 (2002), which cited a California's
25
court denial of a defendant's request, opposed by counsel, to act as
26
co-counsel.
5
1
2
Accordingly, the State opposes the Defendant's request to

be appointed, as co-counsel.
III.
4
5
6
7
8
9
CONCLUSION
The State respectfully requests that the Defendant's Motion

to Continue Trial Date and Motion to Appoint Co-Counsel be denied.

DATED this
d~~y
Of..JkY!.Ia '
, 2012.
10
RICHARD A. GAMMICK
District Attorney
Washoe County, N vada
11
12
13
14
By____-+~~~------------
ZACH
15
Depu
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17
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19
20
21
22
23
24
25
26
0224RCR20110633414
6
CERTIFICATE OF FORWARDING
I hereby certify that I am an employee of the Washoe County
District Attorney's Office and that, on this date, I forwarded a true
copy of the foregoing document, through the Washoe County interagency
mail, addressed to:
6
7
PUBLIC DEFENDER
PUBLIC DEFENDER'S OFFICE
8
9
10
11
12
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15
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25
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DATED this 27~ day
1
2
JEREMY T, BOSLER
BarNo,4925
One Califomia Ave
Reno, NY 89509
(775) 337-4800
PI;
~:
0I
....~
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEY ADA

7
8
9
THE STATE OF NEYADA,

Case No. RCRI 1-063341
Plaintiff,
;0
v.
Dept. No.2
;1
12
13
14

Defendant.
-------------------------/
REPLY TO STATE'S OPPOSITION TO MOTION TO SUPPRESS
15
16
17
attomey of record, Joseph Goodnight, Deputy Public Defender, and hereby submits his reply to
18
the State's opposition to his motion to suppress all evidence obtained as a result of his detention
19
and arrest on August 20, 20 I I.
20
21
This reply is based upon the attached points and authorities and any testimony,
documentary, and real evidence as may be presented at the hearing on this marter.
22
Argument
1.
23
The State's opposition relies on Rusling v, State, to support the unlawful pal-down of
24
Mr. Coughlin. Opposition at 4-5. However, the facts in Rusling are distinguishable from those
25
26
in this case. In Rusling, the defendant immediately fled the scene when approached by officers,
he hid in bushes requiring a canine patrol dog to assist in finding him, he was wearing a jacket
1
as well as jeans and a t-shirt, and he would not follow the officer's orders to keep his hand
away from his pocket. 96 Nev. 778, 780 (1980). Mr. Coughlin neither fled the scene, tried to
hide, was wearing ajacket. nor failed to follow officer's orders. In fact. Mr. Coughlin was
wearing simply a t-shirt and thin shorts, was accompanied by his Pekinese dog, made no
attempt to flee, and ultimately followed the instructions given by law enforcement. The State
6
7
8
9
10
11
argues that Mr. Coughlin's Socratic questioning of the officers may be held against him, but
then provides no authority for such a contention. Opposition at 5.
The same is true of the State' s argument regarding the subsequent search of Mr.
Coughlin's left pocket after the unlawful pat-down. The State presents argument, but no
authority. Opposition at 7. Again, the Terry Court clearly stated, "it is nothing less than sheer
12
torture of the English language to suggest that a careful exploration of the outer surfaces of a
13
person's clothing in an attempt to find weapons is not a 'search.'" Terry v. Ohio, 392 U.S. 1. 16
14
15
(1968). When one position is supported by authority, and the other lacks it, the absence of
16
authority indicates the absence of a controversy. This is even more apparent when the position
17
lacking authority is the one tasked with the initial burden of justifying the search. See [d. at 2 I
18
(the government's bears the burden of production by coming forward with "specific and
19
articulable facts").
20
Lastly, the State argues that even without the information gained from the unlawful pat21
down and subsequent unlawful search ofMr. Coughlin's pockets, the phone should be admitted
22
23
as the product of a search incident to a lawful arrest. Opposition at 9. Mr. Coughlin disagrees
24
with the State's application of the law to the facts. For example, the State claims that Officer
2S
Duralde possessed reasonably trustworthy information garnered from witnesses Goble and
26
Zarate. Opposition at ll. However, the statements of these two witnesses are in direct
2
contradiction to each other as one claims to have seen Mr. Coughlin receive the phone from
another person while the other claims to have seen Mr. Coughlin pick the phone up himself.
Nothing could be more untrustworthy than two statements in direct contradiction with one
another. Mr. Coughlin intends to show, through cross-examination of the arresting officer and
5
complaining witnesses, that Officer Duralde did not have probable cause to arrest him and that
6
the subsequent search of his person was unlawful.

II. Conclusion
Based on the above, Mr. Coughlin respectfully requests that this court grant his motion
10
to suppress the evidence and the fruits thereof obtained via violations of his Fourth Amendment
11
rights through illegal searches of his person.
12
AFFIRMATION PURSUANT TO NRS 239I3.0JO
13
14
15
16
DATED this
,2012.
17
18
19
20
By
J SE H W. GOODNI
22
23
24
25
26
forwarded a true copy of the foregoillg document through inter-office mail to:

8
9
10
JdSEPH W GOODMGHT
v
IJ
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16
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18
19
20
21
22
23
24
25
26
,.
v
t
1
2
3
4
Jeremy T. Bosler
BarNo. 4925
One California Ave.
Reno, NV 89509
f,;
. .
'1
,!.\~ ~:1
P,&; l: 02
.d{, . :'
..'goJe.
..
(775) 337-4800
..
-. . .~
IN AND FOR THE COUl\TY OF WASHOE, STATE OF NEVADA

9
Case No. RCR 11-063341
Plaintiff,
v.
10
Dept. No.2
11
12
Defendant.
13
_____________________1
14
REQUEST FQR SUBMISSION
15
IT IS HEREBY REQUESTED that Defendant's Motion
(0
Suppress, to which the State
16
17
filed its Opposition, and Defendant filed a Reply to State's Opposition, be submitted to this
IS
court for decision. Defendant further requests a hearing on the motions for examination of the
19
arresting officer and complaining witnesses and oral argument by the parties prior to the Trial
20
Hearing currently set on May 7, 2012 at 9;00 a.m.
21
II/
22
II!
23
III
24
;' ;' !
25
26
/!
1
2
3

The undersigned does hereby aftlrm that the preceding document does not contain the
social security number of any person,
-(
'v\
Dated this ~ day of_'_'_'_"_".0,,\_ _ _ ' 2012,
.."
JEREMY T. BOSLER
/'
By:
8
9
:0
12
13
16
17
18
20
21
22
23
2~
25
26
RTf
J~;EPH ~~
G~t
l
GOOD
forwarded a true copy of the foregoing document through inter-office mail to:
6
7
ZACH YOUNG, Deputy District Anomey

DATED this
> Day of _"_'\_\",,,,,-_",,--/-\-\,_ _ _ _, 2012"

.,
8
9
JOSEPH W GOODNIGHT'
10
II
12
13
14
l5
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20
2:'
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25
Code 6170
2
3

State of Nevada
Plaintiff,
5
VS.
Case No.
Dept. No. SCD
Zachary Barker Coughlin,

7
Defendant.
____________________
~f
8
9
10
ORDER TRANSFERRING JURISDICTION TO MENTAL HEALTH COURT

Based upon the Order of Judge Peter Sferrazza and good cause appearing
therefore, original jurisdiction in the above-entitled matter, also kno",'l1 as RCR 2011-
11
06334 I is hereby transferred to the Second Judicial District's Mental Health Court, on the
12
charge of CT. 1. PETIT LARCENY, a violation of WCC 53. I60, a misdemeanor and CT.
13
II POSSESSION OF STOLEN PROPERTY, a violation ofNRS 205.275.

14
15
IT IS SO ORDERED.
DATED on this the 7th day of May, 2012.
//)
16
f" I
---""y (_</',/,-:7
/- (Y/:A/;;;/X::lp~'7 ,'"
~
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./ /
17
'-"Y'
;1:.'//
,....'
t.F / ,{?",:r"/?:".,.
/'
JI1ST~CE OFI"i'HE "A'Ct
18
19
20
DISTRlCT COURT JUDGE
21
22
23
24
25
26
-1-
,,/;;
/C,>,'./ - --'"
v
1
Code 6170
2
3

State of Nevada
Plaintiff,
vs.
6
7
Zachary Barker Coughlin,

Defendant.
____________________
Case No.
Dept. No. SeD
~I
8
9
ORDER TRANSFERRING JURISDICTION TO MENTAL HEALTH COURT

Based upon the Order of Judge Peter Sferrazza and good cause appearing
10
therefore. original jurisdiction in the above-entitled matter, also known as RCR 201111
06334] is hereby transferred to the Second Judicial District's \;len tal Health Court, on the
12
charge of CT. L PETIT LARCENY, a violation ofWCC 53.160. a misdemeanor and CT.
13
II POSSESSION OF STOLEN PROPERTY, a violation ofl\RS 205.275.

14
IT IS SO ORDERED.
15
/ . / ,,,,._
"~/""~
16
~
~:;, ;f(.~~~~0'~:
OF/HE ~&1\6E
.1 I /
17
;;:.
-'<' ( / /
.7
"
",1:-
/"~
JiilSTIP'E
18

19
20
DISTRICT COURT JUDGE
21
22
23
24
25
-1-
0-J~~/"L
_r
~~.
~~>'
,,"0'-
R~2011-063341
Case No. _ _ _ _ _ _ _ _ _ _ __
Department No. _ _2 _ _ _ _ __
_
IN THE JUSTICE COURT OF THE STATE OF NEVADA

THE STATE OF NEVADA
Plaintiff,

OF PROCEEDINGS
VS.
ZACHARY BARKER CXlUGHLIN
. Defendant.
----------------------1
The
Plaintiff
Defendant has reqnested an audio copy

1)
Hearing Date
2)
Hearing Date
3)
HeariiJg Date
4)
May 7, 2012
Hearing Date
Date
May 16
,20
12
Joseph W. Goodnight, Deputy Public Defender

Name
Address
City, St!te, Zip
(775) 337-4839
Contact telephone Ilumber
A $35,00 fee is due at the time of the request.

Call (775) 325-6575 if you have any questions,
7753256617
09:04.11
05-25-2012
111
F I LED
Electronically
05-24-201204'23:56 PM
Joey Orduna Hastings

Clerk ol1he Court
CODE 3370
TransactIOn # 2978381
2
3
4
5
6
STATE OF NEVADA,
Plaintiff,
10
Case No. MH12-0032
vs.
11
Dept. No. SCD
12
ZACHARY COUGHLIN,
13
________________________,1
Defendant.
14
ORDER RETURNING CASE FROM SPECIALTY COURT TO ORIGINAL DEPARTMENT
15
Based upon the determination of the Specialty Court Senior Judge
16
17
jurisdiction in the above-entitled matter is appropriately returned to the original District
18
Judge handling this matter.

THEREFORE, GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the
19
20 :
Defendant be removed from the Mental Health Court Program and be returned to Reno
21
Justice Court for all future proceedings.

Dated this
22
Jf day of --.JtVl~MJ~,f-----, J.QJb
~ nBuM]
~STRI~
::
JUDGE 1
25
26
27
28
/1
_. -';10N1'O PROCEED
IN FORMA PAUPERIS
Vs,
c,--cl\
DetendantITcnant.
!('
M?Tl~,l~
~~se~ on the follo~i~gfffidavit, (name) ?c:t-S, '\':'l..etS- FI
--a-{~e),
i'
fl
('* -"-\C~:/S
Lawsuit or ev1ction notice
'
Defense to lawsuit or eViction notice'
'-ti"
I 'v~,
c; -:
c,\
;to,
':5
reTests this
c C_
-~\..~~
1\.E'__Gl V (
fa
c~urt for_pcnnission to~_
'i'
r---{;:.'-,.J
,
with01.lt paying court costs or sheriff fees and alteges that he/she has a meritorious chum or defense. yet lacks sumcient
tinancial ability to pay the costs to proceed.
AFFIDAVIT
STATE OF NEVADA
)
)
COUNTY OF WASHOE
55:
( __
CV~
'~V/1
I. (name)
c_:.:_____
C5" [ \
declare under penalty of perjury that the
statements of this affidavit are true and that the responses I It e made to the questions regarding my ability to pay are
true;
_"--"
pJaintiff~ndant n
1)
I am the (check one)
2)
I wish to fif~ with this couI"{ a (c?eck one) i 1 lawsuit Sf 8",iGl10R RGtti~~~
nse to lawsuit or eviction
n6r.ce,
/-C'
C(;\
/"C,)1C" L_ 0
_..
'-"L \.-.-"~- C"-... ( <:--,
'__
___,
___ ,.~
"
3)
( believe in \f..ood faith that I have a val1d -claim Of meritorious defense, nameiy (state briefly your claim or
defense andlor attach~~m.t;nt-,--y.ou wish to file if this Tl1Olion is granted):
4)
1 <.;annot pay the
5)
There are
\
persons in my household, including myself. (If any household members are
dependent upon you for support, state their .tges and relationships to you:
6)
[1
<:.(}5tS.
0f\h\s 'a\!\\on,
,)S \
landlord! 1 tenant.
\a<.;k sufficient incDme. assets or other resources.
,ct.}
Retirement Benefits
$---\-\----
Child Support
Unemployment Benefits
Worker's Compensation
Rental Income
Other benefits or income
7)
$-~+-~f_-._
$---'114----,.1'---_$--++1.,./0---$---.:\\,:I/~----
The following represents a complc:te list of my assets nnd their value (If you uo not own the described
items, "wite "nonc", Do not mclude clothing and ordinary household furnishings. I f you havl!' loans 011
any of the itcms~ notice the purchase price and Joan b~anCe):
Purchase
Loan
1
. ' r'O' / (
Yl!J.M.e
Balance
Car (describe)
4 0
''(/I;\(~;' Vt-t-t-.-. u ;)
Second Car (des~nb )
)
Mobile home~ house or other
IQt'
\1\. \
Real estate (describe)

Bank accounts (describe)
Other (describe)
8)
$-----'t-----
My total
,L.
I~
it /J~ 'co' (..'
., _ )
)
_ . (. _'\,;"
r. __ / ,) it-~ '-..
"
househ~:n,;,onth Iy expenses are:
. . . . . '",-
---
~\ ':"r;~Q~\;,~,. "4
r;"f) {;
Utilities
Food
Child Care
Insurance
Medical
Transportation
Other (describe)
',pTAL MqNTH~Y E.2(PENSES
9)
$
j
l'
$
k:; ,,}';'
$ _ _ _ _ _ _ _ __
$ ___________________
$'~.J! -r~__,_---$ ~b' I ( J

$'--"'71rJj-~"""7"""'~
1/
\ ce- \' ,I,,~ O<..~ ~""
~::::e to I
t-
U5
}2t7!( ~:oun
~
__
In
this matter,
Signature:
/_
,k>~<
; / /~ __
~--<-~--
"}-l
--__
~:I:;:~~eS&t?4 ~~3~5i( ~1V~O ~'!~
Subscribed and sworn to before me

This _ _day of _ _ _ _ _ _ _ _ 20 _ _ ,
Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ __
Notary PubliC/Deputy Clerk
ORDER
I")
Motion GRANTED. The Clerk of the Court shall allow ---~----~__,_~-------_cto commence or defend such action \\'jlhoUI cost and to tile or issue any necessary , . . rit. process, pleading or paper Without
charge. This Order shall expire s.ix months from the date below.
IT IS FURTHER ORDERED that the Sheriff or any other appropriate public officer within the State make
personal service of any necessary writ. process, pletuJing or paper without cha.-ge for _____.________________
f-
DA TE D: _ _ _--'L.,f'-.!:......"L,,L...::Z--= __
__
,
DA # 432068
RPD RPll-016399
1
2
IN
3
4

Plaintiff,
v.
6
7
RCR 2011.-063341
0
Def~.
DEPT: R02
1\
5C.=)V J::>
eMWIDBP
CRIMINAL COMPLAINT
10
ZACH YOUNG of the County of Washoe, State of Nevada,
l~
ver~fies
12
of perjury,
13
has committed the crime of:

-p I~"''i'-l>/,",I.r -7,1
1.4
15
and declares upon information and belief and under penalty
that ZACHARY BARKER COUGHLIN,

f'CA.<.G
FE'f'I'f' UtR8B!PI I
';5, 140
541'!.'\,-\
52 .&9 saQ '25 0.0,
a violation of Washoe County Code
a misdemeanor,
COUNT I .
16
the defendant above-named,
in the manner following.
to wit~
That the said defendant on or about the 20th day of August,

2011,
1.8
did willfu11y and unlawfully steal,
1.9
property of 3:Het:::hEL
20
Hundred Fifty Dollars
2~
prqpertjr ez and owned by CORi GOBLEt
22
SSctt:.lr"ee.eeut"..-.-I'Rl<e"'.,"'''e'',,--"\lIf'''~''st.lhlCo'''e"CC1:0f(Ulml1:C'iyo--;,,--"tt<lllee,,vr.aE<ddo.at-,,;-....,.,il-<e 4e>lb'ee,....;ib;.. .......

......... ..
!N;~ e '"~~41:"Q~-!=p)fe"rrnCll'"ilUnl!f2n t ~.Y
23
24
III
25
III
26
III
at Reno Township,
within the county of Washoe,
State of Nevada
17
eo wit:
taxE, and CaLLy a ......'
~ .. e
];!orsQI'al
an iPhone of a valUe of less than Two

___
($250 00) .
said pESOnaI property bei11g Lite

at 01. lleaJ: ::t:e
ne~t:h
lTirginia..,
II.
NRS 205.275,
isdemeanor,
That the
to wit:
in
2011,
did willfully and unlawfull
a value less than Two Hundred
iPhone,
at or near 1 North
Nevada,
such property
to prevent the tru
at Reno Township.
knowing that t
II
such circu
l2
that su
the 20th day of August,
id defendant on or abo
lO
of
POSSESSION OF STOLEN PROPERTY, a
ithin the Coun

osses
of Washoe,
State of Nevada,
or withhold stolen goods having
Dollars
($250.00),
Reno,
nter
owned by
owner from again
GOBLE,
possess~
property was obtained by means
to wit,
Washoe county,
for his own gain or
property,
arceny or under
ances as should have caused a reasonable m
to know
spoda were so obtained.
l3
l4
___ 'n
DATED this
day of
~.,
2011
15
l6
l7
18
19
20
21
22
23
25
PCN RPDll12566C
Custody,
X
Bailed,
Warrant:
26
08234320688
24
District Court Dept:

District Attorney,
YOUNG
Defense Attorney,
Bail "'01C?lQ cR
Restitution:
NJ
I.LC...
an
Pursuant to NRS 174.2341
the fo11owing are the nameS and
addresses of such witnesses the State intends to call in its case in
chief.
RENO POLICE DEPARTMENT
OFFICER NICK DURALDE

OFFICER RON DOSA
CORY GOBLE,
5020 Las Brisas Boulevard,
Reno, Nevada
NATHANIEL K.
ZARATE, 830 E. Plumb Lane, Reno,
Nevada
NRS
~74.234
also requires the defendant,
at least five
10
judicial days prior to the trial date,
to file and serve upon the
21
prosecuting attorney a written notice containing the name and last
12
known address of any witness the defendant intends to call during
13
his/her case-in-chief.
14
of the witness.
Failure to do so may result in the exclusion
15
16
The party executing this document hereby affirms that this
17
document submitted for recording does not contain the social security
18
number of any person or persons pursuant to NRS 239B.230.
19
20
RICHARD A. GAMMICK
District Attorney
21
22
23
24
25
26
Attorney
/
Case No.
,r-jf_.L_
.. -D
~--i~
ROO011...o63341
Department No. _ __ _ _ _ _ __
2
12 AUG 29 P/1 3: 28
STc~!~
iuTTJ
RENO .JU~CE COURT
IN THE JUSTICE COURT OF THE STArlYW~ WAfM

'!HE STATE OF
NEV1iDA
Plaintiff,
REQUEST FOR AUDIO COPY

OF PROCEEDINGS
vs.
ZACEARY BARKER CDUrnLIN
Defendant.
- - - - -_ _ _ _ _~I
The
Plaintiff
Defendant has requested an audio copy
1)
Hearing Date _ 8/27/12 _ _ _ _ _ __

___
2)
Hearing Date.,.-_ _ _ _ _ _ _ _ _----:'
3)
Hearing Date _ _ _ _ _ _ _ _ _ _ __
4)
Hearing Date _ _ _ _ _ _ _ _ _ _ __
Date _ _--.:.:Au::.g\JS::.=,t.::..::2::.9_ _ _ _ _--', 20'.=1.:::..2----'
Jim Leslie, Deputy Public Defender
Name
Addr...
aty. Stat. Zip

Linda 337-4865
Contact telephone number
A $35.00 fee is due at the time of the request.

Can (775) 325-6575 if you have any questions.
To: Ic321.9-c<8-461.-8.0f-I 559h

'__
8-19-11
FrOll: zachcouqhlln
J'
5:17am p. 2 of JJ
FILED
1
3
4
Z81ZAUG29 AM 8: 16
Document Code:
7.ach COllghlin,J'<:sq.
NV Bar No: 9473 (currently suspended)
PO ilOX 3961
Reno, NV 89505
Tde: 775 338 8118
STEVE TUTTLE
B~EHO JC:v.yjJ~B
Fax: 949 667 7402
\
.'
IN THE mSTICE COURT OF RE~O TOWNSHIP

IN AJ\lD FOR TIlE COL"NTY OF WASHOE, STATE OF NEVADA
'I
"
STATE OF NEVADA;
)
)
)
10
Plaintiff,
11
12
1S
16
) CASE NO: RCR2011-063341

)
) DEPT NO: 2
ZACHARY COUGHLIN:
Defendant
:!.2
VS.
)
)
-----------------------)
PRE-JRIAL BRIEl"; MOTION FOR SUMMARY JUDGMENT
17
18
COMES NOW, ZACH COCGHLIN, ESQ., and files the above titled document on his own
behalf and it is based on the argum.mt and authorities herein.
21
23
POINTS AND AUTIlORITIEl;,

In Nevada, its is very important to considez whether the requisite intcnt was there at the tim~
of the alleged act constituting theft. In this case, clearly, that it was not possible for such intent to be
present at the ttme of the "taking". Intent offinder: Every taking by one person of the personal
~6 property of another without his consent is not larceny: and thiR although it is taken without right or claim
27
of right Superadded to this there must be a felonious intent. without which there can be no crime. To
28
- 1/32 -
PRE-TRIAL BRIEF; MOTION FOR SU\I\M,1J<Y JUDG\l\ENT
To: 1c3flle9-fcc8-461a-8eOf-Jea559b
,
8-19-11
fcOi\; zachcoughl1n
5:11am p.]
of JJ
\
render the fmder of lost goods guilty of laroeny an intent to convert them
absolutely to his
0\\"
use must
coexist ""th the act of finding. If such intent does not exist ot the time oflbe fmding. but, instead, the
3
finru.-r intends to restore the property to the owner. a subsequent concealment, or fraudulent appropriation,
does not constitute larceny. Nevads: Stat. v. Clifford,
14 Nev. 72. 33 Am. Rep, 526 (1879).
So the rule clearly deducible from the authorities is that if the fmder oflos! articles neither
7
knows nor has any immediate means of a.~certaining the owner, and appropriates them to his own
use, he is not guilty of larceny, whatever may be his intent at the time. Ifhe does know, or has the
immediate means of ascertaining, who the owner is, there must.be a felonious intent to steal at the
10
time of the taking in order to constitute larceny, and a suhsequently formed intent'is no! sufficient.
Brewer v. State, 93 Ark. 479. 30 L.R.A. (N.S.) 339. 125 S.W. 127 (1910).
12
i3
Knowledge or notice as to owner Generally. The other element of the offense, in addition to
l4
the intent to take complete and excllL\ive dominion over the goods found, relates to knowledge or
15
notice a.<; to the owner. lithe finder, at the time of finding, does not know who is the owner of the
16
property, and there are no marks thereon, or other circumstances by which the owner maybe
discovered, the appropriation to the finder's me does not anoounlfu larceny discover the owner. So. it
18
is not larceny to appropriate property which one fOlds on a highway with no marks to show who tho
2C
owner is. Tyler v. People (IlL) supra; Lane v. People (1848) 10 Ill. 305. A man, knowing the owner
)1
of goods, cannot lawfully pick them up without returning them to him; but a man, not knowing the
2 ,'
. .c
owner. can. The doctrine, therefore. is that if. when one takes goods into his hands, he sees about
them any marks, or otherwise learns any facts. by which he knows who the owner is, yet with
24
25
felonious intent appropriates them to his own use, he is guilty of larceny, otherwise not Some of the
;~G
cases say irhe knows who the owner is, or bas the means of ascertaining; but the better form of the
7,' 1
doctrine is as just set down, because every man, by advertising and inquiring, can fOld the owner if
28
he is to be found, Brewerv. State (Ark.) supra. The court said in Randal v. State (Miss.) supra. that
- 2/32 -
PRE-TRlAL BRlEF, MOnON FOR S\J\1MAR YflJOOMENT
'10: lt3f21eHtt6-m.-3.UHe.559b
Ftea: ,achcaoghlin
"it is a settled principle oflaw that if one lose his goods, and another find them and convert them to
his own use, not knowing the owner, this is no larceny." Similarly it was said in Wolfmgton v. State
3
(Ind.) supra, that "if the fmder does not know, and has not, atthe timc oftakmg possession ofth.
gQ(lds, ilie means Qfilicn knQWing the (lwucr, the case is QUe of trover and C<lnversion, and not of
c.
larceny." The mere fact of a person's converting to his own use goods found by bim, regardless of the
'I
attending circumstances, does nnt, as a matter oflaw, make him guilty of theft Reg. v. Slavin (N, R)
supra. Conversely,
it~
at tbe time of the taking, the taker knows or bas means of discovering ihe
owner, it is his legal and moral duty to hold and restore the goods to him; and if, under such
circumstances, he al1s01urely appropriates them to his own use, excluding the dominion of the owner,
11
12
it is larceny. l\evada; State v. Clifford, 14 )lcv. 72. 33 Am. Rep. 526 (1879).
COIJNTONE;
13
15
16
WCC 53.160 Petitlarceny:

"Defmition; punishment. Every person who:
I. ~, takes and carries, ~ Of drives 8WlIY tbe oersonaJ goods
or property of another, under the value ofS250.,.
commit~ petit larceny and is guilty of a misdemeanor."
\7
J8
19
The rule that the finder of property so marked that the owner can be ascertained is guilty of
larceny if he converts it to his own use applied in case of a bar of bullion lost from a stagecoach.
State v. Clifford, 14 Nev. 72 (Nev., 1879).

21
DDA Young chose to charge Coughlin with the petit larceny code section found in the
Washoe Coullty Code. He did that for a reason. It~ easier to a get a conviction under wee 53.160
23
24
of petit larceny, given the fact that "intent" is not an element in WCC 53.160, while it is a required
element of the NRS version ofpetity larceny in :\RS NRS 205.240 (which is too bad, because NRS
26
205.0832 would have helped DDA Young gel the language he needs to attempt to make "lost,
mislaid or abandonded" property a subje~1 of petit larceny, However, DDA Young must take the
28
- 3/32 -
PRETRIAL BRIEf. MOTION FOR SUMMAK\ JUIJGMENT
, To;
From; ,athroughl!n
lcJf~7e9-fccB-461.-BeOf-7e.559b
B-19-11
5;17am
p. 5 of JJ
good with the bad. The good about WCC 53.160: he doesn~ need to prove Coughlin had the intent
:lI
to steaL 'The Bad: there is nothing in the WCC that accomplished what NRS 205.0832(d) does for
the NRS (ie, defmes theft to include situations where one" under NRS 205.0832(d): "Comes mto
control of lost, mislaid or misdclivered property of another person under circumstances providing
"
6
means of inquiry as to the true owner and appropriates that property to his or her 0""11 use or that of
another person without reasonable efforts (0 notify the true owner."). Good with the bad. Too
bad for DDA Young. he is stuck with wee 53.16O!Uld the wee is general because that is
what he put in his Complaint!Uld Amended Complaint, and the wee does not define "theft"
Ie
the saroeway that the NRS does under NRS 205.0832{d). It would simply be prejudicial to
-,1
12
13
14
10
:i.7
18
19
::c
21
allow DDA Young to pick and choose bilS ofc'Odes and laws here and there and make a pastiche
with which to charge and prosecute from.
See, NRS 205.240. has an "intent" component to it: NRS 205.240:
"Petit larceny; penalty. I. Except as otherwise provided in NRS 205.220,
205.226,205.228 and 475.105, a person ('~Jmmits petil larceny if the person: (a)
Intentionally steals, takes and carrie~ away, leads away or drives away: (I)
Personal goods or property. with a value of less than $650, owned by another
person;
And this is the section DDA YoWlg would probably like to see grafted onto the wce to
make it so he could charge
wce 53.160 (getting around the intent element) while also having the
ability to defme "theft" or "larceny" to include situations where one "Comes into control of lost
22
mislaid or misdelivered property of another person under circumstances providing means of inquiry
23
24
as to the true owner and appropriates that property to his or her own use or that of another person
25
without reasonable efforts to notify the true owner":
26
NRS 205.0832 Actions which constitute theft .

28
. "l. Except as otherwise provided in subsection 2, a person commilS theft if.

WIthout lawful authority, the person knowingly: ...
- 4/32 -
PRE-TRIAL BRIEF, MOTION FOR SUMMARY JUDGMThT
,10: lelf,ne9-fee8-467a-8enf-1e.559b
From: ,aeheouqhlln
8-19-11
5:11..
p. 6
of 33
2
3
1
I
(d) Comes into control of losL mislaid or misd~Iivered property of another person
under circumstances providing means of inquiry a.~ to the troc owner and
appropriates thai property to his or her own use or that of another person without
rea~onable efforts to notify the true owner."
Certainty and particularity--In eeneraI: Crime must be charged in indictment with
5
6
7
predslon and certainty and even ingredient ofwhich it Is composed mmt be accurately and
dearly aHe:ed. Ornelas v. United States, 1956, 236 F.2d 392.
Jndicimmt And lnfonuatiOll-- Infonnation alleging that t~ defendant aided and abdted
four murders needed to specify hOI\' he did so. Evans v. State, 2001, 28 P.3d 498, 117 Nev. 609,
lC
11
12
rehearing deuied. An indefinite indictment deprives defendant of notice of particular act

alleged to have been committed by accused and deprives defendant of his ability to defend
properly against accusation. and therefore indefmite indictment denies defendant his
14
fundamental righl~. U.S.C.A. Const.Amends. 5, 14. Wright v. State, 1985,701 P.2d 743,101
15
Nev. 269.
16
- 7
L
18
Purpose of requinment. certainty and particularity-- Principal purpose of indictment is

to provide defendant with descriptloo. of charges against him in sutljcimt detail to enable
him to prepare defense and plead double jeopardy in later prosecution; however, indictment is
2C
21
22
not constitutionally defective if it states elements of offense charged with sufficient clarity to
apprise defendant ofwbat to defend agajnst. U.S.C.A. Const.Amend. NevilL5 v. Sumner, 1988,
852 F.2d 463. AcclL~ation must include such a description or the acts alleged to have been
24
25
committed as will enable the accused to defend against the accusation. N.RS. 173.075, subd. 1.
Sheriff. Clark CQunty v. Blasko, 1982,647 P.2d 37I, 98 Nev. 327. Generally. an infonnation
which charges an offense solely in tenns of condusorv Iangul!ge does not pro\-ide adequate
:~B
notice of the charges to accused and therefore does not state a public offense. Letnberes v.
- 5/32 -
PRE-TRIAL BRIEF; MOTION FOR SU1.f!;lAR \' JUDGMENT
To: 7clf27e9-fccB-467.-8eOf-)ea559b
,
From: 2achcouqhlln
8-29-11
5:11am p, 1 of 33
I
I
State, 1981,634 P.2d 1219,97 Nev. 492. Tn the information, the prosecution is required to make a
definite statement offacts con.~lituting the offen~e in order adequately to notifY the accused of the
:1
charges and to prevent the prosecution from circumventing the notice requirement by changing
theories of the case. N.R.S. 173.015. 173.075, subd, 1. Sheriff, Clark County v. Levinson, 1979.
596 P.2d 232, 95 Nev. 436. Indictments whIch set out statements of acts constituting the offenses
6
7
in such a manner as to inform the accused with reasonable certainty of the specific Ilfl'ense with
which he is charged are sufiident State v. Belligas, 1979.594 P.2d 724,95 Nev. 358. Accused
"
has right to be informed of nature and cause of accusation against him and must be afforded a
1C
reasonable opportunity to obtain witnesses in his favor. Zessman v. State, 1978, 573 P.2d 1174. 94
11
12
Nev. 28.
13
14
10
16
1'i
18
1'~
20
21
22
23
24
~5>
26
27
cB
50 Am. Jur. 2d Larceny 58. Abandoned. lost. or milWlld property:

Most modern authority holds that larceny may be committed when a person finds
and retains an owner's lost property,[lj so long as it was the finder's intent to
deprive the owner of the property.(2] To establish the offense of theft of lost or
mislaid property, the state must prove: (1) that the property was lost or mislaid,
(2) that the defendant knew or learned the owners identity or learned of a
reasonable method of idenlif)~ng the owner, and 50 Am. Jur. 2d l.arceny 58 (3)
that the defendant failed to lake reasonable measures 10 return the property. [3]
When one acquires lost property which he or she knows to have been lost or
mislaid and does not take reasonable measures to return it to its owner, the
acquirer commits larceny if his or her intent is to dispose of the property for the
acquirer's own benefit or that of another person.[ 4] Taking or withholdmg of
such property is not "'fongful unless the fmder failed to take reasonable measures
to return the property to its true owner.[5] There is authority that there can be no
c~viction for the offense of theft of lost or mislaid property without sufficient
eVIdence that the property was actually lost or mislaid.[6] Other authority states
that, before larceny of such property may be charged, there must be evidence that
the owner still claims a right or interest in the propedy.[7] Abandoned prooortv
is not the subject oflan:euy.[9J because property that has been voluntarily
~bandoned hy the owner becomes subject til appropriation by the first taker or
tmder, who acquires it absolutely.[IO] The Model Penal Code provides that a
person .who comes intll control of property of another knowing it til have been
lost, mISlaid, or delivered under a mistake as to the nature Qr amount of the
property or the identity of the recipient is guilty of1heft it: with a purpose to
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deprive the owner of it. the person fails to take reasonable measures to restore the
property to the one entitled to have it.[ It}
IFN I J Long v. State. 33 Ala. App. 334. 33 So. 2d 382 (1948); Calhoun v. State.
191 Miss. 82, 2 So. 2d 802 (1941): State v. Kaufinan, 310 N.W.2d 709 (N.D.
1981); State v. Mack, 31 Or. App. 59, 569 P.2d 624 (I9n); State v. Jim, I3 Or.
App. 201, 508 P.2d 462 (1973). As to stray animals, see 54, 55...<\5 to when
finder of lost goods may be guilty of larceny, see 88. [FN2] State v. Moore, 46
N.C. App. 259, 264 S.E.2d 899 (1980). (FN3] State v. Smith, 276 Mont. 434,916
P.2d 773 (1996). [FN4] People v. Dadou. 167 Misc. 2d 628, 640 NY-S.2d 425
(City Crim. Ct. 1996). [FN5! State v. Evans, 119 Idaho 383,807 P.2d 62 (Ct.
App. 1991). [FN6] Statev. Mack, 31 Or. App. 59. 569 P.2d 624 (1977). Floral
designs placed upon a grave are of value to their donors so long as they remain in
a condition to serve the int~'Ilded purpose. hut when they have withered and died
they cease to be the subject oflarceny. Busler v. State, 181 Tenn. 675, 184
S.W.2rl 24 (1944). [FN7] Shedd v. State. 350 So. 2d 1085 (Fla. Dist. Ct. App. 1st
Dist. 1977). [FN9J Morissette v.V.S., 342V.S. 246. 72 S. Ct. 240. 96 L. Ed.
288 (1252); Com. v. Wetmore. 301 Pa. SuDer. 370. 447 A,ld 1012 (1981).
[FNI0] Am. JUT. 2d, Abandoned, Lost. and Unclaimed Property 27. [FNIl]
Model Penal Code 223.5."
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Larceny by finder of pmpert)'. 36 A.L.R. 372:

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I Lost property
a General rule
b Lost goods as subject of larceny
c Place where property is found
d Intent of fmder
e Knowledge or notice as to owner
fWithholding property for reward
g Statutory provisions
II Mislaid property
a Generally
b Intent of finder
c Property found in property purchased
"I. Lost property
o. Genua/. rille
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The general rule is that the tinder of lost property i. not guilty of larceny unless he
appropriates the same to his own use with knowledge of, or the immediate means of
ascertaining, the owner thereof, and with felonious intent entertained at the time of the
fmding. See the cases cited throughout this annotation.
Thus, in the report<:d cas" (Atkinson v. Birmingham, ante, 366), it is held !hal the
appropriation of money found on a puhlic street is nOllarceny where the owner thereof is not
in sight. no marks appear on the money, and no other means of ascertaining the true o\\ner
are available at the time the finder appropriates it.
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Ib. rule was slated by the court in the following language in Com, v. Metcalfe (1919) 184
Ky, 540, 212 S,W, 434: "The finder of\oot property, wh"", there i. no clue to the ownership.
although inadvertently or negligently lost, becomes the owner of the property. wbere the
owner is never discovered and fails to assert his ownership, and hence a finder of lost
property is not guilty of larceny wben he takes possession ('f and convert.. to his use property
the owner of which he does not know, and where he has no clue to the O\o,nership; bUl if the
finder has a clue to the ownership of the property, the taking will be larceny, if feloniously
done."
So the rule clearly deducible from the authorities is that if the fruder of loot articles neither
knows nor has any immediate means of ascertaining the owner, and appropriates them to his
own use, he is not guilty of larceny, whatever may be his intent at the time. lfhe does know.
or ha;; the immediate means of ascertaining, who the owner is, there must be a felon iou"
intent to steal at the time of the taking in order to constitute larceny; and a subsequently
formed intent is not sumcient. Brewer v. SUite (1910) 93 Ali" 479, 30 LRA (N's,) 339.
125 S.W, 127,20 Ann. Cas. un.
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The mere fact that a person converts to his own use goods found by him does not, as a matter
of law, make him guilty of theft. The question of guilt must be determined by the jury from
the attending circumstances, such as the description of goods found, the place ot' finding, the
time elapsing between the finding and the conversion, the probability of the owner being
discovered the manner of dealing with the goods, and the elion or want of effort to di,cover
the owner. Reg. v. Slavin (1900) 35 N. R 388.
b. Lost goods as subject of larceny
The authorities fwnish a strong color for the opinion, which Jl"'1'haps is entertained generally, that
anciently goods casually lost were not considered to be the subject of larceny under any
circumstances. Ransom v. State (1852) 22 Conn. 161. Baron Parke, in the leading ..se upon the
subject under consideration. reached this conclusion from a review of the earliest authorities,
saying: "In the earliest times it was held that chattels which were apparently without an owner.
nullius in borus, could not be the sobject of larceny. StauntOrd, one of the oldest authorities on
~'l'iminallaw. who was a judge in the reign of Philip and Mary, says (bk. I, chap. 16): 'Treasure
trove, wreck of the sea, waif or slray, taken and carried away, is not felony, "Quia dominus rerum
non appare!, ideo cujus sunt incertum esl" For this he quotes FiIz. Ahr. '('-OrOlI.; pp. 187. 265.
'lbese passages are taken from 22 Ass. 99, 22 Edw. m., and mention only 'treasure trove,'
'wreck,' and 'waif;' and Fitzherbert sa)~ the punishment for taking sucb is not the loss of life or
limb. The passage in 3 Co. lost 108, goes beyond this. Lord Coke mentions three circwnstances
as material in larceny: first., the taking must be felonious. whicl! he explains; secondly, it must be
an actual taking, which he also explains; thirdly, it is not by trover or rmding. lie then proceeds
as follows: 'If one lose his goods. and another find them, though be convert them animo furandi
to ?is own use, it is not larceny, for the ftrst taking is lawful; so if one lind treasure trove, or
waif, or stray (here "wreck" is omitted and "stray" introduced). and convert them ut supra, it is no
larceny, both in respect. of the fmding, and that "dominus rerum non apparel:"" Reg. v. 'Thorburn
(1849) I Den. C, C. (Eng.) 387, Temple &
M. 67, 2 Car. & K. 831, 18 L. J. Mag. Cas. N. S. 140, 13 Jur. 499, reported also as Reg. v.
Wood, 3 Cox, C, C. 453, 3 "iew. Sess. Cas. 581.
d. IIlIetII offlltder: Every taking by one person of the personal property of another without
hIS consent 18 not larceny; and this although it is taken without right or claim of right
Superadded to this there must be a felonious intent, without which there can be no orim . To
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render the fmder of lost goods guilty of larceny an intent to ootlvert them absolutely to his
own use must coexist with the act of rmding. If such inlent does nol exist al the time of the
finding, bu~ instead, the finder intends to restore the property 10 the owner, a subsequent
concealment, or fraudulent appropriation. does nol constitute larceny. 2\evada: State v.
ClitIord ( 1879) 14 Nev. 72, 33 Am. Rep. 526.
It was said. ht Rountree v. State (1877) 58 Ala. 381, that the mere taking away
of found property, with httent 10 convert it to the finder's use, is not sufficient to
constitute larceny, as there must also appear a felonious intent.
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"The finder of personal property which has been inadvertently or negligently lost, and
who takes it into his possession, lbereby severs the possllSsion of lbe owner; but the
finder does not commit larceny in so doing, unless he takes it with the intention to
appropriate it to his own use, and to permanently depri ve lb. owner of his property and
use of it" Com. v. M<ltcalfe (1919) 184 Ky. 540,212 S.W. 434.
In Berry v. State (Okla.) supra, it was held that lbe intent to appropriate lost
property to lbe finder's own use was established by evidence lbat he hid it ins lead of
making reasonable efforts (0 restore it (0 the owner.
The question whether the goods were taken originally by lbe accused feloniously, animo
furandi. is always a question of fact, and usually the principal one, for the jury to
determine. Ransom v. State (1852) 22 Conn. 161. This intent need not be proved by
positive testimony, but may be inferred from circumstances. Weaver v. State (1884) 77
Ala. 26, 5 Am. Crim. Rep.
366. It may be ascertained, like lbe intent wilb which any olber act is done, by a careful
examination of the facts and circumstances preceding, attending, and following the
rmding. Allen
v. State (1890) 91 Ala. 19, 24 Am. St. Rep. 856, 8 So. 665; Wolfington v. State (1816)
53 Ind.
343. Inquiries may be made as to the manner in which the finder conducted himself with
the goods, and his present means of knowing or a.~ccrtaining lbe owner. Allen v. Stak
(Ala) supra.
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To constitute'larceny lbere must be a criminal intent at lbe time of the taking. Drummond
v. State (l913) 71 Tex. Crint Rep. 260, 158 S.W. 549, holding that where a boy found a
parr of gloves, and took them into his possession for the purpose of carrying them to the
person whom he supposed to be the owner, and later, learning that another person had
lost gloves and advertised for the same, took them to him and left them upon being
assured 1hat lbey belonged to the third person. he had no such intent to steal as is
necessary to constitute larceny.
To constitute lbeft, said the Texas court of appeals, "lbe fraudulent intent, which is the
gist of this offense, must exist in lbe mind of lbe taker at the very time of the taking: and.
In lbe case of lost property, the time of lbe taking is lbe time of the finding of the
property. I~ lbe ~raudul~nt intent did not exist at the time of the taking, no subsequent
fTaudulent Intent In relation to Ihe property will constitute theft." Martinez v. Stale (1884)
16 Tex. App. 122.
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"It may reasonably be said not to be a violation of any social duty for a man who finds a
lost article In take it home for the purpos.: of finding out the true owner; and ifhc does
this honestly in the first instance, and afterwards, though he may have discovered the
true owner, is seduced into appropriating to his own use, he is not guilty of larceny,
though he does wrong." Reg. v. Riley (1856) Dears. C. C. (Eng.) 149.
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The supreme judicial court of Massachusetts, in an opinion by Gray, 1., then chid
justice, said: "The finder oflost good~ may lawfully taU them into his possession; and if
he does so without any felonious intent at that time, a subsequent conversion of them to
his own use, by whatever intent that conversion is accompanied, will not coo..litute
larceny. But if, at the time of first taking them into his possession, he has a felonious
intent to appropriate them to his own use and to deprive the o....'l!er of them. and then
knows or has the reasonable means of knowing or ascertaining, by marks on the goods or
otherwise, who the owner is, he may be found guihy of larceny." Com. v. Titus (1874)
116 Mass. 42, 17 Am. Rep. 138, I Am. Crim. Rep. 416.
e. Knowledge or notice as to /lime

GeneraDy.
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The other element of the offense, in addition to the intent to take complete and exclusive
dominion over the good~ found, relates to knowledge or notice as to the owner, If the
fmder, at the time of fmding, does not know who is the owner of the property, and there
are no marks thereon, or other circumstances by which the owner may be discovered the
appropriation to the fmder's use docs not amount to larceny. A man, knowing the owner
of goods, cannot lawfully pick them up without retuming them to him; but a man,
not knowing the owner, can. The doctrine, therefore, is that if, when one takes
goods mto his hands, he sees ab0u4 them any marks, or otherwise learns any fads,
by which he knows who the owner is, yet with felonious mtent appropriates them to
his own use, he Is guilty of larceny; otherwise not. Soote of the cases say if he knows
who the owner is, or has the means of aseertainmlf, but the better form of the
doctrine is as just set down, because every man, by advertising and inquiring. can
find the ownedebe is to be found, Brewer v. State (Alii.) supra.
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The court said in Randal v, Slate (Miss.) supra, that "it is a settled principle oflaw Ihal if
one lose his goods, and anotl\er fmd them and convert them to his own use, not kno,," ing
the owner, this is no larceny." Similarly it was said in Wolfington v. State (Iud,) supra.
that "if the finder does not know, and has not at the time of taking possession of the
goods, the means of then knowing the owner, the case is OM of trover and converSIOn,
and not of larceny,"
The mere fad of a person's converting to his own use goods found by him, regardless of
Ihe attending circumstances, does not. as a matter onaw, make him guilty oflheft Reg
v. Slavin G'/, B.} supra,
Conversely, if, at the time of the taking, the taker knows or has means of discovering the
owner, it is his legal and moral duty to hold and restore 'the goods to him; and if, under
such circumstances, he absolutely appropriates them to his 0"'11 use, excluding the
dominion of the owner, it is larceny_
Effort to find owner.
Since the finder's belief, or ground of belief, in regard to finding the owner, is to be
determined by the circumstances apparent to him at the time of finding the property, guilt
cannot be predicated of a failure \0 exercise diligence to fmd the owner, The finder is not
bound to search for or to take any other measures to discover the owner. Brooks v, State
(1878) 35 Ohio Sl. 47; Tanner v, Com, (1857) 14 Grall, (Va.) 635; Perrin v, Com, (1891)
87 Va. 554, 13
S,E, 76, See also infra, L g., for statutes declaring the contrary nIle. In Tanner v. Com.
(1857) 14 Gratt (Va,) 635, supra, the court said: "Where there are no indicia by which
the owner can be found, the appropriation to the tinder's use does not amount to larceuy;
for, as it has been held, the finder of a chattel actually tost is not bound to take any means
to discover the owner; he must know him immediately from marks about the property or
otherwise. It
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In some of the earlier cases it was declared 1hat a failure to use fe3Sonable means to
discover the owner, by adverti.~iug, rendered the finder guilty, Reg, v, Coffm (1846) 2
Cox, C. C. (Eng,) 44; Reg, v, Reed (1842) Car, & M, (Eng,) 306; Reg, v, Kerr (I837) 8
Car, & p, (Eng,)
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176. These expressions, however, are dicta. and have been overruled. Reg. v. Shea
(1&56) 7 Cox, C. C. (Eng.) 147.
The view has been taken, rightly, it would seem, that a neglect to take reasonable
measures to fmd the owner raises a presumption of feloniolL' intention in the taking.
State v. Briscoe (1900) 3 Penn. (Del.) 7, 50 Atl. 271.
If the defendant at no time claims the property as his own, or attempts to conceal it, hut
on the contrary, makes efforts to discover the owner of it, and in faL'l does discover the
owner of a portion of it, and restores the same, he clearly is not guilty of larceny,
McLaren v, State (1886) 21 Tex, App. 513, 2 S.W. 858,
The omission to use the ordinary and well-known means of discovering the owner of
goods lost raises a presumption of fraudulent intention. more or less slrOng, against the
fmder. State v. Briscoe (Del.) supra.
A conviction for the theft of a watch was upheld in Rochell v. Stale (1909) 55 Tex. Crim.
Rep. 152, 115 S. W. 583, where it appeared that the accused found it. but made no effort
to ascertain the owner: that he wore it concealed until he moved to another to"'ll. wh~re
he wore it in the ordinary way; that when it~ return was demanded by the sheriff, the
accused refused to surrender it, but stated that he would hold it for the owner, although
persons who were his relatives testified that he stated 011 the day he came into possession
that he had found it.
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As to
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wec 53.160, it is not clear how Coughlin could be said to have "takes or carries, leads
or drives away ... " where Coughlin himself made a 911 call and on tbe excuplatory video can he
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heard suggesting the parties remain calm and wait for the police to arrive and resolve any disputc_
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It is not clear how there could be probable cause for the arrest and prosecution in RCR 20 11-063341
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where there is no allegation or factual support to suggest that Coughlin "intentionally" stole
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anything. It would have to be clear that something was not abandoned for one 10 steal somdhing.
22
Further. again, as with the WCC, there is no indication that Coughlin could be said to have "takes
and carries away, leads away or drives away.. ." given Coughlin's own 911 call and suggestions to
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the volatile group of youths that they shoudl remain peaceful and wait for the police. Lastly_ it is
not clear that anyone there could have known the iphone was "persortal procprty... owned by another
person... ". There is support that Goble abandoned the iPhooe, if it is even his, therefore he would
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no longer oYm it. Some might say the iPhone would be at the hottom of the Truckee River, and
devoid of value. and therefore incapable of being larcenized
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a. Generally
Property which the owner intentionally so places that he can revert to it. and then
forget~. is mislaid. as distinguished from lost property, which is that with which the
owner accidentally parts and does not at any time know where to find. See Reg, v,
West (1854) 6 Cox, C. C. 415, De.1rs, C. C, 402, 3 C. L R, 86,241. J. Mag, Cas, N.
S. 4, 18 Jur, 1030,3 Week. Rep. 21. 29 Eng. 1. & Eq. Rep. 525. and the cases cited
throughout this subdivision,
Unlike lost property, the froder of mislaid propcny acquires no right to its possession,
the right of temporary posess ion being in the owner or oceupant of the premises where
it is found. Accordingly the general rule is that a person is guilty of larceny if, with
felonious intent, he appropriates to his own use property merely mislaid, though h~
has no knowledge or means ofknowledg~ as to the true ownerln Slate v. Craig (S.C,)
supra, it was held that the detlmdant was guilty of larceny in appropriating to his own
use a pocketbook inadvertently left on a seat of a streel car. In sustaining the
conviction the coun said: "The evidence shows that the purse was not lost property.
but misplaced property. The oonductor saw the purse, was going to pick it up, when
defendant took it. 'Ine property was mislaid, and accidentally left on the trolley car; It
wa~ never lost or abandoned. The defendant reasonably supposed the owner conld he
found, and he knew that it was not losl property, but misplaced, and accidentally kft
where he picked it up."
A purse accidentally left in a store is not lost, but mislaid, so that a finder who
appropriates it with felonious intent is guilty oflarceny. State v. McCann (Mo,) supra:
Reg. v, West (1854) 6 Cox. C. C. (Eng.) 415. Dears, C. C. 402. 3 C. 1. R, 86, 241. J.
Mag, Cas. N. S. 4, 29 Eng, L. & Eq. Rep. 525, 18 JUT. 1031,3 Week. Rep. 21.
So, a pocketbook or other property laid down in a barher shop is merely misplaced.
and a finder who appropriates it mav be convicted of larceny. Lawrence v. State
(Tenn.) supra; Reg.
.
.
v, Moore (1861) 8 Cox, C. C. (Eng.) 416,7 Jur. N. S, 172, Leigh & c. c. C, 1. 30 L
J. Mag, Cas, N, S. 77, 3 1. T N, S, 710, 9 Week. Rep. 276.
And if a person pich up and appropriates a ring, money. or other property mislaid or
dropped in a dwelling house, he is guilty of larceny of mislaid property. Stale v.
Cummings (1866) 33 Conn. 264. 89 Am. Dec. 208: Roberts v. State (1889) 83 Ga,
369. 9 S.E. 675, 8 A.m. Crim. Rep. 474.
In State v. Cummings (COM.) supra, it appeared that the defendant, a servant. look a
diamond ring from a washtub into which the owner of the jewel accidentally dropped
it, and appropriated the same to her own use. It was held that the ring was not lost
property. and that, therefore, the defendant was guilty of larceny. The court said:
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"What, then, are the facts as claimed 10 be proved by the state? They are, that the
owner of the ring left it by accident in the tub where she had been washing; that,
knowing where it was, she went for it in ten or fifteen minutes; that. in the meantime.
it had been taken by the prisoner out of tbe tub; that she knew whose it was and
denied the taking of it, and concealed it and brought it to New Haven as her own, and
offered it for sale. Under these circumstances it is very apparent that, except for th~
act of the prisoner, there was no loss of the ring, any more than ifthe owner had left it
on her table for a temporary purpose,"
In Reg. v. West (Eng.) supra, it appeared that the prosecuting witness, after making a
purchase, left his purse on the defendant's stall. The defendant picked it up and
appropriated the contents to her own use. It was held that she was guilty of larceny.
In Lawrence v. State (Tenn.) supra, it appeared that the prosecuting witness left his
pocketbook, containing $480, on a table in a barber shop. After the prosecutor left, the
barber picked up the purse and appropriated the mQllcy to his own use. It was hdd
that he was guilty oflarceny.
A purse accidentally left in a carriage returned to a livery stable by the hirer is lIot
lost, so as to require the application of tbe foregoing rule in a prosecution for theft
against one who found the purse UpOll taking immediate charge of the carriage upon
its return. Moxie v. State (1908) 54 Tex. Crim. Rep. 529, 114 S.W. 375.
In ~'tate v. Courtsol (1915) 89 Conn. 564, L.RA.19IM, 465, 94 At!. 973, it appcar"d
that the prosecuting witness, while riding in a street car, left a package of money on
the bench on which he sal. After he left the car the defendant, who wa.' also a
passenger in the same car, picked up the package and appropriated the money to her
own use. It was held that she was guilty of larceny. The court said: "'There was no
evidence to support counsel's daim that the package was lost. The evidence shows
that it was left upon a public conveyance by its owner, upon a bench or scat where he
had placed it. He remembered where he left it. and speedily sought it, and found that
the accused had taken it. It is well settled that property so left is not lost, but is mislaid
property, The owner is treated as still constructively in possession of it, although its
custody may be in another, in whose shop or car it has been left. 2 Wharf. Crim, La\\',
11th ed. 1139; 2 Bishop, New Crim. Law, 878, 879; People v. McGarren (1837)
17 Wend. (N.Y.) 462; State v. McCann (1853) 19 Mo. 254. The accused herself did
not claim that she supposed the property had been lost. Sbe took it up, believing it to
be her own package containing purchases previously made by her. When she
discovered that it was not. she knew that it was a package left upon the car by some
person who undoubtedly would call upon the trolley company for it. The court,
therefore, properly refused to give an instruction which would give the jury to
understand that up<m the evidence they might find that the package was lost, and that
the accused. when she picked it up, honestly believed that it was a lost package. As
the fact~ were undisputed, the court was correct in giving the instruction which. the
accused complained of in her sixth assignment of error, namely: 'This case that you
have before you is not a ca.~e of lost property, tec/mically speaking-that is, actually
lost or abandoned; but is a case, as the books and cases describe it. of property thai is
mislaid: The instruction complained of in the seventh reason of appeal was also
- 24/32 -
PR..TRIAL BRlEF;MOTION ORSlMMARY JL'DGMHNT
15 of 33
,To, lc3fZleS-fccS-!61a-SeOf-leaSSSb
1
2
3
Froa: 2achcoughlln
3-29-12
1,11am
p,
16 of 33
correct. As already stated, the constructive possession of mislaid property remains in

the owner. The finder of such property, knowing it to he mislaid or Icft by mistake. if
he takes it with the felonious intent to appropriate it to his ow11 use, and thus deprive
the owner of it, is guilty of larceny. This would constitute a felonious taking from lhe
possession of another of property belonging to him. This was the substance of the
instru<..1ion complained of. The language which followed explained the distinction
between the finding in such a case and one where the property has been lost."
,I
1be same rule wa.~ applied in Pritchett v. Slate (1854) 2 Sneed (Tenn.) 285, 62 Am.
Dec. 468, wherein it appeared that an cXl'losion in a jewelry shop lhrew into the street
some watches which were hanging in the shop windows. and that the defendant took
them as lost property.
1
I
10
11
V
13
14
15
16
p
16
19
2C
21
22
b. Intent offUido
It is held that, in order to constitute larceny of mislaid property, there must be a
criminal intent to appropriate the property to the tinder's own use, in violation of the
owner's rights. Griggs v. State (1877) 58 Ala. 425, 29 Am. Rep. 762; Weaver v. State
(1884) 77 Ala. 26, 5 Am. Crim. Rep. 366; Smith v. State (1893) !O3 Ala. 40, 16 So.
12: State v. Courtsol (1915) 89 Conn. 564, L.R.A.\9\6A, 465,94 At!. 973; Martinez
v. State (1884) 16 Tex. App. 122; Warren v. Slate (1884) 17 Tex. App. 207.
The constructive possession of mislaid property remains in the owner, and the owner
or occupant of the premises becomes his bailee. Foulke v. New York Conso!. R. Co.
(1920)228
N.Y. 269,9 A,L.R. 1384, 127 N,E. 237. The fmder of sm.it property, knowing it to be
mislaid or left by mistake, if he takes it with the felonious intent to appropriate it to
his own usc, and thus deprive the oViller of it, is guilty of larceny. State v. Courtsol
(19\5) 89 Conn. 564,
L.RA 1916A, 465, 94 Atl. 973.
In Griggs v. State (Ala.) supra. Brickell, rh. J., said that the taker of goods mislaid or
left hy mistake is guilty of larceny by appropriating them to his own use, regardless of
whether the intent to keep then was formed at the time of, or subsequent to, the
taking."
Regardless, Officer Duralde ganled the system by listing the charge as a felony, and such a
valuation is not reasonable, as such the motion 10 suprcss should exclude the fruits of the
impennissible search in light ofNRS 205.251:
24
25
"NRS 205.251 Determination of value of property involved in larceny offense. For

lhe purposes ofNRS 205.2175 to 205.2707, incllLqivc:
27
I. The value of property involved in a larcenv otTen"" shall be deemed to he th~

highest value attributable to the property by any ~easonable standard.
28
- 15/32 -
PRE-TRIAL BRIEF; MOTION FOR SUMMARY JUDGMENT
To, lc3fZle9-fcci-46la-ieOf-7ea559b
From, ,a,hcough11n
8-19-11
5,11'0
p, 17 of
2, The value of property involved in larceny offenses committed by OIle or more

persons pursuant to a scheme or continuing course of conduct may be aggregated in
detennining the grade of the larceny offenses,"
Indeed, RPD Officer Duralde's Arrest Report reads: "Nex1 I spoke to the victim, Cory
GOBLE who stated that he has an Apple Iphone that he had bought acouple of years ago for $300,"
6
7
Clearly, it is not reasonable to believe that a smartphoen purchase "a couple years ago" for $300 had
not depreciated in value at least $50 in that time (at the time of arrest the value cutoff for grand
larceny was $250. but as of October 2011, it is 1I0t S650 in Nevada),
The recordings of the 911 calls by Goble further demonstrate the extent to which he and his
10
compatriates, including Zarate. were willing to lie to the police to accomplish their goaLto achieve
11
12
13
the return of an iPhone that Goble felt entitled to receive as expeditiously as possible and by means
that quite arguably exceeded any right he bad to exert (ie, threatening to and attempting to steal
Coughlin's bicycle and his dog, lying to 911 operators, making false allegations about someone
15
"socking a minor", ganging up on Coughlin with a number of other young men behaving in an
ultra-agressive manor. etc),
:8
It mayor may not be relevant to consider that the iPhone would have, apparently, been in the
19
river were it not for someone claiming it, or that Goble apparently felt entitle to avoid any
20
consequences attaching to his extremely negligent practice of, allegedly, leaving a smartphone on
21
the pavement unattended while he goes off to his Jeep for several minutes at least, in downtown
22
Reno, during a period of four or so years of the unemployment rate hovering aroudn 15%, Goble
24
apparently sought to avoid the hassle of pursuing a civil rememdy or otbern,se behaving in a civil
25
and patient manner in pursuing the return of a phone that mayor may not have been his, Goble
26
refused to pursue such a return in a setting that was divorced from the overly coercive and volatil~
tenor presented by Goble and his many friends accosting Coughlin and backing Coughlin up to
L8
- l.6/32 -
PRE-TRIAL BRIEF; MOnON FOR SUMl\iARY mOOMENT
33
To: lc3f?,7e9-fcc8-467a-8eOf-7 559b
Fe.. : zacbcoughlln
8-19-11
5:17..
p, 18 of JJ
oncoming traffic on Center St. bridge in front of the Sienna while Coughlin attempted to hold onto
his bicycle and his dog,
'i1
On one of his 911 calls, Goble allegations that "someone just socked a minor"-,.apparcntiy
4
indicating that Coughlin punched the 17 year old young man seen in the videos. Clearly, no one is
5
!
,
saying that now, nor in any of the police reports, however, it was defmitely useful for Goble to say
that to the 911 operators, and the textual record provided ofthe calls and dispatch report~ includes a
citation to this allegation of physical violence as well. The operator and the police hear that
10
12
"someone just socked a minor" and it gets their attention and skews the approach by the police
immeasurably.
J1
On his other 911 call. Goble makes like the Jon Lovitz liar charact<,'f from the 1980's Saturday
1?
Night Live sketches ... the "wait, yeah, that's the ticket ... " liar character with a catchphrase. Goble
14
starts the call indicating that Coughlin "just stole his phone" and "is being super aggressive and
15
giving us all sorts of trouble" but then Goble decides, "wait, no, yeah, that's it, he is tJying to get
1'5
away too!'. So which is it? Super aggressive and giving you all sorts of trouble or tJying to get
18
away? And why are Goble and his associates li..ted in the 911 and dispatch text reports as the on~'s
19
yelling? Why is Goble heard on a 911 call s~'rearning "give me my phone or I am going to threaten
20
you right now!". Why are Goble and his associates the one's reaching into Coughlin's short's pocket,
?1
attempting to take Coughlin's dog and bicycle. if, as Goble told the 911 operator, it was Coughlin
22
who wa, "being super aggressive and giving us all sorts of trouble"?
23
24
But, best of all, on Goble's 911 call of August 20th, 2011 at 23:22:52 at the 31 second mark.
the wise 911 operator asks:
27
Operator (0): "how did he end up with your cell phone?".

Goble: ~'my ~hone Was just sitting on the ledge and I was just skateboarding and stuff,
and he Just pIcked It up. Everyone saw him pick it up."
28
- 17/32 -
PRJl..TRL4L I3RlEF; MOTION FOR SUMMARY JUDGMEl'o.'T
io: 7cJf2ie9-fcc8-461a-8eOf-le.,,9b
from: lachcouqblin
8-29-12
5:17a.
p. 19 of JJ
Well, is that true? If so, then why did Zarate write in his Witness Statement that the
2
unidentified man gave the phone to Coughlin? That is rather different than Coughlin ju.<t walking by
and picking the phone up off the ledge. What, exactly, did everyone see? What about the
s
6
unidentified man holding the phone aloft and indicating he would shortly throw the phone in the
river? In the background on that same call Goble's associates can be heard menacingly commeming
on talting and touching Coughlin's dog and bicycle. Conghlin can be heard exclaiming "you just
assaulted me! ".

Then, at the 1 minute 7 second mark Goble says:
lC
11
J2
Goble: "Dude, just give me my phone, its right in his pocket just get it out. I am
about to grab it out of his pocket"
Then at 1 minute 57 second mark Goble reiterates:
13
14
Goble' "He is just getting super aggresive with us, grabbed my phone, I swear, and
he will not give it back ".He grabbed my phone, I swear, its in his pocket, dude ... I
was right here, my Jeep was right here, my fucking Jeep was right there!".
So, which is it, Goble? Was he skateboarding and stuff, <'r in his Jeep? Why docs Gohle's
17
18
written Witness Statements from that night indicate he was only "flfieen feet away" from where you
sct your phone down when Coughlin allegedly walked right up and grabbed it? Doesn't "h~ just
19
grabbed it" sound a bit more like someone "grabbing" an item by force from someone, in a big hurry,
21
Z2
23
and attempting to run away, rather than, what Nicole Wat,on says happened, ie, that an unidentified
man picked the phone up, held it aloft, announced he would "throw it ill the river", etc ...
Goble and his associates belligerent menacing attitudes and behaviors clearly startled and
frightened Coughlin that night. Further, they were simply off-putting. While one might simply
hand over a phone to Goble, assuming Goble is telling the truth when he assert., it is his, one would
26
27
28
not necessarily be being all that careful in doing so, if the law requires one to take reasonable steps 10
return lost property to its rightful owner'? Even if it were true to say Goble called the phone and saw
- 16/32 PRE-TRlAL BRim'. MOTION FOR SUMMARY ruOOMENT
To, lclI27.9-lcc8-461a-B.OI-1.a559b
i
)
I
I
From, zachcoughlln
8-29-11
5,11am
p.20 0133
it light up, that is hardly conclusive proof that the pbone is C",ble's. What if someone Goble and his
friends w<ll'e familiar with had announced they lost tbeir phone earlier that night? Now. what if
",
Goble knew that person's phone number, and used that knowledge to present an appearance to
.1
1
I
Coughlin that the phone rightfully belonged to Goble merely because Goble !Day have been able to
5
I
I
call the phone and make it ring? And its not at all clear that Goble was actually able to do that
./
Indeed, if Goble was so able to, then why didn't the phone light lip during the entire 5 minute
videoiaudio 10 the arrest? Why is Goble's voice heard in the background suggesting to the RPl)
Officer's that Coughlin may have "switched the phone" to his other pocket? Goble et aI behavior was
10
menacing and indicated a willingness to massage to the truth to a large degree. This is particularly
11
,.
1"
clear when viewing the video of the interaction between Goble and Coughlin of June 5th, 2012. It is
13
interesting to note that Coughlin's law license was suspended on June 7th, 2012 at 3: 48pm just hours
1.4
after Coughlin sent the DA's Office an email pointing out the inequity of failing (0 prosecute Goble
15
for the lit cigarette projectile battery upon Coughlin wilere Coughlin's entire live, professionally and
16
personally had, essentially, been curb stopped by this petit larceny arrest.
17
18
19
Next, on the video of the battery upon Coughlin by Goble from June 5, 2012, Goble is heard
massaging his story back and forth:
20
21
23
24
26
27
28
Coughlin: Who are you?

Goble: I'm over it, its all good. Remember? We went to court together. Its all good
~oughlin: Ycab. Oh, its all good for you'! Oh, good, I'm going to lose my career.
Goble: I'm sorry that sucks.
Coughlin: Yeah, what's your name, Cory?
Goble: Yeah
Coughlin: Hey, how are you guys?
(early twenties brunette female); Wonderful, how are you?
(early t,;"enties A~ian male): you can film \IS all you want
Coughlm: Hey, did you lie to the police~
Goble; Do?
Coughl!": \ eab, Did you guys say I just ran up and grabbed the phone?
Goble: Inat s basICally what you did.
- 19/32 -
PRE.. TRIAL BRIEF; MOTION FOR SUMMARY JUDGMENT
To: JcJf11e9-fcc8-!61a-8eOf-JeaSS9b
,
,rOIl: zachcouqhlin
9-29-11
5:11d1l
p. 11 of Jl
1
,
2
,
:
, 3
4
6
7
:'
;c
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14
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Coughlin: OIeay, is that basically it or is that what I did? And what did you tell the
police?
Goble: 'I hat's exactly what you did,
(brunette female): He's...he's ...he fucking has a camera~
Coughlin: What did ...are you a little high'! You goLyou've got "f.U.C.K." tatfoed on
your hand (spelled out on his four knuckles).
(brunette female): We don't do drugs, yourre a crazy person, excuse me, excuse
me .. Just cuz someone's talking to you ....
Goble: I was just saying I was over it...
(brunette female): Windows up. (rolls Lell:u8 SUV windows up).
Coughlin: Ob, wondedul, you're over it.
Goble: (flicks lit cigarette at Coughhn from about 2 to 3 lilet away at a high rate of
speed. The lit cigarette hits Coughlin's suit jacket at his left shoulder and the tip
exploded into sparks, then falls to the ground. This is shown right before the 52
second mark of the video ofthi. June 5th, 2012 iocident. Coughlin's camera jerks
right when Coughlin is hit with the lit cigarette. which was projected at C.()ughlin by
Goble flicking it in a propulsive manner between his middle and index fingers and his
thUlJlb .. .it actually got traveling at a fairly high rate of spt.'ed and the flicking and
cigarette darting through the air, and the cigarette hitting Coughlin's shoulder and
exploding are all very discernible in this video, especially the audio of those souud~.
particularly when con~idering that the c.'IIl1era jerking coincides exactly with the
e"')llodiug sound).
Coughlin: Oh, you just did me such a big favor, guy."
Coughlin could have, at that time. attempted to effectuate au ill-conceived "citizen's arrest"
16
similar to the one RPD Officer Duralde alleges Goble et aJ performed on Coughlin on August 20th,
J 7
18
19
2(:
2011, however, Coughlin made the rationale. reasoned, safe decision to refrain from so attemptmg
such a risky "citizen's arrest".

Ihe video from just prior to the August 20th, 2011 petillarceny arrest, wherein Coughlin
made a 911 call and reported the assault and battery that Goble and his gang were committing upon
22
him, shows Coughlin explaining to Goble et al that reaching into Coughliu's pockets was a very poor
choice and that everyone involved needed to relax, settle down, be peaceful. etc. and Coughlin
25
referenoed the tragic consequences of failiug to do so that had, at that time. just recently been seen in
26
the death of25 year old Stephen Gale during an armed robbery of a female's purse on California
.- .
Avenue.
... 'i
- 20/32 -
PRE-TRIAL BRlEF: MOTION FOR SUMMARy JUDGMEKT
,To: 1cJf2,7e9-fccH6Ja-8eOf-Jmb
Fr .. : ,aeheoughl!n
8-19-11
H1...
p,
11 of 33
It is important to make note of the ready willingness to lie that Goble et al demonstrate.
Goble, Zarate, el allied to the 911 operator and the officers on the scene to get Coughlin arrested.
j
1
placed in cuffs, searched etc. (and to provide sufficient probable cause to perfonn a search incident to
4
an actual fact pattern that likely would have been more fitting of the typicial "its a civil matter"
5
6
response Coughlin has been given by the RPO so mallY times this year when he has reported various
misconduct by landlord's and their counse~ some of whom lack a law license though they are
\
!
practicing law).
[0
It was only after all that was accomplisbed that Zarate realized he better put something a bit
'I
more truthful down on paper, and that is when the unidentified man who held the iPhone aloft and
11
12
13
announced to the denilens of the skate plaza that he would "throw it in the river if some011<J doesn't
claim it immediately" is referenced in Zarate's Witness Statement, which reads:
15
"One man picked up the poone, and the man ",ith th~ bike took it from him and
started to try to leave when the owner of the phone tried to ask for it back, he became
resistant and impolite."
This is in marked contrast to the statements Officer Duralde attributes to Zarate in Duralde's
18
Narrative, wherein Zarates is quoted thusly: "GOBLE's friend, NathanieJ ZARATE, then informed
19
him that COUGHLIN bad just wallled by and taken GOBLE's phooe." I next spoke ",jlh
20
21
ZARATE who confirmed that he bad observed COlJGHUN take GOBI"E'S phone from where
22
GOBI.E had set it dgwD, and then observed COUGHLIN put it in his kfi front shorts pocket"
23
Goble, in his I'.ntten statement, continued to lie, however. In his Witness Statement Goble wrote:
24
25
:'1 was ~tthe Plaza and set my phone down. An older man walked by and grabbed
N.'y Inends brought it to my attention. I nm afu,r him and asked him tor it back.
He hed and said he didn't have it. We called it and saw it ringing in his pocket. He
refused (0 give it back to I called 911."
1t.
26
Which 1ben at I minute 57 second mark Goble reiterates:

- 21/32 -
PRE-TRIAL BRIEF; MOTION fOR SUMMAR Y JUDGMEl\T
,10: 1cJIZ7e9-fcc8-461a-BeOI-lea\19b
From: z.chcouqhlin
Goble: "He is just getting super aggresive witb us, grabbed my phone, 1 swear_ and he
will not give it back ... He grabbed my phone, I swear. its in his pocket, dude ... [was
right here. my.Jeep was right here, my fucking Jeep was right there!".
However, Duralde's Narrative reports:
J
1
"
'i
1
1
:
j
I
I
,
,
"1 left COl:OHLIN witb Officers ALAKSA and ROSA so tbat I could continue
with my investigation. Next I spoke to the victim, Cory GOBLE who stated tbat
he has an Apple iPhone tbat he had bou2ht a coogle of years ago for $300.
(,JOBLE had set his phone down 011 a concrete wall in the pla7.a at and was
skateboarding approximately 15 feet away from it.

('JOb Ie, at least according to the version Goble relayed to Offic(''f Duralde, had set his phone
10
down and was only 15 feet away trom where he set it... However_ if that were true, then why didn't
Goble claim the phone from the unidentified man when, as admitted by Zarate and Goble's
12
associate Nicole Watson, the man held the iPhone aloft and loudly proclaimed to those in the skate
13
plaza that he would take the iPhone and "throw it in the river" if someone did not claim it
14
-c
immediately? Could it be that Goble was not a mere 15 feet away. bm rather, was off in his Jeep
10
doing something tbat sufficiently distra~ied his attention from the iPhone he apparently abandoned
on a slab of dOVlntown Reno concrete'! Did take over 90 seconds for Goble and his two associates
18
to approach Coughlin? Did Goble really "run" after Coughlin and ask for his phone back, or did
1,
Gohle gather two belligerent, menacing associates to approach Coughlin in a group of three
2(;
21
::::3
24
27
28
demanding to see what was in Coughlin's pockets?
COUNT TWO:
NRS 205.275 Offense inyohing stolen property: Definitjon:

IMlnaity; !'e$titutjon; prima facie evidence: determinatiOll ofvalne
of property,
"L A ~on commits an offense involving slolen property if the

person, for hIS or her own gain or to prevent the owner from again
possessIng the owner's property, buys. receivl'S, possesses or
withholds property:
(a) Knowing tbat it is stolen property: or
- 22/32 -
PRE-TRIAL BRIEF, MOTION FOR SUMJ..1ARY JUDGMENT
,To,
I
1
9-lHl
5:17...
p, 24 01 JJ
(b) Under such circumstances as should have caused ..
reasonable person to know that it is stolen property",

",6, For the purposes of this section. the value of the property
involved shall be deemed to be the highest valu~ auributable to the
property by any reasonable ,,1andard,
flOO' zachcoDqhlln
1,31?le9-lcc8-461a-geDI-lea55~b
7, As used in this section, "stolen property" means property that

has been taken from its owner by larceny, robbery, burglary,
embezzlement, theft or any other offense that is a crime against
property, whether or not the person who committed the taking is or has
been prosecuted or convicted for the offense."
6
7
'The Complaint does not allege any facts to suggest that Coughlin knew or should have
9
known the iPhone to be "stolen property", No probable cau.~e. lbere is nothing in the Complaint to
suggest the iPhone was given to Coughlin by someone whom had "stolen" it or that Couglin
]1
"received" the iPhone from someone whom had stolen it. It almost appears that the District
12
Attorney is seeking to
1j
SuflicienCY of indictment Trial court did not abuse its discretion in dismissing without
15
16
prejudke, 011 grounds of lack or specificity. indictment of four defendants for theft in connection
with gold recovery investment offering, though arguably indictment could be read as alleging theft
]7
by material misrepresentation. as indictment lacked specificity with regard to which defendant

18
19
allegedly made which misrepresentation, and State had been rep~atedly told its charging documents
:10
were defective or vague, N,R,S, 173,075,205,0832(3), State v, Hancock, 1998,955 P,2d 183, 114
21
Nev, 161.
J)DA Young makes no allegation that the unidentified man whom threatened to take the
24
jPbone and ''throw it in the river" "stole the iPhone, Otherwise, it seems DDA Young is suggesting
Coughlin 'commits an offense involving stolen property if the p.:rson, for his or her own gain or to
26
prevent the owner from again possessing the ovmer's property, buys, receives. possesses or
withholds property" from himself, rather than the unidentified man. However 205,275, also
28
- 23/32 -
PRE-TRlAJ, BRIEF; MOT10N FOR SUM.'\fARY lUIX,M/;'t<T
From: zachcoughlln
To: lc3flle9-fcc8-161a-8eOf-lea559b
8-19-11
5:17am
p,
15 of 33
I
I
requires that Coughlin did so: '. (0) Knowing that It is stolcn property; <IT (b) Under such circumstances as
should have caused a reasonable person to know that it is stolen property."
DDA Young's Amended Complaint provides no support in any way to suggest that the
4
unidentified mall stole the iPhone, Indeed, Nicole Watson admits the man notified the individuals
congregating in the skate plaza that he wished to see someone claim the iPhone, There certainly is
not support for. nor has there been any suggestion that this unidentified man "stole" the iPhone, So,
that leaves DDA Young to suggest Coughlin "stole" the iPhone, then "received" or "bought" the
iPhone from himself. That is just too tortured an approach, DDA Young must simply seek to
'I
10
1
convict Coughlin of petit larceny under those circumstances,

Actually, the indictiment and Complaint is insnfficient here, as absolutely no facts are
J3
alleged or set forth to flesh out each of/he elements of an NRS 205.275 possession of stolen
14
property charge, DDA Young has a duty under the Rules of Professional Conduct to mak~ sure
1S
16
17
18
19
there are such facts alleged:

Nevada RPC Rule 3.8 Special Rcsp()nsibilities of a Prosecator.
prosecutor in a criminal case shall:
"The
(a) Refrain from prosecuting a charge that the prosecutor knows js not st!Ilported
by probable cause;"
DDA Yuun:'s Dttember 5th. 2611 Amended CllIIlplaint reads:
2J
"COUNT II. POSSESSION OF STOLE~ PROPERTY, a .;olation of}./RS 205.275,

a misdemeanor, in the manner following, to wit:
23
24
26
28
That the said defendant on or aooul the 20th day of AuglL~t, 2011, at Reno
Township, within the County of Washoe, State of Nevada, did wID" and
~~wfuQy p _ or withhold stolen goods having a value less than Two Hundred
Fifty Dollars ($25?OO)..N.lrlt: an iPhone, al or near I North Center Street, Reno,
Washoe County, Nevada, such property ~ing owned by CORY GOBLE, for his own
gam or to prevent tbe true owner from again possessing said property, knowing thai
the property was obtained by meanS of larceny or under sud! circumstances as
shook! have caused a reasonable man to know that such goods were so obtained.
- 24/32 -
PRE-TRIAL BRIEf; MOTION FOR SUMMARY JUIlG.\1B'NT
,To: lcJflle9-fcc8-l61a-8eOf-lea559b
'r.. : "chcoughll.
8-<9-11
~:11""
p," of"
However, as ShO,,"11 above, DDA Young's Amended Complaint simply fails to

2
3
specdY in any way whatsoever whom "stole" the property or how Coughlin "knew" or under
what circumstances Coughlin "should have known that such goods were so obtained" by
1
j
1
]
"larceny", It is prejudicial to allow such a deficient Amended Complaint to stand.

6
7
8
9
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11
12
J3
\4
IS
16
17
18
19
20
21
24
"Bernier was ordered to stand trial for possession of stolen property, a

violation of ~RS 205.275, Bernier then petitioned for a writ of habeas corpus
contending the evidence adduced by the prosecution WlIS insufficient to establish
probable cause that she had committed the charged offense. The district court
considered and denied her petition and Bemier here reassertS the same contention,
Bernier does not deny having possessed the property; rather, she argues the proof
did not sbow that she knew the property was stolcn and that such knowledge
cannot be inferred from mere possession. We agree that mere possession is
insl1fficiL'tlt to establish the requisite knowledge; however, possession is a fact
which may be considered with all other facts by a reasonable pel1\on in
fonnulating a strong su~picion that Bernier knew the property was stolen. See
Staab v, State, 90 Nev, 347, 526 P.2d 338 (1974)" BERNIER v, SHERIff,
CLARK COUN1Y, 569 P.2d 406 (1977),
"Wiechers was ordered to stand trial on ...NRS 205.275 ... he contends ...
the state failed to produce sufficient evidence to establish probable cause that he
committed the charged oft\mses. We agree .. " restitied that at no time did they tell
Wiechers thal the engines were stolen. The record shows the lestimony... was
given in exchange for the prosecutor's agreement, inter alia, to afford them partial
inununity and other special considerations. 'This record is bruTen of any inference
or suggestion that Wiechers was implicated in any manner in - or with - the
Volkswagen theft ring; and, in fact, it ailinnativc1y shows thal he bad no
knowledge that the engines had been stolen. I See Staab v, State, 90 Nev. 347, 526
P.2d 338 (1974). Furthermore. Wicchers paid for the stolen engines in the
ordinary course ofbu~iness with his "regular" business checks. This conduct
alone appears to us to be inconsistent with the state's argument that Wiechers
knew of and participated in the charged criminal activity, Accordingly. we
conclude the state did not meets its burden of showing probable cause, as required
by, WIECHERS v. SHERIFF, WASHOE COUNTY, 543 P,2d 1347 (1975).
Similarly, Coughlin himself called 911, Nothing on the tape of the arrest Can be said to
demollstrate Coughlin refusing any instruction of the RPD, Rather, Coughlin asked a Socratic style
question and the RPD officer told Coughlin to stop talking. COhghlin would have been subject to a
;:>8
- 25/32 PRE-TRIAL BRIEF; MOnON F()R SUM,\1ARy lUDGMEl--,'
,To: 7c3f":e9-fccBl67a-BeOf-7ea559b
From: zacOcouqhlin
8-2912 5tllaa p, 27 of 33
disturbing the peace charge had he failed to lollow the Oftker's instruction. There i. simply no
evidence to support any of the elements of the crime charged conclusively.
!
I
Staab v State, 90 Nev. 347,350,526 P.2d 338, 340 (1974): "11 is the fact of
possession that provides the inference of guilt, an inference which is founded on the
manifest reason that when goods have been taken from one penon and are quickly
thereafter fOood in the possession ofanother there is a strong probability that they
were taken by the latter. State v. Young, 217 So.2d 567 (FIll. 1(68). Weinstock's
prior oWlWnhip was clearly established and Staab's possession under aU
circornstances raised the inference of guilt that was left ulW"plained."
The iPhone was not taken from C'JOble. Regardless of which of the venions Goble gives that
you go by (in his 911 call he says he was in his Jeep, which was "right there", while in his Witness
Statement he indicates he was standing about 15 feet away from where he set his phone down), it is
11
12
13
clear that the phone was not "taken from" Goble. Zarate, according to Duralde Supplementary
Declaration says the phone was grabbed from the ledge, but then Zarate, in his Witness Statement
says the phone was given to Coughlin by the unidentified man, tbe same man Nicole Watson admits
on the tape of Augu,t 27th, 2011 that she heard and saw hold the iPhone aloft and threaten to "throw
16
it in the river" if someone didn't claim it immediately (on the video, Zarate is then seen pulling
.17
18
Watson aside, walking her away from the camera, and, seemingly, dissuading her from further
19
undermining Zarate's credibility with her own statements, which are a vast departure from Zarate's
20
to the RPD).
21
1
24
26
Dutton v. State. 94 Nev. 461, 581 P.2d 856 (1978): "Here Dutton claimed
he did not personally possess the stolen camera, and did not haw specific
knowledge that it was stolen. .. We therefore perceive no error by the district court
m adml~mg the evidence to show both the circumstances surrounding the
transactton, and Duttoo's knowledge of the stolen character of the goods. 2.
Dutton next claims the evidence was insufficient to sustain the convi(.1i91!, .
because the State failed to prove he knew the Carnllr!! WaS stolen, .. .In order to
sustain a c{)n~ictiOll for possession of stolen property the State must show: (1) the
propertv was In ~act stolen, (2) the property was possessed by the accused with
knowledee that It Wl!S stolen at the lime ofpossession, and (3) the property Was
[!9Ssessed bv him WIth the f;ehmious intent of depriving the tme owner of the
property.... "Knowledg~ that property was stolen can seldom be proved by direct
- 26/32 -
PRE-TRlAL ltlRlliF: MOTION J'()R SUMMARY JUOOMEl'IT
,To: lc3fl;.9-fccS-I'1.-SeUf-l 559b
,
I
I
I
j
1
,
1
2
3
lrOll: HtMtlIlghl1n
8-19-11
5:11..
p,
28 of lJ
evidence and resort must often Il<l made to circumstantial evidence .... There is
abundant corroboration in \he instant ca..e: the camera wa.' sold at a grossly
inadequate price; Dutton engaged in furtive conduct in negotiating with the
undercover officer. he knew the dealer was a fence: and conflicts were present in
his testimony dealing with his reasons for corning to Acme."
Similarly, Coughlin himself called 911 reporting the violent. threatening, and menacing
1
,
behavior of Goble et al. Nothing on the tape afthe arrest can be said to demonstrate Coughlin
refusing any instruction of the RPD. Rather. Coughlin asked a Socratic style question and the RPD
8
!)
10
1i
officer told Coughlin to stop talking. Coughlin would have been subject to a disturbing the peace
charge had he failed to follow the Oft"icer's instruction. There is simply no evidence to support any
of the dements of!be crime charged conclusively. To say Coughlin's inquiring as to whether he
might have any Constituional right to refrain from opening his pockets to any police officer whom
12
1-'
might like to see what are in them. regardless of how shaky and inconsistent the supposed
14
statements supporting the probable cause are (nobody is talking about how a man "socked a minor"
10
now, or even upon the arrival orthe RPD ...Zarate et aI's staternent~ are rife with inconsistencies, as
16
are the tapes of Goble's 911 calls, etc.
18
lJ
SUPPRESSION MOTION
What seems clear from reviewing Officer Duralde's Narrative in his Arrest Report is a clear
retaliatory bent by Duralde to take revenege upon the lawyer who would dare suggest a detainee
21
might have some sort of rights and thal there exists some actual standard the RPD must meet prior to
conducting a search incident to arrest. That Narrtive reads:
24
?7
28
"I contacted defendant Zachary COUGHLIN, who fit the description of the
suspect and was pointed out by the people in the group. I told him that ifhe had
someone else's phone that we might be able to settle the i~sue by him just giving
the phone back. COUGHLIN replied by saying that r did not have enough
~formwon for a Terry stop. I told COUGHUN that I did have enough
mformallon for a Terry stop and asked him again ifhe had the phone.
COUGHLIN !ben a.~ked me if he had the right to not answer my question and I
tnfo~ed hun thai he did have that right CQUGlILIK Was wearing baggy
dothlllg thai could conceal a weapon according to my training and experience.!
- 27/32 -
PRETRIAL BRIEF; MOTION FOR SUMMARY JUDGMEN-r
From: zachcoughl1n
,To, ltlf1.1eHcc6-461a-8eOf-7eaS59b
'J
8-19-11
5:17am
p, 29 of 33
then asked COUGHLIN to stund up and move away from the group of people that
had been detaining him, COUGHLl~ complied and I perfonned a pat search for
weapons,"
As the video of the arrest demonstrates, Coughlin Wlls actually wearing a thin t-shirt and a
thin pair of white and blue plaid summer shorts with only the typical one pocket per side, Not cargo
6
shorts, just thin white cotton with blue plaid regular old guy shorts, So, in other words, Officer
!
I
somebody anytimes he feels like it (especially if the suspect tries to suggest he might have some
Duralde's "training and experience" teaches him that he can pretty much justify patting allover
"rights"), as long as Duralde makes mention of the "haggy clothing" the suspect had 011, and the
"baggy clothing that could conceal a weapon according to (his) training and experience" , A similar
1.1
12
gaming ofthc system is revealed in Duralde overcharging Coughlin for a felony, for a three and a
13
half year old iPhone that was barely worth $300 new, and which would have only been worth
::'4
approximately $65,00 at the time ofthe arrest assuming it was ill good condition and would come
1S
17
18
19
20
21
22
with a short warranty upon pW'cbase, which is not clear at all.
NRS 171.136 When arrest m.a,y be made:

" L If the offense charged is a felony or gross misdemeanor, the arrest may be
made on any day. and at any time of day or night,
2. If it is a misdemeanor, the arrest cannot be made between the bours of 7 p,m,
and 7 a.m" except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is commifftd in the presence of the arresting
officer,...
(d) Wben the offense is committed in the presence of a private person and
the person makes an arrest immediately after the offense is committed;
23
It would he inaccurate to suggest Goble et aI made a citizens arrest The video from just
2S
prior to the RPD arriving demonstrate (as do the RP D dispatch records) that Coughlin himself made
a 911 call and. on the video, Coughlin is heard suggesting everyone relax and wait forthc police to
arrive in a peaceful approach to resolving the situation, 'I hat being the case, Officer Duralde (and
- 28/12 -
PRE-TRIAL BRIEF; MonON FORSUW,o!ARY JUDGMEJ:iT
10: 7c3f~.9-fcc8-167a-8.0f-7ea559b
From: ,achcouqhlin
8-29-12
5:17a.
p. 30 of JJ
this is belied by the smug commentary he made to Coughlin indicating as much) was left
overcharging the crime (by inflating the value of the iPitone) sufficient to make a felony charge,
thereby overcoming the problem with the fact that, as it wa~ after 7 p.m., and the alleged offense
4
!
1
I
was not "committed in the presence of the arresting officer", Officer Duralde would have otherwis~
been able only to issue a citation, rather than conduct a search incident to arrest and a custodial
"!
arrest (much less inflate Coughlin's bail and cause Coughlin the greater embarassment of a felony
arrest on his record, all added benefits to charging Coughlin wit/, a felony that Coughlin openly and
.1
l:
:
smugly remarked on to Coughlin. But, Officer Duradle's clever gaming of the system
wa~
not over
lC
yet :'-iext he attempts to excuse his failure to countenance any of Coughlin's complaints of assault
j
l~
and battery by the group of aggressive youths, while weaving in a "citizen's arrest" rationale that no
13
one else had managed to suggest at that point, certainly not Goble and his friends. ActnaUy, Goble's
:!..;
911 calls says just !be opposite, ie, that Coughlin "is being super aggressive and given us all sorts of
10
trouble". Duralde's Narrative continues:
'
_0
17
is
- ?
L
2C
'
..
-- -
"As I checked COUGHLIN's left front shorts pocket, he yelled loudly that I had
just grabbed his penIS. I could feel an object resembling a phone in the pocket but
not a penis. As COUGHLIN was trying to make a scene and was vel)' hesitant
to follow the dirediO!!s that I was giving hlm, I placed him in handcuffs.
Officers ALAKSA and ROSA were there with me at that time.
Duralde never gets around to mentioning, specifically. just how and about what Coughlin
was being "very hesitant to follow the directions that" he was "giving him". Just exactly how was
22
Coughlin "being hesitant". If a detainee has a problem with an Officer's bare hands touching the
:23
,;4
skin on his penis, does that mean the detainee is "trying to make a scene"? Apparently this being
;2f)
"very hesitant to follow the direction" Duralde was giving Coughlin was alarming enough to jlL~tiry
26
DlIl'adle then placing Coughlin in hand cuffs, approximately on~ minute into Duralde arriving on
27
the scene. Officer Duralde fails to mention in his Narrative what the videolaudio of the arrest
28
- 29/32 -
PRETRLr..L l3RIEF; MOTION FOR SUMMARY JUDGMb;-.IT
,10:, lc3f.le9-fcc8-461a-8eOf-lea559b
From: zachcouqblln
8-29-12
5:11am
p. 31 of J3
demonstrates occuring at this time, ie, that Coughlin, at the 3:45 minute mark of the 5 minute 17
,
I
I
,
!
second video of the arrest can be heard a~king the RPD "do you have the right to be going through
my pockets right now,!". This "going Ihrough" of the pockets would have been occurring while
Coughlin was handcuffed (as indicated in Duradle's report, but still only being "detained". So,
.,
of their pocket< (not just manipUlating the exterior oftheir clothing under some tortured application
\
I
of the "plain fee'" doctrine) without that being, technically. a "search incident to arrest". Duralde's
i
,
')
according to these officers, one can be handcuffed and have the police going through the contents
Nantive continues on to demonstrate Duralde seemingly reading a physical injury element into the
10
crime of assault (rather than just mere apprehension of immediate and substantial bodily harm) in
11
12
demang that Coughlin provide some proof of physical injuri.:s to Duralde before Coughlin's
13
allegations regarding the misconduct of Goble et al would be given anywhere near the attention
24
Goble's allegation where being given by Duralde at that time. Goble, however, did not trouble
15
Officer Duralde with any pesky allusions to onb Constitutional Rights, so, perhaps. that could
16
explain the seemingly differing standards of proof Officer Duralde applies to allegation presented
17
18
19
20
21
22
::::3
24
to him by disputing parties::

"COUGHLIN then stated thai he bad been " ..... ulh:d by the group of people who
were with the victim. I asked COUGHLIN if he had any injuries to suhstantlate
tilt clajrn and be stated that he did not I then infonned COt:GHLIN that they
bad ~al authoritY to detain hlm as he had been ohseryt:d taking the pbone.
COUGHLIN continued to say that be wanted to press charges for assanlt against
the people who had detained him."
What is interesting is that Duralde does not find Coughlin "had legal authority" to press
charges against those who assaulted him as they has "placed him in imminent fear of substantial
~S
:6
;::7
28
bodily harm". even though Coughlin had "observed" them doing so. It just seems like, once one
invokes any sort of Constitutional Right, RPD Officers of Duralde's ilk get exceedingly clever in
excising any sort of rights one might wish to assert from those available to anyone who doesn't so
- 30/32 -
PRE-TRl".!. BRlEF; MOTION FOR SUW"IARY JlJ1XJ~1ENT
From: l.chcoughlin
,To:, 113fl}eHcc8-467a-8eOf-lea5S9b
a~sert
8-19-12
5:17..
p, lZ 01
a Constitutional Right at some point in the interaction. And thaI is textbook retaliation.
Retaliatory arrest. Retaliatory prosecution. Duralde's Narrative continues:

3
6
7
8
9
](
11
12
"lleit COUGHLIN with Ofticers ALAKSA and ROSA so thaI I could continue
with my investigation. Next I spoke to the victim, Cory GOBLE who stated that
he has an Apple iPhone that he had bought a cOlIDle oCyea!'S a:.o for $300.
GOBLE had set his phone down on a concrete wan in the plaza at and was
skateboal1liD: approximatelY 15 feet away from it. GOBLE's friend, Nathaniel
ZARATE, then infonned him that COlJGHLIN bad biB walked bv and taken
GOBLE's phone... I next spoke with ZAR'\ TE who confinned that he had
observed COUGHUN take GORM),'s phone from where GORLE bad set it
!I!!l!n. and then observed COUGHLIN put it in his left tront shorts pocket. I
obtained GOBLE's cellular phone number and called the number from another
phone. I heard a vibrating noise coming from COUGHLIN's left front pocket and
touched the outside of his shorts where I had previously felt the phone 1 oould kel
the phone vibrating. I then stopped calling GOBLE's phone from the separate
phone and the phone in COUGH LIN's pocket slopped vibrating. I then placed
COUGHLIN under arrest for Grand Larceny. as he had taken the property of
another person valued above $2 50."
CONCLUSION
is
16
deciding upon thill matter.
17
18
19
A}<'FIR\tA'fION AND DECLARATION
I dedare, pursuant ro NRS 53,045, IDlder penalty of perjury IDlder the la'll! of the State
of Nevada that the foregoing is true and eOlT<'d and that this document does not contain any
social serurity numbers, pursuant to IS RS 239.030, an amnnation to that effect this hereby is,
22
DATED this 28th of Augu.~t, 2012:

2S
28
Zach Coughlin, Esq.

Defendant! Co-Counsel for Coughlin
- 31/32 -
PRE-TRIAL BRIEF: MOTlON FOR SUMMARY JUDG.\iliI'T
JJ
From, zachcouqhlln
To"lc)f2Je9-fcc8-4ti1a-SeOf-leaSS9b
8-29-12
\;11..
p.
33 of 31
PROOF OF SERVICE
2
On this date, I caused a copy of the foregoing document s to be served upon the following by
sending to their registered email address and fax number as found on www.nvbar.org. hand delivery
to dropslot or front desk, and by placing a true and correct copy of the foregoing document in the
'I
Zachary N. Young, Esq.

Washoe County DA
I South Sierra P.O. Box 30083
Reno, NV 89520
9
Phone Number: 775-3283200 Fax number: 775-3256703

Email: zyoung@ida.washoecounty.us
1G
11
12
13
Jim Lelsie, Esq.

P.O. Box 30083 Reno, KV 89509
Phone Number: 7753374868 Fax number: 775-337-4856

J5
16
BarNo. 4925
One California Ave
Reno, NV &9509
(775} 337-4800
Attorneys for Defendant
18
19
].()
21
Zach Coughlin, Esq.

2j
75
28
- 32/32 -
PRETRIAL BRIEF: MOTION FOR SUMMARY JUOO~J
~T ..
kll'21e9-fcc8-461a-8eOf-lea5S9b
,{ X"J,
FrODl: zachcoughlln
FACSIMILE
[)ate:
8/29/2012
To:
From:
7c3f27e9-fcc8-467a-8eOf-7ea559b45d5bgeneral693298
zachcoughlin
Subject:
Pre-Trial Statement/Brief
8-19-11
S: 17""
p. 1
of JJ
Case No.
FILED
"RCR2011-063341
Department No. _ _2_'_ _ _ _ __
12 AUG 30 AM fO: 06
Slr:!;~
TtJTT:'E
"RENO JU::> neE COURT
IN THE JUSTICE COURT OF THE STATE ~~o#o4pA~_

IN AND FOR THE COUNTY OF WASHOE - . \ ")
Plaintiff,

OF PROCEEDINGS
VS.
Defendant.
--------------------,
The
Plaintiff
Zachary Coughlin (o:>urtesy ropy per Judge Sferrazza)

Name
P.O. Box 3961
Add"",
Reno, NY 89505
CIty, State, Zip
,(775) " 338-8118

Contact telephone number

FIL.ED
1 DA#432068
12 SEP - 7 AM 9: 56
Sl EVe: ", Vi ~ LE
B:EHa.tT~
3
4
nmm

Plaintiff,
8
9
10
vs.
Dept-No.2
II
Defendant.
12
Case No. RCR2011-063341
------------------~/
13
ORDER FOR COMPETENCY EVALUATION PURSUANT TO NRS 178.415

Upon motion of counsel for Defendant herein and good cause appearing
14
15
therefor,
16
IT IS HEREBY ORDERED that the Defendant be examined by a psychiatrist or
17
other person Who is especially qualified by the Division of Mental Health and Developmental
18
Services of the Department of Health and Human Services pursuant to NRS 178.417, for the
19
purpose of determining:
20
21
1.
If the Defendant is not of sufficient mentality to be able to understand
the nature of the criminal charge(s) against him;
22
2.
If, because of mental insufficiency, the Defendant is not able to aid and
23
assist counsel in the defense interposed upon the trial or against the pronouncement of the
24
judgment thereafter and if the Defendant is able, if he chooses to assist and cooperate with
25
counsel.
26
1
IT IS ORDERED that the Defendant is to appear for the mental health

evaluation and cooperate with the evaluator on the date and time set for said evaluation.
IT IS FURTHER ORDERED that the evaluator should review all pnor
evaluations in conducting the examination pursuant to this Order, in particular, the actions of
the Defendant at the Nevada Adult Mental Health Services and his conduct in the court during
the several proceedings that he has been involved in.
IT IS FUTHER ORDERED that the Defendant is to appear before the
Honorable Peter J. Sferrazza of the Reno Justice Court, Department No.2, on the 15 day of
October, 2012, at the hour of9:00 a.m. for a competency evaluation hearing.
10
DATEDthiSBYOfseptemb , . 2.
th
~#-?-7
11
12
13
14
15
j
j
I
I
1
I
I
I
I
16
17
18
19
20
21
22
23
24
25
26
.
2
3
4
age, and not a party to the within action, and (b) that affiant served a copy of the attached on the
6
8
9
10
II
12
Name:
Address to which
mailed/delivered:
13
14
September 7, 2012
15
16
17
18
Name:
Address to which
mailed/delivered:
19
20
September 7,2012
21
Zach Young, Esq.

P. O. Box 30083
Reno, NV 89520
James Leslie, Esq.
P. O. Box 30083
Reno, NV 89520
22
23
24
Name:
Address to which
mailed/delivered:
25
26
September 7,2012
Zachary Barker Coughlin

P. O. Box 3961
Reno, NV 89505
CaseNo.7ol\ -
6JJ L{{
FILED
Department No. __
'7....-...b~_ _ _ __
12 SEP 12 M1 9: 47
STEVE TUTTLE
In the Justices' Court of Reno TownshW~.~G~~

County of Washoe, State ofNevada~fPUiY
******
Plaintiff,

OF PROCEEDINGS
______________________
~I
The
Plaintiff
Defendant has requested an audio copy of
proceedings of the following:

1)
Hearing Date
2)
Hearing Date _ _ _ _ _ _ _ _ _ __
3)
Hearing Date _ _ _ _ _ _ _ _ _ __
City. State. Zip
)) 1J~ j ,<t"-(p~ I '" t::'c<~~,v-f>.- ir:e~ve.f- ~~::~t

{.k.p
.
.~ <?""""'
;;, +- Cj.k-.
~ fee due at time of request. Please provide' 'mailing add'r~ss if you wish to .
y
have the CD mailed to you.

Call (775) 325-6575 with any questions.
. FILED
Case No. RCR20H-063341
12 SfP 17 AM 10: 52
Department No. _ _2;..'_ _ _ _ __
STEVe.:
ruTil,
RENO ,)!/SJ!CE COURT
BY [....,
,-t:e.-<.>-JlS--
IN THE JUSTICE COURT OF THE STATE OF NEWAllA

THE srATE OF NE\W)A
Plaintiff,

OF PROCEEDINGS
vs.
Defendant.
------------------~I
The
Plaintiff
1)
Hearing Date
3)
Hearing Date
4)
Defendant has reqnested an audio copy
9/5/12
Hearing Date
2)
Hearing Date
Date _____Se~~~_II_e_r_1_7_________~,20 12
J~ leslie, Deputy Public Oef~

Name
Oty, State, Zip

Contact te1ephone number

Please indicate if yon wish to have the CD mailed to yon.
FILED
Case No. Rffi2011-063341
12 SEP 17 PM 3: 13
Department No. _ _..;;;2_ _ _ _ __
Sic VC TUTTLE
diE~D~1;lORT
{ ...
IN THE JUSTICE COURT OF THE STATE

6->.
<;,
'lliE STATE OF NEVADA
Plaintiff,

OF PROCEEDINGS
vs.
Defendant.
----------------------~/
The
Plaintiff
1)
Hearing Date
7/16/12
2)
Hearing Date
8/29/12
3)
Hearing Date
4)
Hearing Date
Date
Septanber 17
,20 12
Jarres Leslie, Deputy Public Defender

Name
Add ....
City. Slate, ZIp
CQntac:t telepbone Dumber

Call (775) 325-6575 if you bave any questions.
_.
Hl/t!2/2B12
tiS: 28
PAGE
LAKES CROSSING CTR
775&881985
Ill/Be
......
-
a.JIIaIM I
........-
IIILD..'"
.........................
......
FAX TRANSMISSION SHEET

DATE~:__~1~O~~~ln~O~1~2
______________
NUMBER OF PAGES _ _ _-.!8!--_____ (Including Cover Sheet)

.Judge Peter Sferrll:lZa
FAX#_~3~2~S~~S9~1--__
Jim Leslie. Esq.
DOCUMENTS SENT TO:
FAX# ___3~3U7~4~85~9~__
Zilch Young, D.D.A.
FAX # _-,3~2oil:5-:!!.67.!.!!O~3_ _
FAX# ________
DOCUMENTS SENT FROM: _.-.!S;!!b!!!!a!!...r.!!M!!Il!l'yed!i!!!!a_ _ _ _ _ _ _~_ _

PHONE NUMBER: (775) 688-1900
_~E,"",xt!.o..!;22!:1t,--_ _ _ _ _ __
.
SUBJECT OF DOCUMENTATION:
Zacbary Barker Cougblin \

,
Case # RCR-2011-G63341
COMMENTS:
CQNflDENTIAUTY NOTICE
The d~u"c.'" ac.tompa.YI1l2 IhM. ttlttoJ' trJIa$Mil,lon Coftta'n CONfIDENTIAL INFORMATrON hfloJl.glnr: tr.I the Mndtr thllt Is lepU)' JWwikl;,cd.
The ItI(n".ati01ll "in.ended eml, ror the un of lilt In,lIV1dul. lOr C!nblJ lined .b....c. If YOu aft nOl (lIe: iDtcntkd rlpicnt. yfllil art lit.... l'iorifitd Ihlll _..,
di'u~IoJ.. n:. cl)'Pyial!. di,trifJution. u.. t nr hike. Dr:lllY KhOQ rdfl.rr nn die ((Jnftdll of fI,l .. tclcco,.ed CONflOtNTlAL INFORMATION ;, Jrridlt
prnhibi,e~ (Fed. Ret'. 4lent Pan I}. If YOII Int....(' 1'c:clfiVtd thl.'1 tel~nJJ) in tl"rnr. plein nntil, us by tdcphonlf Imnaltdillsly to arnt"".o rebl", of tbe
nris;no1' ftlOP), tr-allmiuloa.
lB/El2/2B12
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Cd., DIsea_ 0ffa6w
October 1, 2012
The Honorable Peter SferraZza
Justice Court ofReno Town.fhil'
P. 0. Box 30083
Rena, Nevada 89520-3083
RE:
(ase /'Jo"
ZochlJry Barlcer Coughlin

RCR-2011063341
i'
. .,
Dear Judge Sferri1=:

Pursuant to the above referenced court order dated September 7, 1012, Mr. Zachary
Darlcer Coughlin was evaluated by Tom Durante, LCSW IJ l He has found Mr. Coughlin
meets the criteria to be considered competent to proceed with adjudication. Enclosed
you will/ind a copy of the examiner '.' report.
If I can provii!e you with any further infor11llJtion please feelfree
~'CLl.A.
)to
~~I ~
th W Neighbors, Ph.!,..,.A'If,PDirector
/0
contact me.
...
EWN:sm
, :. ~~;~
Enel: Evaluation ofCompetl'ncy

ce.
-"
Jim Les/ie, E.~q.

Zach Young. D.D.A
( I
, ~
",
16/62/2612
68:28
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63/68
,
i
. . . . . ,. '''' .......... 011
fi
""'--
. . CM.WnI' .....
October 1, 2012
The Honorable Peler Sferrazza

Justice Court ofReno Town5hiJl
P O. Box 30083
Reno. Nevada 89520-3083
RE.
Zachary BQ~Jcer Coughlin
Case No.'
RCR-2011-063341
"
Dare(s) afService:
Person(s) P~~forming E~aluatiQ"M:
Rea.5Qn for Evaluation:
0912812012
Tom Durante. LCSW lJ /
Competency Evaluation
Amount 'iJrJe:
$170.00
."
~;
Make checle Payable To'

Lalee 's Crossing Center
500 Gaf/ell; Woy
Sparks. NV 89431
:-,
, "",
EWN:sm
cc:
Regional Business Office

, ."
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7756881985
64/68
NOT!:: Ttllt inror~atIof'l hal be"n dilcloved 10 yoU '10m

recOrds "holl confidantlallty ,!- protecd by '.~erallaw, Flct-
8"'1'8gIJI"llonl (42Cf:J:t Part 2) Pl'otl1btt )'011 from me1ttng A~
'tun"" dlselo.ufa af,1 \IiIithOull"e apee.t,c wrillan conlon!. of,'1'18
.,
.,:",. ..
,
perth 10 whom It petll,,,,, or aa oIMrw',. parrmllld Dy JiJct'I

regl,1I8110"", A ;.nera' a,,"'harl~.Uon lor ,he ,.I.a" of medical
or at)!ar Inrorrn!ttlon Ie NOT !.turtlclent fOr
PlJf1)Otl,
,ft"
Releosod
EVALUATION OF COMPETENCY
TO PROCEED WITH TRIAL
Name:
Case Number:
Date of Evaluation:
Dale of Report:
1oJ:::u:!1e,Thle .~arA:zl'A.
~ m l~lie, :EStj.
2ach~~.1)DA
-;

RCR2011063341
09/28/2012
10/01/2012
R!:ASON FOR REFERRAL:

Zachary Coughlin was referred for an evaluation of competency by Department
Two in the Justice Court of Reno Township in the County of Washoe for the
Sfate of Nevada. ,According to the Criminal Complaint, Mr. Coughlin is charged
with Petit Larceny, a misdemeanor, and Possession of Stolen Property, a
misdemeanor. The purpose r;f the evaluation is to determine 1) if the Defendant
is not of sufficient mentality to understand the nature of the criminal charges
against him and 2) if, becau:;e of mental insufficiency, the Defendant is not able
to aid and assist counsel in the defense interposed upon the trial or against the
pronouncement of the judgment thereafter and if the Defendant is able, if he
chooses, to assist and cooperate wilh counsel.
r ..~
"
LIMITS OF CONFIDENTIALITY:
The client was informed of the pLlrpose of the evaluation and of the limits of
confidentiality, He declinecl to sign the receipt of Notice of Privacy Practices,
however, he voluntarily agreed 10 partiCipate In the interview.
METHOD OF ASSESSMENT:
~
'.,:--
"
An interview of Zachary Coughlin at Lake's Crossing Center

th
A review of the Amended Criminal Complaint, dated December 5 , 2011
h
A revieW of Arrest Report, dated August 20 , 2011
A review of Transcript of Proceedings Report
A review of the client'r, records from Northem Nevada Adult Mental Health
Services
A review of the client's records from Lake's Crossing Cenler
HISTORY:
According to the Arrest Report, Mr. Coughlin is alleged to have taken a cell
phone off a concrete wall that was owned by the alleged victim, who was
skateboarding nearby and laid the phone down. It is also alleged that, when
confronted, Mr, Coughlin denied having the phone. It is documented thaI when
both the alleged victim as well as officers from the Reno Police Department
10/02/2BI2
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LAKES CROSSING CTR
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Zachary Coughlin
Case # RCR-2011-063341
Page 2
called the phone' number belonging to the cell phone, the phone rang insIde Mr.
Coughlin's pocket. Mr COu~lhlin was subsequently arrested and transported to
the Washoe County Detention Center
BRIEF SOCIAL HISTORY

The information for the soGial history was obtained chiefly from the client's
records. He reported that no major changes have occurred since his most recent
evaluationS from Lake's Crossing Center, completed in April of 2012, with the
exception of his livelihood as an attorney has been jeopardized secondary to his
'
various legal entanglements.
The client has reported that he was born in Washington State but he has lived in
the Reno area throughout most of his life. The client reported that his parents
divorced when he was 3 years old, although both remained involved in his
childhood and both remarried. The client has two full sisters and several step
siblings. Mr. Coughlin has ~tated that he was diagnosed with Attention Deficit
Hyperactivity as a child. The client graduated high school and earned degrees
through the University of Nevada, Reno, and the University of Nevada, Las
Vegas. The client reported that he earned his law degree in 2001 and proceeded
to focus on family law, employment, and civil rights issues. He has worked for
several law firms although has stated that he has had difficulty maintaining'
employment because of his "assertiveness and strong opinions". The client has
never been married but has described one significant relationship of four and a
half year duration. He has reported that the relationship ended in June of 2011
secondary to multiple stresses. He has had several prior arrests including
Trespass, Resisting Arrest, and Use of 911 Emergency System when No Actual
or Perceived Emergency Exists,
He has denied any significant medical
problems or history of having had a head injury.
As stated above, the client has stated that he was diagnosed with Attention
Deficit Hyperactivity as a child. He has reported attending counseling for
depression and anxiety while in college as well as after obtaining his law degree,
The client has been prescribed antidepressant medication and, most recently,
has been on Adderall tor Attention Deficit. The client has denied any past suicide
attempts and he has reported no inpatient psychiatric hospitalizations The client
..:
,
'~
',"
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LAKES CROSSING erR
Zachary Coughlin
Case # RCR-2011-063341
Page 3
has reported that he first drank alcohol in high school. His alcohol use increased
as an adult with "lots" of times of being intoxicated. Mr. Coughlin has reported a
history of attending Alcoholics Anonymous. He reported in April that he had
been sober since August of 2007. He denied street drug use.
'
MENTAL STATUS;
The client is 35-year-old, Caucasian male who appears to be approximately his

stated age. He was casually and appropriately dressed and his hygiene and
grooming appeared adequate, He walked with a' normal gait. The client
exhibited a full range of affect. He described his mood as "alright", a/though
admitted that he was frustratHd that he was referred for an evaluation He denied
any thoughts of harm to himself or to others, The client appeared dramatic and
anti-authority. His speech was goal directed. The client appeared to ruminate on
how he has been mistrealed throughout his legal difficulties but he was easily
redirected. The client's thoughts appeared organized. He was oriented to
person, place, time, and !iituatian. There was no evidence of psychotic
symptoms arid at no point during the interview did the client appear to be
responding to internal stimUlI. Mr. Coughlin indicated that his sleep and appetite
has been within normal limits, He appeared well rested and well nourished. The
client's immediate, recent, and remote memory appeared adequate. He was
able to follow instructions throughout the outpatient intake process.
He
discussed his recent evaluations by lake's Crossing Center's staff and recites
the names of prior evaluators. Comments about his history appeared to
accurately reflect historical information in his records. The client's abstract
thinking abilities appeared to be within normal limits. He reported that a dog and
a lion are alike in that they both "have four legs" and a poem and a statue are
alike in that they are "both works of art", He stated that "down is to YR as night is
to day', The client's proverb interpretation abilities appeared adequate as did his
test judgment. Mr. Coughlin. appeared to be of above average intelligence as
evidenced by his vocabulary and general fund of knowledge. The client
frequently questioned requests made of him (for example, the pat search by
security as required), b'ut was able to comply when informed of the procedure or
rule.
'.
PAGE
eb/eS
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LAKES CROSSING CTR
PAGE
07/08
NOTE: Tnls Inform.tlon ha, tI"n disC1o".d to yGU fro,"
record, whole co.,fldenll&IIIY is PfOIBclad by 'ed,ral law. Fe,,"

.,,1 regula""n, (42CFR Part l) prohibit 10U ham mlk1"t I'I'IW'
, ... rthlK dlKloSl.lfll of k w!thou' ,he , ...cifie wrlt'len ~"1lI of Ihe
Oerlon 10 ..whom ft petf8ins. or .. OII'1.,..",e pertrrilfM DV 'uth
regulallOl"lC, A gener.1 authorlze,'on lor th~ rei.... of rn$dlcel
or ottwr ""form.rlon ,. NOT suffldent tor ttllS P"fpoH
Zachary Coughlin
Case # RCR-2011-063341
Page 4
R'I...adlOJt.t:be.~..~ .
.::n~ Lt:'6/i ~J E.sQ,
~h ~OOl6.l)1>R.
COMPETENCY EVALUATION:
The client correctly identified his charges and provided what appeared to be an
accurate description of the allegations against him. He was aware that the
charges were misdemeanors and that a misdemeanor charge could be
punishable by up to 6 months in jail. Mr. Coughlin was able to identify the
various levels of charges and he was aware that a misdemeanor charge was less.
s'erious tl1an a gross misdemeanor or felony.' He was aware that the pleas
available to l1im included "guilty. not guilty, and no contest". He defined a guilty
plea as "admitting doing it (the crime)' and a plea of not guilty as "saying I'm
innocent". Mr. Coughlin stated that a plea of no contest is "not admitting guilt but
stating that the State probably has enough evidence against you", He stated that
if a defendant enters a not guilty plea, his case will go to trial. If he enters a guilty
or no contest plea, the defendant will be sentenced. The client stated that Ihe
defense attorney "advocates on your behalf" and the district attorney "prosecutes
the charges agaInst you".. Mr. Coughlin reported that the judge "weighs the
evidence", When queried <1S to the judge's role of protecting the defendanfs
rights and keeping control of the courtroom, the client did not disagree. Mr.
Coughlin identified himself as the defendant. He stated that a witness is
someone who can tEistify about the case". The client identified possible
witnesses in his own case. Mr. Coughlin defined the concept of probation as
"period of time after sentencing when there are cond.ilions on your behavior". He
identified possible requirements of probation as including "no drinking, obey all
laws, do what the court says". He defined the concept of plea bargaining as ha
negotiation or agreement; you avoid trial, plea guilty. or no contest to a lesser
charge". The client understood that if entering a plea bargain, the defendant
gives up the right to appeal or go to trial.
.
Mr, Coughlin was able 10 identify his attorney. Although he voiced disagreement
with how his attorney has handled certain aspects of his case, his arguments
were made in an organized manner and did not appear to be a result of
delusional content or other symptom of mental illness .. Mr_ Coughlin was able to
accuratety describe and demonstrate appropriate courtroom behavior. He stated
that if he had a question or comment during cour! proceedings he was to
"whisper to his attorney", Mr. Coughlin indicted that he felt that he could abide by
this process. He engaged in reciprocal dialogue throughout the competency to
stand trial evaluation.
t9/92/29f2 9B:2B
775GBB1~85
LAKES CROSSING CTR
PAGE
N01'E: This Inlorrra8,tu)/I h been disclosed fa 'you
08/08
'tom
reCOICU IjIfhOH conllcl."r,ahtv Is proteclfd by 'ecrllilral law Fao,

"r..' 'egvlll~on" (42CFA PMI 2) pn:ahlbit you 'r<m making any
rutlhtir dISclosure of IIl11flt",oul 'hi BpaCillC wrItten cona ." of If'Ie
peraon 10 tI1om It plnain!'. or otr'I.~r ptrm,u.d rtf SdCh

~1"lons. A gemnal ilufhorlUllon tor the '.I~ 01 maGIcal
or O'Ihar In1ol'm'tlon 18 NOT ,l,ItRe'8nllor INs purpoa.
Zachary Coughlin
Case # RCR2011063341
PageS
ReI._I~ 1.el~ ~1I227a ...

;Ji tr'l Le.sli t.'J .:;q .
ltJ,C.h ~.1)DA
SUMMARY:
It is this writer's .professional opinion that Mr. Coughlin currently meets the
criteria to be considered competent to stand trial. ' He was able to adequately
describe the charges against him. He was aware of the level of charge.' He was
aware'of the possible consequence if he were to be found guilty. Mr. Coughlin
identified the available pleas and described a basic understanding of the pleas.
He demonstrated a basic ul'1derstanding of the roles of the various courtroom
participants. He adequately identified the concepts of probation and plea
bargaining.
It appears that the concern over Mr. Coughlin's competency has 'been on his
ability to wor!< with his attorney in his own defense. It is this writer's professional
opinion that Mr. Coughlin also currently meets this criterion to be considered
competent to stand frial. Although Mr. Coughlin often holds strong opinions, his
thoughts and his approach in working with others does not appear to be the
result'9f a mental illness. At no time was there evidence of bizarre patterns of
thought that would suggest illness nor did it appear that he was unable to control
his behavior. As described above. Mr. Coughlin followed directions wtien
counseled that certain procedures of the evaluation process would riot be
compromised. He was able to engage in reciprocal dialogue. Mr. Coughlin
demonstrated these abilities and it appears that he can work with his attorney as
well as participate in the legal process appropriately if he so chooses.
Please feel free to contact me at 77~6881900, ext. 250, if you have any
additional questions or concmns.
-t,~"y~~
Tom Durante. LCSW
Clinical Social Worker III
td
10101/12
,,,,,
...
Case No. __RCR2 0_1_1-O_6_33_4_1_ _ __

__
2
Department No. _ _ _ _ _ _ _ __
12 OCT 23 AM g: I I
IN THE JUSTICE COURT OF THE STAf~~

THE srATE OF NEVADA
Plaintiff,

OF PROCEEDINGS
VS.
Defendant.
- - - - - -_ _ _ _ _--1
The
Plaintiff-..:.:.X_Defendant has requested an audio copy
1)
October 22, 2012

Hearing Date _ _ _ _ _ _ _ _ _ _ __
2)
Hearing Date _ _ _ _ _ _ _ _ _ _ __
3)
Hearing Date _ _ _ _ _ _ _ _ _ _ __
4)
Hearing Date _ _ _ _ _ _ _ _ _ _ __
Date _ _ _ _0ct0ber..:..;..;.....;...;..22..;..._ _ _ _,' 20 12
Linda Gray
Name
Public Defender's Office

Address
City, SIIte. Zip
Contact telephoDe number

IN THE JlJlIrEitCMURT OF RENO TOWNSHIP,

COUNty\jpoW1\SftOE, STATE OF NEVADA
2012 OCT 39 AM 19: 3~
f?=C
CitationNo._L=-_"_ _ _ _ __
Cas~~o. UP- '2<>11 ~a n Lf!

Department No. __<-_'=____
-'
vs
-;7
i
Defendant.
---'~='A..~r:~V\ _ _ _------'1
_
.
I
.]
lI
AUTHORIZATION TO REPRESENT
Z"'~ G~ )').1:,1) 5~;...J) ",l . n'''"9 ,l~"""~"?l''''

~ ,
10 :;= ~~
~!~' 7~~~~
m
I
hereby authOrize/my attrme;=:IS
c-< / :.>
S D,
at
q (
1-e1 Q j;.,..",.."., 'rioJ, ,ko, ., ",..., "')
the Court approve this authonzatlOn.
to UOj(~
~! Jl"",,, C\.to
7qckLr-',?'0(~~
DATED
If
~ ~Rlct;I/J.,,<---. I.{/ .If

'1i ( 'f" vP doe <..- -...-..;
~,
au hereby requ~st that
in this cas
.;;~~(~
7L",lJ.~ ~ 'Q/s~c4J..
DEFENDANT
1; o..pf ~"'~~(c~~
i
The Court has reviewed the foregoing AUTHORIZATION TO PI\RESENT. Pursuant to WS A. j
178.388,theCourt~ereby:
~-\
v,
.\A,.c ~rJ
eJl0:::/)-'7
<d ~c ~L" . \ ~!V"""<?_( . . ~.

's request. Derendanr o~ erea release<!'on his own recogruzance1<>1'(
t~hv/.J.d >;:/;
? 2:
e<:fY' .
Sr..-br'<? c. ~
approves Defendant
t-
C\ I {'-P",
'f'<"',y,/,q
C(
(C
IS
pending trial ifhe has not already been admitted to bail.
D' denies Defendant's request.
JUSTICE OF THE PEACE
RJC-60 (10102)
5'-{!... Lo'
C~.~(~s,
~<~:,
I!
"
FILED
1
2
3
4
5
20ll HOV - 7 Ali 10: 24
JEREMY T. BOSLER, BAR No.: 4925

350 S Center St 5th fl
PO Box 30083
Reno, NV 89520-3083
(775) 337-4800

Plaintiff,
10
11
CaseNo.: RCRII-063341
vs.
12
13
14
Dept. No.: 2
ZACHARY B. COUGHLIN,
Defendant.
__________________1
15
16
MOTION TO OUASH SUBPOENA DUCES TECUM
17
On November 6, 2012, I Biray Dogan, deputy public defender was served with a
18
subpoena by the above named criminal defendant's mother during a motion hearing. Currently,
19
I serve as defendant's attorney in an unrelated criminal case in RCR12-065630. That the
20
Subpoena Duces Tecum (attached hereto as Exhibit I), requests a "[c]opy of any and all cell
21
phone records (incoming and outgoing calls), text messages for cell number (775) 527-9440 for
22
the dates of 8/2012011 and 8/21/2011).'" Based on information and belief, Jim Leslie, Chief
23
24
25
26
I
i
1
, It appears that the defendant used a oopy of the Public Defender's subpoena duces tecum.
1
,
'1
i
Deputy Public Defender, defendant's stand by counsel in the above captioned matter has
already provided the defendant with the requested material.
The subpoena should be quashed because I do not possess the material requested in the
subpoena. See NRS 50.165. Moreover, I was not involved in any way with the above captioned
5
criminal matters pending against the defendant, and therefore have no personal knowledge. See
6
7
NRS 50.025. In sum, there is no good faith basis to serve myself with a subpoena in the above
captioned matters. NRPC 3.1.
Conclusion
10
For the reasons stated above, the defendant's subpoena duces tecum should be quashed.
11
AFFIRMATION PURSUANT TO N.R-S. 239.030
12
13
14
15
16
Respectfully submitted this
r!J
~ day of ~,2012.
JEREMY T. BOSLER
17
18
19
20
21
22
23
24
25
26
2
1
2
Reno, Washoe County, Nevada and that on this date I faxed, a true copy of the attached document,
addressed to:
Zachary Coughlin
949-667-7402
8
9
10
DATED this
~.
day of
N\J\\Q;\',,), QI, 2012.

r
~\~ibW~).s .
~e lb s
11
12
13
14
15
16
17
18
20
19
21
22
23
I
I
I
24
25
26
I.
\
i
j
:-.10, RCRII-06.1J.lI
!Jepl. "l'. 2
St:BPOENA DUCES n:ClJM
I" r HE JUSTICE COURT OF RE:-JO TOWNS! liP

COU,TY OF WASHOE, ST:\TE OF 1><EVADA
Till'S fA rIO OF
~E V:\DA,
/1'
Pbimitl
... .
vs.
/:\CHARY FlARKER COl'GHUN, Defendant.
B r;;e?~, lJJ.cl t:
((1
1'0:
FRO~I: ZACH COUGHLIN, ESQ, (Attorney temporarily suspended in Nevada self represented)
Pl'RSI.',\'<T 1'0 NRS 17n 15 WE COMMAND YOU TO APPEAR BEFORE:

Department 2
Reo" Ju'tj~e Court
One South Sierru Slre~t, Reno, :-Ievada

On
NOVEMBER 19TH, 2012

10 testify for the above-nallled Defendant
AT 8,30 AM IN D2, BEFORE HONORABLE JUDGE SFERRAZZA
!\\Y I'ERSOI\: FAIU:-.!U TO APPEAR :vIA Y BE HELD IN CONTEMPT OF COURT

ACCORDING TO NRS 22, I 00 THE. PfNc\LTY FOR CONTE:VIPT OF Cot!RT IS A
FINE liP TO $500 AND/OR 25 OA YS IMPRISONMENT,
Dated:
11/6/12
Zach Coughlin. Esq. (suspended attorney) If }OU have an} questiuns

1471
regarding your appeamnce, ple.ase

comact: Zach Coughlin at
e, 9th st.
reno, 99512
B:'
949 667 7402
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
tel and fax, 949 667 )1402 ZachCoughlin@hotmail.com
COL"'!'V OF \VAS flOE
) ss,
)
**.
1....
'. ,"cd thh SUbpOCllil 0))

T~ ~ ~llhc:k>ettfi~!l at' _
---c-~~k3~~~~_ _ _ "
by dd~cri!lg" copy of this Subpoena Ie>
.o~ by
complying with the mailing requirements found in ,NRS 174.345
I
I
_il
or mailing it f)mc
11/6/12
Slgnatur of .-\tt~rnl;") (suspen ed
attorney}
Date
."------.-
~l.L1JJlOE:--;,\ DUCES TECUM: ITEMS TO BE I'RODlX'ED' Copy of anI' and all cell
pilo<l".rccorJ, (incl>mmg and outgomg calls), ICX1 11les.ilges for cell numh~r (775 )527.
).140 i or [he d,ltcs of 8 ':(l/~(j I i :lnd 8i~ J /20 J 1.
you may
xl!lil\l\l~J<"nd ba'i; tu app,,,u if )'()tt prowl" lho!sc materials H) a rcpr(';,entath c o.blWx
or to Zach Coughlin
Oil or November 17th, J012
FILED
1
CASE NO,: RCRII-063341
DEPT, NO,: 2
2012 NOV -1 AM 9:
I~
3
4
IN THE JUSTICE COURT OF RENO TOWNSHIP,
*****
Plaintiff,
10
II
12
RESPONSE TO
"SUBPOENA DUCES TECUMS"
vs,
13
14
Defendant.
----------------------------I
15
Daniel Wong, Chief Criminal Deputy City Attorney, of the City of Reno and the Reno
16
City Attorney's Office responds to the two "Subpoena Duces Tecums" served on him on
17
Tuesday, November 6, 2012 at approximately 11:50 a.m. This Response is based upon NRS
18
174.305 et seq. and the following Points and Authorities.
19
20

I.
21
FACTS
A representative of Defendant Zachary Barker Coughlin (hereinafter "Defendant") gave
22
two purported "Subpoena Duces Tecums" to Daniel Wong on Tuesday, November 6,2012 at
23
approximately II :50 a.m. while Mr. Wong was in the hallway of Reno Municipal Court, See
24
25
26
27
28
Declaration of Daniel Wong. The actual documents are attached to Mr. Wong's Declaration
attached hereto. Id. The only change is the "RECEIVED" stamp applied and" 11-06-12 at
approx, IISOA" notations made by Mr. Wong thereon upon return to his Office. ld.
III
1/1
II.
RESPONSE
A.
NRS 174.305 is entitled "Subpoena for attendance of witnesses; fonn; issuance" and it
The "Subpoena Duces Tecums" Do Not Comply with NRS.174.30S.
provides:
1. A subpoena must be issued IJy the clerk under the seal of the
court. It must state the name of the court and the title, if any, of the
proceeding, and must command each person to whom it is direct~d
to attend and give testimony at the time and place specified therem.
The clerk shall issue a subpoena, signed and sealed but otherwise
in blank, to a party requesting it, who shall fill in the blanks before
it is served.
2. A subpoena must be issued by a justice of the peace in a
proceeding before the justice of the peace under the seal of the
court.
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II
12
See NRS 174.305 (emphasis added).
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There is no evidence the "Subpoena Duces Tecum" was issued by the Reno Justice Court
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Clerk or a justice of the peace. See both "Subpoena Duces Tecums" attached to Declaration of
IS
Daniel Wong.
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There is nothing on the faces of the "Subpoena Duces Tecums" establishing they were
issued by the Reno Justice Court Clerk of a justice of the peace. Jd
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The "Subpoena Duces Tecums" are directed to no one as no name follows "TO:" on the
purported "Subpoena Duces Tecums." Jd
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B.
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The "Subpoena Duces Tecums" Are Not Valid NRS 174.315 Subpoenas.
The "Subpoena Duces Tecums" allege "PURSUANT TO NRS 174.315 WE

COMMAND YOU TO APPEAR BEFORE: Department 2, Reno Justice Court, One South Sierra
Street, Reno, Nevada." [d. NRS 174.315 is entitled "Issuance of subpoena by prosecuting
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attorney or attorney for defendant; promise to appear; infonning witness of general nature of
grand jury's inquiry" and provides for issuance by only a prosecuting attorney or attorney for
defendant. See NRS 174.315. Defendant appears to hold neither position in this case and he
cannot use NRS 174.315 as authority for issuance of subpoenas.
III
C.
The "Subpoenas Duces Tecums" Are Harassment and Abusive.
Mr. Wong has no knowledge or information about Defendant's Reno Justice Court Case
No. RCRll-063341 other than he believes it involves the allegation of the theft of a cell phone.
See Declaration of Daniel Wong. The "Subpoena Duces Tecums" seek "Copy of any and all cell
phone records (incoming and outgoing calls), text messages for cell number (775) 527-9440 for
the dates of 8/20/11 and 8/21111." See "Subpoena Duces Tecums" attached to Declaration of
Daniel Wong. Mr. Wong has no knowledge of any cell phone records or text messages for cell
number (775) 527-9440. See Declaration of Daniel Wong. Mr. Wong has no knowledge of any
cell number (775) 527-9440. Id Mr. Wong does not possess and has no access to any such cell
10
phone records or text messages. Id Mr. Wong asserts that Defendant knows Mr. Wong has no
II
records and no such knowledge. Id Having to respond to the "Subpoena Duces Tecums" takes
12
up Mr. Wong's valuable time. Id
13
14
15
16
17
The "Subpoena Duces Tecums" are directed to no one as no name follows "TO:" on the
purported "Subpoena Duces Tecums." See "Subpoena Duces Tecums" attached to Declaration
of Daniel Wong.
It is not clear that Defendant intended a Subpoena Duces Tecum for Mr.
Wong. Mr. Wong heard Defendant tell his representative "give that guy one" pointing to Mr.
Wong as Mr. Wong happened to walk by Defendant in the Reno Municipal Court hallway. See
18
Declaration of Daniel Wong. No purpose is served by giving Mr. Wong two "Subpoena Duces
19
Tecurns." Defendant repeated the "give that guy one" pointing to Reno Municipal Court Legal
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21
Defender Lew Taitel, Esq. as Mr. Taitel happened to walk with Mr. Wong by Defendant in the
Reno Municipal Court hallway. Id.
22
Defendant knows Mr. Wong is the Chief Criminal Deputy City Attorney for the City of
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27
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Reno and the Reno City Attorney's Office and is very busy. The only explanation for the above
is that Defendant is harassing Mr. Wong and abusing the subpoena process.
II!
II!
/f!
Respectfully submitted this

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"11V1
day of November, 2012.

JOHN 1. KADLIC
::0:i;~~
Chief Criminal Deputy City Attorney
Reno City Attorney's Office
P.O. Box 1900
Reno, NV 89505
(775) 334-2050
1
1
DECLARATION OF DANIEL WONG
2
STATE OF NEVADA
3
4
COUNTY OF WASHOE
)
)
)
:ss
I, Daniel Wong, declare under penalty of perjury pursuant to NRS 53.045 that the
following is true and correct:
1.
City Attorney's Office.
8
9
I am the Chief Criminal Deputy City Attorney for the City of Reno and the Reno
2.
A representative of Defendant Zachary Barker Coughlin (hereinafter "Defendant")
10
gave two purported "Subpoena Duces Tecums" to me on Tuesday, November 6,
11
2012 at approximately 11 :50 a.m. while I was in the hallway of Reno Municipal
12
Court. The actual documents are attached to this Declaration. The only change
13
is the "RECEIVED" stamp applied and "11-06-12 at approx. 1150A" notations
14
made by me thereon upon return to my Office.
15
3.
I have no knowledge or information about Defendant's Reno Justice Court Case
16
No. RCR11-063341 other than I believe it involves the allegation of the theft of a
17
cell phone. I have no knowledge of any cell phone records or text messages for
18
cell number (775) 527-9440. I have no knowledge of any cell number (775) 527-
19
9440. I do not possess and have no access to any such cell phone records or
20
text messages. I assert that Defendant knows I have no records and no such
21
knOwledge. Having to respond to the "Subpoena Duces Tecums" takes up my
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valuable time.
4.
I heard Defendant tell his representative "give that guy one" pointing to me as I
happened to walk by Defendant in the Reno Municipal Court hallway. Defendant
repeated the "give that guy one" pointing to Reno MuniCipal Court Legal
Defender Lew Taitel, Esq. as Mr. Taitel happened to walk with me by Defendant
in the Reno Municipal Court hallway.
5.
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Pursuant to NRS 53.045, I declare under penalty of perjury that the foregoing is
true and correct. Executed on November 7,2012.
'<0. RCRII-063341
Dept.
~t).
St'BPONA O\JCES TFD)M

11', THE JUSTICE COlJRT OF RE"lO TOWNSHIP
COD,TY OF \VASI'IOE, STATE OF NEVADA
TWO S rATE OF NEVADA, Plaimiff,

vS,
IACHARY RARKFR COL!GlILlN, Defendant.

TO:
;~'RO:"{: ZAeR COUGHLIN, ESQ. (Attorney temporarily suspended in Nevada self represented)
PU,Sl'ANT TO NRS 174 315 WE COM~jAND YOU TO API'FAR IJFFORE:
Department :;
Reno Ju,ti~e C,lurt
One South Sierra SIred, Reno. Nevada
to testify for the above-named Ddendant.
On NOVEMBER 19TH, 2012
AT 8,30 AM IN D2, BEFORE HONORABLE JUDGE SFERRAZZA
>\\Y PERSO;\ FAIU!\1G TO APPEAR 1'.1A Y BE HELD IN CONTEMPT OF COURT

ACCURDING TO NRS 2~.I()O THE PENALTY FOR CON rEMI'T OF COURT IS A
FiNE liP TO $500 AND/OR 25 DA YS IMPRISONMENT
Dated: 11/5/12
Zach Coughlin, Esq.
(suspended at torney)
1471 e. 9th st.

reno, 89512
If you have an)' questions

rcg;ll'ding your app~3rance, please
contact Zach Coughlin at
949 667 7402
By' Zach Coughlin

1471 E. 9th St.
Reno, NV 89512
tel and fax'
949 667 ?402 ZachCoughlin'iYhotmail, com

) 55.
cm"(I'Y OF WASfI(l[
I hereby ,c'nit;!
[I!U~
...
I served this Subpoena on _

__, at the location of _
_
fly delivering u copy of thIS Subpoena to
~aiJ~it~~rson~~l<.o~ by complying with the mailing requirements found ~n ,NRS, 174.345

S~bpoeI1a
or
mailing it Dat~
1l!6/12
you may
Signa!lIf or' i\tt~me) lSuspended attorney)

Date
.-----Sl2.l,lPQf:-:,\ DUCES l]:Cl!!VLlJEMS TO BE PRODUCED: Copy of any and all cell
phone fecord, (lJlCOllHng and outgoing calls), text me""g"s i()f wll number (775i527l)~~1J lor [he date:, vfS:2(1!2011 and 8'11/20) 1.
xl!l\l\l\lE,lgqj()t i1mc to JPpe~[ if .\\)ll provide Ih~s" tn:I,,,riws to a ftpre""nlatlvc l,*~x
or to Zach cough} Ul
on or
November 17th, 2012
.,I,
i
'I/f1""-~
'io, ReR 11-063341
Depl.
"0. 2
rp
Sl'Bl'OENA DUCES TE.CUM

I'" 'r HE JUSTICE COt'RT OF RENO TOWNSHIP
7/~~7Lf})
('/- rjlfft /I')O
COl'l'.'TY OF WASHOE, STATE OF ~EVADI\
Till' ~TA n' OF NEVADA, Phintitl

Vii.
ZA('!']ARY BARKER COl'GHLlN, Defendllnt.

1'0:
FRO~1: ZACH COUGHLIN, ESQ. (Attorney temporarily suspended in Nevada self represented)
PL'RSl'ANT TO NRS 1743 J 5 WE COMMAND YOU TO APPEAR BEFORE:

Department 2
i,cno Ju,tkc Court
One South Sierm Street. Reno, :-.Icv:lda
tOlcstJfy for the above-named Defendant.
AT 8,30 AM IN D2, BEFORE HONOR~BLE JUDGE SFERRAZZA
A"Y PERSON FAlLING '1'0 APPEAR M1\ Y BE HELD IN CONTEMPT OF COURT

ACCUR DING TO ;RS 22,100. T1 If' PP.];\LTY FOR CONTE:VU'T OF cOt'R-r IS A
lIKE l'P TO $500 .,\ND/OR 25 DAYS IMPRISON:VIE:-JT.
DaleJ:
11/6/12
Zach Coughlln, Esq.
1471 e.
(suspended attorney)
9th st.
If you h~ve an) questions

regarding your appearance, please
contact: Zach Coughlin at
reno, 89512
949 667 7402
B,, Zach Coughlin

1471 E, 9th St.
Reno, NV 89512
tel and fax: 949 6671402 ZachCoughlin@hotmail.com
)
COl':"TY OF \Vt\SI10E
"'.
her<b~
",'I1;['Y that I $cn'cd thiS Subpoena ()n _

__, a{ the location of _
___.
~
..
by delivering a ;;opy of {his Subpoena to
~aJd\vjt~pl!rsonaii{,.or. by complying wic:.h the mailing requirements found in NRS 174.345
I
Subpoena or mailing it Dmc

1l/6/l2
Sign~1tur
Or Attorney
Date
--------~YJl.PQh''''\ DJJi:LS n;,kU,~t: ITEMS TO BE f'RODl;CTD: Copy of any and all cell
phvnerccor:ls (i:Jeoming and outgoing calis), text me"agcs Jor ,ell number 1775)527'J4"0 iGr (he d~tcs 01'8'2012011 and 8,211201 L
you may
x.i~*~.ltnot bah.' to "Ippedf iCyou provide Ih~sc matl;rbl~ to a rc:presr.!l1tatlvc '-'*~x

or to Zach coughlin
un
or
November 17tl1, 2012
CERTIFICATE OF MAILING
I certify I am an employee of the Reno City Attorney's office, and on this date, I placed a
copy of the foregoing RESPONSE TO "SUBPOENA DUCES TECUMS" in a sealed
envelope placed for collection and mailing in the United States Mail at Reno, Nevada, postage
prepaid, following ordinary business practices addressed to:
1471 E. 9'h Street
Reno, Nevada 89512
DATED this -:::)~
v
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FILED
JOHN J. KADUC
Reno City Attorney
CREIGTON SKAU
Deputy City Attorney
Nevada State Bar No. 34
P.O. Box 1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneysfor City of Reno
ZDIZNOV -7 PH 4: /8
STEVE ,II'll'
RENO JU'O'iGE
rr
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IN THE JlJSTlCE COURT OF RENO TOWNSHIP
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COUNTY OF WASHOE, STATE OF NEV ADA
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'iJRr
8Y_._
STATE OF NEVADA.
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Plaintiffs.
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Case No. RCR2011-063341

Dept. No.2
vs.
COUGHLf"l. ZACHARY BARKER,
___________________________i
MonON FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR
PROTECnVE ORDER REGARDING ISSUANCE OF SUBPOENAS
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COMES NOW, City of Reno ("'City"). as the employer and on behalf of Reno Police
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Department Officers Ron Rosa and Thomas Alaksa. and Court Marshall Joel Harley and Reno
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Emergency Communication Center employees Savannah Montgomery and Scott Weese (and
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any other City employees (collectively "City employees") whose names were unreadable in
23
subpoenas), by and through their counsel of record, John J. Kadlic, Reno City Attorney, and
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Creig Skau, Deputy City Attorney. and hereby moves this Court for an order to quash the
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subpoenas claimed to have been served on for these City employees in violation of Justice Court
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Rules ofCivii Procedure (.lCRC'P) 45 and for the entry of a protective order pursuant to the
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IiI
, ,
JCRCP 26, This Motion is based upon the attached memo of Points and Authorities, the
2
attached Exhibits and any additional or further evidence the Court deems just and proper.
I.
Statement of Facts
4
5
The following procedural background is relevant to this matter:
A. On October 26, 2012, City of Reno Emergency Communication Center employees
(ECOMM) Suzy Rogers and Kelley Odom received emails from Zach Coughlin
containing nine (9) Subpoenas. copies of which are attached as Exhibit "1" and
9
incorporated herein by reference,
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11
12
B. On November 2, 2012, City sem Mr. Coughlin a letter to two addresses via US Mail
infonning him. among other Ullin!!",.
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14
available for
pick-LIp provided he submit payment to the City of Reno for $) 08. A copy of the
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16
letter is attached as Exhibit "2" and incorporated herein by reference. On November

~ame
17
5,2012. this
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two addresses.
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letter was sent again to Mr. Coughlin by certified mail to the same
C. This correspondence also infomled Mr. Coughlin that the four (4) subpoenas he
20
claimed to have served regarding the appearance of the City employees Ron Rosa,
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22
Thomas Alaksa, Savannah Montgomery and Scott Weese were ineffective because
23
of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated
24
because service of the subpoenas for these four (4) individuals was ineftective, these
25
individuals would not be appearing on November 19,2012. (Exhibit "2").
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D. On November L 2012, Mr. Coughlin delivered twelve (12) subpoenas and a ''Notice
of Errata and Revised Supplemental Motion For a New Trial" by sliding them
through the security glass in the front of1ice of the Reno Police Department at
2
3
approximately 4:50 p.m. after being told the office was closed. Three (3) ;ubpoenas
contained in this packet are duplicates. As such, this packet appears to contain the
same ten (10) subpoenas he previously sent to Reno ECOMM employees Kelley
A copy of this packet is attached as Exhibit "3" and
Odom and Suzy Rogers.
incorporated herein by reference.
E. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to
9
both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking
10
II
documents previously requested in earlier subpoenas duces tecum. These subpoenas
12
also contained mUltiple pages of requests for materials unrelated to Case RMC
13
RCR2011-063341.
14
A copy of these documents is attached as Exhibit "4" and
incorporated herein by reference.
15
16
F. On November 5. 2012, Deputy City Attorney Robert Bony received a telephone call
17
from Mr. Coughlin regarding the Ictter this ot1ice mailed on November 2, 2012.
18
Among other things, Mr. Coughlin did not indicate he would be withdrawing his
19
subpoenas for Ron Rosa, Thomas Alaksa. Savannah Montgomery and Scott Weese.
20
Mr. Coughlin did state to have these witnesses ready for trial.
21
22
G. On November 6,2012, Mr. Coughlin submitted a new document entitled Subpoena
23
Duces Tecum containing seventeen (17) pages of blended documents regarding
24
matters pending before Reno Justice Court on November 19, 2012 and the State Bar
25
Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department.
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27
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The subpoena duces tecum on the first page of the packet contains many unreadable
names. A copy of the packet is attached as Exhibit "5".
H. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of
materials from an unidentified person. The cover sheet of the packed is entitled
"Subpoena Duces Tecum" regarding Case RCR201106334J. This document also
appears to contain names of other individuals but the handwriting is unreadable. It is
5
6
not knovlIl if the other individuals on this subpoena are City employees. A headnote
on the Subpoena indicates that if the requested documents are e-mailed to Mr.
:;
.,
I
~
Coughlin, personal appearance may not be required.
A copy of the packet is
attached as Exhibit "6".

10
II.
II
Argument:
12
A.
13
JCRCP 45 addresses subpoenas. In pertinent part it states:
14
IS
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Service
(b) Service.
(1) A subpoena may be served by any person who is not a party
and is not less than 18 years of age. Service of a subpoena upon a
pcr.;on named therein shall be made by delivering a copy thereof to
such person and, if the person's attendance is commanded, by
tendering to that person the fees for one day's attendance and the
mileage allowed by law. When the subpoena is issued on behalf of
the State or an otlicer or agency thereof. fees and mileage need not
be tendered. Prior notice. not less than 15 days, of any commanded
production of documents and things or inspection of premises
before trial shall be served on each party in the manner prescribed
by Rule Sib).
22
The subpoenas Mr. Coughlin e-mailed to Kelley Odom. Kariann Beechler and Suzy
23
Rogers on October 26. 2012 and November 3, 2012 and re-delivcred to the Reno Police
24
26
Department on November 2. 2012 and November 6, 2012 commanding the appearance of the
many different City employees above are delicient and inefTective as they lilil to comply with
27
personal service requirement of "CRCP 45(b). Accordingly. service was ineffective and all of
28
the subpoenas should be quashed.
In addition to the failure of personal service. all ofMr. Coughlin's subpoenas referenced
'(
in Exhibits "I ", 'r. "4" and "5", also:

1. Violate JCRCP 45(a)(I )(0) in that they do not set fortb the text of subdivisions (c) and
(d) of JCRCP 45.

2. Violate JCRep 45(h)(I) which states that a "subpoena may be served by any person
who is not a partv"
ECOMM employees Kelley Odom, Kariann Beechler and Suzy Rogers on October 26.
to the proceeding. All of the subpoenas were e-mailed to City
2012 and November 3.2012 andlor hand delivered to the Reno Police Department on
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12
13
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November 2, 2012 and November 6.2012 by Mr. Coughlin. a party in this matter.
3. Violate JCRep 45(b)( 1) which states that service of a subpoena commanding attendance
require~
that payment for one day's attendance and the mileage allowed by law. No
witness fee or mileage fee has been submitted by Mr. Coughlin for the appearance any
15
16
nanled City employee.
17
4. Violate JCRep 45(c) \\hich states that a party or attorney responsible for the issuance
18
and service of a subpoena shall take reasonable steps to avoid imposing undue burden or
19
expense on a person subject to the subpoena. Mr. Coughlin is serving a litany of
20
subpoenas on many City departments and City employees regarding this case. However,
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he is also serving ,ubpoenas on City departments and City employees on a multitude of
23
other casc, and proceedings that are unrelated to the instant action. These subpoenas are
24
unduly burdensome. duplicative, irrelevant. unintelligible, oppressive, harassing, seek
25
information that is irrelevant to this action and violate the applicable procedural rules.
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27
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Ba,ed on the above, the requirements of JCRCP Rule 45 have not been met and the
subpoenas fOT all City employees to appear on November 19, 2012 must be quashed. The City
:'
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also moves to quash any other subpocnas Mr. Coughlin e-mailed to City employees Kelley
2
3
Odom, Kariann Beechler and Suzy Rogers andlor submitted to the Reno Police Department
which do not relate to the City or to this matter.
B.
Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As
described above. Mr. Coughlin. a Nevada attorney with a suspended license. is abusing the
subpoena process granted to him by this Court. He is e-mailing multiple City employees or
9
dropping off the same subpoenas (some of which relate to this matter and many which relate to
10
11
a State Bar proceeding or other criminal matters) at multiple City departments. This is creating
12
confusion and leading to a waste of time and resources of public safety employees. As an
\3
attorney, Mr. Coughlin should be aware of the subpocna process. Tllis is not the tirs! matter in
14
which Mr. Coughlin has abused a court procedural matter. For this Court's information, Reno
15
16
Municipal Court Judge Holmes issued a Sua Sponte Order Denying Relief Sought in Improper
17
Document on March 13.2012 linding. among other things, that Mr. Coughlin failed to follow
18
proper legal procedure in preparing and liling motions in a matter pending before that Court and
19
that Mr. Coughlin blatantly abused that Court's tax filing process. As such, that Court ordered
20
that Mr. Coughlin be prohibited from faxing any documents to that Court. A copy of this Order
21
"
22
is attached as Exhibit "7",
23
Based on the above, pursuant to JCRCP 26(c)(2) and .JeRCP 26(c)(3). City respectfully
24
seeks an Order trom this Court requiring Mr. Coughlin to submit any subpoena he intends to
1-)
serve in this. matter to this Court for review prior to issuance and service to ensure Mr. Coughlin
26
27
28
is seeking relevant information regarding a specific case and is following the appropriate legal
process.
HI.
CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery,
Scott Weese, Joel Harley or any other City employee whose names were unreadable in the
subpoenas for failure to comply with JCRCP Rule 45;
2,
To quash any other subpoenas Me. Coughlin e-mailed to City employees Kelley
Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department
9
\{)
11
which do not relate to the City or to this matter because they failed to comply with JCRCP Rule
45,
3,
Grant a protective order to the City pursuant to JCRCP 26 requmng Mr,
12
Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior
13
to issuance and service to ensure Mr. Coughlin's subpoenas are relevant and follow the
14
appropriate legal process,
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AFFJRMA nON
The undersigned docs hereby aninn that the preceding docllment tiled in this court does
not contain the social security number of any person.
RESPECTFULLY SUBMITTED this
day of Novernber, 2012,
19
JOHN J KADLIC
20
21
22
Depu y City Attorney
23
1',0, Box 1900
24
Reno. NY 89505
Attorneys,!i)], City (If Reno
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Pursuant to JCRCP 5(B)(4), I certify that I am an employee of the RENO CITY
A DORNEY'S OFFICE, and that on this date, [ am serving the foregoing document(s) on the
party( s) set forth below by:
Placing an original or true copy thereof in a sealed envelope placed for collection
and mailing in the United States Mail. at Reno, Nevada, postage prepaid,
following ordinary business practices.
6
7
Personal delivery.
8
9
EFlex electronic service
10
Facsimile (FAX),
II
Federal Express or other O\emight delivery.
12
Reno/Carson Messenger Service.
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16
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19
20
21
addressed as follows:
Biray Dogan
Washoe COlmty Public Defender
350 S. Center Street, 5th Floor
Reno, NY 89520
lach Young, D"puty DA

Washoe County DA's Olliee, Criminal Division
P,O. Box 30083
Reno, NY 89520
DATED this
''"ltLdaY of November, 2012.
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24
25
Legal Assistant
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Exhibit List
Number: Name of Document:
1
~ubpoenas
2
3
4
5
Letter dated November 2, 2011

Subpoenas
E-Mail of Subpoenas to K. Odorn & K. Beechler
Subpoenas
-
I Number of Pages:
- 18
2
23
9
17
V'

STATE OF NEVADA,
Plaintiff,
Dept. No,_ _-"-_ __

vs.
70--C V\ Cevc;.WU tlJ

SUBPOENA
c'"
To:~lra V\ q tLf41~ )~ (vvl3Lic 5q ~b\.)rJk(f0
Defendant..
You are cr;e:;ded to appear b~forefthe Reno Justice Court ljI Qne Soutb Sierra Street, Reno, Nevada
on the -----J. OJ
day of Y\)DI{ [( VYljO..LV:__ , 20_~
'Z.,;J)()
o'clock O""'.. M.
to testify on tlie part of
._
.
Failure to appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22. J00
and/or NRS 50.195.
.20 \J-
--_.'
STEVE TU11'LE
CLERK OF TIlE COURT

By
'j\::'\:'i\C\-.6Cu_~~~0\.."'\:{'{'O,~
Deputy Cler
AFFIDAVIT OF SERVICE
STATE OF _ _ _ _ _ _-')
)ss.
COUNTY OF _ _ _ _ _ .-l
1, received this Subpoena On the ___ day of _ .. ________.._ _ _ _ _ _ _, 20 _ _, and
personally served a copy of the same upon _ _ _ . _ " _ '
of
------------
_ _ _on the _ _ _ _ day
) 20
Signature of Person Making Service

Subscribed and sworn before me this
_ _ _ _ dayof __________
Notary Public
,20. .._.
V'

STATE OF NEVADA,
Case No.
Plaintiff,
I2.c /2. ?c>!/- 06 '5>')
'2.
Dept. No.
VS.
ZAC~
SUBPOENA
Defendant.
To: _ _K_,-~<!>_(\,-,-_-,-R-=6o=6",--A-,---
_ _ _ _ _ _ _ _ _ __
You are,commanded to appear before the Reno Justice Cour~ at One South Sierra Street, Reno, Nevada
onthe_ I
~'V>_dayof
f\)J;V-lY\f\'oLV
,20 '~I 3'~Q
o'c1ock...:::M
to testify on the part of
_ _ _ __
Failure to appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22.100
andlor NRS 50.195.
C1
~'4 "'- day of _ _\....=-.:::'----:::.-t.:..D:"o".)~==..:)./ __

r) (\. \ '" _
Dated this - -\
-,
\y
--
20
STEVE TUHt>E
CLERK OF TII COURT
By:~,;~~,() tA.'-~ ~~ n
'Ovv--
Deputy Cler
STATE OF _ _ _ _ __
--.J
)ss_
COUN1YOF
____..J
I, received this Subpoena on the ____ day of ________ _

personally served a copy of the same upon _ _ _ _ _ _ __
of
_________ -, 20_ _, and

_ on the ______ day
__
,20_ _ .

_ _ dayof
_ _ _ _ _ _ _, 20_.
Notary Public
J
STATE OF NEVADA,
Case No.
ULL. ~(\-e)5i I
Plaintiff,
Dept. No.
VS.
,.~
2A-c#- Ccv#l~nt
SUBPOENA
TO:
R~.t oMc.ev 1~~"'7'-S~A"--'Ld=-'-,-,5':..:.....4....l....-_ _ __
You a, cOl1l!llnded to appear befor9 th9 Reno Justice cou r1 at One South Sierra Street, Reno, Nevada
on the
I1j ay of
0 V..lYY\t5tk__, 20~ at n( 30 o'clock C\. .M.
to testifY on the part of _ _---:-_ __
and/or NRS 50.195.
<4_1_
Dated this
---.f'Y
_1:---l--_I.~day of_----'fi>-,c-Q"--tt\.o\0..o...\...._ _ _~, 20 \ J

V
STEVE TUTTLg
CLERK OF THE COURT
BY:~V\'~.\ l
\().t.A vV'CM,,,,
Deputy Clel!<
STATE OF _ _ _ _ _~)
)ss.
COUNTYOF _ _ _ _ __
)
1, received this Subpoena on the - . - - davof ------- - --.- __________ , 20_ _, and
"
_ _ _ _ _ _ _.on the
day
personally served a copy of the same upon
of
,20_ _

______ day of _________, 20_.
Notary Public
,
,
,
r

STATE OF NEVADA,
Case No.
{>(k Le>tI--OO'13lr/
Plaintiff,
2 _
__
Dept. No. _ _ _
VS.
2 A L- &1
~v6fkrX\\
SUBPOENA
Defendant.
T&~5r~V
:;'0 t-1: Wee>p
You are c9f1manded to a~ar before thi' Reno Jus/ice cor-2.~ne So~ Sierra SlIeet, Reno, Nevada
on the
l~yof_l:VOV-lYv\l:':)e.v _,20
at
.::6.~()
o'clockC<...M.
to testify the part o f " _
"
_______
Failure to appear may be deemed a contempt of court and subject YOll /0 the penalty set forth in NRS 22.100
and/or NRS 50.195,
on
Dated this. __
'~~ay of
STEVE TUHLE
CLERK OF iHE COURT
BY:1~ct,0L~ &K))"./\\/\'\,.;vr-Deputy CleT
AFFlDA VIT OF SERVICE
STATEOF __________~)
)S5.
COUNTY OF _____
.........J
I, received this Subpoena on the ____ day of ______ _

personally served a copy of the same upon _ _
______ .. _____._ _on the _____ day
of

_ _ _, __ day of _ __
,20._,
----~-.=-:-------
Notary Public
, 20___, and

STATE OF NEVADA,
Case No.
Plaintiff,
gC12 Zv/-Op ~71
De~.No ._~~==~_____
VS.
kh~0Lh~~\
SUBPOENA
lee v~
A
bItQ r . ~rJPLcvs/{Jl,-ucesJIlP~-,-. I'f" 'Rfu~
A~T /'L5j~d
&
T\...)Defendant.
TO:~
;'1
\)
/1
(Yo,
'>- (J:
You 7!e corrMi'anded to appear be(ore, the Reno Justice Court at One South Sierra Street, Reno, Nevada
on the I /y'/A'_dayof 1\J~l1:1.lliv
,2~at ("/';,Q
o'c1ock'--.M.
to testify on'ifle part of _ _
and/or NRS 50.195.
_; il.\.t \
C C:.:tD \.::J~lt/
Dateo this.o<....j - day of

---
_-"-...::0:::'-.:: _ _ _ _ _ _ _ _ _ _ ,
L) .
20 _ _
STEVE 11JTTLE
CLERK OF THE COURT
BY:~OJJ f:>b\/i \V\lI\..A~

Deputy 3erk
STATE OF
.___-.-J
)ss
COUNTY OF
.J
I, received this Subpoena on the _ _ _ day of ____

personally served a copy of the same upon_______
of
_____________,20_ _ and
- - - _ . _ -on the
__________ ,20. __ .

_____ dayof
Notary Public
,20_
_ _ _ day
_

STATE OF NEVADA,
Case No.
Plainuff,
~<C C!... 7c~12-~6}(J
Dept.N().~
SUBPOENA
Vs.
DUCES TECUM
ou are commanden to deliver the above mentioned d~cPTents before~e ~enoJusti<fe C9urt a~ One
ilIlIy of__
l- y-<-:: ---:? ~\.....::...I_--,< " '
South Sierra Street, Rm;~evada on or before th"
at
3..
o'cloc-(V~/ M_ on the part oj~_ 7 " L ' \ L c c-- ",bl (. \ .
Fai::-lur-e-(-o-:d-:el::-iv-er may be deemed a contempt of court and subjc'<:l you to the penally sel forth in NRii"22.100
and/or NRS 50. J95.
!L
3 (;
DATED this
------.:::.~~ \-..
day of
C'k-\ Ii rn IV
,":jl) \Y
STI,VF. TUTTLE
Clerk of the Court
STATE OF NEVADA,
County of Washoe
)
) SS.
)
I received this Subpoena on the _ _ _ __
dayof _ _ _ _ _ _ _ _ _ __
---,
_ _ _ and personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,

on this _ _ _ _ _ day of _ __

Subscribed and Sworn 10 before me
thIS
day of
---------' ---'
NOTARY PUBLIC
rev 04;2009
v
IN THE mSTICE COURT OF RENO TOWNSHIP
STATE OF NEVADA,
Case No.
(Z Cft 7..,.( i-o (33J (

,
Plaintiff,
Dept.No--.2-
SUBPOENA
Vs.
DUCES TECUM
You are colanded to deliver the above mentioned}ldpttrnents befor4$e Reno JU$tice,Conrt a\ One
day of
J /<:-'" -.------..l ~--- ,
=-c,--_-:-c:-,at
)C'
o'ciockC~. on the part of '? c~,/ I"" C;o L , " C, ' \
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth in 1'-I1I>s 22.1 00
andlor NRS 50.195.
South Sierra Street, Reno, Nevada on or before the
l:Ll:..
DATED this
STEVE.'fl"'ID"""'f"'.E
_____ ._ _ _ __
Clerk Ilf the Court
STATE OF NEVADA,
County of Washoe
)
) SS.
)
1 received thIS Subpoena all the _ _ _ _ _ _ day of
---,
_ _ _ and personally served a copy of the same upon

on this _ _ _ _ _ dayof _ _ _ _ _ _ _ _ __

Subscribed and Sworn to before me
this
day of
NOTARY PUBLIC
rev 04/2009
IN THE mSTICE COURT OF RENO TOWNSHIP

STATE OF mvADA,
Plamtiff,
SUBPOENA
DUCES TECUM
TO:
~~,
/'
~,
\"
( ' , - c..., I't).U \ ,~,
L>eO,J'~.J"'v~'
F /{\?
o
f\,
.j
'C 0
\1
\. S,
<\.
You are commanded to deliver the a ve mentioned documents befole the Reno Jlj6tice Court at One
South Sierra Street, Reno, Ne,:::ada on or befor_e the
day of
c, v--"-"" tr;,
~)
.t ___
>c o'clock'_'_M,on the part of C c'_LL,c,oC'f 0 - _ _ _ 1',
Failure to deliver may be deemed a contempt of cOllrl and subject you to the penaJty set forth i~S 22, I 00
----1--.1--
"'7,]
andlor NRS 50,195.
x?l~\,-
DATEDthis _ _'c..I_
day of
STEVE l1ITTLE
Clerk of the Coon
By-,~\flC~_A G\0tA n1h'V'

-
STATE OF NEVADA,
County of Washoe
Deputy Cl,rd;
)
) SS,
)
I received this SuhpoelU1 on the __ ' _______ day of __ ,
,____ and personally served a copy of the same upon

on this _ _ _ _ _. day of

this
day of
------,-_.
NOT ARY PUBLIC
rev 0412009
'

STATE OF NEVADA,
Case No.
Plaintiff,
f!....ce "?c. il-C'3 ytj(
Dept.No.~
SUBPOENA
Vs.
DUCES TECUM
TO:
. You are commanded to deliver the above mentioned do;''rents befp,fe the Rent Justice Court at <;>nc
South
~~ Reno, N;J~a on or before the
! L( 1'&y of i' IL'''''-"''~ ,;--.::r-.-- b. .'
'ZJ'i
'
_'_. '><.::
o'clock L'-M.onthe/lartof -Z::",-<
C<, ~~
.-.,'
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth in
S 22.100
and/or NRS 50.195.
DATED this
STEVEnmLE
Cl~ik
of the Court
BY~'-V\ cl~ Ov'-t 0 \,~,,\\~,

Deputy Clerk
STATE OF NEVADA,
County of Washoe
)
) S8.
)
I recelved Ih,S Subpoena on the
dayof _ _ _ _ _ _ _ _ _ _ _ _ _ __
_ _ _ and personally served a copy of the same upon

on this _ _ _ _ _ day of _ _ _ _ _ _ _ _ _ _ _ _ __
Signatnre of Person Making Semce

this
day of
NOTARY PUBLIC
rev Q4/2009

STATE OF NEVADA,
K 12.. 7c/j ( -o( ~~ if (
Case No.
Plaintiff,
.....2
Dept. No .
Vs.
SUBPOENA
DUCES TECUM
~l.. l \ C~!iJj!6:t\k! ~
Defendant
TO:---L:
C1
c\
YOll are commanded to deliver the above men.!,~ doc1)Tents before

South Sierra Street, Reno, eyada on or before the
l{~ ot::;f::--<~
o(
,at
' 0 o'clock ~"---it'-M. on the part
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth .
and/or NRS 50.195.
:2
I.....
'2
.20 \ ';)" .
STEVEl'UTIlil'-:--::-_ _ _ _ _ ___
C!;,tk of the Court
STATE OF NEVADA,
Courty of Washoe
)
) SS.
)
I received this Subpoena on the _ _ _ _ _ _ _ day 01' _ _ _ _ _ _ _ _ _ _ _ _ _ _- '

_ _ _ and personally served a copy of the same upon _ _ .. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
on thIS _. _ _ _ _ _ day of
-----.~--~-----~--~-------

this
day of
'---'
NOTARY PUBLIC
rev 04/2009
f
,
.
R'ltNO CITY ATTORNEY'S OFFICE
JOHN J. KADLIC
City Attorney
TRACY L. CHASE
DANIEL WONG
Chief Cnminal Deputy
ChitfCivil Deputy
Crimmal DWlsl0n Deputi~

JILL E. DRAKE
C. HAZLETI-STEVENS
ALISON M. ORMAAS
PAMELA G. ROBERTS
BRIA~ M. SOOUDI
Civil DIVision DepUlIe5

ROBERT F. BONY
JACK fl. CAMI'BELL
GABRIELLE J. CARR
DONALD L. CHRISTENSEN
MARILYN CRAIG
SUSAN IlA U. ROTHE
.JONATHAN SHIPMAN
CRflG SI(Ali
001 AdminIstratIVe SpecIalist

CORINNE I). fRIEDMAN
V!ctnll Advocate
SII/ANNE RAMOS
Novemh~r
2, 2012
Sent Via Certified Mail and Regular US Mail 10:
Zach Cou~hlin
1471 E. 9t1 Street
Reno, Nevada 89512
AND
Zach Cou~hlin
1422 E. 9' Street Apt. 2
Reno, Nevada 89512
Sellt Via Reglltar US Mail to:
Judge Peter Sferrazza

Reno lustice COuti
PO Box 30083
Reno, Nevada 89520-3083
Re:
Mr. Zach Young, Deputy District Attorney

Washoe County District Attorney's Office
One South Sierra Street
1'0 Box 11130
Reno, Nevada 89520
Written Objection pursuant to Reno Justice Court Rule 45 (RJCR 45) regarding Emailed Subpoenas to City of Reno Emergency Communications Center From Zacb
Coughlin Concerning RCR2011-06JJ4 J.
Dear Mr. Coughlin, Honorable Judge Sferrazza and Mr. Young:

'111is office represents the City of Reno (City), including its Police Department and its
Emergency Communications Center (ECOMM) and is in receipt of copies of nine (9) subpoenas
Mr. Coughlin e-mailed to City ECOMM employees Suzy Rogers and Kelley Odom on October
26, 2012 (Copies of letter and subpoenas enclosed for your ease of reference). While the
subpoenas duces tecum are vague and overbroad, the City has tried to comply with the requests
which pertain to City departments. As such, pursuant to the subpoenas duces tecum e-mailed to
the City ECOMM addressed 10 the Reno Police Department Custodian of Records, Emergency
Dispatch Services (City of Reno Emergency Communications Center) and the Custodian of
Records Emergency Dispatch Services of Reno Washoe COlmly, the City has prepared copies of
the call for service records, a CD containing an audio copy of the dispatch radio traffic and a
police report responsive to the "larceny of a cell phone at the skate plaza in front of City Hall in
Mailing: P,O, 80' 1900, Reno, NV 89505-1900 Phy,ical: I East First Street, 3" Floor, Reno, NV 89501
Telephone: 775-334-2050. Facsimile: 775-334-2420
www..cit).ofreno.com
Zach Coughlin
November 2, 2012
Pagel
downtown Reno" on August 20, 2011 at or abuut 11:18 pm to 12:00 am. August 21, 2011 (Case
No. RCR20 11-063341), These materials afC available for pickup by Mr, Coughlin at ,this office
and will be released to him upon payment to the City of $108.00 (Please see attached invoice).
Be advised that the person retrieving these materials wilt need to sign a receipt.
Please be advised that the City lodge-; ohjections to Mr. Coughlin's c-mailcd subpoenas
commanding City employees Ron Rosa, Th()mas Alaksa. Savannah Montgomery and Scott
Weese to appear on November 19. 2012, These subpoenas are deficient and ineffective as they
fail to comply with R]CR 45, inc!uuing but not limited to RJCR 45(a) and/or RJCR 45(b),
Among other things, these suhpocn<ls:
I
i
1. Violate RJCR 45(a)(l)(D) in that they do not set forth the text of subdivisions (e) and (d)
ofRJCR 45.
2, Violate RJCR 4 5(b)( I) which statcs that a "subpoena may be served by any person who
is not.1!l2~I.\Y~, to the proceeding, These 4 slIbpoenas were e-rnailed to City ECOMM
employees Kelley Odom and Suzy R()gers by Mr, C0ughlin. a pallY in this matter.
3. Violate RJCR 45(b)(I) which states that service of a subpoena upon a person named
therein shall be made by delivering a copy thereof to such person". E-mailing the
subpoenas to City ECOMM employees Kelley Odom anu Suzy Rogel'S in the hopes they
wili give the subpoenas to the named witnesses does not comply with IUCR 45(b)(I),
4, Violate RJCR 45(b)( I) which slales that scmce of a SUbrK1Cnl\ l;()lTImanding attendance
requires that payment for onc day's attendance and the ITIlleage allowed by law. No
witness fee or mileage fce has been suhnutled by ,vIr, Coughlin for the appearance of the
4 City employees,
Rased on the deficient and inelfective service of the subpoenas, City employees Ron Rosa,
Thomas Alaksa, Savannah Montgomery and Scott Wcesc will not bc appearing on November 19,
2012 at 8:30 a,m.
The City also lodges its objections to the other materials Mr. Coughlin requested in his email dated October 26, 2012 to City ECOMM employees Kelley Odom and Suzy Rogers as
those materials do not relate to the Case No, RCR2011-063341. These written objections only
relate to c-mailed subpoenas relating to the City, The City cannot comply with the e-mailed
subpoenas Mr. Coughlin sent to the City of Reno ECOMM conceming AT&T and the Washoe
County District Attorney's Office,
'
Mailing: P.O. Box !96tl, Reno, NV 89S6S1900 Ph}sk~l: I East First Street, 3"' Floor, Reno, NY 89501
Telephone: 775-334-2050. hcsimilc: 775-334-2420
wwW.citlofreno.com
Zath Coughlin
November 2, 2012
Page 3
The City is happy to participate in any hearing the Coun may schedule on this matter.
Should anyone wish to discuss this matter, 1 may be reached at 775-334-2050.
Sincerely,
ClY7~
Robert F. Bony
~)
Deputy City !\ttomey
RFB/jmh
Enclosures
cc:
Kelly Odom - Reno Emergency Communications Center
Lynne Austin - Reno Police Department, Records Division
Mailing: P.O, Box I9{lU, Reno, NY 89505-1900. Physicat: I Easl First Street, 3" Floor, Rello, NY 89501
Telephone: 775-334-2050. Facsimile: 775-334-2420
www.citvofreno.com
"
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,,01-
'
IN THE ruSTICE COURT OF RENO TOWNSHIP

COUN1Y OF WASHOE, STATE OF NEVADA
STATE OF NEVADA,
Case No.
Plaintiff,
tc e.. /"! 2-tJCCJ(;J()
Dept.No.~
SUBPOENA
Vs.
DUCES TECUM
. You are comman~ed to deliver the above mentioned ~)Ullents before

Soutl! Slem Street, Re,,~.evada on or belore th<;.
.~_ ~ of'-.=;-~I'-.u;.*-"':'-;::cl.==r:f-,::-:-:--:--:-:--at
.l. "5 (; o'clock"",-",_ M on the part of
.',. c
L c _ ~ \ L.
Failure to dehver may be deemed a contempt of court and subject you to lhe penalty set forth in NR
andlor NRS 50.195.
,
!~\.\'\.
0(1 \ Ir.r
,
DATED thlS ~-:.._ day of_----'.L..L,.;..\",,,,--"Il....
)',AA.L;;;).""V _ ,
_
~1l\\'V
!LJ!!
STEVE TUTTLE
Clerk of the Court
"
[...
Hy
~C~)rHA ()lOt\V!Vv
:
STATE OF NEVADA,
County of Washoe
epoly Clerk
)
) SS
)
[received this Subpoena on the
_______ dayof ____________________________
_____ and personally served a copy of the same upon

on this ______ day of ___ ._
Signature of PeTh'Oll Making Service

this
day of
----------,--_.
,.
,
NOTARY PUBLIC
rev 0412009
"
'.
v
STATE OF NEVADA,
Plaintiff,
.--7
Dept. No.----<----
SUBPOENA
Vs.
DUCES TECUM
TO:
~ ~C
df .J,l.....
t:--..\,
fc) k~ Q
,J,.,,;:-r-
_--,L~ 'u~- c~ \ \J ,':,v~ _-~_''''---lC~~OLli\!:'''':~''''~'-")...,'r-----b \.
ab~ve
J\I6ti~e
You are commanded to deliver the

mentioned documents bef95" the Reno
Court at One
South Sierra Street, Reno, N,e;ada on or befme the
}
day of f' (- ~~ ":> ""
_--'
~
at
o'cJock'_'_ M. on the par! of --,.
.
'.
Oc
I ~
.
Failure to deliver may be deemed a contempt of court and subject you to the penalty set orth i\l
S 22.100 .
andlor NRS 50.195.
3)Q
'1
IlLV
DATED thlS
--l::"'" day of
STEVE TlmLE
Clerk of the Court
STATE OF NEVADA,
County of Washoe
)
) SS.
)
I received thlS Subpoena on the _ _ _ _ . ___ . day af _ _ _ .._ _ _ _ _ _ _~_ _ _.

_ _ _ and personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
on thIS _______ day of _ ..._ _ _ _ _ _
SIgnature of Person Making Service

this
_ _ day of
-------,-_.
NOTARYPUBLlC
rey 04/2009

Case No.
tL 1<" 2(:1 { -o( ~:S Lf r
Dept. No.
STATE OF NEVADA,
PlaintIff,
SUBPOENA
Vs.
DUCES TECUM
!\
~ ,(
iii! (
-=
TO:
\,
I. \
t::\'::l.L:.U.\
Defendant
C \ ,,<: \c,6 \-=--o..---Hh_-Lk--ct',=",(~'<.--'-'y'<"'-"U"'-.!['--_-,--_-..-
___C I''V'-..j? I- '(
() \/\l
IS
Yf ._
J
, .. ,
~ 1/
I;' ..... f
~C k jJ fl:,v~ 10,15 t
'IV
--ZZ:,v(l
You are mmrnanded to deliver the above ml~ do/''I'l'ents

South Sierra Street, Reno,J:l~Y;<la on or before the,'
~ ~:-,$tiJD'( ~atcrJ 0 o'clock ~""-"cM.onthepartof_ _="""'."""_::~~:__.....,...~~c:':-.
Failure to deliver may be deemed a contempt of court and subject you to the penalty sel forth
andlor NRS 50.195.
,f
\
DATEO thIS _ _ )-'.."',0'I
STEVE TUTfLE
Clerk' of the Court
d) .
l'-,
By :~V'{\b~.\ \Ol.IUA\~
Deputy Clerk ,s
STATE OF NEVADA,
Couoty of Washoe
) SS.
)
[ received this Subpoena on the
_ _ _ _ . day of _ _ _ _ _ _ _ _ _ _ _ _ _ __
. _ _ _ and personally served a copy of the same upon _ _ _ _. _ _ _ _ _ _ _ __
on th,s _ _. _ _ _ day of _ _ _ _ __

this
day of
------,-_.
NOTARY PUBLIC

Case No.
STATE OF NEV ADA,
Plaintiff,
vs.
j2-e L
2.011 -6 (.,)3 ~(
.-->
Dept. No ..--L--.--
SUBPOENA
?t~~. {\: ~ /;1 (In

(lmTi';7-1 /tr y'
DUCES TECUM
Defendant
TO:
;t2 *"Y'L
'-_ ,c--'
8:J;'f?
~B \"~"
I
You are commanded to deliver the a ve mentloned documents bef9!" the Reno Jqst.ee Court at One
South Sierra Street, Reno, Ne!ada on or before the
/
day of yI ,- ~-"---
hV"YCA
at
O'CIOCk'~M,onthepartoL~.L_LL,J-f,(l< 0 , ...
Fmlure to deliver may be deemed a contempt of court and subject you to Ille penally
"Itt, i~JmS 22.100
and/or NRS 50,195,
Z)Q
set
.__ 11lL,
DATED this
!i.l'tYf.TIJD'LE _____________
Clerk ofthe Court
STATE OF NEVADA,
County of Washoe
) SS,
)
(received lhis Subpoena on the _ _ _ _ _ _ d.~ of _. _ _ _ __

_____ and personally served a cnpy of the samc upon
on thi.s ._ _ _ _ _ dayof _ _ _ _ _ _ _ _ _ _ _ _ _.
S,gnature of Person Making Service '

Subscnbed and Sworn to before me
this
day of
-----,-_.
NOTARY PUBLIC
rev 04/2009
v
STATE OF NEVADA,
Plaintiff,
SUBPOENA
Vs.
DUCES TECUM
D~:Y'<.1 fvk . ,\\C t))s.l
{;,d
~ -' c (. g,l),,>
. You are commanded to deliver the above mentioned d~;:~ents before e RenoJusti e C(lurt at One
South SIerra Street, RenSk7"va<!a on or before th~
/ '( Idlty of
, " v-" --..:::. \---"--~,
_ _ _ _ _at
i ) (.: o'clock"'--" M. on the part of
7 ,,.C '\ Lc.>~ <,Ii. /. \'
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth in NRi22.LOO
andlor NRS 50.195,

DATED this
\
f
STEVETl[fTLE . _ _ _ _ _ _ __
Clerk ofthe Court
r
By
County ofWsshoe
"I\f\
~ eLL) rH AIY \Ot'\ vr l!JiV
'-}ijcputy Clerk
STATE OF NEVADA,
'"
)
) SS.
)
1receIved this Subpoena on the
day of .._ _ _ _ _ _ _ _ _ _ _ _ _ _ _,
_ _ _ and personally served a copy ofthe same upon ..

on this _ _ _ _ _ day of _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
,
Subscribed and Swom to before me

this ____.
day of
-----,--'
NOTARY PUBLIC
rev 0412009
"

i)
12c~. '20//- 06 3'5
Case No,
STATE OF NEVADA,
Plaintiff,
'2
Dept. No.
VS.
ZAC~ (~6itL Defend,"t.

,-r1
_='--'=--'..l._--'-~.
i
\
SUBPOENA
You are,cOInmanded to apoear before the Reno Justice Court..t One South Sierra Street, Reno, Nevada
on the. 1Cj'l-r-_dayof
Nov.tYV\loly ,20 10!
o'clock D-....M.
to testify on the part of.
Failure 10 appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22.100
and/or NRS 50.195.
S?'?D
Dated this ..
-1J'1-~ day of._.I) L-tl)\.cR.N'
,20 \ y
i
,
!.
,.
,
STEVE TUTT("E
CLERK OF mE COURT
ny:1b:~--ow ~) l--\cA." Y\ UJV--.DeputyCler
STATE OF _ _ _. _ _ ._---')
)ss.
COUNTYOF ________~)
I, received this Subpoena on the . ___ day of._.... _ _ _ _ _..
_ _ _ _ _ _,' 20_ _ , and
personally served a copy of the same lIpon _ _ _ _ _ _ _. _ _ _ _ _ _,on the _ _ _ _ day

of
,20 _ _
,
,
t

_ _ _ _ dayof _ _. ___
Notary Public
"

COUNTY OF WASHOE, ST ATE OF NEVADA
STATE OF NEVADA,
Plaintiff,
?--
Dept. No.
VS.
___ 2'3 V\ fvvt>.HL- A(

~
h ft1Cvt~*(tvi3Lic5~rJ~
Defendant
v?t, V\
TO:
SUBPOENA
You U cF1';;nded to appear b~forthc Reno Justice Court ')I Qne South Sierra Street, Reno, Nevada
on the_--idayof_r\)I)\(.Q.\rv1jO_w_, 20~. 55--;)(')
o'clock GL.M.
to testify on tne part of
.
_
Failure to appear may be deemed a contempt of court and subject you to the penalty sel forth in NRS 22.100
andlor NRS 50.195.
Dated this
J.\'-1-h day of __. : C: . .~j\'.:.: : \:.:-\.: : C:;o:Y-~ ~o: V:. . . ._ _ _ _ _., 20jd-.
STEVE Tunui
CLERK OF TIlE COURT
By:~f\C\~(U_~\;)-D~~
Deputy Cle
STATE OF __________----.J
)ss.
COUNTY OF - - - - - -j
I, received this Subpoena on the _ _ _ day of
personally served a copy of the same upon _ _ _ _.
of
_ _ _ ,20_ _ , and
__on the _ _ _ _ day
,20 _ _

Subscribed and sworn belore me this
_ _ _ day of _ _ _ _ _ .
------------ ------Notary Public
"

Case No.
STATE OF NEVADA,
[? C R '7... e-/ , ---00 '53Z..d
Plaintiff,
2Dept. No. _______

VS_.
tvv$Jk{~
2A L-&J
T~\I \15f"WoV
SUBPOENA
Defendant.
S;;:()_~'t_ .~W:.....;e;;;,-.f~5~(?~-'_ _ _ .__
You are c9i"manded to a~pear before
thr Reno Justice
cor
2:~ne
So\llP. Sierra Street, Reno. Nevada
a.-.
on the
l~yof_I\JOV. .tYvi}':)ev _,20
at_:tL' ~C)
o'clock
.M,
,
Failure to appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22,100
and/or NRS 50.195.
, )\'\-h
Dated thi,
.""'-\
day of
STEVE TUn'LE
CLERK OF THE COURT
By:~0.-=/J%;;( &~'\V'V\JV'rDeputy Cler
STATE 01' _ _ _ _ _ _--')
)ss.
COUNTY 01' _ _ _ _ _ _ _),
__ .______ , 20_._. and
I, received this Subpoena on the _ _ day of _ _ _ _ _.
personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _.

01'.._. ______ _
on the _____ day
_ _ _ ,20_ _
_.
__
. - .... "........---.

_ _ _ _ dayof _ _ _ _ _ _ _ _.20_,
Notary Public
i
,
I
i

Case No.
STATE OF NEVADA,
IQ.LL..Lc>!\---e6'3~~ I
Plaintiff,
Dept. No. _ _-='----___

vs.
24c-H- Ccv#'L~"t.
SUBPOENA
R~1 o(lRc~"-,, 7c-y5-___ ALifK5'A
______ _
TO
i C1_'_
You
coll1/.!!l'nded to appear befory thy Reno lustice CouJ;{ at One South Siena Street, Reno, Nevada
on the_
tilayof~OVJ..m5t.Y__ ,20gat
-":lU o'clock O"'.M.
Failure to appear may be--:dee-m-edc--co-n-te-m-pt-o""f-co-u-rt-a-nd-c-su-:-b):-'
e-ct-y-ou-t-o-'th-e-p-en-oalty set forth in NRS 22.100
a
and/or NRS 50.195.
Dated this
l:
' t d a y of _
._-.l...O~(I_--h.u..:~~~>-8"":V'L____
\'d'
, 20 - - '
[.
I
I
STEVE TUHLE
CLERK OF THE COURT
BY~\' \cl~ \ l
,
Deputy CleA<
\()-L-"'<'\f'O.tV'\..
AFFIDA VIT OF SERVICR

STATE OF
)
)$S.
COUNTYOF _ _ _ _ _ _~)
I, received this Subpoena on the _____ day of __ _
_ _ _ _ _ _ _ _ _ _ _ _ ,20. _-' and
personally servo;<' a copy of the same upon_ _ _ _ _ _.

of
on the _ _ _ _ day
_______ , 20___ .

Subscribed and Sworn before me this
_ _ _ _._ day of _ _ _ _ _ _ _ _ " 20_.
Notary Public
I
,
f
.'
\ .....;

COUl't'TY OF WASHOE, STATE OF NEVADA
C"", No.
STATE OF NEVADA.
(2 c:.' r( '2~I/-() C)'5 J I
Plaintiff,
DeplNo.2
SUBPOENA
Vs.
~7{;,- (
TO:
[\
G'" JDefendat,
t \/ L
DUCES TECUM
<
/'
Lvvv,L '\:\S-d)\.:r
C/Ct:~( ~
___ _ _ _ __
J
[ivc,s/ky'
q tl;,v 11'<"- 1"
JU$tiee,C~rt a~One
You are eOlanded to deliver the above mentioned_dclcuments beforetlPe Reno

South Sierra Street, Reno, Nevaea on Of before the
'I
day of
J 10 v..,..~V'>..Jv
_at
')0
o'cIockC~. on the part of
c'-C V. . . .
c VI r \
Fcc'a-:-j(=-ur-e-to-d-e""l;=-ver may be deemed a contempt of court and subject you to the penalty set forth in Nf{S 22.1 ()()
and/or NRS 50.195.
I f
;<;
DATED In,s
'2'
Co- '-
_~~,_ day of
STEVE TUTTLE
Clerk of the Court
STATE OF NEVAlJA,
County of Washoe
)
) SS.
)
I receIVed this Suhpoena on the ____.____ day of _ _ _ _ _ _ _ _ _ _ _ _ _ _~

_ _ _ and personally served a copy of the same upon __._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,
on this _ _ _ _ _ _ day of _ _.

this
. day "I'
NOTARY PUBLIC
rev 0412009
!
J
"
"

STATE OF NEVADA,
Case No.
PlaintIff,
r'-Z-i7.. CC ii-ct.] 'y'-;(
Dept No._2
SUBPOENA
Vs.
DUCES TECUM
1./ le~}
---------------------------------
9ne
. You are commanded to deliver the above mentioned dO;''l'rents befP,fe the Renr' Justice Court at
ITa Street, Reno, N~x~da on or before the ____
I Lrl'1lll1r of /i I(.'v-<'-V1 . J...,y-___
--L.e>
'
'>(.
o'clock L."-M. on the ~art of. -Z::A, l
='\
.
22.100
andlor NRS 50.195.
t.- .
S (",,,NRS
South
DATEDthiS~x4'-+lv'::. __ daYOf
'()~k\~v _
J..t \'}-
STEVE TlJITLE
Clotk of the Court
Bc~\.Y\cL~ ~\ ~U\\'Y(\I\.,.
Depuly Clerk
STATE OF NEVADA,
"\
)
) SS.
County of Washoe
I receIved this Subpoena On the __________ day of _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
and personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _ __

on this ______ day of __ _
Signature of Person Malang Service

this
day of
NOTARY PUBLIC
rev 0412009
"

Case No.
STATE OF NEVADA,
Plaintiff,
gCC2o/-tJC9~
Dept. No,
VS.
2u: h
CoY({ A~ ~\
UDefend.nt
'2
SUBPOENA
\)
-r:~!t/'v~n_
vee'S
TO:~ ?c2,b~ r A~T'-sh-~~~ ~~~~{1

you JIe coM.nded to appear belPre, the Reno Justice Court at Ooe South Sierra Street, Reno, Nevada
onthel_ Iy'l--h day of I\JOV..Qmmv
,2~ _,at ~(,~O
o'clockc'-,M.
to testify on'The part of
-~-:--~--'----:--:--;:-77--:-::~::::-::=-'
Failure to appear may be deemed a contempt of conrt and subject you to the penalty set forth in NRS 22.100
and/orNRS 50.195.
!i'-\.t\
Dated this _-=-1_

.. _
C t:.t-G -=:=-----._, 20 ---.

v2ltY
I),
day of
STEVE TUTILE
CLERK OF THE COURT
By:~txj.C4~ ll.o LA ''V\Cl\h''-../

Depuiy
erk
AFFlDAvrr OF SERVlCE
STATEOF _ _ _ _ _ _ _~
)5S.
COUNTY OF _ _ _ _ _--')
I, received this Subpoena on the ____ day of _ _ _ _ _ _ _ _ _ _~.
, 20_ _ , and
personally served a copy of the same upon___________ ..__________ .._ ._____on the _____._ day
of
,20_ _ .

_ _ _ day of _ _ __
Notary Public
,.
.
..
Rob Bony
From:
Sent:
To:
Cc:
Subject:
Kelley Odom [OdomK@reno.gov]

Saturday, November 03, 20128:53 PM
Rob Bony
Kariann Beechler
Fwd. FW: request for audio records
Hi Rob,
Here's one we got today.
Kelley Odom
Assistant Manager
Reno Emergency Communications
P.O. Box 1900
Reno, Nevada 89505
(775) 326-6610
Fax: 775-326-6698
Odomk@reno.gov
"Life isn't about how to survive the storm, but how to dance in the rain."
''The information transmitted in this e-mail andanyattachments.includinganyaudio/videofiles.is
intended only for the person(s) or entity to which it is addressed, in response to an official request
for information. This transmission may contain confidential and/or privileged material which is
protected by NRS 179(A) from further disclosure, It is intended for official use only. If you received
this message in error, please contact the sender and delete the material from the computer or any
transfer media."
-----Original Message----From: Zach Coughlin <zachcoughlin@hotmail.com>

To. "'Eeom mOps@reno.gov"' <ecommops@reno.gov>, "odomk@rcno.gov"' "odomk@rcno.gov>, "beechlerk@reno,gov"'
<beechlerk@reno.gov>
Date: Sat, 3 Nov 2012 20:18:12 -0800
Subject: FW: request for audio records
Hi ECOMM,
RENO JUSTICE COURT CASE RCR2011-063341 D2

THIS IS A SUBPOENA FOR
STATE OF NEVADA, PLAINTIFF
V.
ZACH COUGHLIN, DEFENDANT
"
SUBPOENA AND SUBPOENA DUCES TECUM
",.)
ATTN: YOU MUST COMPLY IN ACCORD WITH JCRCP 45 AND OR NRCP

45
ATTN: CUSTODIAN OF RECORDS ECOMM, KELLY ODOM, CITY OF
RENO, RENO POLICE DEPARTMENT ETC.
Please just send me (preferably by email) any and all recordings or documentation
of any sort involving Zach Coughlin or Zach Cuoghlin, whether with a date of birth
of 9/27176 or 91l176, or any other DOB, including for Zachary Coughlin or Zach
Caugh lin or any iteration of those names, including dispatch recordings (not just
the 911 calls, by all recordings, including communications with the police officers
or other law enforcement personel), including those in any way related to incidents
or arrests on, but not limited to, the following:
August 20th, 2011 arrest at IOn. center st by RPD Duralde, involving Officer Rosa
and OFficer Alaksa as well with various 911/rpdldispatch calls including some
made by the following numbers
any call ever made from or to:
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
7752296737
or 775 338 8118
9496677402
also, my former Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena Jor these matrials
on 10 312. J got Leslie removed and am now representign myself in RCR2012-063341. Leslie says ECOMM
and ODOM failed to produce anything or respond in any way ... which I doubt...so please just include the
response to that subpoena in what you send me
i also want anything related to the following criminal cases:
in the Reno MUnic Court 11 cr 22176 (occuring at the w. 2nd st. walmart on 9/91 II at around 9 pm, arrest by
RSIC,
.'
NOve~ber 13th, 2011 arrest in R~ 11 cr 26405 (arrest by reno pd at 121 'Rfver Rock St. reno 89501 at
sometime around noon)
November 30th, 2011 arrest by reno marsbals in 11 er 22176
january 12th, 20 12 arr~st in rmc 12 cr 00696 (at 121 River Rock 89501 as well, please include anythign related
to Richard G, HIlI or Matt Merliss's calls to law enforcement, including anything on Hill's tpo in rcp2012000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill st.
january 14th. 2012 arrest in rcr2012-065630
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in
any way connected to coughlin on or around the 1422 E, 9th St #2 address between december 1, 2011 and the
present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshec or Laura Petrone
anything related to reno marshal rmc arrest in II tr 26800 on 2/27/12
anything on the 11/15/11 incident resulting in II tr 26800 on st laurence involving the rpd, sargent tarter, 652
forrest Sl. richard hill. ctc.
rcr2012-067980 (anything on the june 26th, 2012 ancst by weso deputy machen and bowman, and in fact
anything involving Zach Coughlin and any law enforcement figures at or around North"inds Apartments at
1680 sky mountain drive and or Superior mini storage at
1. Google+ page
7795 White Fir Street Reno. NV 89523

(775) 746-4322
or at somc west tourth street address or Superior MIni STorage, especially on or around september 22n.
2012 whether involving ofticer alan weaver or
sargent oliver miller or not. including calls tor law enforcement response hy matt grant (a woman) or k.
grant or marvin dye or anyone with superior mini storage
,
t
the july 3rd. 2012 arrest in nne 12 cr 12420 AND ANYTHING AN EV ER YTHING OTHER WISE
RELATED TO ZAnl COUGHLIN IN ANY WAY, DONT FORGET THE JAN 132012 STUFF
WITH SARGENT LOPEZ Al\D OFFICER WEAVER AND AVILA, ALL THE SARGENT SIFRE
STUFF.
ANYTHING IN CR 12-0376 .. .ANDYTHING IN MH 12-0032
I am subpoening all these materials incident to Judge Sferrazzas 10/22/12 ORder in RCR20 11-063341,
which he granted me the right
to issue these subpoenas upon yOli without paying up front the ",itness fees or other expenses (lFP)
THanks,
..
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 201111:04:35 -0800

From: EcommOps@reno.gov
Subject: request for audio records
Mr. Coughlin,
Your request for audio records has been received. However, I do not have sufficient information to process it.
Can you tell me the date and time this occurred, along with the location so I will be able to locate the call.
Thanks,
Ella Mae
..
v
Rob Bony
From:
Sent:
To:
Cc:
Subject:
Kelley Odom [OdomK@reno gOY]

Saturday. November 03,20129:51 PM
Rob Bony
Kariann Beechler
Fwd: FW: request for audio records
And another one ...... he's named Reno Direct on this one.
Kelley Odom
Assistant Manager
Reno Emergency Communications
P.O. Box 1900
Reno, Nevada 89505
(775) 326-6610
Fax: 775-326-6698
Odomk@reno.gov
"Life isn't about how to survive the storm, but how to dance in the rain."
!
"The information transmitted in this e-mail and any attachments, including any audio/video files, is
intended only for the person(s) or entity to which it is addressed, in response to an official request
for information. This transmission may contain confidential and/or privileged material which is
protected by NRS 179(A) from further disclosure, It is intended for official use only. If you received
this message in error, please contact the sender and delete the material from the computer or any
transfer media."
-----Original Message----From: Zach Coughhn <zachcoughlin@hotmail.coll1>

To: "ecommops@renogov" r:ecommops@reno.gov>, "odomk@reno.gov" <odomk@reno.gov>, "beechlerk@reno.gov"
<beechlerk@reno.gov>, "ZYOUNG@DA.WASIIOECOUNTY.US" <zyoung@da.washoecounty.us>, "kadlicj@reno.gov"

<kadlicj@reno,gov>, "WONGD@RENO.GOV" <wongd@rcllu go, >. "Istuchell@washoccollnty.us" <lstuchell@washoecounty.us>.
"renodirect@reno.gov" <renodirect@reno.go\,>
Date: Sat, 3 Nov 2012 21:30:08 0800
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
!
I
..
Zach has 2 files to share with you on SkyDrive. To view them, click the links below.
103'
10 i
rmc subpoena 063341 TO ECOMM ODOM AND OTHERS. pdf

0204 ECOMM SUBPOENA.pdf
Download all
From: zachcoughlin@hotmail.com
To: ecommops@reno.gov; odomk@reno.gov; beechlerk@reno.gov
Date: Sat, 3 Nov 2012 20:18:12 -0800
Hi ECOMM,
RENO JUSTICE COURT CASE RCR2011-063341 D2
THIS IS A SUBPOENA FOR
STATE OF NEVADA, PLAINTIFF
V.
ZACH COUGHLIN, DEFENDANT
AnN: YOU MUST COMPLY IN ACCORD WITH JCRCP 45 AND OR NRCP 45

AnN: CUSTODIAN OF RECORDS ECOMM, KELLY ODOM, CITY OF RENO, RENO
POLICE DEPARTMENT ETC.
Please just send me (preferably by email) any and all recordings or documentation
of any sort involving Zach Coughlin or Zach Cuoghlin, whether with a date of birth
of9/27/76 or 9/1/76, or any other DOB, including for Zachruy Coughlin or Zach
Caughlin or any iteration of those names, including dispatch recordings (not just the
911 calls, by all recordings, including communications with the police officers or
other law enforcement personel), including those in any way related to incidents or
arrests on, but not limited to, the following:
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa
2
"
"-,
and OFficer Alaksa as well with various 91llrpdldispatch calls including some
made by the following numbers
any call ever made from or to:
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
7752296737
or 7753388118
949 667 7402
also, my fomler Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena for these matrials
on 10 312. I got Leslie removed and am now represcntign myself in RCR2012-063341. Leslie says ECOMM
and ODOM failed to produce anything or respond in any way ... which I doubt...so please just include the
response to that subpoena in what you send me
i also want anything related to the following criminal cases:
in (he Reno MUnic Court II cr 22176 (occuring at the w. 2nd sl. walmal1 on 919/1 J at ~round 9 pm, arrest hy
RS1C,
NOvember 13th, 20J I arrest in RMC II cr 26405 (arrest by reno pd at 121 River Rock Sl. reno 89501 at
sometime around noon)
November 30th, 2011 arrest by reno marshals in 11 cr 22176
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 8950 I a~ well, please include anythign related
to Richard G. HlIl or Matt Merliss's calls to law enforcement, including anything on Hili's tpo in rcp2012000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill 51.
january 14th, 2012 arrest in rcr2012-065630
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law entorcment in
any way connected to coughlin on or around the 1422 E. 9th St. #2 address between december 1, 20 II and the
present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
anything related to reno marshal rmc arrest in II tr 26800 on 2127/12
anything on the 11115111 incident resulting in 11 tr 26800 on st laurence involving the rpd, sargent tarter. 652
forrest sl. richard hill, etc.
.
rcr2012-0679&0 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact
anything involving Zach Coughlin and any law enforcement figures at or around Northwinds Apartments at
1680 sky mountain drive and or Superior mini storage at
1. Google+ page
,
Ii
7795 White Fir Street Reno, NY 89523

(775) 746-4322
or at some west fourth street address or Superior Mini STorage, especially on or around september 22n
2012 whether involving officer alan weaver or
sargent oliver miller or 110t, including calls for law enforcement response by matt grant (a woman) or k
grant or marvin dye or anyone with superior mini storage
the july 3rd, 2012 arrest in rme 12 cr 12420 AND ANYTHING AN EVER YTHfNG OTHER WISE
RELATED TO ZACH COUGHLIN IN ANY WAY, DONT FORGET TllEJAN 132012 STUFF
WITH SARGENT LOPEZ AND OFFICER WEAVER AND AVILA, ALL TIlE SARGENT SIFRE
STUFF,
ANYTHING IN CR12-0376 ... ANDYTHlNG IN MHn-0032
I am subpocning all these materials incident to Judge Sferrazzas 10122/]2 ORder in RCR20 J J063341,
which he granted me the right
to issue these subpoenas upon you without paying up from the witness fees or other expenses (lFP)
THanks,
Zach Coughlin
1471 E. 9th 5t.
Reno, NV 89512
Tel and Fax: 949 667 7402
Date: Fri, 23 Dec 201111:04:35 -0800

From: EcommOps@reno.gov
Subject: request for audio records
Mr. Coughlin,
Your request for audio records has been received. However, I do not have sufficient information to process it.
Can you tell me the date and time this occurred, along with the location so I will be able to locate the call.
4
Thanks,
Ella Mae
"
v
No. RCRll-1J633~1
Dept
2
"'0.
Sl'BPOENA DUCES TECUM

I), THE JUSTICE comn OF RENO TOWNSHlP
COL':-iTY or WASHOE, STxrE OF NEVADA
On
to Iestify
NOVEMBER 1 9T1-f , 7012
for ~he abovc~nml1ed
IMfendam
AT 8;30 AM IN 02, BEFORE HONORABLE JUDGE SFERRAZZA
i\;';Y PFRSOr-. f AlLiNG TO APPFAR M,\ Y BE HELD IN CONTEMPT OF COURT

ACTOR IJING TO NRS E I 00 THE PPJ,'IL TY FOR CONTEMPT Of COtrR-r IS A
FlNL lip TO $'00 ,\NT)lOR 15 DA YS IMPRISONMENT
DnlCd' 11/6/12
Zac:h Cough 1 in, E5q.
147l e
IfyOll h,we any qUt'stiuns

[~garding
your uppeurarrce, ple(tS~

contact; Zach Coughlin at
9:...1". st.
reno, 8;1512
949 667 7402
By Zach coughlin
1471 S. 9th StReno,
NV 89512
lei and fax' 949 667 )1402 ZachCougr.lin@botmail.com

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11/6/12
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SLBPOENA Oq::ES n:CV~l

)" THE lUSTreE Cot'RT OF RE"10 TOWNSH!P
COU~TY
OF WASHOe, STc\ TE Or l'EVAD,\
Tm STATE. OF 'lEV ADA, Pl3imitt,

vs.
ZACHARY BARKER COl'GHLlN. Defendant.
m~])---rirckr ()yq !~
FRO\t
ZAeR COUGHLIN, ESQ. (Attorney temporarily $\..spendt!d in Nevada self represented)
PURSl'ANT TO NRS [74315 WE COMMAND YOU TO APPEAR BEFORE

Department 2
Reno lu>rice Coun
One South Skrra Street. Reno,
On
Nl:v~ida
NOVEMBER 19TH, 2012

\(1 testify [\Jr Ilw ahQ'C-n,mled Dt/cndant
AT 8130 AM IN 02, BEFORE HONORABLE ,:'U)GE S?RRRAZ7..A
A '>Y PFRS(J\ FA1U!\!U TO APPEAR M,\ Y BE HELD IN CON iTMl'T OF COURT

ACCORDiNG TO 'IRS 2c, 100. TIlE PE"I.'\LTY fOR CO"TE~IPT Of COUR'f is A
FINE UP TO $500 AND/OR 25 DA YS lMPR1SUNMEI'T
Dated:
D~
11/6/12
Zach Coughlin, F.sq.

1471 e. 9th st.
reno, 39512
Zach Coughlin
(st:;::pended <lt~O(:le.,..)
If :ou t.ave .my questions

rcga.rdm~ your ap~an.HKe. pka.'.>c
COlltuct: 7,,,ch C(mgblln at
949 66-;'
74.02
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Reno, NV 99512
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tel wHililX:9F! (,(,7 710"
HENO .IVSTICE ,OIlHT

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or Nf'Vidl,\ cot!'" I Y OF WASIH)L
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\ dcfC:l1"il'; 1)nut'til~n~." J74.2\)5
Continuing duty to dl~dosc:; h,"urc to t:omplJ~ sanctions
rcquc.~! for 1\ RS t 74,2JS Dhein,,, 1'(' h,' prosecuting attornc" "I' "",deuce relating 10
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i( !b'LI3,e(LQ,~y~jc~,CQl!rt in Depart!lli'.!!!l."U..:. $iWa _~t, B!mQLNV.,?JI?.Q2 onJlovel)lberjj)ll:l,

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2012aH;3,1L;lm. to Je:;!ify Qil, the !1!1!t..Qf.l.~chaJY, 6ar~!,r CQ!!9,1]jjn, Fililul'e..~!lY.J1Qrs.Ql1
III witl:1,Qut adequatee!~lgl!'.tQ.Q!?(;Y!!.!!!m9.'Lf!'Lse]Ved \!porl,that !?llion may be ,deemed a
!c.o!l!.'llilpt of the COllrt
Ii PL~ASE iIl9TE THAT _THIS MAY NgT 6f; A. LA,;,,!f\!L COMMMD, AND_ TH!;B.!"FOBRYQ'J, M~ Y
, II QR.MAY N9T l?,I;, Et.J.TITLED IO.J.\'>JI!9R!;.1 AM NOT PBQ\lIPI/ll.QYQU lEc:>AL ,AR\I!C~ IT

I MAYJlE..T.9Q ~AJ_E TOO LNllQll.....THIS SUJlP9J:'NA TQ B!;,SEBIL"D OIi.YQJ1..lli.-UIJ\IIELY
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TI:IAT_DESPIR9Q.!J~!:IqN,6J;LN~ ?_USp'E;NR.EQ!iEMAY~~UE~
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WITNES,~.g.!OS AJ..A1hQ,~ AJ .bEAST !JP..B9111L.ItlEJ=_XIGENCII;:!LQ.
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N.QJ
DQ~_UM!;N]'
CONSUL T YOUR OWN ATTORNEY REGARDING WHEHU';B. OR
.TIllS
NRS 174.315 Issuance of subpoena by prosecutmg atlomey or attorney for defendant;Jltomi!;e to

'!.Ime aG
,Any.9J!!LWishjng 10 is)!ue Z~'.!!..~Qughli~I1!Qmis.~ 10 aI1PJlA!, pl,!a",g emaiL!1 to him at:
~c.!Jcoug!:!IjIJ@M.!!llJ!il..com 9rJax 1(> M~ 6F 74.!1?
NRS 174.345 Service of subpoena
___L!,:x!;.~pt as Qther.yis~ovided tn NRS 174,:!.1, .".subpoena to attend aJllisdemeano,r

trial m"y' be !;rve(tby' mailing ~he.s.ubpoe"aJo th\LP~r~Qll tQ. be s.erve<i J~y'!ggislered or
cerli!!~<L]1laih.Jet!!m.Rc.!ljPl!lt9.\!.e!it!!q.!!:Q!llJh'!t.p'ersoJ1, in.a stli!le.QJ!Q!tlpaid cny-clope,
3.ddres.s!l(!Jo tll.!! rulrson'.!L!i!.stknQwn !'.!l<!re!;s, I}Qt..!ess tha.r).10 9j1ys.b.EltQ.r.~ !he tri<!Lwhjch
the5ubpoena.~oml)1an(\~"~e PJ"rs_Q11J9. atteng,
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3 If a subpoena IS s9rved by n'all a cer!lka!e of Ihe mailing must be filed with lt1e court within 2
days after the subpoena is mmled
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T0. Aliso" M Ormaas Pam Roberts Chllstopi1er HazleltStevens Brian Sooudi Company' Reno
Clly Attorney Andress Cine East FilS! Street. 3rd Fioor P.O. Box 1900 Reno. NV 89505 Phone
L'
Number ~.- Fax number (15<~34-422t1 Email oflnaaSLl@reno.goli_ halJett-stevensc@reno.gov,
II robertsp@reno gov, SOolldib@reno go';
'.'
Joel Harley. and Scott Coppa and Townsend. and Marshal Court Marshal RMC, clistodian of
recolds city of (eno Marshals D'lvlsi:>n. cmd Chief JU$tlrl Roper
roper;@reno gov
renomarshal@reno go'J
harleYI@reno gOY
1 South Sierra Street Reno NV 89502 :(75) 3265125
Chief Marshal Juslln Roper (334 1254 Fax 3341260, roperj@reno qov)
I '"
I! Pam Longan. RMC exculSlve transcnphonlst demanding down paymer.r from Grlmlnal defendant
I appelants ,n vlolalion of nevada law. Donna Balial(j
plongonl@char\er.net clo !~8no Mune'pa! Calln
' 1 South Si"rra Street Reno. NV 89502 fox 775 334 3824 ballardd@reno gov
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II Reno mUniCipal Court cllslo(\lan of records, alld Marilyn Tognom, and thEo "clerk of court for
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IDepartment 3" refelenced II) SAN's Pat King'S corrspondence to Coughlin alleging some reports of
i the clothing Coughlin wore to the filing office counter at
the RMc In March 2012, and any submIssion I
i by the Reno Marshals, Usa Wagner. AdmHllsrrat.ve Judge Wilham Gardner, Judge Dorothy Nash
IHolmes Judge Kenneth Howard. Cassandra Jackson, Usa Wagner, Veronica Lopez
I I South Sierra Sireet Reno. NV 89502 (775) 326"0125, renomunicrecords@reno gov,

'1 Chflstensend@renogov.iax7753342420,'!153343824
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Northwlflds ApartmBnts ASSOCIate LLC

Manage Duane Jakob, IOU cADIA mIU,N kRE:BS
1680 Sky Mountain Or
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:IlPI)I:;o..I,\ ANI) SllIWOI:N;\ 1)1 CFS TITIIM
NEvada Courts Selvices

Nevada Court Services
475 So. Arlington SUIte 1f,
Reno, Nevada 89501
(775) 348-7560
I (Toll Free) 800-570-5583
, Fax: (775) 348-7977
Email.neVCS@nevcs.com
JOel Durden, Ryan Wray, Jeff Chandler, Jennifer Chandler, Cedomo, and Nevada Court SErVices
, Custodian of REcords and "Slati Attorney" LewIs Talle!. Esq.
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RIchard G Hili, Esq and Custodian of Records for Law OIfice of Richard G, HilI, Esq
Hill Company. - Address 652 Forest St - Reno NV 89509 Phone Number 77td480888 Fax number 775-3480858 Emali rhlil@richardhll!aw com
" i Richard G,
J,
Casey D BaKer Custodian of Records for Baker & Baker Law Offices. Pll.C Adaress' 432 W Main
St, 2nd Fir PO Box 25 Danvllie KY 40~23 Phone Number' 859-2382233 Fax number 859~39! 0028 Emarl coaker@centralkylegal com WebSite,
" I WCSO Custodian of Records and L,z Stuchell, a~d Roxy Sliva, and Deputy ,John Machen, Patricia
I,
"
Beckman, Debl Cummings, Jason Hodge, Deputy Beatson Madeline C JOnes, Deputy Van Der
I Wall. Nurse Kathenne. Deputy Michael R HoeKstra, WCOC Medical!Nufsing Staff Custodian af
, Records
jmacnen@washoecounly us, Istucnetl@w"';hc)ecounty us, rsllva@washoecoumy uS
Washoe County Shenff's Office Locatlon'911 PalT Blvd, Reno, NV 89512Main Phone'775328-3001
Emml"shenl1web@washoccounty.us
'" I fax 775 3286308

911 Parr Blvd Reno, NV 89512 FOlenslc SCIence D,VISion at (775) 328-2830 The lax number IS
1(775) 328-2831,
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and please do be sure to give me your views on proper service, there, WGSO Civil DIviSion
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I Roberto Puentes Company
- Address 416 Ridge SI - Reno, NV 89501 Phone Number' 775-786- !

117676 Fax tlJIr;bcc 7751868720 Email PUENTESLAW@AOL COM
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Keith lloyd l.OO'OIS Company - !\ddress 9468 i)outJle R Blvd SUIte /\ Heno , NV 89521 Phone
775-853 7222 Fax nLmber 7758530860 Emaii. ke,thIQomls@earthllnknet
'I' Number
, 'j
bdogan@washoecounly.us
iBway Dagan, Jim Leslie,and Joe Goodmgl,t, ana Eva Nov31<

"
Company, Washo~ County Publrc Defender's Office Address, P,O Box 30083 - Reno, NV 89509
, Phone Number 715-337-4868 Fax numbol i'75 3374856 Emali:Jleshe@washoecounty us,
BDOGAN@VIJ\SHOECOlJNTY US, JGOOONIGH f@WASHOECOUNTYUS
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I Mary Margaret Kandaras Company' Washoe County Dlstnct Attorney Address One S Sierra St.
P,O Box 30083 Reno, NV 89520 Phone Number 775-337-5700 Fax number 775-337-5732 Email'
mkandaras@da washoecounty us
ciTY OF RENO/RENO POLICE DEPARTMENT,

775-334-2121 Police Department. 455 E Second Street Reno, NV 89502 Directions Email
askrpd@reno go~
Deputy Chief Mike Whan (334 3849, Fax 334 3890, whanm@mno,gov ) Lieutenant Keith Brown
(334-3845, Fax 334-3890, brownk@reno gov, rOBERT oONY BONYR@RENO GOV
PLEASE PROVIDE THE VIDEO FOOTAGE OF THE EVENTS LEADiNG UP TO AND THE
ARREST THAT STARTED ALL THIS ON AUGUST 20TH, 2011 FROM BETWEEN
APPROXIMATELY 1110 PM TO 12:30 AM ON aUGUST 21ST, 2011 A LlTIGf\TION HOLD
)
NOTICE OF SORTS WAS CERTAINLY PROVIDED, AT LEAST TO THE' RPD AND ARGUABL Y
TO THE CITY OF RENO AND CITY ATTORNEY'S OFFICE AND THE SIGN IN THE SKATE PLACEI
AT 10 N CENTER ST INDICATES THF RPD IS VIDE:O MONITORING WITH "DOWNTOWN
i" 1'1' PROPERTIES" AND THEIH ClE:ARL Y ARE VIDEO CAMERAS PLACE: ATOP CITY HAL,-, WHICH
,
OVERLOOKS THE SCENE OF I HE ARREST ALL OF THIS SHOULD HAVE BEEN
PROPOUNDED ALREADY in re,20' 1 063341
Officer Nicholas OUl'alde d,rralden@reno :JOY
Ron Rosa rosal@Jeno gOY
, Thomas Alaksa alaksat@reno gov
Sargent MarCia lopea lopezm@r2no go,
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officer travIs warren wal rent@renQ gOY
i officer chriS carter carterc@reno 90'1

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sargen~ paul srfie sdrep@reno
gOI)
officer jason schaur schaurJ@reno gOY

,
officer alal1 hollingsworth holllngsworlha("Jreno gcv
1)' officer trav,s look lookt@renogov
officer wesley leedy leedyw@reno gov
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officer alan weaver weavcra@reno gov

rpd sargent bnan dye dyeb@reno gov
sargent oliver miller miliero@reno gcv
Illetn kellh brown brownk@reno gov
. " III
,', Isargent kim bradshaw bradshawi<@reno gov

PLEASE BE: SURE 10 INCLUDE pH ECOMM DISPATCH RECORDINGS (INCLUDING
., I THE CONTENTS OF COMMUNICATIONS BETWEEN DISPATCH AI';D THE OFFiCERS, PLEASE I
,i
)': INCLUDE THE VIDE'O OF IfiE SKATE. Pl.!\lE: AT 10 N CENrm ST ADN NEAR FIRST AND
I
, '1\ VIRGINIA INCLUDINC3 THE CAMERAS AIOP en Y HALL.. CONc;DIH~li'>ICi TH[ SIGN IN THE
I
SKATE: PI AlA THAT INDICP,TES THE IWD IS ViDEO HECOROING 'II IE: AREA, AND THE
I
RENO AND "PO WERE PLACED ON SHOR TL Y
", II AFTER THE ARRE:ST OF AUGUST 20TH, 2011 IN RCR201 \-063341 SHOULDN'T BE TOO
:,
I HARD TO SHOW WHETHER OR NOT THOSE SKA TERBOARDS WERE TELLING THE TRUTH !
SURE MAKES A LOT OF SENSE TO BET ON fHE 18 YEAR OLD SKATE:BOARDERS VERACITY
i' VERSUS THE 35 YEAR OLD ATTORNEY'S THOUGH, No reasons at all 10 take a more C3utlOllS ,
"~I approach than was laken, probably
"
I LITIGATION HOLD NOTICE THE CITY OF
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Zachary N Young Company Washoe County DA Off,ce Address 1 Sout!' "Ierra POBox 30083
Reno, NV 8%20 Phone Number. 775-328-3200 Fax number T15-32S-6703 Emml
IILYOllng@da,waShOeCGunty,us
1;
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please be ready to testIfy regardIng you partIcipatIon 'n the clandestIne status conference 0 2/27/12
and the 131 pm file stamped ORder for Competency Evaluation In RCR2012-065630,any
communications with or to anyone with regard thereto, your alleged multiple vlolahons of nrs 178405
PatriCK 0 KIng Company State Bar at Nevada Address 9456 Double R Blvd Suite B Reno, NV
89521 Phone Number 775-329-4100 Fax number 775329-0522
please produce any materials related to Zachary Barker Coughlin in any way, shape or form, and be
present and ready to testIfy fully regarding the RMC MarShal peering through Coughlin's bathroom
start (not exactly in the "Immedlate presence of the court", now is It, sufficient for a "summary
crimInal co!\\empt" conviction" CIted on the record by Judge Nash !-1alme,; on 311211 2 In 11 Ir 26800
! by the Marshal and Ihe VIolatIons of tne courthouse sanctuary doctnne by Marshal Harley on behalf I
of Deputy Machen, on bella!! of RIchard Hili to se"le In front of ORmaas the ORder to Show Cause '
In the appeal of the "chard 9 hIli eVIction matter '" cvI1-,03628, as weli as any and aillniormallon or
I cJocument<Jtlon related 10 Ihe "receIpt" by the weso of any and atl Orders of any sort (or any
correspondence whatsoever) In connection WIllI RJC rev2011-001708, rei re,,201 2-001 048, rcr2012-!
06798.0 and any olher Platenal, related to Couglliln and Norlnwmd'i /\partments Associates and or
Supenor Mlnr SI mage ilnd all mater,als llmalll"IJ ihe pracHe"s ano poircles of the wCSO WIth
respecllo maIntaining documentation or transfel flng doclimentation concerning or prOVIding proof of
when the wcsu FIRST rec8'ved or came to have "recerpt' 01 any 50rl of a,ders related to an eVIction I
vis a VIS nrs 40 253 or otherwIse. includl:19 the name of the lOCKsmiths dOing any and aIJ lockouts of
,1 'I coughlln_ and medIa gathered by the wcso, anythmg related to the booi'Jng .nto evidence of the
malenals retrreved by the RMC's Marshals after the period in which tilose Marshals could have
I lawfully conducted an ~earch Inc.dent to arrest. and ~herefore violative of the fourth amendment
I!
!where no wanaqt or otner basts for so f"'"tne'Ving sucn mate-flals has been admItted to,
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'CustodIan Courts Admln'strator 325-6617 Mental Health Court for SEcolio JudiCIal Di5tnct Court
Speclahty
Sh,ela Leslie
oj Recolds fax Ti5
II
III Rene BIondo 715 325,6605 ami Isotcl Meadows 7h 325-6650
II
7b Court Streel
Reno, NV 89501
(775)328-3110
shlela feslle@washoecnurts us, rene Dlondo@washoecourts us, Isabel meadows@washoecouns,us,
joey_hastrngs@washoecourls us
,
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" I Ella MaE, Carther:
Kelley Odorn, i<arianr, Reechi". fCOMM

Operations
, COR Emergency COmmUf1lcatrons
ISupervIsor lIne (775) 334-2399
Off,ce line (775) 326-6613
)(
,carthene@~eno
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gov, odomk@renogov. beechlerk@renogol!
ecornmops@renc gOY
I ECOMM CUSTODIAN OF RFCORDS AND KF! LY 0001,1 AND KARIANN BEECHLER AND RENol
Ii DIRECT AND CITY OF RENO, WASHOE COUN~~:StiERIFF'S OFFICE, WASHOE COUNTY
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SI 11 lI'O EN A ANI) ~WIll'OI.Nr\ P\lCES TECUM
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DISTRICT ATTORNEY'S OFFICE, RENO MUNICIPAL COURT, CITY OF RENO, RENO DIRECT,
SECOND JUDICIAL DISTRICT COURT, RENO JUSTICE COllRT, CUSTODIANS OF RECORD
YOU ARE COMMANDED to appear before the the Honorable Peter J Sferrazza in Department 2 of
the RJC on November 19th. 2012 at 8'30 am to lestrty on the part of Zachary Barker Coughlin
Failure by any person without adequate excuse to obey a subpoena served upon that person may b
deemed a contempt of the court from which the subpoena Issued. {Nevada Rules of CIVIl Procedure,
Rule 45(e)] , please be sure the materials you provide Included. but are not limited 10'
Please just send me (preferably by email) any and all recordings or documentation of any sort
Involving Zach Coughlin or Zach Cuoghlln whether with a date of birth of 9127176 or 911176, or any
other DOB, including for Zachary Coughlin or Zach Caughlin or any Iteration of those names.
including dispatch recordings (not Just the 911 calls, by all recordmgs IOcludlf1g communications with
the polic"B cH,cers or other law enforcement personal). including those in any way related to inCidents
or arrests on, but not limited to. tile follOWing
(.
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August 20th 201'1 apest at 10 n center sl by RPD Duralde. I,,",oivlng Officer Rosa and Officer
by thc following numbers
I . ,. Alaksa as well With valla US 911 hpdidispatcll calls Including some made
any Gall ever made lram or 10.
7753786673
7758153680
7752338593
\
7752303726
7753043004
7152330367
775229 6737
;i
~r"775
338 B118
9_49 667 7402
;,
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. I
i also, my former Washoe County PubliC Defendel Jim Lesiie served Keliy Odom a subpoena for
I
I
I got Leslie removed and am now ",presenllgn myself in RCR2012~

1063341 Leslie says ECOMM and ODOM fa,led to produce anyth,ng or respnnd in any way. which I
, doubt. so please Just Illclude the response to that subpoE'n~ in whar you send me
.
I
1
III also want anyll1109 related to n,e follOWing criminal cases
rcr2011-063341 (petty larceny arrest near 10 n. center 51 on August 20th. 2011 by rpd officer !1\ck
duralde (your dispatcher JESSica Durald'es husband) With assistance by rpd thomas alaksa and ron
rosa (please Include anything about th 1994 laWSUit agalns rosa as a~ officer in second JudiCial
.' , district courl)
! in Ihe Reno MUnic Court 11 cr 22176 (occuring at the W 2nd sl. walr1art on 919111 at around 9 pm,
Ilarrest by RSIC,
, Iii NOvember 131h. 2011 arrest In RMC 11 cr 26405 (arrest by reno pd at 121 River Rock St reno
, 89501 at sometime around noon)
c.
! these mamals on 1U 312.
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()' I~ "
SI'IlI'!lI:NA !\ 'II) <,UBI'OENA DI i(,I'S II:( t:M
"
, November 30th, 2011 arrest by reno marshals In 11 cr 22176

"
january 12th, 2012 arrest In rmc 12 CI 00696 (at 121 RlVer RocK 89501 as well, please Include
anythlgn related to Richard G Hili or Matt Merllss's calls to law enforcement including anything on
I HilI's tpo In rcp2012000018)
, January 13th pullover by rpd durnlde el al of coughlin on near 252 mill sL
lanuary 14th, 2012 arrest \0 rcr201206S630
any of the 911 calls or dIspatch recordings related lo any mcidents or responses thereto by law
enlarement 111 any way connected to coughlin on or around tne 1422 E 9th Sf. #2 address between
decembel 1 7011 ami the present, Including any calis by Chnstopher "Erin" ervin Allaback or Laure
Foreshee or Laura Petrone
anythlgn related to er120376 remanding to custody on Apnl19th and Including anything related to
incarceration at wr:dc between 4119112 and 4/29/12
anything related to reno marshal rme arrest In 11 Ii 26800 on 2127:12
anythmg on the 11115111 Incident resuhing In 11 Ir 213800 on sl laurence rnvolvmg the rpd, sargent
tarter, 652 lor rest 51. richard hili etc
I~
rcr2012 ~067980 (anyrillng on the june 26th, 2012 "nest by wcso deputy machen and bowman, and
in taCT anythlf"lQ Involvin~ lach Coughhn and allY law enforcement figures at or around Northwrnos
Apmtments st 1680 SK'j n~'GUntalr dnve and or SupE-IIor m,m sl0r3ge at
, Goog!e~' page
779'0 White F" Street [-:"co NV S9S23
(775i 7464322
lor at some west fourth slreet actdress ()[ Supenar Mt'l' STorage. espeCially on or around september
I 22nd 2012 whether ,nvolvlcg officer alan weaver or
I sargent o!rver miller or nOi, ilclucllnq calis for law enforcement resp0nse by malt grant (a woman) or
ken fjrant or marvIn dye or anyone With superior r'l1ltli storage
II!I the JUly 3rd, 2012
arre,t rn fine 12 cr 12420 f\ND ANYTHING AN EVEPYTH1NG OTHERWISE

\ RELATED TO ZACH COUGHLIN IN i\NY WAY DONT FORGET THE JAN 13 2012 STUFF
\ WI IH SARGENT LOPEZ !I,ND OFFICE'R WEAVER AND AVILA ALL THE SARGENT SIFRE
" ,I
: STUFF
ANYIHING IN CR12~0376 ANYTHING IN MH120032
II
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s~bPoen'ng ali these rnaten~ls InCident to Judge Sferrazzas 10122112 ORder In ReR2011
: I 06334 " In whlcn he gr~nti?d me tne right
I
to Issue these SUDPoen3S [,pon you wlthoul paying up fr~nt Ihe witness fees or other expenses (IFP)
al1:
,I
,', II Dated this 5th day of November. 2012

Ii
i Zachary
/' Ii
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Barker Coughlrn,
Esq~ (Nevada law ilcense, tempOfilnly sllspended,
lJSPTC license
Esq)
I and glverl perm,ssion te 'S5ue sul)poen~.s by SBN Chief Bar Counsel DaVid Clark
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,II[W()j~:\
! 12 ;\l\ii! :\! :BP(lENA IJI 'CI,S TU.I '\1
In
lact,
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N RS 174
1174 11 S anu subsection

no!
,I pllrly
~;45 Scryi~c" 01 sllhp(l"nll~ I ~ hetp1 a, ,)therwi,,, provitlcd in NRS
:'~ " suf>rocllH Ill"\' he ,er",d hy " peace "mee! or by
and \\110 'islmi ft:')s than n~
,crvic,' or" ,uhpnena n",,1 be
nlil(1e
)tdf:)
any nlher person who is
nrag~ E\C~Pl ~lS olhcr\\j..,c provided ill NRS 289,027.
by ddt""n",, II wry :hc!'eof to the' pCN,"
ni,,"cd~ 1~ Esccpt us
othrl"wi-;c providc.d in 01\S 17-J..."1 i 5. a .\UhpO~lla ltl ~Incnd .1 misdemeanor tria! may 0(' :-.crvcd by
maIling the ~ubpo(:na to the p~1".~m to he
requested from tl111l rcr"'Il.
I,Hld"'"
nIH
k" Il;al1
111I ,,'uhpnL'nil "

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ii ,llll'1
In il
10 tk.,
Cf' cd
Sl'fVL'd
hy It:gistercd or t.'erlilj~d maii.
fe-tlil11
receipt
","led poslpaid cl1\'"I(l!,c~ '/fld!'e,""d to the' person~' bsl ~l1\;Wll
bd,,,,, (he," Ii "hi,b the ,uhpoc'i1" cOllll)l"nds (h,' r,'rsl)J1 to allcnd~ 3~
h "wi." c,nili.al,
III Ihe
Pl,nlill~ iPl,,1 be I~'bi wah Ihe couri '"ihin '
da),
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!ltsd",u!'c 11\ ,1ck"d .. n( o( 1/n,(
d . :l\:J:tiatl! lu dJ\c]I}'\c ;i'i! nf alibi \\ Ilnc:-,\,-'~, prost..'cu(U1f. aUornl~y
It') di~do:;I..'
{(l
d",,,,
!i:-.t of rc~uHal
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t>{)r!l;nUI!l~' dlj!:~ to d"cin.sc:
~RS ! 7~ q
nrli~b
II or" ilness\', .. Ild rnJ"rnlii Iion .":,,li Ilg I" ," !,"ll [c',1 1m, Ill): ""mi nuing clUI) to dl.sci",e: pr(\tec1 i\ c
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\l;j!l1-:SSL'S;
;-;,HH:!IP:!,'-';
I);~dp~\.lr;: h-: dl'!\:mbn: ,1(C\"j.j,-'IK\: fL'!;lting (0
pm:-'ccutlol1: linllWlJ(dlS :\lj{S 17-1: 1:-;
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[! dckn;-ic: lirnJlaltOns. !'\\{S 17'-f n:,
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SUbpnC1l<1
Conlillliing dnl\<;1l
1(1r
attendance
jj plo;,.e..:ultn!} a{wm..:~
P:oiCCli$' $Hlcr<;.
Ji"~I,,,('~
Or\\jtnl.::-.,>cs:
Ilf uttorney
f(lf
form.
l"i~ gr,md jur~'~' illqlllfy~ i\i{-; 17~j 325
E\.lH~
i"ilur\' 10 c"l1lr iy:

1:-"tt,IOC;:.
(kfcnJanl,
RL"CIP1I)\:,d J"...,CIO:-'lll\-
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t\l<S ! 7--1,'!')
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1~')lhll1CC
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uf suhpoena hv ;
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pmtlli~-.: w arpCJI: infi)rmlng \\itne:"l.~ of general tlall1l\'~
7J~~:l5
I'rnd',CiHlfInfl"I'PllcT '" ""nc".. !\iRS 1
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Subp{)cna Illr proUlll'lion {)j' llOtumclllary

~lIhpoenn,
,,~VJd(;JlCt'
;:lnd 01
oh-il.:ct~<
NRS 174 34S
NRS 174.365
depositi{ms:
rlac~ ofi.:xtllTlinliLioll.
NRS
174_3~')
('onkmpt
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;\ND "LJI\'Ol'NA
1)\ ,(V, 'n~,C\JM
Service
or
SIWNH"NA NKS 17~30) Suhlil~!M (\If atit'll(hm,,>.: \}rW\{n..~s~~, h)rm: \<>SH;.\r'H:C, r>;{.;t.::p! ,is pmviJed m NRS 172. If)S
HllIl 174.3 I S I A ~mhrOC"nil Ill!!'>! he ,<."IIL'(j h) llle (krk Iwkl the "cal o1":IK coat! It mllSl sMc Ihe l1il!M" of the f.:Hwl ,md
the Illk. If-any. ("'if lhe pnhx\.'din:;., ~md nltl'..,t {;l.)mmlmJ ":;:Kh i)l.~r:.on iI)"\\\lom il J:., :1Ifo..'CleJ It) <\l\l'.m1 ;md gIve le~\iln()Ily a1
Iht: lime (lIId pl.ICc ~(ll:~dJed thell.'IIl. The ckl'~ "h~j!l ;'>;Ill' ,! o.;llhpH('!I1,I, ')!,":.fH.:J and s.c;;lcti hul olhcmh ..' in bhlllk. to (l pilny
rL'q!lC\llll~ n , .. ho ~h?11 liB 'on IIl..:- bkmh b..:l~lr(: II i~ \~'rWtt ~ ;\ 5\Jbrn~na Inti'); be l .... \ud hy ;lII1MlCC ,)flnC pC":lce in a
pl{KCi;din~> h.'r(l(c 1he j 11'.1 icL' 01 rhl.' IJellCl' IJlltkr 1h' ~ea! (11'111 .... l,.:oUl1 (J$.hk'd!u '\'1{:; by 1967. J4~O_!\ 19h /367, 1987,
\ 2,1) NHS )7~ :; '15 Is"ud\l('c (If '>lIbrx1Cll<l h:v rn\,>",ult;n~ ;:IlHm~:- or all(lIP~> for (kl'l'l1(iwl!, rr<)mls~~ h1llppcar: infi)lming
II IInt'')\ o/" gcnci ,11 O:Jiurt' ()I ~rand jury'" !nqtlil y 1 nl-.' pro~t't'UIII)g ,1ill)1 nt') ma) j""llo.; :'Iubp()\!nih '\llb'>cr JIgd In the
prose-cHllng mtotlle) for VI' lIne ... ,.:" \\ ilhin 1f1l..' SWk'_ HI ~lJrl'XIJl "I' 11k' prn;-,CCla!f)1l ()f \\ lhl:n [he f!HiI1d it!!.)' may din.:cr to
arr('ar heJiH'{' fl. upm; fillY (jI\\:')iig:ltion pcndrn.tJ hclon: In(; 1~1 and )urj 7 f {;~ IlE('\-')t:cUfing <If($[m:y ~lr the tlflljfllC~ for (ile
defendant 111(1)' 1"'!lUt' !-'ubpnen<l', \llhstl ihed hy {ile ivmcr 1111; {:l) Wiln..::...,\~;., Wljhill r11(" Stale to appr:ar bCrllrc [he C(HII1 al
I"hidl ,m indll'IOlCI)f, I1lf~Hm(llIOtl 01 nlPHnal u:mp :Jlnl ~"Io be Illd. til} \\."i!iI":",,\ ~-j!rl..'iid) :>ubpIKn;:Jcd who .m.: requireu
10 le;lpp~dj;r) all} JU';lt"y ('poll en ;lny time til>.' ctlmJ b t,\ !\:":(In\l'!}e JI1 11).:- sAne (~hl' \\>lIhll1 (i!J da)." and rll..:: [!ln0 may be
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(Inll promj'-t,: hI <1PPC~lr giv-.:n by II!..: ~\!lllc~:,

lti)pC,lr\ilnlL (ilJ '(\::nldj wnhd! Ul h.:r~t:JI f" the \\llllt::,:- b:- !HiIllt." and
i occup:JlIon: (b) \tlk ...' ,1 \\riu('l'; nl)/alIPn oflhe Jilk \~hC!1 fin: olill pro'lli~..: 10 ,lppt\Jt ,\,jo, ~:',fV~'il ,md lite InrormaWlH f!JV(.'1l
t bl.- Ihe PLT>(\il t1l,lkin;; Illl ('f~d :YUf\lhl'!ll ,IPlwi1r l.klliitV!fl(-', jh~ PI.'I')<)O <1:> H;r: '<\ll)h>,\ <"Uh[Kll.'ll'IVti. and (n IM.!(IIh:: a
S[,lle lIlay dCC('rt deliHT)
' ;\ny pu<,on
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l'l?fliliCHe (ir~Ct\ rl;(' l'{l!~f;1 i!l1Jl~' fll\~ U(imn,lll(lp 'd ft)nil Ifl P,H ;I':.!.raplh (.Jj and
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d1~' (rdn,U'fpl o(llh' pr'Kt','dOll~)" (/\Jde,' Ie: N!\~ b) p}()'). 1~(JX:;\
"dl$'l!j{>n
\\ItIlL':.~ (e'>ldi~'~ :'Del]:1 "1,jJ~mtll! mU')lllf mcll,;It'd III

1'J7'), tl()_ (9XS. ,,?~: 19~jJ, 6,'::; 1l)9!. ~Il~:' 11)')3 II))) \:R,) !-:.L3~5 i'n,dUl'ki'lllj p:'!~\ln(;t
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C\lllr!L~ ptt hn'u~i!1 bci1.Q; a ;J(~[lILt ((H"rt 'IUl!l:S III dll"tilt.'1 (~HI'li;. :.!\ \Ir,!,..'r lot [[.;\t ptUpns..: 1l\~1~ be m ..ldc hy th<!- dl~lItt;l
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SI IBPOr,;-.,; '" /\ND '>1 ilH'OFN '\ Dl'CFS H:CI ,1\1
,I
IN THE MUNICIPAL COURT OF THE CITY OF RENO
COUNTY OF WASHOE, STATE OF, NEVADA
FILED
RENO MUNICIPAL COURT
Case No. II nP~I)IO. 3

Dept. 3
MAR I 3 2012
CITY OF RENO,
5
Plaintiff,
vs.
6
TIME '4
BY (ctn~::::::>~"""---_
DOROTHY
HOLMES, JUDGi
~ASH

Defendant.
8 ___________________1
10
11
12
13
SUA SPONTE ORDER DENYING RELIEF SOUGHT IN IMPROPER DOCUMENT
On March 9, 2012, at 12:38 p.m., defendant Zachary Barker Coughlin, an attorney and
self-represented litigant in the instant traffic citation case, began fax-ftling a 218-page
document to the Reno Municipal Court purporting to seek various and sundry types of relief
14 from this court on a "Boulevard Stop" traffic citation matter. He labeled his document "Motion
15
to Return Cell Phones; Motion to Set Aside Summary Contempt Order; and Notice of Appeal
16
of Summary Contempt Order." Said document was filed by the Clerk of the Court, on Monday
17
March 12,.2012, after causing much disruption to the court's operations.
18
19
The court herein issues this Order sua sponte to prevent the plaintiff, Reno City
20 Attorney, from devoting any additional time or resources to this document, and to relieve the
21 plaintiff from any burden of attempting to respond to said document. Likewise, the court staff
22 is relieved of any obligation to further deal with this aberrant document.
23
The court finds that the defendant has failed to follow proper legal procedure in
24
25
26
preparing and filing his motions and purported Notice of Appeal. The court also finds that Mr.
Coughlin has blatantly abused the court's fax-filing process offered for the convenience of
27 parties appearing in this court. As with his previous, mostly incoherent document, this
""",
28 document filed by Mr. Coughlin appears to be a recitation of family grievances, lyrics to rock
MUNlCU'","COI.ffil
Po.lb 1900
a-.NVtU~
(to:I:ll14U90
1 songs, disjointed legal ramblings, citations and argument in another case with another judge in
2 a different department of Reno Municipal Court, and, is, thus, even more irrelevant to the
instant case than the 224-page document previously filed by Mr. Coughlin.
IT IS ORDERED that any and all relief sought by the defendant Zachary Barker
5
6 Coughlin in the above-described document is denied.
7
IT IS FURTHER ORDERED that Zachary Barker Coughlin shall refrain from, and is
8 hereby barred and prohibited from faxing any documents to Reno Municipal Court.
IT IS ALSO ORDERED that if Zachary Barker Coughlin wishes to file documents in
10
II
Reno Municipal Court on any matter assigned to Department 3, he must present signed
12
originals only, in appropriate legal form and format, limited to no more than 15 pages in length,
13
and before they are filed, the clerk of the court shall present them to this court for review in
14
chambers, and this court will make a pre-filing detennination if they can be filed by the clerk.
15
,
. 16
IT IS SO ORDERED
Dated this 13th day of March,'20 12.
17
fJk~ ~4~~
18
19
The Hon. Do
y Nash Holmes
Reno Munic pal Judge
20
21
22
23
24
25
26
27
..,.,
28
~A!.COORT
1'0 BooF 1900

~NV":SUS
(70l11H U9Il:
ggRIIEIC6IE OF SERVICE
3
4
5
Pursuant to NRCP 5(b), I certify that I am an employee of the Reno Municipal

Court, Reno, Nevada, that I am over the age of 18 years and not a party to the above
action, and that on this date, served II true and correct copy of the attached document
to the following as set forth below:
Allison Ormaas
Oeputy City Attorney
PO Box 1900
Reno NV 89505
8
9
10
11
12
13
Zachary Barker Coughlin, Isq,
1422 E. 9'" Street #2

Reno NV 89512
X Placing said document In II aealed envelope and placed for collecting and
mailing by Unites States mail In Reno, Nevada, postage prepaid following ordinary
business practices.
Washoe County Jail
Court Services
14
15
16
17
18
19
Facsimile (FFAX)
Electronic Mail (E-mail)
Inner-office mail following ordinary business practices
Personal Delivery.
DATED: March 13,2012,
20
21
22
23
Reno Municipal Court
Dorothy NaSh Holmes,

Judge
po. 80x 1900

Reno, NV 89.505
(775) 334>&22
aliment Three
.'
IN THE JUSTICE COURT OF RENO TOWNSHIf

COUNTY
2
3
Il E 0
or WASHOE, STATE or NEv3flrUiDV -8 AH 1/: 48

REI/~TJI,!;V
5TA TE OF NEVADA,
I/C!\
>,l!'
8Y-rD~SL._
Plaintifl's,
4
5
vs.
CASE NO.: RCR2011-063341
COUGHLIN, ZACHARY BARKER
DEPT. NO.: 2
Defendant.
7
&
EX PARTE EMERGENCY ORDER PENDING HEARING
10
11
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15
16
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18
19
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21
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23
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25
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27
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R~QO
City Atlorpt.'y
This matter bas come before the Court based upon the following circumstances:
A.
The Reno City Attorney's Olliee ("RCAO") represents a number of City of Reno
employees who have been named in subpoenas. The RCAO contacted Court personnel on
November 7. 2012 to request a time to appear tbr an order shortening tinle regarding a motion to
quash and for protective order. Due to the proximity of the trial date in this matter, November
19,2012, the Court directed the RCAO to file and serve its substantive motion and provide
notice that the matter would be heard on November 8, 2012 at 9:00 am. The City of Reno filed
its motion On November 7~ 2012.
B.
At the hearing on this matter on November 8, 201 2, Deputy City Attorney Creig
Skau appeared on behalf of the RCAO and the City employees requesting protective relief. Zaek
Young was present in court. Mr. Coughlin did not appear. Mr. Skuu represented that he was
under the belief that the Public Defender's olliee represented Mr. Coughlin, that the Public
Defender was served believing this was s.ervice upon Mr. Coughlin, that he learned Mr. Coughlin
represented hinlself this morning and attempted to caB and left a voice mail message with a
phone number believed to be Mr. Coughlin's at 8:30 this morning.
c.
The Court is advised that the Public Defendcr, Jeremy Bosler and the City of
Reno Chief Criminal Deputy City Attomey, Dan Wong, may also have received subpoenas and
filed requests for relief similar to the RCAO's requests.
D.
The Court read the ReAD's motion in preparation for the hearing. Duc to the
absence of notice to Mr. Coughlin. no argument was received on the merits of the motion.
P,O. Box 1900

Rmo. NV 89!'i05
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However, the Court linds that the RCAO's motion and supporting materials present a sufficient
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evidentiary basis to issue this Order.
The Court deeming itself sufticiently informed and good cause appearing therefore,
IT JS HEREBY ORDERED as follows:
1.
A hearing on the merits of these nlaUers is hereby set betore this Court for 9:00
a.m. on November J 3, 2012. Oral presentations shall be limited to 10 minutes each. The Clerk
shall notify Mr. Bosler and Mr. Wong of the hearing.
2.
Any subpoena not properly issued by the clerk or otherwise not properly issued
JOin accordance with NRS ) 74.305 is hereby quashed. Any subpoena not personally served by a
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non-paTty or otherwise properly served in accordance with NRS 174.345 is hereby quashed. 'lbe
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Court reserves its ruling on any other grounds such as relevancy or undue burden until the
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hearing on the merits.
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3.
A protective order is hereby granted pursuant to JCRCI' Rule 26(c), effective
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until the hearing on this matter on November 13, 2012, to the effect that upon se:rvice of this
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Order on Defendant Zachary Barker Coughlin. Defendant Coughlin shall not thereafter issue or
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cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena
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duces tecum in this case unless he has first presented the proposed subpoena or subpoena duces
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tecum to the Court for the Court's review regarding adequacy, relevancy and necessity of the
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subpoena or subpoena duces tecum, and sufficiency of the proposed Inethod of service.
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4.
Counsel from the Reno City Attomey's Oftice is directed to promptly attempt to
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serve a copy of this Order and the RCAO's motion and any supplements by personal service
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upon Zachary Barker Coughlin
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89512. with a copy mailed to said address. Service shall also be attempted by email at
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"zachcoughlin@hotmail com".
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Dated this
al
the address in the Court's file, 1471 E.
~day of November, 2012.
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Ileno Cily :UIO.'III:y
1',0. Do); 1900
Ut:no. NV
8.9~OS
-2
9'" Street, Reno, NV
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JOHN J. KADLIC
Reno City Attorney
CREIGTON SKAU
Nevada State Bar No. 34
P.O. Box 1900
Reno. Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys for City of Reno
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Case No. RCR2011-063341
STATE Of NEVADA,
Dept. No.2
Plaintiffs,
vs.
COUGHLIN. ZACHARY BARKER,
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AFFlI)A VIT OF SERVICE
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Pursuant to JCRCP 5(B)(4), I certify that
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r am
an
employee of the RENO CITY
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ATTORNEY'S OFFICE, and that on this date, J served a copy of the MOTION FOR
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PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER
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REGARDING ISSUANCE OF SUBPOENAS and a copy of the EX PARTE
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EMERGENCY ORDER PENDING HEARING on the persons set forth below:
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Served via US Mail. Reno Carson Messenger Service and E-mail:

Zach Cou~hlin
1471 E. 9' Street
Reno, NV 89512
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zachcoughlinCw,hotmai1.com
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{ll
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if:
\
Served via RelloCal'lU11l'MtSJellger Service
Jeremy Bosler
th
350 S. Center Street. 5 Floor
Reno, NV 89520
Halld Deliverer!
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Dan Wong, Chief Deputy City Attorney

I E. 1st St., 3rd Floor
Reno, NV 89505
Pursuant to JCRCP 5(B)( 4), I certify that I am an employee of tbe RENO CITY
ATTORNE V'S OFFlCJ'.. and that on tbis date, I served a copy of tbe EX PARTE
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EMERGENCY ORDER PENDING HEARING on the persons set fortb below:
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Served via Reno Carson Messellger Service

Biray Dogan
th
350 S. Center Street, 5 Floor
Reno. NV 89520
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Served via Reno Carsoll Messenger Service

Zach Young
Washoe Coullty DA's Office. Criminal Division
P.O. Box 30083
Reno. NV 89520
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AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in tbis court does
not contain the social security number of any person.
DATED this
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ega! Assistant
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........ " ... ,...... """,, ... '.""..1""''''', ..,,',........ ,..'''.........."..,,~
!
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JILLENE A. ZARKER
Notary Public State of N8vado 1

.<w;intmom _
in County i
No:Q4.04012El;lInlo_2'.201S i
i"' ,. " ....,........ " .. " .. "".. " ... " ..........................' . " .......
.. .........
~
OR\G\NAL
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MARYKANDARAS
Nevada State Bar Number 3974
P. O. Box 30083
Reno, NV 895203083
(775) 337-5700
ATTORNEY FOR WASHOE COUNTY
F\LEO
2D lHlOV \ 1+ Ati 10: 59
***
STATE OF NEVADA,
Plaintiff,
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Case No. RSC2011-063341
vs.
Dept. No.2
12
ZACH COUGHLIN,
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Defendant.
________________________
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MOTION TO OUASH SUBPOENAS
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COME NOW, Custodian of Records, Deputy John Machen, and Liz StucheIl of the
Washoe County Sheriff's Office, Washoe County Nevada, and Zach Young, Deputy District
Attorney, by and through counsel Mary Kandaras, Deputy District Attorney, Washoe County
District Attorney's Office, Civil Division. The parties have received "subpoenas and subpoenas
duces tecum" to appear on November 19, 2012 at a misdemeanor trial on the charge of petty
larcency.
The parties request that all subpoenas and subpoenas duces tecum issued by defendant
Zach Coughlin be quashed because they were not issued and served in accordance with NRS
174.305. They were not served as required by NRS 174.345. Assuming but not conceding that
the subpoenas were validly issued and served, they should be quashed as authorized by NRS
174.335(2) as compliance is unreasonable and oppressive. To the extent that it is possible to
discern what defendants seeks, the items and testimony sought are not relevant to this criminal
case.
The subpoenas at issue:
On Friday, November 9, 2012, Liz Stuchell, Supervisor of the Civil Section of the
Washoe County Sheriff's Office, received a packet of subpoenas via certified mail.
Her name and that of Deputy John Machen were hand written on the front page. The
subpoenas were sent to the Washoe County Sheriff's Office (Civil Division). These
were not issued by a court, nor was a witness fee tendered. (Exhibit A); (Affidavit of
Mary Kandaras).
10
As part of the same packet of subpoenas received by Liz Stuchell, the "custodian of
11
records" was also hand written. It is unclear if this is intended to be a subpoena duces
12
tecum. Liz Stuchell attempted to discern what records were sought. It should be noted
13
that the documents list some 18 separate groups, over 80 agencies and individuals.
14
Substantively, the subpoena is extremely confusing, consisting of run-on sentences
15
which move from topic to topic and case to case, making it unreasonably difficult for
16
the witnesses to discern the topics and testimony or the documents sought. (Exhibit A);
17
(Affidavit of Mary Kandaras) .
18
On or about Monday, November 6, 2012, Deputy District Attorney Mary Kandaras
19
became aware of a subpoena duces tecum issued to her. A copy was provided via email
20
by Liz Stuchell. (Exhibit B). Deputy Kandaras has not been served in accordance with
21
NRS 174.345. The subpoena duces tecum does not list what records are requested.
22
Moreover, she is unavailable the date of trial due to a previously scheduled hearing.
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(Affidavit of Mary Kandaras).
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25
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On November 9,2012, Deputy District Attorney Zach Young, and the prosecutor in this
case, was served with a subpoena duces tecum requesting cell phone records of phone
number (775) 527 - 9440 for specified dates. (Exhihit C).
-2-
A criminal trial is scheduled for Monday, November 19,2012 on the charges of petty
1
2
larceny. It is requested that the subpoenas be quashed. With respect to Exhibits A and B, those
subpoenas were not properly issued or served. None of the individuals named have any
personal knowledge of the facts of the instant case. (Affidavit of Mary Kandaras)
With respect to the subpoena issued to the prosecutor Deputy District Attorney Young,
a subpoena is not the proper mechanism to receive those records. Rather, that is a discovery
issue. Another option is for Defendant Coughlin to properly subpoena the holder ofthe cell
phone records.
The parties request that the Court's order issued November 8, 2012 (Exhibit D) be
10
extended to the referenced subpoenas in Exhibits A and B. Specifically, paragraph 2 of that
II
order states that "any subpoena not properly issued by the clerk or otherwise in accordance with
12
NRS 174.305 is hereby quashed." Subpoena in Exhibit A was not issued by the court. That
13
order also states if a subpoena is not served in accordance with NRS 174.345 it is quashed.
14
Subpoena in Exhibit B was not personally served on Mary Kandaras. (Affidavit of Mary
15
Kandaras).
16
17
Exhibit C, the subpoena to prosecutor Young, should be quashed as he is not the holder
of cell phone records - the company generating such records must be subpoenaed.
18
CONCLUSION
Based on the foregoing it is respectfully requested that the motion to quash be granted.
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(/
(/
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Dated this 14th day of November, 2012.
RICHARD A. GAMMICK
District Attorney
6
7
B~~
P. O. Box 30083
Reno, NY 89520-3083
(775) 337-5700
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ATTORNEYS FOR WASHOE COUNTY
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/
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P:ICiviIIMKIWCSOICoughlin Mtn to Quash Nov 2012.wpd
\
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CERTIFICATE OF SERVICE BY MAIL
' Pursuant to JRCP 5(b), I certiry that I am an employee of the Office of the District
3
4
within action. I certiry that on this date, I sent bye-mail and I deposited for mailing in the U. S.
Mails, with postage fully prepaid, a true and correct copy of the foregoing in an envelope
addressed to the following:
Attorney of Washoe County, over the age of 21 years and not a party to nor interested in the
Zach Cou~hlin
1471 E. 9 Street
Reno, NV 89512
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Dated this 14th day of November, 2012.
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(~.:
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AFFIDAVIT OF MARY KANDARAS

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STATE OF NEVADA
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COUNTY OF WASHOE
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I, Mary Kandaras, being fIrst duly sworn and under penalty of peIjury, do hereby depose
and say:
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1.
Sheriffs Office in its legal matters;
2.
12
3.
the charge of petty larcency.

The subpoenas at issue:
15
of Deputy John Machen were hand written on the front page. The subpoenas were sent
17
to the Washoe County Sheriff's Office (Civil Division). These were not issued by a
18
20
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22
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25
26
Friday, November 9,2012, Liz Stuchell, Supervisor of the Civil Section of the Washoe
County Sheriff, received a packet of subpoenas via certifIed mail. Her name and that
16
19
The parties have received "subpoenas and subpoenas duces tecum" from
defendant Coughlin requesting appearance on November 19, 2012 at a misdemeanor trial on
13
14
I have become aware of Zach Coughlin due to the receipt of correspondence
regarding his legal issues;
10
11
I am the Deputy District Attorney assigned to represent the Washoe County
court, nor was a witness fee tendered. (Exhibit A).
As part of the same packet of subpoenas received by Liz Stuchell, the "custodian of
records" was also hand written. It is unclear if this is intended to be a subpoena duces
tecum. Liz Stuchell attempted to discern what records were sought. It should be noted
that the documents list some 18 separate groups, over 80 agencies and individuals.
Substantively, the subpoena is extremely confusing, consisting of run-on sentences
which move from topic to topic and case to case, making it unreasonably difficult for
the witnesses to discern the topics and testimony or the documents sought. (Exhibit A)
On or about Monday, November 6, 2012, Deputy District Attorney Mary Kandaras
became aware of a subpoena duces tecum issued to her. A copy was provided via email
by Liz Stuchell. (Exhibit B). Deputy Kandaras has not been served in accordance with
NRS 174.345. The subpoena duces tecum does not list what records are requested.
Moreover, she is unavailable the date of trial due to a previously scheduled hearing.
(Affidavit of Mary Kandaras).
On November 9, 2012, Deputy District Attorney Zach Young, and the prosecutor in this
case, was served with a subpoena duces tecum requesting cell phone records of phone
number (775) 527 .. 9440 for specified dates. (Exhibit C),

4.
10
11
12
With respect to Exhibits A and B, those subpoenas were not properly issued or
served.
5.
With respect to the subpoena in Exhibit C issued to the prosecutor Deputy
J3
District Attorney Young, a subpoena is not the proper mechanism to receive those records.
14
Rather, that is a discovery issue. Another option is for Defendant Coughlin to properly
15
subpoena the holder of the cell phone records.
16
FURTHER YOUR AFFIANT SAYETH NOT.
17
~.
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by Mary Kandaras
22
this 14th day ofNovernber, 2012.
.l
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GAU.l
..
Nota... ~"""" .. 8taIs 01 ~
P:\CiviIIMKIWCSOICoughlin Mtn to Quash Nov 2012.wpd
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CASE NUMBER: ng I2-0204 ng-0435 ng-0434
STATE BAR OF NEVADA

NORTHERN NEV ADA DISCIPLINARY BOARD
~TATE
BAR OF ~EV ADA.
)FTITION
V.
I'
~.ACH
COUGHLIN,
BAR 9473
~ESPONDENT
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) ng 12-0204 ng-0435 ng-0434 motion to
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YQU ABE j;;QMMAI!!QED tQ illllleilr befQr.t tbe Slate Ela[ Qf. M!!~a!la ilO!! !'l2tl!J!lm l!!e~i!!!iI
Dill,IIl!i!!a!Y BQl!rg allbe Stale Ba[ QI Ml1~ga' MQrt!Jf![!! Office.l!4~ DQl!bll! B!;!2U!ellilrd
lk.'l9. NV ~95:ilj. State of NIDrada. WillillQ!! CQl!nlll. Qllihe dal!! of NQll!!lllll!!r :l4tt!. :il!!1~. all!
i!l! lQ l!!tifl!2!llhl1 Ilila Qf Zl!,bl[ l;Iarl!er CQug!Jlin. Eaill!re Ill! i!nl!Il!!OIQO wilhQul a!:ll1!1uam
!!~I<Y!ie lQ QIll!ll ~ liubIlQ!!ni! !!!!rvf!d YIlQn Iballll!OiQ!lIlli!ll till df!I!Ill!!!I i! ~Q!!mlllill al tbll '2UI1
"l1m wtli,1:! tOil lu!bllQl!na iIlYI1!!. [1!!!!Va!!iI Byl!!!! of CMI ~[2~!!!!1I[!!, BIIII1 4~(!I)1
f)
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PLEASE NOTE THAT THIS MAY NOT BE A LAWFUL COMMANO ANO THEREFORE YOU MAY
QR MAY NQT BE Er:mT!..EO TQ IG~QBE. I AM NOT PRQlIlDING YQU LEGAL AQlIICE. II
MA.'LE TQQ.L.ATE TQQ !.AI!; EQB THIS S!JePQEI!!A TO BE SERVEQ QI!! YQU IN A TIME!. Y
J
MANNER R!;QUIBING YQUB CQME!.IANC!; WITH IT... F!,,!RIHEB. wt:Il!.!; BAR CQNSEL HAS
' MADE INDICAIIQN IHAI Q!;EITE CQUGHLIN BEING SUSf!;NQ!;Q HE MAY "ISS!.!!;;"
4
SUBPQ!;;NAS. ANQ IHE sel!! MAY HAV!; FURTHEB IM!:!Ij;;ATEQ ~Q!.IGtI!.IN WQULD I!!Q1
NEEQ IQ PAY WITNESSY.f.!; AI AI.!.. QR AI bEAST UP FBQN1. Itlt;; el:{IGEN~IES QE
HAlliN!;> aQI!:! IliE NOVeME!EB j4T. 2111;1 III<[ :I!!~ HEARING WII1LTHE Ibn (EYEN WI:!EBE
" 11:!!; MQ1I~E liN!:! DUE PROCESS PROVISIONS AN!;! liME ~EBIQOS QF Ii~R 1!)S ETC ARt;;
ABGIJA61.Y NQI eEI~~ FQbLQWEOl ANQ 1I:!E ~!;nY I.AR~!;;NY TRIAL ON NQVEMeER
19Tt!. !:Q111IN Bj;;BZ!!j1-!!~341 !:lAVE MilOe II QIEFICUI.T IQ ASC!;BIAIN TH!; !;lll\QI_
lill~!.I!BfM!;JtlS.AII!;NQANT TO A DQCUMENT SUCH AS THIS. AS S~H. PLEASE
- 116 SUBPOENA AND SUBPOENA DIJCES TEClJM
~\.1R OWN ATTORNEY REGARDING WHETHER OR NOT THIS DOCUMfl'U.

CARRIES AND WEIGHT OR lAWFUL COMMANP OR DISpLAY OU,UTHORIIY
To' Alison M. Ormaas, Pam Roberts, Christopher Hazlett-Stevens, Brian Sooudi Company: Reno
City Attorney Address: One East First Street, 3rd Floor P.O. Box 1900 Reno, NV 89505 Phone
Number: -- Fax number: 775-334-4226 Email: ormaasa@reno.gov, hazlelt-stevensc@reno.gov,
robertsp@reno.gov, sooudib@reno.gov
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Joel Harley, and Scott Coppa and Townsend, and Marshal Court Marshal RMC; custodian of
records city of reno Marshals Division, and Chief Justin Roper
roperj@reno.gov
renomarshal@reno.gov
harleyj@reno.gov
1 South Sierra Street Reno, NV 89502 (775) 326-5125
Chief Marshal Justin Roper (334.1254, Fax 334.1260, roperj@reno.gov).
Pam Longoni, RMC exculsive transcriptionist demanding down payment from criminal defendant
appelants in violation of nevada law, Donna Ballard
plongoni@charter.net c/o Reno Munclpal Court
1 South Sierra Street Reno, NV 89502 fax 775 334 3824 ballardd@reno.gov
Reno mUnicipal Court custodian of records, and Marilyn Tognoni. and the "clerk of court for
Department 3" referenced in SBN's Pat King's corrspondence to Coughlin alleging some reports of
the clothing Coughlin wore to the filing office counter at the RMc in March 2012, and any submission
by the Reno Marshals, LIsa Wagner, Administrative Judge William Gardner
1 South Sierra Street Reno, NV 89502 (775) 326-5125, renomunicrecords@reno.gov,
christensend@reno,gov, fax: 775 334 2420; 775 334 3824
Northwinds Apartments Associate LLC

Manage Duane Jakob, IOU cADIA milAN kREBS
1680 Sky Mountain Dr
.
Reno NV 89523
fax: 775 7479202
NEvada Courts Services
Nevada Court Services
475 So. Arlington Suite 1A
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fa" (775) 348-7977
Email;nevcs@nevcs.com
JOel Durden, R. Wray, Jeff Chandler, Jennifer Chandler, Cedonio, and Nevada Court SErvices
Custodian of REcords and "Staff Attorney" Jeff Chandler
Richard G. Hili, Esq. and Custodian of Records for Law Office of Richard G. Hili. Esq.
- 2/6-
SIJBPOENA AND SIJBPOENA DlJCES TECUM
NV 89509 Phone Number: 775-348Richard G, Hill Company: - Address: 652 Forest 51. - Reno,
0888 Fax number: 775-348-0858 Email' rhill@nchardhillaw,com
Casey D. BaKer Custodian of Records for Baker & Baker Law Offices, PLLC AddreS\43,28~9-~;~~
SL 2nd Fir, P.O, Box 25 Danville, KY 40423 Phone Number: 859-238-2233 Fax num er,
0028 Email: cbaker@centralkylegal.com Webs~e:
WCSO Custodian of Records and Liz Stuchell, and Roxy Silva, and Deputy John Machen, pagi~a
Beckman, Debl Cummings, Jason Hodge, Deputy Beatson, Madeline C, JOnes, Deputy Van e
Wall, Nurse Katherine, Deputy Michael R Hoekstra, WCDC MedlcaVNurslng Staff Custodian of
Records
.
Washoe County Sheriffs Office Locatlon:911 Parr Blvd., Reno, NV 89512Maln Phone:775-3283001 Emall:shenffweb@washoecounty.us
fax 775 3286308
Roberto Puentes Company: - Address, 416 Ridge St - Reno, NV 89501 Phone Number: 775-7867676 Fax number' 775-786-8720 Email: PUENTESLAW@AOL,COM
Keith Lloyd Loomis Company: - Address: 9468 Double R Blvd. Suite A Reno, NV 89521 Phone
Number: 775-853-7222 Fax number: 775-853-0860 Email: '
bdogan@washoecounty.us
Biray Dogan, Jim Leslie,and Joe Goodnight, and Evo Novak
Company: Washoe County Public Defender's Office Address: P.O. Box 30083 - Reno, NV 89509
Phone Number: 775-337-4868 Fax number: 775-337-4856 Email:jleslie@washoecounly,us,
BDOGAN@WASHOECOUNTY.US, JGOODNIGHT@WASHOECOUNTY,US
" c,
Mary Margaret Kandaras Company: Washoe County District Attorney Address: One S. Sierra St.
P,O, Box 30083 Reno, NV 89520 Phone Number: 775-337-5700 Fax number: 775-337-5732 Email:
mkandaras@da.washoecounty.us
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.
.
23
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/ ,;
ciTY OF RENO/RENO POLICE DEPARTMENT:

Deputy Chief Mike Whan (334,3849, Fax 334.3890, whanm@reno,gov ) Lieutenant Keith Brown
(3343845, Fax 334-3890, brownk@reno.gov, rOBERT bONY BONYR@RENO,GOV
PLEASE PROVIDE THE VIDEO FOOTAGE OF THE EVENTS LEADING UP TO AND THE
ARREST THAT STARTED ALL THIS ON AUGUST 20TH, 2011, FROM BETWEEN
APPROXIMATELY 11:10 PM TO 12:30 AM ON aUGUST 21ST, 201LA LITIGATION HOLD
NOTICE OF SORTS WAS CERTAINLY PROVIDED, AT LEAST TO THE RPD, AND ARGUABLY
TO THE CITY OF RENO AND CITY ATTORNEY'S OFFICE AND THE SIGN IN THE SKATE PLACE
AT 10 N. CENTER ST INDICATES THE RPD is VIDEO MONiTORING WITH "DOWNTOWN
PROPERTIES" AND THEIR CLEARLY ARE VIDEO CAMERAS PLACE ATOP CITY HALL, WHICH
OVERLOOKS THE SCENE OF THE ARREST, ALL OF THtS SHOULD HAVE BEEN
PROPOUNDED ALREADY in rcr2011-063341
- l'6-
SUBPOENA AND SUBPOENA nUCRSTECUM
Zachary N. Young Company: Washoe County DA Office Address: 1 South Sierra P.O. Box 30083
Reno, NV 89520 Phone Number: 775-328-3200 Fax number: 775-325-6703 Email
2/27/12
Zyoung@da.washoecounty.us
.
please be ready to testify regarding you participation in the dand.estlne status conference 0
and the 1:31pm file stamped ORder for Competency Evaluation In RCR2012-065630,any
communications with Dr to anyone With regard thereto, your alleged mulliple violations of nrs 178.40
Patrick O. King Company: State Bar of Nevada Address: 9456 Double R Blvd. Suite B Reno, NV
89521 Phone Number: 775-329-4100 Fax number: 775-329-0522
')
1D
i2
13
, .,
.
please produce any materials related to Zachary Barker Coughn in any way, shape or form, and be
present and ready 10 testify fully regarding the RMC Marshal peering through Coughlin's bathroom
stall (not exactly in the "Immediate presence of the court", now is it, sufficient for a "summary
criminal contempt" conviction .... cited on the record by Judge Nash Holmes on 3112/12 in 11 tr 26800
by the Marshal and the violations of the courthouse sanctuary doctrine by Marshal Harley on behalf
of Deputy Machen. on behalf of Richard Hili to serve in front of ORmaas the ORder to Show Cause
in the appeal of the richard g. hill eviction matter in cvll-03628, as well as any and all information or
documentation related to the "receipt" by the wcso of any and all Orders of any sort (or any
correspondence whatsoever) in connection with RJC reYZ011-001708, rci rev2012-001048, rcr2012067980 and any other materials related to Coughlin and Northwinds Apartments Associates and or
Superior Mini STorage and all materials detailing the practices and policies of the wCSO with
respect to maintaining documentation or transfemng documentation concerning or providing proof of
when the wcso FIRST received or came to have "receipt" of any sort of Orders related to an eviction
vis a VIS nrs 40.253 or otherwise, including the name of the locksmiths doing any and aU lockouts of
coughlin, and media gathered by the weso, anything related to the booking into evidence otthe
materials retrieved by the RMC's Marshals after the period in which those Marshals could have
lawfully conducted an search incident to arrest, and therefore violative of the fourth amendment
where no warrant or other basis for so retrieving such materials has been admitted to.
11)
SpecialIty Courts Administrator Shiela Leslie, Mental Health Court for SEcond Judicial District Court
Custodian of Records fax 775 325-6617.
Rene Biondo 775 325-6605 and Isabel Meadows 775 325-6650
75 Court Street
Reno. NV 89501
(775)328-3110
shlela.leslle@washoecourts.us, rene.biondo@washoecourts.us, isabel.meadows@washoecourts.us,
joey.hastlngs@washoecourts.us
/
.' ~ I
"
See you at the hearing, court from Which the subpoena issued. [Nevada Justice Court Rules of Civil
Procedure. Rule 45(e))
Dated thIS November 3rd 2012'

_r.-~ "',"'"
,r>..
\\
~,.;;~~-,,-' "
-~ ... ''.. .....
./
-,_./
Za~hary BarkUough/;n, Esq. (Nevada law license temporarily suspended, USPTO license in tact
an given per $SIon to ISsue subpoenas by SBN Chief Bar Counsel David Clark, Esq.)
,
- .tin-
SUBPOENA ANI) SUBPOENA DUCES TECUM
I
Richard G. Hill Company: - Address. 652 Forest 51. - Reno, NV 89509 Phone Number: 775-3480888 Fax number' 775-348-0858 Email: rhill@richardhillaw.com
Casey D. Baker Custodian of Records for Baker & Baker Law Offices, PLLC Address: 432 W. Main
St., 2nd Fir. P.O. Box 25 Danville, KY 40423 Phone Number: 859-238-2233 Fax number. 859-4390028 Email' cbaker@centralkylegal.com Webs~e:
0
<
"
I
I
WCSO Custodian of Records and Liz Stuchell, and Roxy Silva, and Deputy John Machen, Patricia
Beckman, Debi Cummings. Jason Hodge, Deputy Beatson, Madeline C. JOnes, Deputy Van Der
Wall, Nurse Katherine, Deputy Michael R Hoekstra, WCDC MedlcallNurSlng Staff Custodian of
Records
Washoe County Sheriffs Oftice location.911 Parr Blvd., Reno, NV 89512Main Phone:775-3283001 Email' sheriffweb@washoecounty us
fax 775 3286308
'!
; ;1
1i
1?
Roberto Puentes Company: - Address: 416 Ridge 51. - Reno, NV 89501 Phone Number: 775-7867676 Fax number: 775-786-8720 Email: PUENTESLAW@AOl.COM
Keith Lloyd Loomis Company: - Address: 9468 Double R Blvd, Suite A Reno, NV 89521 Phone
Number: 775-853-7222 Fax number: 775-853-0860 Email: '
L,
14
t r-~
I
I
:~
l~
:2
Mary Margaret Kandaras Company: Washoe County District Attorney Address: One S, Sierra Sl
P,O. Box 30083 Reno, NV 89520 Phone Number, 775-337-5700 Fax number: 775-337-5732 Email:
mkandaras@da.washoecounty.us
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,,'
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;-::
I
i
bdogan@washoecounty.us
Biray Dogan, Jim Leslie,and Joe Goodnight, and Evo Novak
Company: Washoe County Public Defender'S Office Address: P,O. Box 30083 - Reno, NV 89509
Phone Number: 775-337-4868 Fax number: 775-337-4856 Email:jleslie@washoecounty.us,
BDOGAN@WASHOECOUNTY.US, JGOODNIGHT@WASHOECOUNTY.US
.z -)
;: ::
2 ::
,: ~;
ciTY OF RENO/RENO POLICE DEPARTMENT:

Deputy Chief Mike Whan (334,3849, Fax 334.3890, whanm@reno.gov ) Lieutenant Keith Brown
(334-3845. Fax 334-3890, brownk@reno,gov, rOBERT bONY BONYR@RENO,GOV
PLEASE PROVIDE THE VIDEO FOOT AGE OF THE EVENTS LEADING UP TO AND THE
ARREST THAT STARTED ALL THIS ON AUGUST 20TH, 2011, FROM BETWEEN
APPROXIMATELY 11,0 PM TO 12:30 AM ON aUGUST 21ST, 2011...A LITIGATION HOLD
NOTICE OF SORTS WAS CERTAINLY PROVIDED, AT LEAST TO THE RPD, AND ARGUABLY
I TO THE CITY OF RENO AND CITY ATTORNEY'S OFFICE AND THE SIGN IN THE SKATE PLACE
AT 10 N. CENTER ST INDICATES THE RPD IS VIDEO MONITORING WITH "DOWNTOWN
PROPERTIES" AND THEIR CLEARLY ARE VIDEO CAMERAS PLACE ATOP CITY HALL, WHICH
OVERLOOKS THE SCENE OF THE ARREST, ALL OF THIS SHOULD HAVE BEEN
PROPOUNDED ALREADY in rcr2011-063341
- 3(6-
SUBPOEJliA AND SUBPOENA DUCES TECUM
--------
----------------.'"~
---------
N\-VAD~ RU\,L, ()\- C\VIL \'RO(T.I1URI'., Rl'l.e 45101 ,,~[) 45101
1<) I'RIrJ ECTION 01' PERSONS SliB.lFCI TO S\ 'BPOl'.NA,

(1) A purt\ \)r an attl)mc) n:;,;,p()Tl'>ihk li.)f lnl: 1s.o.;l.lsn,,;.c .md ~ct'v\.;e ofa :,unroena ~hall tak"e reasonable Slt.'PS to av{}id
1111po:.ing ~nJlll' burucll ~)r C\rCrlM! \111 a person ~\lhjc~t io \b<1\ 5uhp<)l.:na. file C(\urt (In behalf 01 whic~ lh~ sub~ocna ~as
iSSUl'd shalll'n 1(lIlY thIs Juty and Irnr<ls~ UP(!I1 tho: p<lrt~ or <I!torney in bn.'O.ch of lhi;;. duty an Upp\\)rnat.e san..:tlOn. whIch
111<\) Im:luJt:. bur is nol lillll\\!U ltl. 10M c;1l1ling:.:; and a rcasollahk JUomey's Icc.
pChon ~umm\lrhkd ll} pl\~dll\:1:: :md pl.'rlllit inl>pe~li(}n and r,::"Pl mg. (If desig.nated booh. pape!''i. docuJ11cn(~ 01'
tanglbk thIngs. or lllspl.'r.;!ion of p/,l'mi;,c~ nccu nul appl'~r In person at \h~ place of prnuuc\iull or inspo;,.\:lkm un!c~"
(1)( A) i\
C()l11flHlnlicJ to appeal' for !kp(lsi[lon, hCilrll1g or trw!.
\
,
'1
,
\
I
{HI Suh,je,,;,t 1(\ purugraph (0),21 ufthi~ rule. a perM'" commanded w produl:t! <.tnt! PCI mil inspection and Cl>pylng Iml).
within 14 dllyS afh;:r ~~rV1L'e \)1'lhi: ~ubpocnu Ilr bcl(-,te the lime spel.'ified lor cC'lmpliuncr;: ifslIch time i~ ies5lhan 14 da~'s
aller M:11'ice, "crvc upon the pany or :iUornC} 1.l~signatcd in the subpoena wriuel1 ohjccllon \0 in~pcc\ion or copying of an)
or all or the: designated m.tteri'lls or of the pl'Cml:iCit If nhJct.thm b, l11i.1de. thl: part} s.en ing the subpoena shall not be
Clllitkt.llll inspect and cop)' the Illdtcrials or in~pc.:[ the premises eX~t:rt pursuant hl all order or the court by which the
... ubroena \\a<; issued. lJ'objl:l'li()n h~:-. bcc:n maLle, Lhe party !H."n'ing the subpoena m<ly. upon notice to lhe pr.:rsoll
c()mmanot;u to produce, mO\'i! a~ any lime ti.1\' an uruer to C\.)mpc! the produclion. SUdl an mdcr lO cQmpel production ~hal
plm~":l .my person who i~ nol Uparty or un Ot1iC!!f or a pan} from Significant t:xpel1~C resulting from lr.e inspection and
(.;oP) iog mmm()ndcd.
13
(3)(Al {)n timely lTI(lIjUl1, lht; Ct!un hy whlc.h <.t sl,.thpoctUl. was
I4
Ii) rail .. to <lllo\\' reasonable time
j(lf
is~ucd
s.hall quash or moolty the subpoena ifil
cotnrlianr:c:
(iil rCr.juirt:s U ~r:'i{'n \\h~\ i~ [1\..I( a party I.H' lin O!fiCCf llr 't\. pi.my U1 \ra~ el ~o u place mNe. thun \lin miles fmm the place
where th~l p.!r::,n!l re;-;.iJcs.;"> empln)cu or regularly lr:mS3cls oU5ine~5 in pCr$nn. C'\C'cpt that swh a person may in order to
ath."nd lna! be commandcl.l tu lr,\vd from any ~UL'h pl:lcC within the ,. . t~tt: in which thl.! trial IS held, or
(iv) o;unj.:l:l'l .I pcrsnl1 Ln

di I I (a
lin JUt.:
hurdl'll,
~ubp(lcna
20
~
Ii) require:' disclo:;urc (II
:J
trade secrt't or other l'l1ll1i1.1enLiaJ I'l'searl'h, dc\ dopmcnl. or t'ommcrcml inlormation, or
lit) Il!~luir~:. Ji-;dnsu\ c ,)r an unrctaillcd \.'xpcrt's opinioh or mli.)I"ll1atron nm describing spt:cilic c\'C'nt:-. or oC('Ul1"en(.:e~ in
~\"~U\,I! ~l,J r'~hing from the 1.''I(pcn's ..tuay maJc not at the rcl./U(.'M 0/ ,my party, [hc \.'1)Ur( may, to proteCl1J person
~Uh)C'cl to or ,11!t:ctcd hy the subpoena, quash or modi IY {he :;uhpocna or. II" rhe part}' in \..\ ho,c;c hehfllf thl2' ,>uhpoellu i~
I.... "ueu . . l1mv,<, a mh~lilntid! l1eed for the testimony or maltriallhat CHnnd' be OIhcmist' met \\ ithoul undue hard.slliJ1 and
l
assun;s Ih'lI t ,l~ Per.-nn, I{) \.\ -, 1(\1l1 lIrr: :-'Ul.p()cna IS aJdle,\~t.:J \\ - bt.; rcasunabt) J;omp!.:m,iltcd. the coun rna\ nrdef
'
,
,
til
appc.tntn . . c ()r pr()Ju~[I\ln llnly upon spcciCi~J ~onJII;on~.
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~J) Dt ~Ta:S IN ~ESPONI)JI\Cj r'() SLBP()[NA (r) A pcr$(ln rc~ponding to a $uhpocna 10 produce dl)CUmcnls ~h3.11
produce thl'ln as t.hl:\' arc kr.:'pt U1 Ih- U:iU:.l r.:otJrse I"~ ',I ,
h II
'
.
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pu~rnc'i'<; 01 :-. a organIze and label then' w c\)rrt!spmvJ with {he
~~ltcgn~!~~ ~11 ~he J:m .u~u., (2), When in~ornlatioll $~hicCl tu.a ~l\bpl.leno.~:\ withhdd nn a dalm that it I:' pnY\[t:g.cd or suhjcc
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~}n,)l(.;r:tll n. a,~ ~nal rrtparutlon m~lI!l!ab. the -.:\.ilnl shall be. made I!~pn:~:-.Iy anJ shaH be supponed b) a dt'scriplion or
lht: Ilalure 01 tl~l' Jt'Cllllll'I\l'... t:'mnmUnil.'liions. nr thing:>. nm produccll thaI i,\ . . ul1ident w enable the dt'milJlding pari)' 10
cO!l(c!'.l the dall1l.
- ",bSVBJ>OENA AND SU8POENA DUCES TECUM
EXHIBITB
EXHIBITB

Case No.
STATE OF NEVADA,
Plaintiff,
Dept. No.
f2 crl 7 ...1 -0 c3-;J I
'~
SUBPOENA
Vs.
DUCES TECUM
. You are commanded to deliver the above mention} uments befo~e Reno Ju,tice,coU!1 at, One
South SIerra Street, Re?,.~evada on or before the
tl day of 1'0 \..,,~~ f '
=-::--_-:-:::--.at
Cl. 20
o'clockC~. on the part of 'zev:=K C; ... <c. h . \
22.100
and/or NRS 50.195.
Nils
DATED this _,4_.).....V\_day
of_~L:::..)-=:~-:W:. .:::;GL=:;.,:.V__, dD \ ~ .
:.'
'
STEVE TUTTLE,
Clerk of the Court
STATE OF NEVADA,
County of Washoe
)
) SS.
)
... .I received this Subpoena on the _ _ _ _ _ _ day of _ _ _ _ _ _ _ _ _~~,,;;.;.-w

."
:x
... "
"
_ _ _ and personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _ _ _&" n'"

;;..~----1
"
on this _ _ _ _ _ dayof _ _ _ _ _ _ _ _ _ _ _ _ __

this
J:"
0'0
day of
NOTARY PUBLIC
rev 0412009
EXHIBITC
I
I
I
I
EXHIBITC
No. RCR 11-063341
Dept. :-':0. 2
StBPOENA OUCES TECt;M
J~ THE JUSTICE COURT OF RENO TOWNSHIP

COl'!\TY OF WASHOE, STATE OF ~EV'\DA
Tlit STA 1'1:: OF NEVADA, PhimilT,

vs.
/M'j-IARY FlARKER COL'GHLlN, Defendanl.
2..uJ ~ ~v' '3}
TO
lA.JG D
r:RO~{: ZAeH COUGHLIN, ESQ. (Attorney temporarily 6uspended in Nevada self represented)
PL'RSl'A~T TO NRS 1743 IS WE COM'I'I,\ND YOU To API'FAR BEFORE

Depal1m~nt ~
Reno Ju,tk" Court

One Sumh Sierra Street.
-c
'7.-
R~no. :-':cvada '-'b ~ <;'

AT 8;30 AM IN D2,
to rcslif), for
Ih~
ab(lvc-named Dd'cndant.
BEFORE HONORABLE JUDGE SFERRAZZA
A\;Y PERS01\ FAILING ro APPEAR MA Y BE HELD IN CONTEMPT OF COURT

ACCORDING TO NRS 22.100 THE PEN ..\LTY FOR CONTE\>!f'T OF COURT IS A
FINE lip TO $51)0 AND/OR 25 DA YS IMPRJSONMEN r.
Dated:
11/6/12
Zach Coughlin, Esq.

1471 e. 9th st.
reno, 89512
B:
Ifyou have any questions

reg(l!(hng your uppeamnce, pkasc
contact: Zach Coughlin at

949 667 7402
Zaer. Coughlin
1471 E. 9th St.
Reno,
NV 89512
tel and fax:
949 667 P402 ZachCocghlin@hotmail.com
~d' .'(VA..
) s,.
C'Ol'\TY OF \\ASIIO[
i
brb,."r1it'i';hat i,'
c;:;~ CV'i
..
'led
t~iS
W,~!.Jl..A c(
ath C-~:~catJon
)j
at _ttn .5]
J-. ~~. dd~"r:Jng u c1/: of this Subpoena (0
.e1
1)
Sll)6Clla*o':..7
yv<t..
.;",d,,~~rrs,m;~lYing with the maillng leqUir~m ts found in NRS 174.345
~\~
Sig'
of Person D
Subpoena
re
'I.!rj
or mailing it
'---
you may
Date
1/611<
-
~---(1l!6!12
Signatur ()f' .-\ttDrn~) (suspended attorney)

Date
--.-----.S{JIlPOE"J,\ DUCES TECUM; ITEMS TO BE PRODUCED: Copy of any and all cell
phuTle,reCOrds (Incommg and outgolng calls), text Ille~sugcs l~)r ,ell number (775)527')-140 lor <he dotes of &.':0/20 II :lI1d 8;:21 !20 II.
x~~~~.nO!. have to ~1ppcar if" YJt.l provid.: Ihcsl: rnaterial~ to n tcpres~ntiltlvC oiiWx
or to Zac:!1 Coughlin
on or
November 17th, 2012
EXHIBITD
EXHIBITD
I
2
However, the Court finds that the RCAO's motion and supporting materials present a sufficient
evidentiary basis to issue this Order.
The Court deeming itself sufficiently infonned and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
I.
6
7
8
9
l!JI!,
A hearing on the merits of these matters is hereby set before this Court for 9:00
on Noyember 13.2012. Oral presentations shall be limited to 10 minutes each. The Clerk
shall notify Mr. Bosler and Mr. Wong of the hearing.

2.
Any subpoena not properly issued by the clerk or otherwise not properly issued
lOin accordance with NRS 174.305 is hereby quashed. Any subpoena not personally served by a
11
I
I
non-party or otherwise properly served in accordance with NRS 174.345 is hereby quashed. The
12
Court reserves its ruling on any other grounds such as relevancy or undue burden until the
\3
hearing on the merits.
14
3.
A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective
15
until the hearing on this matter on November 13,2012, to the effect that upon service of this
16
Order on Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter issue or
17
cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena
18
duces tecum in this case unless he has first presented the proposed subpoena or subpoena duces
19
tecum to the Court for the Court's review regarding adequacy, relevancy and necessity of the
20
subpoena or subpoena duces tecum, and sufficiency of the proposed method of service.
21
4.
Counsel from the Reno City Attorney's Office is directed to promptly attempt to
22
23
upon Zachary Barker Coughlin at the address in the Court's file, 1471 E. 9th Street, Reno, NY
24
89512, with a copy mailed to said address. Service shall also be attempted by email at
25
serve a copy of this Order and the RCAO's motion and any supplements by personal service
"zachcoughlin@ho~com'"
26
I
,
Dated this
&
27
28
Reno Qty AttoraC)'
P.O. 80. 1900
ReD.,. NY 8950:5
.-
"
x~~xx~r 1471 E.
; j
J'
Document Code:
Zach Coughlin.Esq.
9t~ ST.
,...,
<=
89512
L~ ';.0
Reno. NV~ 89512

Telephone and Fax: 949 667 7402
Counsel ti)r Defendant Coughlin
;~
Z:{/l
"'.'<
'J:~'~'.:2
d.. ~'-=;'-::
--=..
t ","
I>; TlIEJUS'II( [ COURT OF RENO 10WNSllIP c;
~1-~
CO"
IN AND FOR THE COUNTY Of WASHOE, STATE OF NEt A~'
\~
,...,
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0
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"
--
c.1'
-0
:::s;
..
cJ'I
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0
(:)
STATE OF
Pbinliff,
""8
~
1.
12
~EVADA:
" S.
ZACHARY COUGHLIN;
)
)
)
) CASf NO: RCR2011-063341
)
) DEPT. NO: 2
)
13
Defendant.
':'1
)
)
16
AND E~!ERGENCY REQuEST FOR CONTI:le]ANCE GIVEN ST.~TE BAR EEARmG OF 11/14/12
MOTION FOR MISTRIAL AND MEMORANDUM OF LAW

AND MOTION FOR RECONSICERATI0N OF RULING ON SUPPRESSION MOTION
COMES NOW. ZACI1 COUGHLIN, ESQ .. and files the aoove titled document on his own
behalrand it is based on the argument and authorities herein. and the attachments. Please note, this
is submitted lor tiling with the understanding that Couglin \Vas adjudged competent by the evaluator
,{'(j
21
IrOIll Lakes Crossing, Mr. Durante. but with the caveat that it is only being submitted prior to an
actual Order being entered by Judge Sfcrrana finding Coughlin competent (and thus, no exhibiting
/
:~
the violatiolls ofNRS 178 ..105 previously displayed by DDA Young. WCPDs Leslie. and
Goodnight. co-signed by their sup<!rvisor Jeremy Bosler) in light of Coughlin's reasonable be.liefthat
local law enforcement and Dr prosecutors will soon have him subject to yet another round of
26
retaliatory anc,t and prosecution, with all the auendant unnoticed bail hearings increasing his bail
tcnlilld, and deprivations of cvcl1lhe most basic items necessary IO accessingjuslice (like piece of
- 1/231 -
MOTION FOR MISI RIA L .>\ ND MEMORA "DUM OF LAW
'0;"
v
Document Code:
Zach Coughlin.bq.

XPf1~f
3
4
147] E.
9c~
ST. 89512
Reno. NV>II9OO:< 89512

Counsel for Defendant Coughlin

11' AND FOR THE COUNTY OF WASHOE. STATE OF NEVADA
8
STATE OF NEVADA:
)
Plaintin~
10
VS.
12
ZACHARY COCGHLlN:
)
) CASE NO: RCR2011-063341
)
) DEPT. NO: 2
)
:3
Defendant.
14
)
)
. '~
} (;
MOTION FOR MISTRIAL AN)) MEMORANnUM OF LAW

MID EMERGSNCY REQUEST FOR CON':'INUANCE GIVEN STATE BAR HEMING OF 11/14/12
A.ND t<OTIOli FOR RECONSIOERhTION OF RULING ON SUPPRESSION MOTION
COMES NOW, ZACH COUGIIL1N. ESQ., and files the above titled document on his own
18
behalf and it is based on the argument and authorities herein. and the attachments. Please note, this
is submitted for filing with the understanding that Couglin was adjudged competent by the evaluator
11'001
Lakes Crossing, Mr. Duranle, but wilh the caveat that it is only being submitted prior to an
22
actual Order being entered by Judge Sferrazza finding Coughlin competent (and thus, no exhibiting
23
the violations ofNRS 178.405 previously displayed by DDA Young, WCPDs Leslie, and
;:4
Goodnight. co-signed by their supervisor Jeremy Bosler) in light of Coughlin's reasonable belief that
25
local law Cnll)fCemcnt and or prosecutors will soon have him subject [0 yet another round of
?6
27
retaliatory arrest and prosecution, ,\ilh all the attendant unnoticed bail hearings increasing his bail
lenfrAd. and deprivations of even the mm,1 basic items necessary
to
accessing justice (like piece of
- 1/231 -
MOTION FOR MISTRIAL AND MEMORAl'\DUM OF LAW
Document Code:
Zach Coughlin.Esq.
x~~f
J
4
147l E. 9th S"
89512
Reno. NV~ 89512

Tdephone and Fax: 949 667 7402
Counsel for Defendant Coughlin

IN AND FOR THE COUNTY OF WASHOE. STATE OF NEVADA
"
STATE OF NEVADA:
"
Plaintiff,
.
"V
)
)
11
.
d
vs.
"
ZACHARY COUGHLIN:
CASE NO: RCR2011-063341
)
) DEPT. NO: 2
)
13
Defendant,
14
16
AND EMERGENCY REQUEST FOR CONTINUANCE GIVEN STATE BAR HEARING OF 11/14/12
AND MOTION FOR RECONSlDErtATION OF RUr.ING eN SUPPRESSION MOTION

17
18
COMES NOW. ZACH COUGHLIN. ESQ., and files the above titled document on his own
behalf and it is based on the argument and authorities herein. and the attachments. Please note, this
;9
is submitted for filing with the understanding that Couglin \\as adjUdged competent by the evaluator
20
fi'om l.akes Crossing. Mr. Durante, but with the caveat that it is only being submitted prior to an
2.2
actual Order being entered by Judge Sferrazza finding Coughlin competent (and thus. no exhibiting
the violations ofNRS 178.405 previously displayed by DDA Young. WCPDs l.eslie. and
Goodnight, co-signed by their supervisor Jeremy Bosler) in light of Coughlin's reasonable belieflhat
75
local law entorcement and or prosecutors will soon have him subject to yet another round of'
26
27
i5
retaliatory arrest and prosecution. with all the attendant unnoticed bail hearings increasing his bail
tcn!()ld, and deprivations of even the most basic items necessary to accessing justice (like piece of
- 1/231 -
MOTION FOR MISTRIAL AND MEMORANDl:M OF LAW
'V
IJocun1l);1 {od.!
/:l{)ttmgl'1hnl:~Q
1\\ flJl >,J" 'klilkJnClIlh ~u~vena.:d)

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alll'l!iMn wuh a~"""fIt'rc near tile !lI"!,~rN..'y '1lle;)tj IhOl\t of Jooe ',Ih HQlmC'li!lf
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r,~ll!'<j; ()t< !;;l1'6\da\ de.prte ~fld.~ 'I'Ilq~'" Croll'! ~th~" oounw. lltaliw d() <;{\ ,\I.
l ",l~ ~Itd <hre..'! resulr of \-If Cou,,1lhn's refusal 10 cooperate "11ft t~(! coml hI ~~1 h,s
<'l"~ hva"o\!. tllm he.!"n~ nevtr happen<.'rl ~ I() dars 10 which Ie oold thr ht~nn~
"r,d,e! 'lIl.S 4(j zq(SI h:l\t no ... "~p<fed Mr. C~hhn'$ motion 0; \I!rk, and I~t
,cll.:fhe ....:ds" I'Q\> nmc-hIIrr! &c.i1l5t h ~bBndoned thorl mnllon. II ....11_\.
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I'i<:ase fintf ''''p"malll ~"~chmc"l> wpportm!;t the ~\"11",,"< her~", tJff'

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Iht llCW ';>."CVU>'O j.amd htl;!"." "1:31\\'1 R'Crr.l.fd (; \1,\1 (~lo..') b..ll.tl 3'l1l
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1~~hll(Ci<! '"we<;' wnll ~Il\.lll~ fmtn CQ.u.,;.M,\\, wll<ch 'n 00 ,,~, 's \1\(,,-p'ol'll<1a~
l;lil.'lll's fib und Illy O\~n files their impcnuIS51hty lIlr1uJ:nclIlg lhe
RJC. to COl II to give me II hearmg on 1lI~' November t 6th, 20 I f fibn.:
of a MoHon to Collt~SI PcrSOllal Proper,,' hen ",uhin .he J 0 day> fluned by ~RS 40 253(7}-{S) lhcmtng onl) look pll'l~(, ulkr '
RIchard's SI)... W\!\!k 'Iacatt~lfl. on n.emhcr 2{lth 20\ \ "' acC()rd
wHit Rlchard's \.\nlll:n mdlcal10n to me lhut oc \.\tlutd he abk to i!Ct

1he rue 10 wall lhallong on hiS Il(C(JUnt an ImJl('lm!S'ilble, sugg...
...,\10n l'l) RIl hard thai he c(luld Impmrerfy mllu<:n..:e:t
Inbunal. as n'a~ Rl,hard threat" rh:ll hI! \V{)uJd ha\;:, m~ 2JVCn Ihe
J'JH.hm v ",ll1lt '\C'\\tM~ I!tl~ant" \TC'ol\m.:'nl ,1-1 hepl up m\
Plt'llse indicate in .... nllng \\1131 )'ou havt! done 10 lnvcsngate

Richard G Hill'.. alkgalions. [L<; set fonh In his JJlflUar;.' 14th. 2012
~ne\'!llJCC 3l!ainst me, In wrllmg. including, but not hmlted to ilill''\
~!kga\loos ~IS a \IS tl\-.! cn1nm,,1 trespil':.s!l.~ of me m on
NQ'$cmbet ! 3th. 201 I, Icadme. [0 !ll;ustodlaI arrest,and three
[flljfiC (ttaflons b} RPl> Si1rg~nI Taner follOWing my release on
November 15th. 201 t when I ventured lO HIli's office to retrieve
m\ stale Issued dn'rcr's litl"ll.'>C. wallet (cn.-dl[s card. monL'Y), and
ITl\' ,'hem's tiles and mv own files and hard drives and other
m~wrm1s Tn):'> 1~!1 \",,);mal, wnl:len griev<ll'Itc aga\\l5l RlehMu !hn
and Ca~'Y Bah-r, III compliance wIth my RPe 8 3 obllgatlolls
resp.xUJlg lhe"lr lailtl~ to tvm over my hard drives, dn\oer's license.
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RICHARD '"1,1. Of- THE RENO POlice DEP:\R","AENTS
from: lxbO>agllIln ["""i!ln6CllC"'4'l1..c~~.ca<n!
s.m. Morodlly. ~""'~mt>et It. lon ~ 10 PI-1
CflRIS CARTER Al'.D SARGENT LOPEll~ THE TIME

PRIOR 10 rHE LANDLORD. MERUSS ALLEGWL Y
KICKING OOWN Till' DOOR, IS OF MATERIAI.LY
To.: ,rJbak""~I';hllllh'1.wn1
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Ca!rf'y, C'Q,ltln1 open tllfI-" ~roj <"OefI it I ~uId, (dM'lW'R'll' to ~ toy ~iol~ it~,
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This .::orrespunden.::e rl!mmds ) \,IU of lind furtTh:r pJaCt.-"'5 YOli on

1'l(l{K: ofth.::l! Ihl;' fae. that "OW have been placed on a
I.ln(iATION HOLD NOller: THE VIDEO FILMED BY
11l3'1etOlclYO<J!b.Ii:1IW!)'t.<III!S 1,"*1le"1'1oCi.Y,IOt5a~I)'DJmJl(l{O:~
attemptj"'l to C~ lhe ~'" Pf(ltM1O'l5 .act,0fd00 IenIIn~ TflI;' (II'll< 'nill"'.. fo!
w "lIdll 00....!"1 t<':> lI,l""1l you or)'<AA <'IIIIcl! ~ I'W by <"NIli ~ I~ te'11'1e If ind wl~\ 1 Coli!
Ql"l nil' e.~ [bt1rrl~ ~ mat~~ IIMaed odeo~. ~t{ 11'<!tUM> "'~
~tt ~ am II\OI:iOro ~u ..... ~ Ii:> .... II9!hrotqt!l1e rot..u oIT _pSO!!t~
II'!ttlholdong II11It1olri ~El(Iwillle! rO'ltfflor' YOIX berWT IMn Hisl
Rr:!.EVA\lCE '[0 SEVFRAI CIVIL lAwsurrs AND
CRIMIMl PROCEEDINGS RICHARD Uto IN COURT.

U@EROATII WHEN HE TESTlflElHflAT TIlE RPD
,\;;~O\JNCU} 'I IIEMSfLVLS AS LAW ENI'OIlCEMI'NT
A~D ORnEREf) COU(ilfLiN TO COME OUT ()F THE
Bt\SEMrh r .t!!m.B. ro 1Hi: l)()OR BEING KICK)::'o IN
RICHARD SE:'IIDS THE STATE BAR 0" NI: VADA LETfERS
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Inllur..: 10 1O$:,'>tlt;iltC. m a!l~ rcul way, th~ cfirmn:lI trcsPilS~
allegations, H\ \\\,hl.\t\ln ofth.: ClUlbnml! de~r.\lon \;\"on my
11"~lIIg you pomted qU~S(lOns, you hum ..
'dly tiled a SCR III
Pdltlon 1\\ an atl\.'mpt l(t-.!>"cu:'i:" Y\YuT r.lllurcw u~k an\ of thl!
pOllli~d (JI.IC~llnn~ J hil\'~' pr1!Vloll<;l) put Jhrth to ~ou n:g.Jrdlng thai

Hlmll1ai tre~"'!>
maller, further:> (lU admined \lllx'm~ UllJ\-\ arc

(allcg~'dh) $flhe lalmll.11 relation he:\~\Xn Judge Wilham Uardn..::r
;IfIU !IH.ig~ 1 II)l\n G:udn~y (dL'~pl1e Ih:lt l'l(lllg qWle (."I!;lr In 111:I<-'l:cnt IIluIgS 10 $IU)
} lXllIER, OffiCER CARl ER'S POLICE REPORT IS

D[MONSTRATEDTO BE fULL OF LIES BY Tl-fE: VERY
VID[()S THA r IIILl PROPOU/'o.OEDTO nn:: CITY OF RENO
PROSECt.;'WRS. PARTICI,;LARL Y WITH RESPECT TO
WHETHER coU<tl!!.IN REFUSED 1() I.EAVE AfTLR BF1N(J
WAR?-JEDoR 'IOLD ro DO SO ATo.JDTliE EXTFNT 1'0
WIJlCHCAR'fFR WAS liKAIRF.'rO ISSUE A CITATION OR

RELY ON .\ SIMJ'LE W.'\R~JN(; 1;..1 I.lGHT THER};OF
COLGUUN ACTUALLY A.SKS CARTER f\= TilE VIDEO
lilLI, FILMED WUY HE DOESNT JUS1 ISSUE SlIDI A
WARNING OR CITATION Then, Clln~1 glX!~ on to attempt to

Olli'f !ll~ \ le\\5 on ~sef\ ICo.!~, hov.'ever rudimentary Iho.!! may re,
bemg careful to IlOII! to Coughhn "~ou'r~ n,)1 th.;: Victim her\!"~ 10
lhl!' I!\.!o:nt that ifill and Ml!rhss lr~~pass iow Coughhn'~ fonnt.'T la\\.
"me<'! on thiS dalt'. \\ah Inc- help oflho: RPO_ Soldal \' Cook
<''ilU'')t~ ha~ bl..:n Violated. ilnd Carter &11d LOPCl hav{' VIolated
Whcel ... r y Cos!>
,
\.J
An, \:VH;lu~$ Ol\1el slg.ned by Judg\! S!\:~lillJll \""'" ~\ilk m \11.111 of
th..: I(ulurc to have the Ind..out orOCf s(''fwd upon (',mg.illm and II
locloul perlilrmt.'d "wJ[hm 2-1 hour<;" orthe Sherin's rc~'~lpt I)t Ilk'
Order of both (kt 25th. 21)1 J (the- slmp\c one page Order ~lgn..:d ~
Judge Sfcrru77<J lind notal..:d in hIs own hand\\fi!lllg,j and orlh.:

O,l(lb.:r 17th. 2011 rmdings M rae:. Conclu"'IOI1~ {If 1.<1\\. and
Ortkr lor Sumll'lar.v ["Icllon) both of "hlCh ..... ~r..: f\.-'t'CI\CO n:.' the
WCSO \,dl (\,<cr 24 tm\J~ from .... hL"" the lockou\ s \\.:rc
mndllcll'd, and rhcrd{lw. both such Ordl,;'n> 'Wcr.: .1IIl1e. lmd
tn,.'rd()rL'. Rl{'hard tJ J 1111. E!>q. comll1lUed trc:ipas~ upon

t {\\lghhn'$ I(m\~r home \;i\\ otTIcc, thr\,.'V\ .......>\\ "grl!/It 4..-31 {'If
{'ollghlrn'~ p'-'rwnalty (some
II 'len' !>Cnfullelltalj. and voth lilll
or
and
B~ker
lh~'
doortherl,.'Ofund cffl'C1l.latcd 1J ItX;\,OUl tand
Imve-Iled repealedly
In L;OUllllhn." In indlcatmg lhal

t\,ll!:!-hlm \\",\\> ~t'I\'e,flhc ~llmm2lr:> L\ IC\"-'lI\ {)rJ~f ,\n t'\{wICI,\h\:r
I~t. 2{)11 ',O.... re the) <llso adrntl Ilwl Coughlm \\a~ nm.at hIs !llnner
home la\\ ollie" at 111" tlill" W(,S(} DeptH) Ma...h.:-n ro~{cd It \)n
~1i\\:hclll1ed
undl,.'T
onth ill 1m. Novl!l1lber 7th. 201 I fikd Afflda\ J! OfSL"r\'tee <ltl:::-.tllll!
to h;l\'~ "personal!) served" Coughlin the SUmmil!} L\ !Cllon ()rd~r
on No~cmher 1~I 2011 (WCSO CIvil DIVISion SUpo.!n Isor
adrmtt~d a~ much to tou!;Ntn In .... fltm-
f~J A )181~nh."tlt lhullh~ wnUen rnnlce 1\ as
.;.cm..-d on rhe tenant III
llcrvr\lQIla" WIth ~
,%) ,\ c"Iw \}f\n" .... (1tI\\ not\C\! w;\ooQUdl<l l.(t1ant

(!Jl ,\ ~ oflhesit'l'ed v.rilten fwtal agreclllCnt, ifan)'.
Ib, h,epl "hen the renant Itus 11I11ly tiled Ine affida\ \t de~nh<l In
,'ll~l()nl and 1I f1I-~1IlInped<XIpy ofl! has ~p I~Cil1\'ed~' the londlord
(IT tnc landlord-s ag.CIlf. alld e"I(CCpf when the fundtord IS prohibl!d purSullnl
!\)}"f!:s 1\1$;\ l~,lhelftl\dk.fdNiht-bMkwd'~lI~o:nlmQ~.uln~bL.!
III:rrtu~r. pfmido! for rhe nOIl!\Jmiflal'K'(' oflhe tenon! In Ihe p(('miM:~ h}
k>.:luljZ 01' OIhefll-liie
hrt~r whm IS m; dOlmuge d...'1'IOs,\t {<!\t~{ $SOQ. ot.arguahly
.)700 gn'C'n the extent !(l which the Standard Rcnt<ll A~ment
(dfordeJ me the ehol\'e v.nh fL'Spcct 10 how cleaning ",a~ 10 bt=
done and lilt' \!",tet1t to which HIli and Bakr have fouled to t(j.mpl~
\\llh
Mr Bake \,ou ha\e eommmed profesSIOnal misconduct (and filII

agamst me III a letter 10 the SBN dared Janua/)
14th 1012 purponlllg to be sent on your behalf III "fulfilling your
!)It'd;t gr"-"\<lnl!~
NRS 40 253,
~
\Jpon nOlJcompllun~e" 1111 Ih!.' noh.;~

(nj'Ill<.-lrtml\\)ld ('if the \nnd1(Wd'~~ell\ m~ arrAY b) llt)iOO\l\ or
COnllllmnt fur Ll~t\;11ll11 10 Ihe JU,IKi: ,.oun uflhc lo"'n~\l!p!ll ",hl.;h the
dv.clhn!L apartment. lliOb!le lIome (>I'C<)Inmerci31 p'eJlN><:, lIT.: i(-.;;]Ied Of I"
Ihe UI~tri<;t wun Oflhc OlI1l\ty in \\Iucb Ihe dlO,cUwg,.
~IXUI,."\It. nk,b.I~
Il<lm.: ~'I com,ner~ll,1 WIl1I!\e~ JJ'~
hxawd. I'<h\~he,crl]o1.'Jllr\.,;;Il.;:tIOiI iller

lhc nlaltl'f Tht fOUr! md~ tbtrtUJI-1.IO lWaLlllJltlku.liudUl1Jht. Jlw:ll[
Qr ,no5mb" or 'M {'WID(\- 19 Il'DlO" !!,t Irnan, Within 2.t bUilD atur
Wtjlll of !be grder. Thr .md,,!! midi uJIt' ftr fOD1aj"
(t I ! he <1;11<: (h~ t<!ll(ln<.:) "(\n1\\1C!I;<::~1
(~I'I he mllO\!I1! ,)1' pcnoJlc lUI rl'Si!1 \ ~
I~'! lhc nll\foUnl~<J1 ~~\ deaulllg, ,'>I;'>LlI'I~ ('f rNt d"'.K.,.,.,h f'<'\\J In
adl':)uc,:, 111 C'l.I.l'!>' Oflh~.' fih! \II(lllfh.). mn.1'1' Ih.: t~"Ufl!
(~,I Thedlllc Ill.: 1<!1l1111 pm mcnt~ l:leellll1~'lkhl1qtiCI1!
Ul :10, wa\' to Coughiin in Itk.- "ba~mcnl" or 0111..:1'\\ IS( rssm:J hun

<In) ;<;0)'\ of '\\";\Jl\lrtl); \0 \em,,::" 01 ~ordcr to emcrgt:"" of .any !>on.
,\hal~(leH;r Mr l3a~e(. vow \\\.':n.' nN I.!ven there Yet }OU vk'\\cd
Ihe \IUI.'O takcn ~y RI("hard Ihll 01'[11<'" moments In qUCl>lron .... hc-rc
the RrD -'ere al the basemcOl dwr pDor 10 Dr M~'(l1i>s <h:km!,t il
down. inclu(hng those momCnL~ v.her.:: Dr Merl(~~ is. 1(1..."en in OO!!
'<Ideo whlspeftl1g to RIChard ifIll Iflht:T\.' really was all tllJ~
tdcntrl}'mg fhem~el\\.'S as lal\ ~ntorcr.'ment and issumg ('oughlm
(In uru.:r \1) cmcr1,c \>,.hl..:h \\o;!\\! lmh\:oocd, t!~n \.. h~ \he
whl~p.:nng? Why dId RIchard fUl! to mchlde the ne to<>k of lhe
moment", where th~' RPJ) ,"Cre LIt thc ~hasemcflt~ door ,m faded 10
ukn\lly th.:mselvcos or Issue 1m) I<mfuIOrder!.' 11(1.... \\ould
Coughlin I..n(lW thnl an" V{)ICCS thai mil) h<lh' tw..~11 audible did Ollt
Simply bcltmg to mor.:or' tit.: gnon~ }h!l and Ba~er roulfnci\ 1m\!
lrum Nt.'Vat1a C.)urt SCf\lce.<, to Trr..~paSS Nhrnd Coughlin')) Ic.)rmcr
home la\\ ollic<:,'s bad yard gatl!, \'i~iung III
~~ I fhe length of lIIne Ihe I~~nt h~s rcnl<l!Ocd in PO'i~>S!o!l ""iLholl!

Pil}'Jllg n...ns
IfJ) 'It!< alllDUTll orTent c\a\mtd d\l~ and delinl.II\I!\I1
pal~. threes 1t1nc,:>;o.
da~'. (Itli.' rmglng Ihe d{)()f ~II
repealedly lor 30 mUlutl'~ lit a tlmc.

\\!lrlt'lhc mhl!rtR \Vmv, Jnd I)tlrdcn. and other licensed proces..
""'-f\I.!(') tr~\'lUs.S\!" l.ohll1d &, a lntl;ked bad,Y<lrd g<l'~ :md h.\ng<, on
\\jnJ()\~'I and JX'1,'f:i Ihwugh closet.ll;.lli1d~ \\ hI!\: Issumg lhrt!al~
mlcnJ>:d 10 mdl,alc Ihe) art.: bcmg made h} ~mn~(Jnc \\olth color or
law t'l\:hll1U Ih\:\f Vvl\ld". whil\! dU.'iSl'li up In an omlil ~fl'.'clnw\h
1l1t~nd ..-d to conflJs~ lIlt' publIC 11110 thnu..mg Ih.!~e pfucess 'ief\.~rs
arl! Shl!nH's Dt:rUtll':,'1
RPC 3 8 nl'-hg!\tl(ln~ s(rnp:< put, Mr, Ba~er.ln ~(lurOppositkln to

MOlion III C{}llSt~t Persondl Proper!) Lien m Re\2011-OO170S. on
page 5. you lie where you \\,Tlte ",\-hen Coughlin refused 10 emerge
from tnc m\Cmcnt after beIng -oreeted to 00 fo\) by the pol\ce.
Merhss '>'.'as forc<.'d to l;ic~ Jov.'TI th~ door to gain access 10 hIS own
rro~" You kno", (hal thaI is nOt true The Reno PolIce
Oq\1rtmenl did not idemii) thl!m~ln:s ai> law enforcement or
()lherWl~ i~sue ali !a\\.ful Or~ Jlrectmg Coughlin 10 "emerge
rrom (he basement" You haw demonstrated a lad, ofcandor to
the IrlNinal In thal regufd In oollspiracY \\ flh RIChard Hill In a
Vldl....)UiPl-"d tntcrvkw, RrO Sargent Lopel admIts. lha~ neither she
new Officer ('aner, I\{)r ,my(lll~ .;:tsc Ihul d'l). Illenttfkd them~!wi>
\ldC05 HIll took Ihal <fa) reveal those "pJib~ are vltaml(15,
~omC'thmg
\ill\ fall!. to clan!\- w1th the SB~. and 11)\1 neveT has
provIded an) sort ofmdlcatlOn of what the "crack pIpe and bag of
\\t.t.'d~ looked h!.ee'(.ilclly, nor has he respondl.':d m reque~s fOf
phutographs thereof. or Il1.1de inclu::atIOtl why lie did not call the
rol\\.~. gwen the f~t !.hat l\~ Ita:> lU\o\l.'l;!d la\\ enforc-crnem \\t
ever:- other pos~able tum,
I I,ll and Ba!.er hme continued 10 IJil 10 dellV!:rCoughlm's security
m domg ~), where Ihey falk"(\. i.) ptlw\de the r~qu\sl\.C
l'omspondern:e wahm 30 da}S of any :ouch eVICtIon, have v)olatt.''.;
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~I ~tJ,,,w''''r.'"HI""\I'7';;';'HIt.-''''''Q''''lb
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the Nid Jh' mlhe oimmt'nl IS the lact tnu! RPD Sarg~m
I ()rl\."/ltdmJ(t~d th:lt O""ther :.nl:'. nor (tlner. nor anYOf'k,' ""Xfdlllll"l.:d thcm'>(.'hc~ It.. Jim enl"fJiI;O:l1n:m and or i,,~uo!d Coughlin
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OcciamlJon In RE~2(1i !001708, fikd a '>C<lII[ 7 Ja\~ afkr [h~
"rrc~t /Jill l~rtaml\' :atl~ [0 m~'\lton anv ~UI.:h alb::t'<! mom~nt
\Viler~ I!~ RI'D ~Idy IIwm~\oics as l~\\ ellli.)n:e~)em llnd )-;.suc
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Document Code:
Zach Coughlin.Esq.
PLEASE UPDATE COUGHLIN'S NEW ADDRESS
1471 e. 9TH ST. rENO. NV 89512
Counsel tor Defendant Coughlin
N>
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IN THE JUSTlCE COURT OF RENO TOWNSHIP ,

IN AND FOR THE COUNTY OF WASHOE. STATE OF NEVADA
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STATE OF NEVADA:
Plaintiff.
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1/
vs.
ZACHARY COlJGlIIJN:
Defendant.
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1S
)
)
)
) CASE NO: RCR2011-06334I
)
) DEPT. NO: 2
)
)
SUBMISSION OF MA TER IALS RELATED TO RETURN OF SERVICE OF SUBPOENA ANO

MOTION FOR ORDER FOR AUSTIN LICHTY'S ADDRESS FROM DMV (TRUCK HE WAS IN
HAD PLATE OF 288 prv TEAL FORD F-150) AND FOR IDENTITY OF OWNER OF AND
CALL RECORDS FOR DA Y OF ARREST FOR 775 378 6673
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COMES NOW, ZACH COUGHLIN, ESQ., (temporarily suspended attorney with

Disciplinary Hearing tom()frDw, where Panel denied request 10 Bifurcate (please see attached
accusations and dvd exhibit) and files the above titled document on his own behalf and it is based on
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the argument and authorities herein, and the attachments.

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Facts and Law:
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Tanner Chan and Lucy Byington werc percipIent witnesses and Chan seemed to be making a
911 call that ha.~ not been produced. Jessica Duralde is a 911 dispatcher whom was working for
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ECOMM during the 8/20111 arrest by her husband. RPD OtT. Nick Duralde. It would be useful to
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subpoena and question her, and find out whether all the 911 calls and or dispatcher to rpd
communciations and recordings and records have been propounded. further. DDA Young's multiple
s
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violations uf"NRS 178.405, and the WerD's auger ror a dismissal or mistrail.
Goble's AT&T records:
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08/20111 09:351' 0:20
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08120111 10:031' 0: 12
40
08120111 10:081' 0;10
43
0812011 I 10:431' 0: I I
17752338593 177552794400:00
17755279440 177523385930:4 I
17755279440177523385930:08
17755279440 177530430043:30
17755279440
17752338593
17752338593
17753043004
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48
08/20/1111: 21P 0:2117753786673177552794400:0017755279440

08/20/11 II :26P 0:21 17753786673 17755279440 0:00 17755279440
08/20/11 11:33P 0: 12 17752303726 177552794400:00 17755279440
08/20/11 11:361' 0:01 17755279440177523037260:0017752303726
08/2111 I 12:07A 0:0817758153680177552794400:2217755279440
sms:
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50
0812011 I 09:241' 17753786673 17755279440 IN

08/2011 I 10:231' 1775304300417755279440 IN
08/20/1 I 10:39P 17753043004 17755279440 IN
08/21/1 I OI:12A 17753786673 17755279440
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RELEVANT NUMBERS:
304-3004 (10:43 pm call to iPhone lasting 3 minutes and sms text messages to iPhone at 10:23 pm
and 10:39 pm)
775-378-6673 (I I:21 pm and I I:26 pm calls to il'hone. also matches an incoming sms messages to
the iphone of 9:24 pm on 8/20i I I and 8/2 IIII at I: I2 am). Coughl in absolutely needs to know
whose phone this is and has been unable to. A subpoena to the carrier is a necessity or some other
means of determining this individuals identify (Zarate's testimony speaks much to these two calls, or
purports 10, and they are central to the whole "saw it lit up" versus Zarate's confirming Judge
Sferrazz'as "so you personally eye witnessed this?" qucrries. versus Zarate contradicting himself by
saying he was too far away, alternately.
230-3726 "Nick" (RI'D Officer Nick Duralde) seems to have used his own phone to call the il'hon
in question at I I:33pm and then call from the iphone to his own phone at II :36 pm. Otlicer
Duralde's presence at the continuation 1'0 the Trial is absolutely necessary and having him under a
subpoena is likely required ...
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police report Witness Statement or Goble:

home number 287-9555
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MOTION fOR MISTRIAL AND MEMORANDUM OF LAW
cell: 5279440
2
lamte:
home: 747.4773
work: 7475050
911 dispatch records:
II :23:26 pm and 11:27: 11 pm calls by Goble from 2338593 (matches myspace for Austin Lichty
or at least number mentioned therein ... However. the video and still frames Coughlin took reveal
"UFC Guy" passing Goble the phone with which he made the 911 call of II :27: 11 pm .. .If UFC Guy
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is such a stranger to everyone (and one of the videos with Lichty may reveal Lichty indicating UFC
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Guy's !irst name, at least..). then why docs Goble slip up mutliplc times referring to him as a
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"friend", and why does he. at one point. have possession of what is apparently Lichty's phone to pass
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to Goble to make Goble's second 91 \ call? And why did Goble testify that he only made one 9\ I
call? Could it bc because the second 911 call was fraudulent. wherein Goble misleads the dispatcher
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about how "someone just socked a minor"?)

Whole latta summary evictions and summary contempts goin' round these days in
Northen Nevada legal circles. at least (even "summary criminal contempts". truly a rare
species). King of brings to mind "summary executions" ... Libya of yesteryear. Pol
Pot...okay, that's takign it do far. .. but "summarily dismissed" Appellant truly appreciates
this Court's recognition of its own 6/7/12 Order Tempomrily Suspending Coughlin from
the practice of law. This Court therein demonstrated the high ideals it adheres to.
recognizing (where many other local prosecutors, Courts, and court appointed defenders
did not) that it is not permissible to try to have it both ways with respect to matters of that
sort whether we want is talking about and ordered temporarily suspending one's law
license pursuant to a SCR III (6) Petition or an order for competency evaluation in light of
NRS 178.405 and NRS 5.0 IO.
However. Garin's Respondcn'ts Brief itself argues Coughlin's "failure to cite
to" the Appendix or ROA somehow disposes of everything. yet Garin gets the benefit of
all 5 volums of the roa to work with. meanwhile. coughlin is denied access thereto on
mUltiple occasons by this Court's electronic 1I1ing system. and only !irst obtaine dpartial
access thereto on Oct023. 20 12 ... and still had not been afforded access to vol 2 until today.
Coughlin has done a great deal of research on these issues and feels he has a lot to do. if
given a bit more time. Plus the SBNfPanel ar jamming him lip with a 11/14112 "combo
hearing" that violates every aspect of scr I05(2)(c) and this courts 617112 order ("sale
purpose" proceeding singular, ser III (7)(8) .... elcano mcgcorge '78. rmc nash HOlmes
greivanc ng120435 mcgeorgc '77 (see 60838 and 61426 and this matter 60302).
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MOTION FOR MISTRIAL AND MEMORANDUM OF LA W
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At the richard G. hill and casey baker triple traffic citation trial in II tr
26800. the next day. judge nash holmes entered her "Order Finding the Defendant in
Contempt of Court and Imposing Sanctions" on 2/28112. wherein. amongst other things,
Judge Holmes writes. on page 2 of her Order:
"The court had the defenant sworn at the beginning of the trial stating that the
court has found that most self-represented defendants tend to testify a great dal as they
cross-examine opposing witnesses so the defendant would be under oath fTOm the start,
100". One. that is ridiculous. Two, that is not as Coughlin understood it to be (rather,
Coughlin understood that if he chose to waive his rifth Amendment Right and Testify in
his case in chief. then he would be under Oath when presenting any such testimony. But,
regardless. Coughlin did not lie. regardless of the reckless. reprehensible, troubling
allegations that Judge Nash Holmes makes so easi Iy later in her Order of 2/28/12 (which
she doesn't bother to bolster with an),thing more than unattributed hearsay (especially
consdering the second bite at the apple, so to speak. she took ill issuin another Order
attemting to transmogrify "a simple traffic citation trial" into a full blown Disciplinary
Hearing (albeit a summary one. natch). Further, don't recall ever hearing 'bout a RMC
judge putting a City of Reno prosecutor under oath from the start. and Pamela Roberts,
Christopher Hazlett-Stevens. Jill Drake. and Allison Ormaas sure seem to do an awful 101
of testifying themselves as they cross examing witnesses (or. for that matter. as they
examine their own witnesses on direct. often asserting facts not in evidence. though it is
morc typical for them to do that ill their closing arguments).
"Nor docs the trial judge's speculation that Appellant "might use his closing
argument to present unsworn testimony,rcpresentation. First, although the majority opinion
describes the trial court's speculation as a legitimate concern. I would observe that the
record suggests otherwise. From all indications. Appellant committed these horrible
crimes. During the court proceedings. however. Appellant consistentl} maintained proper
decorum and. even when he vehemently disagreed with his appointed counsel.
demonstrated that he was capable of calmly and rationally relating his concerns to the trial
court. Further. Appellant himself informed the trial court "I know what I'm not supposed to
talk about anything other than evidence that came up in this trial. So it's not like I'm trying
to testify [.)" [n addition, both of Appellant's appointed attorneys indicated that they would
be willing to work with Appellant to "make sure no objectionable matter comes into the
closing argument." [n any event. however, [ would observe that, if an assertion that "the
defendant is going to do something wrong" were a basis for denying a defendant's right of
self-representation. v il1ually no defendant would ever be permitted to participate
personally in his or her defense. Accordingly, the law does not recognize the likelihood of
a defendant's incompetent selt~representation as a basis for denying the right When
delivering the closing argument, however. Appellant would be held to the same standards
as a licensed attorney. the Commonwealth would have an opportunity to object to any
improper argument or deviations from proper procedure. and the trial court would have
been able to rule upon any such objections and grant any relief that it deemed appropriate.
FN20 FN18. SOLO, 139 S.W.3d at 857. FN 19. See ['aretta. 422 U.S. at 834, 95 S.Ct. at
2540, 45 L.Ed.2d at 581 (,[t is undeniable that in most criminal prosecutions defendants
could better defend with counsel's guidance than by their own unskilled efforts .... And,
although he may conduct his own defense ultimately to his own detriment, his choice must
be honored out of 'that respect tor the individual which is the lifeblood oflhe law.");
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\'lOTION FOR MISTRIAL AND MEMORANDUM OF LAW
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Crawford v. Commonwealth, Ky .. 824 S.W.2d 847, 849 (1992) ("A defendant has an
absolute right to waive counsel and to represent himself and no determination as to the
effectiveness of such representation need be made."); Wake, 514 S.W.2d at 695 ("'No one
contends that an accused must be capable of adequately representing himself in order to
make a valid wniver of counsel."). FN20. See Faretta. 422 U.S. at 834 n. 46. 95 S.Ct. at
2541 n. 46. 45 L.Ed.2d at 581 n. 46 ("!T]hc trial judge may terminate self-representation
by a defendant who deliberately engages in serious and obstructionist misconduct.'').
Ky.,2004. Soto v. Com. 139 S.W.3d 827.
Judge Nash goes on to write "the COlirt finds that defendant's contemptuous
conduct consisted of his" and amongst a laundry list of synonyms for "difficult" Judge
Nash Holmes throws in a "deceitful" blast. then on page 3 of her ORder amongst a lot of
things don't have time to address now she writes "9) defendant's lying to the court in
response to direct questions posed by the court with regard to his recording the
proceedings". Huh? Please do explain Judge Nash Holmes. And please do follow the
affidavit requirement in NRS 22.0 10 to the extent your Order purports to rely upon some
unattributed hearsay from one of your Marshals about something in a restroom (and please
do try to get the order of events correct. ie. the one restroom break came BEFORE the only
point at which Judge Holmes went into her sua sponte interrogation of self representer
Coughlin about recording and or "recording devices". which Judge Nash Holmes launched
into IMMEDIA TEL Y following the one restroom break... and it sure would have been
intcrsting to hear anything ORmaas said ex parte to the Court during that break, even if
itwas ferrkd to the court by a Marshal. REgardless. Judge Holmes play by play rendered
two weeks later is one of the most disturbing, misrepresentation filled discourses one could
EVER come across ever, inside or outside of the law, considering her position and the
manner in which she leverages it. good lord what the world does not need right now is a
27 year old Ct Marshal with tatoos exposed all over his short sleeved ensconced arms.
nostrils naring angrily on a daily basis at any defendant in any way questioning being
ordered to sign things without reading them. that Marshal making $85,000 a year plus $50
in benefits being told he is the eyes and ears of the court outside the courtroom and that his
attestations to the court, however murky. negligently made. not in an affidavit as required
under NRS for those allegations based upon conduct not in the court's immediate presence,
or outright spurious, will necessarily result in attorney's losing their licenses on a
"summary criminal contempt basis". Judge Nash Holmes is supposed to realize that, right?
Right"
Judge Nash Holmes concludes her Order with "The court finds that the
defendant's actions were intentional and done in utter disregard and contempt for the court,
and in the presence oj' the court. for the purposes of disrupting and delaying the
proceedings and dishonoring the rule of law and this court, and constitute the misdemeanor
of criminal contempt, a violation ofNRS 22.0 IO. Good cause appearing therefore. the
following sanctions are imposed: It is ordered, pursuant to NRS 22.100. that the
defendant be incarcerated at the Washoe County Regional Detention Facility for the term
of five (5) days, from the time he was taken into custody on this court's order on February
27. 2012, and that ,cntcncc shall not be reduced for any reason."
Huh, that's the strangest thing ...
NRS 22.100 Penalty for contempt.
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t. Upon the answer and evidence taken. the court or judge or jury, as the case may
be, shall determine whether the person proceeded against is guilty of the contempt
charged.
2. Except as otherwise provided in NRS 22.110. if a person is found guilty of
contempt. a fine may be imposed on the person not exceeding $500 or the person may be
imprisoned not exceeding 25 days. or both.
Huh? That's weird. Judge Nash Holmes, in effecting the rarest of
"contempt" species (even rarer where levied against an attorney representing a "client"
even if in I t tr 26800 then attorney Coughlin's self representation rna) not tit so easily into
such a designation seems to be finding a way to get around the fact that lots of the stulIshe
vaguely cites to in the 2/28/12 ORder (you know, the bold face type-ish. gut punch, chop
block. cheapshot "findings by clear and conv allegations that Coughlin
Its a real tooled up Order Finding Defendant in Contempt and Imposing
Sanctiosn by Judge lIolmcs if }OU look close enough. You'll not a real careful steering
away from phrases from Cooke and the line of cases detailing how incredibly narrow an
exception and application the law will permit for "summary criminal contempt" .. .Judge
Holmes Order will not contain the buzz phrases necessary to support a "summary criminal
contempt" finding .... like "immediate presence" or "every element under watchful eye of
the Judge" or "the use of the summary contempt power is proper only for "charges of
misconduct, in open court, in the presence of the judge, which disturbs the court's business,
where all oflhe essential elements of the misconduct are under the eye of the court. are
actually observed by the court. and where immediate punishment is essential to prevent
'demoralization orthe court's authority' beforc the public" Pounders v. Watson,52I U.S.
982,988, 117 S.C!. 2359, 138 L.Ed.2d 976 (1977) (per curiam) (quoting In re Oliver,333
U.s. 257. 275. 68 S.C!. 499, 92 L.Ed. 682 (1948.
Rather than mentioning "immediate presence" Judge Holmes Order's reads
"the court held the defendant in criminal contempt of COllrt for his behavior and activities
committed in the direct presence of this court during the trial" ...
Curiously, Judge Nash supports her "summary criminal contempt" Order by
mentioning a non-summary contempt statutory section, NRS 22.0 I0, then going onto to,
apparently. legistlate from the bench a little and classifY :-.JRS 22.010 as "criminal
contempt" despite the fact that nrs 22.0 lOis not a criminal statute.
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NRS 22.030 Summary punishment of contempt committed in immediate view and

presence of court; affidavit or statement to be filed when contempt committed outside
immediate vieVI' and presence of court; disqualification of jUdge.
I. If a contempt is committed in the immediate view and presence of the court or
judge at chambers, the contempt may be punished summarily. If the court or judge
summarily punishes a person for a contempt pursuant to this subsection, the court or judge
shall enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence
of the court or judge;
(b) Finds the person guilty of the contempt; and
(c) Prescribes the punishment for the contempt.
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2. If a contempt is not committed in the immediate view and presence of the court
or judge at chambers. an atlida~it must be presented to the court or judge of the facts
constituting the contempt. or a statement of the facts by the masters or arbitrators.
3. Except as otherwi,e provided in this subsection, if a contempt is not committed
in the immediate view and presence or tile court. the judge of the court in whose contempt
the person is alleged to be shall not preside at the trial of the contcmpt over the objection
of the person. The provisions of this subsection do not apply in:
(a) Any case where a finaljudgmcnt or decree of the court is drawn in question
and such judgment or decree was entered in such court by a predccessor judge thereof I 0
years or more preceding the bringing of contempt proceedings for the violation of the
judgment or decree.
(b) Any proceeding described in subsection I ofNRS 3.223, whether or not a
family court has been established in the judicial district
NRS 22.010 Acts or omissions constituting con tempts. The following acts or
omissions shall be deemed con tempts:
I. Disorderly. contemptuous or insolent behavior toward the judge while the judge
is holding court. or engaged in judicial duties at chambers. or toward masters or arbitrators
while sitting on a reference or arbitration, or other judicial proceeding,
2. A breach of the peace, boisterous conduct or violent disturbance in the presence
of the court, or in its immediate vicinity. tending to interrupt the due course of the trial or
other judicial proceeding.
3. Disobedience or resistance to any lawful writ. order, rule or process issued by
the court or judge at chambers.
4. Disobedience of a subpoena (Iuly served. or refusing to be sworn or answer as a
witness.
5. Rescuing any person or property in the custody of an officer by virtue of an
order or process of such court or judge at chambers.
6. Disobedience of the order or direction of the court made pending the trial of an
action, in ,peaking to or in the presence of a juror concerning an action in which the juror
has been impaneled to determine. or in any manner approaching or interfering with such
juror with the intent to influence the verdict.
7. Abusing the process or proceedings of the court or falsely pretending to act
under the authority of an order or process of the court.
One is kind oj'left wondering: why didn't Judge Nash Holmes just use the
summary contempt statute that Judge Howard cited to (NRS 22.030) incident to his
sentencing Coughlin. staring right then (no stay for arranging (() avoid prejudice to
Coughlin's clients from Judge Howard. no way. Josc ... nor from Judge Ellion on April 19th,
2012 when he put Couglin in jail for 8 days over a manufactured dispute over the terms of
a Competency Evaluation (Judge Elliot didn't think avoiding prejudice to Coughlin's
client's affairs was important enough to grant even the slightest stay ...some might say these
Judges wanted to wreck Coughlin's career as good an awful as possible. and weren't ati'aid
to usc Coughlin's client's interests in the process to do il.
Oh, may it is because ofthat inconvenient stuff in NRS 22.030 about how
someone gotta sign an Affidavit if
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This bit about it not being Coughlin's fault he didn't know Judge Nash
Holmes had via her 2!28i12 Order characterized the "contempt" to be the "misdemeanor of
criminal contempt" ,ort of "contempt" means Coughlin arguably did not violate the
USPTO rule related to reporting "within 30 days" any of a the type required by 11.25.
But. within 30 days of finally getting a copy of that 2128/12 "Finding of Contempt and
Order Imposing Sanctions" of Judge Holmes (Coughlin only first became aware such a
written Order existed upon receiving the SCR 117 Disability Petition the SBN has tried to
force on Coughlin ... Coughlin is fine. he is not disabled. He is runnin' it. So, "within 30
days" offinaliy gelling that Order. Coughlin reported to the lJSPTO. and the same can
arguably be said of reporting this Court's 617112 temporary suspension. The only thing is
that Coughlin was in jail from July 3rd, 2012 to July 21. 2012 on the ridiculous and since
dropped by the City of Reno July 3rd. 2012 "disturbing the peace" charge ... so arguably a
tolling of 17 days or so should be subtracted from an analyses of whether Coughlin timely
reported.
It was only upon finding the 2/28/12 ORder attached to the SCR 117
Petition in 60975 (which is a spurious negligent document in its own right) that Coughlin
was apprised of the fact that Judge Holmes had put the summary contempt Order in
writing. Coughlin notified the United States Patent and Trademark Ollice (USPTO
wherein Coughlin is license as a Patent Attorney as of this date, or at least as an agent to
whatever extent Coughlin's one state law license is suspended pursuant to this Court's
6!7!12 Order in 60838)
For a patent attorney agent like Coughlin. there are di grounds for discipline
hy the USPTO: (i) conviction of a serious crime, 16 (ii) discipline on ethical grounds by
another jurisdiction or disciplinary disqualification Iiom participating in or appearing
betore any Federal program or agency. t 7 (16 37 C.F.R. 11.25 prescribes procedures for
interim suspension and discipline based upon conviction of a serious crime or conduct
inovlving moral turpitude or conviction or a criminal offense involving moral turpitude.
dishonesty, or breach oftrust.( for examples. see: D2006-20. D2007-03. D2008-0 I.
D2008-12, D2008-23. D2009-0 I. 02009-05. D2009-14 and D2009-42 in the OED
Reading Room at http://des.USPTO.govlFoialOEDReadingRoom.jsp. These are only a
few examples. There are more examples in 20 I0 and 201/ time period. These can be
viewed in the aforementioned OED Reading Room ""ebsite.) 17 37 C.F .R. 11.24
prescribes procedures for reciprocal discipline. However, OED has the option of initiating
a disciplinary action based on its own disciplinary rules and not do a reciprocal discipline.
Rule 37 C.F.R. 11.25(a) requires that a person practicing betore the Ollice "shall notify
the OED Director in "titing ... within thirty (30) days .... ' from the date ofa conviction of
a "crime (underscoring added for emphasis).
(That 2/28/12 Order was then, under the RMC's Certificate ofServiee, mailed to
an address the RMC knew full well was no longer good for Coughlin, and the RMC failed
to fax. or email or otherwise seek to remail it to Coughlin upon receiving it back upon an
"undeliverahle" indication by the USPS (despite feigning some real strong efforts to get in
contact with Coughlin at the rime in her 3114/12 written grievance against Coughlin to rhe
SBN (to be fair, it is true that incident to Coughlin being a victim of domestic violence and
benefitting from two Orders of I'rotection from Master Edmondson, ""ho really would
make a great Family Court Judge already) Coughlin's access to his mailbox was interterred
with by his abusers and, allegedly. upon information and belief. members of the USPS
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Golden Valley Station. l'v Energy (NY Energy and the USPS are no friends to victims of
domestic violence or those whose lease are valid under IISA.160. as leases can be verbal
in Nevada, and the USPS and NY Energy, essentially two monopolies, should not be
allowed to demand social security cards and \Hitten lease from anyone. much less
domestic violence victims. merely b(.'Cause the numbers indicate it helps their profit
margins to adopt such an approach. Talking to you Buck Hyde, Terri James, and "Ms.
Passot". and the former detective working for NY Energy whose name escapes, and Sue
King unaulhorize practitioner of law for Park Terrace Town Homes llOA and or Galye
Kern, Esq. could answer a few questions about the extent to which they advocated behind
the scenes to deprive Coughlin of power in his rental (despite offering to pay for it and put
it in his name upon his former housemates, whom ~M and PTTHOA admits were there
with the express approval of the HOA Board upon recieving approval from Sheila Lester
and the Board incident to former WNM manager Robyn Bataldo presenting a proposal
directed thereto to it. and when those "tcnants"(who were arguably employees given the
work for rent trade admitted to) rent or sublease to Coughlin .... That ain't squalling.
Sheila. You might call it a subtenanc;, actually. But its not "squatting" .... and anyone
interfering with Coughlin's ability to get his mail during this time, rough lin January 2012
through mid March 2012, should be liable for any consequential damages ... however, it
would help if one could go to the RMC and ask to see a docket with RMC Marshal getting
their Affidavits out and clandestine, rehearsed letters to the SBN out detailing how
Coughlin said he was going to "depose" the filing office statT about the dockets .... How
about just print out a docket, maybe charge a reasonable print fee, and leave the totalitarian
hostility lor another time, Marshal Menu!. Coppa, Harley and Townsend? And "Clerks of
Coun" or Administrative Assistants calling up Bar Counsel and rep0l1ing on this or that
aspect of an attorney's clothing when he goes to the RMC tiling office counter to check on
the status of cases or deadlines or upcoming hearings) ... There are collection agencies and
then there are couns of law, and the distinction should always be extremely apparent to the
public.
After the conviction is reponed to OED by a practitioner, the Director of
OED will make a determination as to whether the criminal otTense constitutes a "serious
crime." Coughlin has reported to the SBN and the USPTO the following convictions from
the last year:
11/30111 conviction in II CR 22176 Reno Municipal Coun Judge Kenneth
Howard petty larccny conviction of "candy bar and some cough drops" (allegation
totalling $14.00). Judge Gardner denied Coughlin's request for a continuance despite
opposing counsel in the eviction case form Coughlin's former home law office applying an
unlawful rent distraint upon exculpatory videos proving that Wal-Mart had expressly
threatened to retaliate upon Coughlin by abusing process incident to Coughlin's
complaining to Wal-Man managers, including W. 7th SI. Wal-Man Manager John Ellis
about the apparently fraudulence inherent to Wal-Man's manager constantly "forgetting"
the Return Policy they hold out to the public and used to crush their competitors for years.
Judge Howard refused Couglin even one cominuance in this matter, even where the Reno
Sparks Indian Colony (which owns the land that Wal-Mart sits on and rents it to and profit
shares with that Wal-Mart) Police Department Otlicers Kal11eron Crawford and Donnie
Braunwonh, in addition to Wal-Mart's Thomas Frontino, were caught lying on video tape
in consideration of their testimony at trial that she search incident to arrest (wherein a a
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few cough drops were tllUnd in Coughlin's pockets) for the alleged commission of a
misdemeanor, occuring outside the ofticer's presence and after 7 pm at night
6118112 criminal trespass conviction in II CR 26405 before RMC Judge William
Gardner incident to a summary eviction of a commercial tenant where non-payment of
rent was not pled or noticed: lockout of 1IIIII1 of Coughlin from his former home law
otlice at 121 River Rock St., Reno. NV.
2/27112 "summary criminal c()ntcmpt" conviction by RMC Judge Dorothy Nash
Holmes shortly alter she. upon information and belief. met with othcr RMC Judges and
was made awarc of an Order for Competency Evaluation of Coughlin. and thus requiring
Judge Nash Holmes to cease persisting in the obviously well coordinated. agenda into
action that several RMC Judges (and perhaps some others) developed against Coughlin
incident to there numerous dosed door mceting sessions where Judgc \Y. Gardner insists.
somehow, local attorney Richard G. Hill. Esq", presence, involvement, or name never
came up once. despite Hill's fingerprints being all over all four of those prosecutions
incident to yet another retaliatory arrest and prosecution by the Reno Police Department of
Coughlin in RCR20 12-065630 ("misuse of emergency communications"/911 calls) arrest
incident to the domestic violence Couglin and his dog. Pekingese Jackson Pawluck where
a victim of. by RPD Sargent Paul Sifre and Officer Jason Schaur, with Sargent Sifre
having had Coughlin arrested just over 48 hours previously on 1/12112 tor "ja>walking",
yep, a custodial arrest lor jaywalking. Reno 911 in RMC case 12 CR 00696, which Judge
Linda Gardner's brother W. Gardner transferred to Judge Nash Holmes Department from
another on 2/27/12 as well ..
If the Director detennines that the offense was a "serious crime", the Director will
file a request with the Director of the USPTO tor an interim suspension of the practitioner
from practice before the USPTO. The pmctitioncr will have the opportunity for a hearing,
however. the only grounds for not granting the request are that (i) the crime did not
constitute a serious crime. (ii) the person is not the person Who committed thc crimc or (iii)
the "conviction was so lacking in notice or opportunity to be heard as to constitute a
deprivation of due process 37 c.r.R. 11.25(b)(3). "Irrespective of the merits of the
conviction. failure of a practitioner to advise the Director of OED ofthc conviction could
su~ject the practitioner to discipline under 37 c.r.R. 10.23(c)(14). if OED learns of the
conviction after the thirty (30) day reporting period has expired. State law violations
under the category of reciprocal discipline fall under suspension or disbarment from
practice on ethical grounds by a state umler 37 C.F.R. I0.23(c)(5). or conviction under a
state law oftense involving moral turpitude under 37 C.F.R. I0.23(c)( I). Examples of
conduct in the category involving criminal convictions include: assault with a deadly
weapon: engaging in sexually explicit conversation with a minor over the internet: hit and
run and DUI; sexual assault: encouraging an illcgal alien to come to the United States:
insider trading: wire fraud; and possession and trafficking of a controlled substance. In re
Tamura, 02008-23: In re Lever, 02009-14; In re Reynolds. 01999-12; [n re Maiorino,
02004-11; [n re Rostoker. 02004-15; In re Marks. 02005-05; In re Tezak. 02006-05; In
re Rose. 02006-16.
Luckily tor Coughlin. all three (or it is four if you count Judge Howard
finding Coughlin convicted of "summary contempt" as well as "peny larceny" in the WalMart case 0n 11130/11) of his "criminal" convictions are convictions was so lacking in
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notice or opportunity to be heard as to constitute a deprivation of due process 37 C.F.R.

11.25(b)(3).
And, in fact, the II TR 26800 "summary criminal contempt" conviction is
not even a real thing, or an actual crime in Nevada, at least not statutorily.... And that's the
whole point: "summary criminal contempt" should be such a rare conviction that is
shouldn't get to take lip space in a statute.. When Coughlin was incarcerated. he heard some
Deputies saying some things though that indicale these sorts of things are not all that rare
at the RMC these days ... "put the kid in a "hug a thug" program one week, he's back on a
jaywalking charge two weeks later ... and she give him 6 months in jail? She's just beyond
at this point, man .... ". And the 3 days for "summary contempt" nrs 22.030 from Judge
Howard is "civil contempt", ie, not a crime or misdemeanor, not that Judge Howard's
Order is all that much of a celebration of due process particularly where he justified he
departure Ii'om Aingersigner's requirement by saying he wouldn't issue jail time (well,
actually. he said. jail time was not typical. .. so it wasn't like he gave a guarantee or
anything as a consolation to his both denying the Sixth Amendment Right To Counsel and
even one continuance to Coughlin. whom Judge Howard knew had just been evicted less
than one month prior. .. and was being prosecuted for a first offense charge of shoplifting
food? Uh-huh. Guess the take home message is good gawd don't you dare allege
prosecutorial misconduct toward the work of Pam Roberts. Or don't let the wrong folks
down at the RMC hear about it. And don't tile a written complaint against RPD Officer
Nick Duralde with the askrpd'ifTcno.gov system or the coplogic thing and be unprepared a
month latcr at the arraingment on the wal-mart charge if things really, really, start to go
pear shaped. strangely so even. when thrust into a trial less than a month after getting
access to the police report (where the City Attorney. as apparently is usually the case. has
had the report tor nearly a month already by the time you get it) think things are going to
go all that well ....
Upon reviewing Coughlin's recent tilings in 6190 I and the Motion for '\Jew
Trial in II CR 26405, and including the video taped admission by RPD Sargent
LopeL.how can one not conclude that Hill. Merliss, Sargent Lopez, and Officer Carter,
Marshal Harley, Thomas Frontino and Kameron Crawford and Donnie Braunworth are all
in violation of the following statutes:
NRS 199.310 Malicious prosecution. A person who maliciously and without
probable cause therefor, causes or attempts to cause another person to be arrested or
proceeded against tor any crime of which that person is innocent: I. If the crime is a
felony. is guilty of a category [) felony and shall be punished as provided in NRS 193.130;
and 2. Tfthe crime is a gross misdemeanor or misdemeanor, is guilty ofa misdemeanor.
Further. whereas Hon W. Gardner, before lunch during the trial on 6/18/12
presented one set of circumstances to Coughlin regarding Coughlin testying in his own
defense ... atier lunch (and some apparent retooling of his approach) Judge Gardner
presented an entirely different set of circumstances the he announced would attach shoudl
Coughlin waive his Fifth Amendment Right (and in II TR 26800. Judge Nash Holmes
seems to see an assertion ofa Fourth or Fifth Amendment Right as ajoke. and an obvious
and righteous opportunity to draw an inference ofguilts .... and she is a Judge .... Great.)
So, considering Coughlin had already been incarcerated 8 days incident to
two different "summary contempt" convictions by RMC Judges Howard and Nash Holmes
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incident to Coughlin's self representation ... why would Coughlin testifY in his own behalf
in the trespass trial bel()re.l. W. Gardner? What was there to gain? What there really
much of any chance that Judge Gardner was going to be swayed by any testimony by
Coughlin? Had Coughlin not already managed to get Hill and or Baker to admit most
things Coughlin would otherwise to to establish thorugh his own testimony (ie, Hill admits
to his ridiculous storage lien demands that consist of continuing to charge the same $900
for "storage" that was charged lor "full usc and occupancy". and the audio at the very start
of the II cr 26405 court audio on 4/10/12 reveals a hilarious discussion between court
appoint defense counsel Loomis and his "client" Coughlin wherein Loomis absolutely cosigns Richard G. Hill, Esq.'s "double dipping" (ie Hill wants to get the big rent associate
with "full use and occupancy" while still precluding Coughlin from "use and occupancy"
of the premises. But Loomis isn't about to argue a claim or right delense on Coughlin's
behalf there (if Hill is charging Coughlin the same rent as when Coughlin was entitled to
"full use and occupancy" ... thcn docsn't that sOI1 of imply Coughlin is entitled to the "full
use and occupancy"? One cannot imagine how intimidating it is to be in the RMC after
two separate summary contempt jail stay' in previous self representation contexts,
especially when one is tlat broke, and another such stay. and all the bail revocatiosn
attendant thereto would likely wipe one out. ..
And in the trespass case, where Hazlett-Steven's persisted mentioning
pajamas (and the video reveals Coughlin si wearing sweats and a t-shil1 ... so is it not
Richard G. Hill who displays a lack of candor to the tribunaL .. see also his unsupported
"they taped it on the door because you ran away" claim. Rich ... your associate Casey Baker
testi lied you were not there. Coughlin was not there. Baker makes no such allegation of
Coughlin running away incident to some taping of a lockout order on the door or attempts
to tirst effect personal service thereof Nor does the WCSO ... so really. Rich, what do you
base that on? Is this like when you said
See. Judge Nash Holmes 2/28/12 "Order Finding the Defendant In
Contempt Of Court and Imposing Sanctions" purports to be finding Coughlin guilty of "the
misdemeanor of criminal contcmpt, a violation ofNRS 22.010" ... but that's the thing,
though. Judge Nash Holmes is remixing NRS 22.0 I0 and adding the words
"misdemeanor" and "criminal" to it, because they just ain't there. Now, Judge Nash
Holmes may have meant to invoke NRS 199.340. but she didn't.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of
court of any one of the following kinds shall be guilty ofa misdemeanor: I. Disorderly,
contemptuous or insolent behavior committed during the sitting of the court, in its
immediate view and presence. and directly tending to interrupt its proceedings or to impair
the respect due to its authority; .. .3. Breach of the peace, noise or other disturbance directly
tending to interrupt the proceedings of a court, jury or releree;4. Willful disobedience to
the lawlul process or mandate of a court; 5. Resistance. willfully oftered. to its Imvful
process or mandate;"
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That's interesting ... its almost as if 35 year veteran member of the Bar, Hon.
D. Na~h Holmes did some picking and choosing amongst the various civil and criminal,
summary, and plenary contempt statutes and. kind of, made a pastiched of what she like
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best from each one and what best fit her agenda with respect to Coughlin .... the only thing.
though, it that that is not legal. and as such. the "conviction" for "misdemeanor of criminal
contempt" cannot stand. Coughlin must admit. .. he has been referring to it as a "summary
criminal contempt" eon\iction ... when. in fact, it doesn't seem Judge Nash Holmes ever so
characterized it. .. its just that...well. when you don't get a trial. or an arraignment, or court
appointed counsel. or the right to appeal. or bc allowed out of jail even where the RMC
keeps the money your mom went and paid to bail you out...its hard to think of such a
conviction as anything other than "summary" in nature. Despotic. tyrannical, wholly
inappropriate. devoid oflhe quality of justice or any sense ofa measure and even
application oftraditional notions of substantial justice and fair play are some
charicterizations that some might say. Not Coughlin. He likes being out of jail.
Stl"dllger still is how Judge Nash Holmes goes on to support her throwing
license attorney representing himself in a traffic citation matter Coughlin in jail for 5 days,
starting right then (and no stay to arrange for lack ofprcjudiee to Coughlin's client. either)
upon some application ofNRS 22.100, where in her 2/28/12 "Order Finding the
Defendant In Contempt or Court and Imposing Sanctions" Judge Nash IJolmes writes "it
is ordered. pursuant to NRS 22.100. that the defendant be incarcerated at the Washoe
County R[:gion
Strange How Hazlett-Steven's in the trespass case gets to argue all this
"'using it as a residence" prejudicial facts not in evidence ... even where Judge Gardner
ruled those matters not relevant....only for Judge Gardner himsclfto cite to and rely on the
"had your dog their" "using it as a residence" in his decision? ..... hmmmmn .....
Glover v. Eighth Judicial Dis\. Court of State ex reI. County of Clark, 220 PJd
684 11 OCRIMTNAL LAW IIOXXX1Counsei 11 OXXXI(FjArguments and Statements by
Counsel IIOk2134Comments on Failure to Present Evidence or Witnesses IIOk2137k.
Comments by defense on failure of prosecution to present evidence. Nev .. 2009 Negativeinlerence argument made by defense counsel during closing argument, that the State did
not introduce voluntary videotaped unsworn statement that defendant made to police the
day that the victim was shot because the statement would absolutely devastate the State's
case. was improper. in trial of defendant for murder in which defendant claimed selfdefense, as defense counsel was arguing facts not in evidence, defense counsel was putting
his personal knowledge and belief on the scales, State's objection to defendant's attempt to
admit the videotaped statement. that the prior out-of-court statement was inadmissible to
bolstcr defendant's in-court testimony. was a proper hearsay objection. and it was improper
for defense counsel to argue a negative inference based on a proper hearsay objection.
Strange How Hazlett-Steven's in the trespa-;s case gets to argue all this '''using it as
a residence" prejudicial facts not in evidence ... even where Judge Gardner ruled those
matters not relevant. ... only for Judge Gardner himself to cite to and rely on the "had your
dog their" "using it as a residence" in his decision? ..... hmmmmn ...
from Judge W. Gardner's decision in the criminal trespass case 11 cr 26405:
THE COURT (RMC Judge William Garnder): No. we're done. That's it. You
know how it works. The prosecutor goes first, you go second. they finish up. They have
the burden of proof. That's it. No more argument. That's very clear. Alright, let me just
make a couple comments here. Both parties have identified -there's numerous issues here.
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The big issue is the warning. Under our statute. both 207.200. and KMC 81 O.OID. the party
-it docsn't even talk about the vex or annoy. the party who goes or remains. either one. Mr .
Hazlett-Stevens pointed that out. into any building alier being warned by the owner or the
occupant. and the owners and occupants can be agents with ostensihle. actual or implied
authority. and certainly Mr. Hill and Mr. Baker had that authority. That's clearly
established by the evidence. Ifyou go back onto that property alier having been warned.
you are guilty of a trespass. and I guess the question is what is a warning? And unlike
many areas in the law. it's not defined under the trespassing ordinance. or the trespassing
statute. It's a notice requirement And the real issue in this case -there's a number of issues,
but I do -there's no question, Mr. Coughlin. that you were on property that belonged to
another at 121 Kiver Rock on November 13th. and that's in the City of Reno. and there's no
question about that. The question is. what type of warning did you have? You had so many
types of warnings, it's hard to figure out which one is the best. First of all, the first warning
-and by the way, when we talk about warning here. when you look at the statute under
state lawaI' the Municipal Code, both the Legislature and the City Council have given
some guidance that indicate lor some occupants they've got sufficient warning if the
property is posted in a conspicuous manner in intervals of not less than 700 feet. So,
something as broad as that is sufficient warning under our trespass statute. And the statute
goes on to say it's prima facia evidence ofa trespass if the property is posted or fenced on
a property. That's prima tacia. So. the question is did you have notice? Did you have some
sort of warning not to be on that property. and here's what the Court has determined. You
received some kind of mild notice. and a warning when yOU were given a 5-day notice and
a 30-day notice. Probably in and of itself. probably not enough to support a trespassing
finding. But at two separate hearings in October of 20 II. on the 13th and the 25th. where
you were present in Court. there can be no question that the issue is whether or not the
owner of that property wanted you on that property more, or should you be on that
property. Then, right in open Court. Judge Sferrazza evicted you from the property. He
t,)lIowed that up with a written Eviction Decision and Order clearly indicating that you
were evicted. and that the stay was denied. So. I don't know what -that would be what I
call super notice, or super warning. coming from the Judge himself. Page -149 It's often
the situation we never get that kind of warning. So not only did you get a warning. you got
an Order from the Judge that you were evicted from the property. That was then posted on
the front door of a property that you had been in and returned to on November pt, 2012
(sic) the day it was posted. There was a copy leli on a cotfee table later at some point in
time after Mr. Hill had entered the property and realized that there had been someone in
the property. You were emailed. Whether or not you received that email. I don't know. but
there wa, at least another attempt to email you at an address to which you had responded.
and to an address, an email address. to which you had responded that you would not accept
emails on your -as notice. Finally, you were mailed a Notice of Entry of Judgment to 121
River Rock. I'm sure -I would gues;, you didn't get that, but the parties here did cvcl)thing
possible to provide you notice. to provide you warning, and you had actual notice, yOU had
constructive notice, that you shouldn't be on that property. The State of Nevada and the
Supreme Court decision which Mr. Hazlett-Stevens quoted this morning and I have in
front of me. State v. McNichols, \ 06 Nev. 651. clearly, clearly. says that after someone
has been evicted, a subsequent reentry in the property is a trespass. A trespass reentry is
what the Supreme Court called it. did not create an objective of that expectation of
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privacy. So, that's just the first section. That's been proved beyond any doubt. There's no
question that portion ofthe statute has been proved. And I would also submit that Mr.
Hazlett-Stevens is correct. And after going back on that property numerous occasions,
selling up a residence with your pet in the basement. constitutes a separate basis
independent trom the notice requirement that you wcnt on to that property with the intent
to \'cx or annoy the owner. So. under an} theory set forth by the City, I lind you guilty of
the charge of Trespassing. We can proceed to sentencing."
Also pretty suspect how City Attorney Hazlett-Stevens argues Coughlin
can't make argument about the Appeal (facts not in record?). when Hazlett. later on,
followed with this:
"City Attorney Ilazlett-Stcvens: With regard to all ofthe issues Mr. Coughlin
brought up in regard to commercial residence. commercial property. notices, whether or
not they can take summary eviction proceedings against a commercial tenant, this is not
the proper !(Jrum to decide that issue.
That. Mr. Coughlin, had an opportunity to address in front of Judge Sferrazza, in
his appeal in thlllt of Judge Flanagan. which you actually did hear in evidence today. That
matter is appealed. and Judge Flanagan already denied the appeaL"
And old prosecutor Hazlett was nice enough to preserve for the appeal, to
whatever extent Loomis having judicial notice taken at a previous hearing went out the
door with Loomis. the issue of the RJC being divested ofjursidiction, precluded the "Trial
upon Coughlin depsoiting $2,275 rent escrow with the court, on [0125/11" before the RJC
from goign forward given the improt at: say. Mack v. Mack-Manley, or Foster dingwall, in
that the RJC would be divested of jurisdiction upon Coughlin's filing a Notice of Appeal
on 10118111, there makign the eviction order void nrcp 60b4 lack of jursidiction:
MR. HAZLE1T-STEVENS: No. it's in evidence. Your Honor. And I'll draw your
attention to the part that says. "Decision." And it also says. "Matthew Merliss present.
Casey Baker -represented by Casey Baker," and then it also indicates Zachary Coughlin
present. And then I'll draw your attention to the decision where it says "eviction granted
etlective October 31 st. 2011. at 5:00 p.m." That's what Judge Sterrazza announced in
open Court with Mr. Coughlin. according to Mr. Baker. listening. actively listening to the
Judge. He wasn't writing anything down, but he was actively listening to the Judge when
he announced that decision in open Court. And you have the Order granting eviction right
there. Now. there was another issue whether or not the proceedings were stayed pending
some sort of appeal, but that Motion to Stay was also denied in the October 25th, 20 II,
hearing. And you'll see in City'S I, it Page -I 27acmally says. "Tenant's verbal motion to
stay, denied." The case was over at that point.
But here is the part of Coughlin's cross examination where Hill truly
demonstrates the malpractice and misconduct he committed: Q So your office converted it
to a no cause summary eviction notice? A More precisely, sir. the decision was made to
forego the rent eviction and simply do a 30-da) no cause. Q Okay, and if subsequently the
tenant was considered a commercial tenant. would that not be tantamount to sort of a
wrong side legal surgel)? A Well. I don't quite understand your metaphor. sir. But the fact
olthe matter is it was a residence. The lact that YOll were illegally conducting a business
there, a side issue, number one. Number two, you didn't I"'dise it in the Justice Court. Q You
say it was a residence. Is it zoned for just residential use? A I don't have any idea. sir. Q
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Well, why did you say it was a residence if you don't have something to base that upon? A
That's what the lease said, and there was no lawful business being conducted, Q The lease
said -did the lease say a commercial use was acceptable? A I don't know, Mr. Coughlin."
A review of the attache (partial, unofficial) transcript of the summary
eviction proceedingI"Trial", along with the Appendix reveals Coughlin clearly did raise
and pled the issue. and cite to the law forbidding the use of summary evictions against a
commercial tenant where non payment of rent is neither pled nor noticed ...
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1 believe there is a couple quasi 60(b) basis for challenging the validity ofany -to
the extent this COlirt views the Eviction Order as a warning, which 1 think is kind of the
big inquiry here, Maybe not. but to me, it seems like it's possibly what the case could come
down to. To the extent the Court does consider a valid Eviction Order appropriately
served, a warning sufficient to satisfY the criminal trespass statute, I believe there is a
couple 60(b) like basis to challenge that Order. One is brought up by Mr. Loomis, who so
astutely pointed out that under the McManley case there was a Notice of Appeal filed in
the interim between the initial October 13th hearing, and then the October 25th trial. MR,
HAZLETI-STEVENS: Judge, this is getting into testimony -or evidence that's not in
testimony, testimony that's not in evidence rather. It's not there about any appeal taken,
THE COURT: Mr. Coughlin" MR, COlJGHl.IN: Well, I believe Mr, Loomis' THE
COllRT: Your argument is limited to the facts that were produced toda} at trial. MR.
COUGHLIN: Just today. not what Mr. Loomis Page 136- THE COURT: That's correct,
IOday's trial, So to that extent. the objection -and [ try to give parties a great deal of leeway
in closing argument. but when you start getting far alield of what was argued, presented
via facts of the [rial, that's not proper argument. MR, COUGHLIN: Okay, and 1thought it
was part of the record at this point. And itit's not too late, I'd object to the notice by email
that was introduced. THE COURT: Okay, go ahead. BY MR. COUGHLIN: Beyond that
60(b) basis. I believe there is an additional basis in that -there is a couple. I think under the
ANVUI. AN-V-U-lE A-N-V-U-1. which is kind of the main Nevada case on summary
evictions of commercial tenants, That was a restaurant in Vegas doing a lot of business,
like $500K a month or something, and they got evicted, and it went to the Nevada
Supreme Court, and a lot of litigation was done over that. And the holding, the take home
holding fl'Om that was that it's ba,ically a summary judgment standard in the summary
eviction proceedings, The tenant merely needs to present a material issue of law or fact to
beat a summary judgment motion. If they do that, the Court may do nothing further, and it
has to go on to a (inaudible) unlawful detainer approach. Served, 20 days to respond,
discovery, all that. So, my position would be that there's a 60(b) basis for viewing this -any
summary eviction order, as void in that [ was a licensed attorney, at that time, at least, and
I held that out as my law office. I filed a tenant's affidavit that I was a commercial tenant. I
pled that. Mr. Hill testified today that he wasn't aware of that. and he didn't consider it a
particular Page -137 - I 38- con~ideration, ti:lf his neurosurgeon client who had spent $60
grand on this, That's where I'm at the analogv of the wrong side lenal surgerY' because 1
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think it could wind up potentially being fairly important to his client if it's proven that a
wrongful eviction occurred, Ifit's proven that yes, I did present a (inaudible) issue of
material fact, that this was a commercial tenancy, and to the extent judicial notice could be
taken that it was merely a No-Cause Eviction Notice that was pursued and that nonpayment of rent was not alleged, then this could be problematic, and Mr. Hill might wish
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he had considered that point whether this was a commercial tenancy, and I'm not subject to
summary eviction proceedings in 40.253, and (inaudible) pay my rent as alleged as being
in fact very important."
Alsn whatever Baker and Hill seek to argue now, incorrectly (because they
are flailing around. like at the criminal trespass trial. during the gotcha moments when
Coughlin points out that. despite billing their client $60K, they don't know the case or the
law all that well with respect to the narrow finer points of law that will ultimately decide
the case. Sure Rich and Casey can push paper with the best of them, and it looks legit and
sounds pretty law firm ish and stufL.until you start to pick it apart. then its just junk food,
plain and simple. Like, for instance, Casey Baker, Esq. gets Judge Sferrazza to sign his
FINDINGS OF FACT, CONCLUSIONS OF LA W. AND ORDER FOR SUMMARY
EVICIION ... : "This matter having come on regularly for an evidentiary hearing pursuant
to NRS 40.254 and NRS 40. 253(6) on October 13.2011, and continued on October
25.20 II, before the Honorable Peter 1. Sferr azza, sitting without a jury: the
plaintiftflandlord, Matt Merliss (HMerliss"), having been present, and represented by
counsel, Richard G. Ilill, Chartered and Casey D. Baker. Esq. , and defendantitenant,
Zachary Barker Coughlin, Esq. ("Coughlin")" WelL'shoot, Casey ... way you wrote that
there, sound like the tenant is an attorney practicing law out of the spot your landlord
client is rentin' to him. don't it? Now, what that mean'? Commercial tenant. No Cause
Eviction verboten unless pled non-payment of rent they didn't, Coughlin wins. now that
Hili's hollow little reign in the trail court and District Court has come to and end.
It is categorically false for Judge Nash Holmes to assert, in the audio record on
3/12112 the order ofcvents and when she asked Coughlin her questions about recording,
considering when a restroom break took place an exactly what it is she asked Couglin and
when, and what his responses were. and when some allegations by "the Marshal" were
made, what they consisted of, etc .. on 3/12/12 in II tr 26800 the audio transcript reads 7
minutes into the audio record the RMC provided the SBN:
.Iudge Nash Holmes (Nash): It appears to me in this case that the defendant is
suffering from some extreme form of mental illness, during the trial 1 asked the defendant
attorney repeatedly if he was recording the proceedings he denied that vehemently a few
times and then he quote took the fifth a few other times and then he requested to be
excused to go to the bathroom and the Marshal later reported to me that while the
gentleman was in the bathroom he disassembled a recording device in his pocket and took
the memory out of it and it was later found in that, uh, by the Marshal no one else had
gone into the bathroom and that was retrieved and it was put into his possession at the
Sheriffs office and when they booked him into jail for the contempt charge that was
booked into evidence and I asked the Sheriff's office to hold that into evidence. 1 believe
he has violated Supreme Court Rule 229(2)(B) which was amended by ADKT 440, August
1st, 201 I. ... "
One Coughlin did not do an}1hing of the sort indicated by Judge Nash Holmes (by
way of un attributed hearsay, like her car sleeping allegations in her 3/14112 letter re
Coughlin to the SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes
following her statement atlhe 7 minute mark that "11 appears to me in this case that the
defendant is suffering from some extreme form ormental illness." Further, that which
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Judge Nash Holmes had communicated to her prior to the start of Trial on 2/27/12 in Iltr
268()O needs to be testified to under oath. rather than have Bar COllnsel assert to half baked
"can't ask the judge about her mental processes" loophole. as he has done.
City Attorney Ormaas sure could be made to explain her statements on the record
regarding whether the citation or report in II tr 26800 contained any mention of
retaliation. given she was looking right at it and given what she said in court Also, the
whispering with Marshal Harley, and the bits aboUl Coughlin reporting to Ormaas what
RPD OFficer Carter said to Coughlin in 6190 I. and Ormaas's responses thereto on
2/27/12, and Dan Wong. ditto at an earlier hearing on that maller."
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Simply put. there was no questioning by Judge Nash Holmes of Coughlin as to

whether he was recording an)1hing or whether he possessed a "recording device" until
AFTER the one and only restroom break Judge Nash Holmes mentions on the audio
record. And that sua sponte interrogation of Couglin occured IMMEDlA TEL Y AFTER
TilE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES
REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH
HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL
PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S
EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO
SEEMED A BIT UPSET ABOUT SOME OF TilE QUESTIONS COUGHLIN ASKED
THEM IM:-'1EDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OFTIME
WIIERE JUDGE NASH HOLME'S ASSISTANT INDICATED. ON THE RECORD IN
ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT Judge Nash
Holmes just COUldn't be found. and how odd that was."which is odd, considering what was
going on in II cr 22176. II cr 26405 12 cr 00696 and II tr 26800, and rcr20 12-065630
and rer2011-063341 at the time (lots orreasons for and indications that local law
enforcement and prosecutors and public defenders were non too happy with Coughlin."and
consider the 2/24/12 email vacating the 2/27112 status conterence between young and
dogan that neither YOung nor Dogan wish to testify about ... bUl which seems to have been
held an)ways after a written communication of its being reset was transmitted to Coughlin
by Dogan, wherein. during the time Judge Nash Holmes couldn't be found (maybe she was
at one of the group meetings amongst Judges about Coughlin that RMC Administrative
Judge William Gardner referenced on the record in II CR 26405'1 Interesting the Notice
of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr20 I2-065630 (apparently in retaliation for
Coughlin's tiling of2/21/12, and DDA lach Young was still smarting from a tiling by
Coughlin of approximately 11/28112, which resultd in Young promptly amending his
complaint in rcr20 11-063341 to add a charge that was duplicative, even where YOung
failure to allege theft or possessing/receiving "trom another' under Staab makes his so
charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty,
apparently. That, and violating NRs 178.405, which YOung did by filing in rcr20 11063341 with a stamp of 2:55pm a fugitive document of his own. an Opposition to
Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12 .. ,nevermind YOung
tried to hold a TRIAL on 517112 in that case despite the Order finding Coughlin competent
in cr12-0376 didn't even get signed and entered until SI9!12 ... ditto the Trial seeting of
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5/8/12 in RMC II cr 26405, the criminal trespass case. NOt much respect for nrs 178.405
(including within NRs 5.0 I0) here in Northern nevada ..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 16800 until July
2012 ... but did tile a Notice of Appeal 3/71J2... despite "summary criminal contempt" being
a final appealable order. Judge Nash HOlmes continues to refuse to follow NRS 189.0 I0050 (so Coughlin has to type the transcript, yay ....
This brings us to the merits of the appeal. Because a summary contempt
proceeding dispenses with procedural safeguards ordinarily deemed essential to fair
criminal trials. decisions of the Supreme Court (Cooke v. United States, 1925,267 U.S.
517,45 s.n. 390.69 L.Ed. 767: In Rc Oliver. 1948,333 U.S. 257, 68 s.n. 499. 92 L.Ed.
682: Harris v. United States. 1965,382 U.S. 162.86 S.C!. 352,15 L.Ed.2d 240; Johnson v.
Mis;issippi. 1971. 403 U.S. 212. 91 S.Ct. 1778. 29 L.Ed.2d 423) and Several courts of
appeals.(United States v. Meyer. 1972, 149 U.S.App.D.C. 212. 462 F.2d 827 (collecting
cases); United States v. Willett. 4th Cir. 1970,432 F.2d 202; United States v. Peterson,
10th Cir. 1972,456 F.2d 1135; United Slates v. Marshall, 9th Cir. 1971. 451 F.2d 372. But
see In Re Niblack, D.C.Cir.1973. 476 F.2d 930, and In Re Gates, D.C.Gr. 1973,478 F.2d
998, discussed at note 7. infra) ave severely constricted the scope of the summary
contempt power.
One constraint on the usc of Rule 42(a) is a requirement that there be 'need for
immediate penal vindication of the dignit:. of the court'. Cooke v. United Slates, supra. 267
U.S. at 536. 45 S.C!. at 395. The defendants in Cooke had written and delivered an
insolent letter to a district court judge who had just presided over several cases in which
the defendants had an interest. and who wa' about to preside over other such cases. The
Supreme Court. reversing summary contempt convictions. carefully distinguished
obstructive contempts in open court from other forms of contempt. Disturbance, violence,
or disrespectful behavior may be dealt with summarily, if committed in open court,
because of the need to vindicate the court's authority on the spot. 'When the contempt is
not in open court. however, there is no such right or reason in dispensing with' normal
plenary procedure. 267 U.S. at 536. 45 S.C!. at 395.
The Court has preserved the distinction it articulated in Cooke. In Re Oliver. supra
notc 2, reversed the contempt conviction of a witness who appeared before ajudge sitting
as a one-man grand jury in Michigan. The judge-grand jury found the witness in contempt
for giving evasive answers to his questions, The inquiry had occurred in chambers. with
jew people present. Quoting from Cooke. the Court made clear that summary contempt
power can constitutionally reach 'only such conduct as created 'an open threat to the
orderly procedure of the court and such a flagrant detiance of the person and presence of
the judge before the public' that. if'not instantly suppressed and punished, demoralization
orthe cOU11's authority will follow.' (Cooke) (267 U.S.) at 536 (45 s,Ct. 390).' 333 U.S. at
275,68 S.C!. 508.
Two more recent cases, Harris v. United States, supra note 2, 382 U.S. at 165, 86
S Ct. 352, and Johnson v. Mississippi, supra note 2. 403 U.S. at 214, 91 S.C!. 1778,
reaftirmcd, with reliance on Cooke, the view that need of immediate action to restore order
- 19/39 -
to an ongoing court proceeding is a prerequisite. both constitutionally and under Rule

42(a). to use of the summary contempt power.
2
l'ederallaw. 18 U.S.c. 401. confers upon a court the authority to

punish by imprisonment "misbehavior of any person in its presence or so near thereto as to
obstruct the administration of justice.., idc 40 I(I). and "disobedience or resistance to its
4
lawfill writ, process, order, rule, decrce, or command," id. 401(3). A linding of direct
5 contempt is appropriate only if the criminal contempt occurred in the presence of the judge
and "the judge saw or heard the contemptuous conduct and so certifies." Fed.RcCrim.P.
6
42(b). Contempt in the presence of the court "mllst be punished on the spot to maintain the
CJ
court's authority." Th~ use of the summary contempt power i; proper only for "charges of
misconduct, in open court. in the presence of the judge, which disturbs the court's business,
g
where all of the essential dements of the misconduct are under the eye of the court, are
actually observed by the court, and where immediate punishment is essential to prevent
9
'demoralization of the COUIt's authority' before the public." Pounders v. Watson,52I U$.
10 982,98&, 117 sn. 2359, 138 L.d.2d 976 (1977) (per curiam) (quoting In te 01iver,333
U.s. 257, 275, 68 S.Ct. 499. 92 L.Ed. 682 (1948.As we have recognized. however, the
li
contempt power may be abused. We have held the summary contempt exception to the
normal due process requirements, such as a hearing, counsel, and the opportunity to call
12
witnesses, "includes only charges of misconduct. in open court, in the presence of the
judge, which disturbs the court's business. where all of the essential elements of the
13
misconduct are under the eye of the court. are actually observed by the court, and where
1, immediate punishment is essential to prevent 'demoralization of tile court's authority'
before the public." In re Oliver,333 U.S. 257, 275 (1948) (quoting Cooke, supra, at 536).
:5
We have stressed the importance of confining summary contempt orders to misconduct
occurring in court. Where misconduct occurs in open court, the affront to the court's
16
dignity is more widely observed,justitying summary vindication. See In re Green,369 U.S.
] "l
689,692 (1962) (relying on due process cases); HarriS1l. United States,3&2 U.S. 162, 164
(1965) (defining boundary between summary and ordinary contempt under Fed. Rule
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Crim. Prae. 42).
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[t is true that courts have long exercised a power summarily to punish certain
conduct committed in open CDurt without notice, testimony or hearing. Ex parte Terry, 128
U.S. 289, <) S.Ct. 77, 32 L.Ed. 405. was such a ca'c. There Terry committed assault on the
marshal who was at the moment removing a heckler from the courtroom. The 'violence
and misconduct' of both the heckler and the marsha/'s assailant occurred within the
'personal view' of the judge, 'under his own eye: and actually interrupted the tria! of a
cause then under way
That the holding in the Terr\' case is not to be considered as an unlimited
abandonment of the basic due proce~s procedural safeguards, even in contempt cases, was
spelled out with emphatic language in Cooke v. United States, 267 U.S. 517, 45 S.Ct. 390,
69 L.Ed. 767. a contempt case arising in a tederal district court. There it was pointed out
that for a court to exercise the extraordinary but narrowly limited power to punish for
contempt without adequate notice and opportunity to be heard. the court-disturbing
misconduct must not only oecur in the court's immediate presence. but that the judge must
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have personal knowledge of it acquired by his own observation ofthe contemptuous

condut . This Court said that knowledge acquired from the testimony of others. or even
from the confession of the accused. would not justify conviction without a trial in which
there was an opportunity for defense. Funhermore, the Coun explained the Terry rule as
reaching only such conduct as created 'an open threat to the orderly procedure of the court
and slIch a tlagrant defiance of the person and presence of the judge before the public' that.
if'not instantly suppressed and punished. demoralization of the coun's authority will
follow.' Id., at page 536 of:!67 U.s .. at pages 394. 395 of 45 S.Ct.
... "'for the purposes contemplated by the provision of the constitution, the
presence of the officers of the coun-men whom, it is safe to say. were under the
influence of the court-made the trial no more pubiJc than if they too had been excluded:
People v. Hartman, 103 Cal. 242, 244. 37 P. 153. 154.42 Am.st.Rep. 108." The RMC
regularly clears the court of members of the public (as is did in II cr 22176. the walmart
case) and (w holds Coughlin', criminal case until the very end of the last stacked docket of
the day and or locks 10 couns doors, so that Coughlin's Trials cannot be said to occur in the
presence of anyone otherthan the jUdge. the prosecutor, coughlin, and whatever witness is
testying, and an Administrative Assistant or Judicial Assistant (to the exten they too arc
are not considered "officers of the Court" and not subject to the exclusionary rule. So the
idea that these summary conempts were necessary "preserve the dignity ofthe court" in
front of "the public". see alston Sutton 683 f. supp at 684. in re spencer 985 so. 2d 300,
260 f.3d at 127. in re scott 1978 wi 26483 at 3. 477 ne 2d at 260. matter of daniels 530 a.
3d at 1273.
... In re Oliver. 333 U. S. 257. Sixth Amendment Righi to Counsel of Coughlin
violated in both II cr 22176 and II Ir 26800, also orders no sufficiently detailed or
capable \)f being known how to comply with. not sufficient warning, violat Houston v
Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke reqUire all elements of "summary
criminal contempt" occur" in the "immediate presence" oftne Court. Maybe Marshal
Harley and some other Marshal have misled Judge Nash HOlmes, or maybe something
worse is going on here .... but what ludge Nash HOlmes said on the recording is entirely
misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash
Ilolmes. maybe she is repealing a lie. but regardless her reliance on unattributed hearsay is
distrubing an inappropriate. particulary where she not only purports to issue a "summary
criminal contempt" conviction against an attorney, but also where Judge Nash Holmes
appears to try to transmogrify what she sees as "a simple tratlie citation trial" into a full
blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That
Marshal needs to sign an atfidavit, under NRS 22.020 and Judge Nash HOlmes ought to
have to pUI something on the record, under oath, in response \0 Coughlin's recent subpoena
(and SBN Pat King wishes to let Judge Nash HOlmes phone in her testimony. and it
probably won't even be sworn testimony, but rather just some musings by Judge Nash
H?In: es purporting to make "rulings" finding "by clear and convincing evidence" all sorts
of things outside her jurisdiction) on 11/14112, on. Partick O. King, SBN Bar Counsel has
also filed Motion to Quash the Subpoenas Coughlin attempted to have served on Marshal
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Joel Harley. Marshal DeIghton. Judge Nash HOlmes. Judge William Gardner, Judge
Gardners Adminbtrative Assistant Lisa Wagner. who can't quite tind the NOtice of Appeal
Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in II CR
26405 (the appeal was dismissed under an NRS 189.0 I0 analysis by Judge Elliot, whom
also got Coughlin appeal of the 11 cr 22176 conviction resulting in this Court's 617112
temporary suspension Order in crll-2064. which was denied based upon a civil
preparation of transcript down payment rule. in that criminal appeal, where the RMC has a
thing in place with this Pam Longoni that violates Nevada law in that it refused to give
Coughlin the audio cd of the trial fur some time. insisting only Longoni would be allowed
to transcribe it. and that the transcript's preparation would absolutely not start until a down
payment was made, Plus, even where Coughlin caved to the payment demands .. Longoni
repeatedly hung up the phone on him and otherwise ignored his communications (there
may be an issue of the email Longoni holding out 10 the public issuing a
.. bounceback ..... hut she needs to sign an affidavit as to whether she put Coughlin on a
blocked list. and upon information and belief. Coughlin faxed his request to the number
the RMC held out for her on her behalf too ...
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In her March 141h. 2012 grievance against Coughlin to the SBN (now
NO 12-0434, and perhaps, NG 12-0435. depending upon whom you ask and what King
means by "Clerk of Court" ... because in King's 3/23/12 email to Coughlin he apparently
identities Ms. Maril) 11 Tognoni as "Clerk of Court of Department 3..... whoever, wouldn't it
be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need to
send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the
SBN's King for King now apparent contention that the NG12-0435 "ghost grievance"
consisting of Judge L. Gardner'S April 2009 Order was not tiled by the RMC Judges? Oh,
Clerk of Court Orduna Hastings? Dn you have anything to say about this? Judge Nash
Holme's 3/14/12 grievance to har counsel reads:
"
Re: Zachary Barker Coughlin. Nevada Bar No. 9473
Dear Mr. Clark:
This ktter constitutes a formal complaint of attorney misconduct andlor disability
against Zachary Barker Coughlin. The accompanying box of materials demonstrates some
of the problems with the practice oflhis attorney being experienced by myself and the
other three judges in Reno Municipal eoun, My two most recent Orders in what should be
a simple traffic citation case arc self-explanatory and are included, together with copies of
massive documents Me, Coughlin has faxtiled to our court in this case. Audio recordings
of two of my hearings in this matter are also included. He failed to appear for the second
one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based
011 nul' Department I judge being out for surgery, We have multiple addresses for Mr,
Coughlin and can't seem to locale him between cases very easily. We arc setting that case
for Inal and attempting to serve him al the most recent address we have (1422 E. 9th St, #2
Reno NY 89512). although I heard today he may be living in his vehicle somewhere. We
do have an address for his mother, however. as she recently posted part of a fine for him,
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Judge Ken Howard, Department 4. had a case on Mr. Coughlin late last year that is
now on appeal to the Second Judicial District Court. Judge Bill Gardner. Department 2.
also has a Inaller currently pending in his court with Mr. Coughlin as the defendant. I have
enclosed some copies of documents hom those malters. in chronological order, simply
because they appear to demonstrate that he is quickly decompensating in his mental status.
Our stafT also made you some audio tapes of Coughlin in the him and him and him and
him and him and him and him him and I will him and him and nim and him and him in
Departments 2 and 4 so you can hear for yourself how this allomey acts in court. You can
see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this
attorney. My Judicial Assistant was contacted by the Washoe Public Defender in February
when I had Mr. Coughlin jailed for Contempt of Court and they stated that they represent
him in a Gross Misdemeanor matter in RJC. 1 have no other information on that
You will have the full cooperation ofmyselt: the other judges, and the sta/fof
Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself
as a vexatious litigant in our court. antagonizing the stafT and even our pro temp judges on
the most simple traffic and misdemeanor matters. 1 do think th;, is a case of some urgency,
and I apologize ti)r taking two days to get this package to you: our IT person was ill and
could not make the copies of the audios orMr. Coughlin's hearings until today, and I felt it
was important that the audios be included in the materials to be considered by the State
Bar. On February 27. 2012. Mr. Coughlin told me he was actively practicing law and had
appointments with clients. [do not know if that was true. but ifso. he could be causing
serious hann to the practice of law in Northern Nevada and could be jeopardizing
someone's freedom or property imerests. "
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it is instructive to consider judge William Gardner'S comments on the record at the

trial in the criminal trespass maHer from Coughlin's former home office again it isjudge
William Gardner who is the brmher of Judge Linda Gardner whose April 2009 sanction
order was cited by Washoe legal services and named party in this matter at this sole reason
for tiring Coughlin additionally Washoe legal services now employs as pan of the ECR
program with Theodore who was at one time Coughlin said on this criminal trespass
matter until apparently Joe figured out the Calder was doing his business partners Nevada
court services table is a court-appointed attorney by the defendant defense allorney by the
Reno municcourt
23
at the 19 minutes mark of the audio of the 6118/12 trial in the criminal trespass
matter I 1 Cr 26405:
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Judge Gardner: finally the it leaves the issue of rccusal although you have not
rabed in the caption of the pleading news. with in the party their about page do we about
address this issue before and I've denied that motion to recuse there is nothing raised in
any oflne pleadings that causes me to be bus)' in this case other than a fair detached
observer of the facts orlhat will be denied for
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MOTION FOR MISTRlAL AND MEMORANDUM OF LA W
Coughlin Your Honor just interject that not just prefaced that by saying Nevada
doctors did your announced any judge Your Honor and completely fair so let's give me a
2
lot of confidence the corridor but I do believe there might be a judicial candor something
this is where judge has litigants before him who have a case involving a family member of
3
the judge and some other sphere and I think that Mike and mandatory recusal auto but I
did find and follow mandamus action adventure sister attended court in 20091 was fired
from ajob as if surveillance attorney for Washoe legal services was told 1 was fired
because of her because of conduct bv neither resulted in her order distilleries and starts
marshaling services I did follow ma~damus petition response to that. Judge of the Supreme
6
Court father wasn't worthy of more revie",cr require and responsiveness and and now
there's this grievance for the court and I call it not be flipped by: p.m. macula conception
grievance because nobody can tell me who filed it or how the can grievance but that order
one 2009 sanction may require me to pay personally $1000 in attorney's fees under NRS
him .085 as a consequence of my advocacy is a domestic violence attorney after number of
9
bus client a battered woman tenant or alimony incident to a 20 year marriage when I was
ordered to slaughter my pocket that is now grievance it upon information believed that it
can grievance with the State Bar because your sister judge Linda Gardner did the order to
11
you whereupon you indicated that you get judge Nash Holmes whereupon judge Nash and
skipped for counsel along with a number of other materials that I've not been privy to
12
despite my anempts to secure them from the filing officer the comt or !Tom door counsel I
13 have made numerous attempts to get these recordings at antenna materials as arc not
directed at
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Judge W. Gardner: thank YOli Mr. Coughlin let me just tell you this that case goes
back to the Family Court of no real knowledge except that I have read the Order it is
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unrelated and irrelevant 10 this case. I have not really discuss the merits of this case with
my sister who is a judge in the Family COUIt there WOUld've been no reason to discuss that
16
case and even if that would've happened it would have not, un, 11m, there really is no
nexus between her being a judge hearing the case for Europe attorney and and my been a
judge some three years later on a case where you arc a defendant in, so the motion to
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recllse is denied and 1 think that identifies the issues that you faced in the motion you filed
19 June 5, 2012 it looks like now we are ready to go to trial is that correct, Mr. HazlettStevens?"
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Hazlett-Stevens that's correct Your Honor: I'll call Richard Hill to the stand"
Judge W. Gardner curiously defines and limits to an overly narrow extent,
Coughlin' appearance betore him. even where Coughlin had been torced to represent
himself in violation of the Sixth Amendment given the utterly traudulent "court appointed
representation" by Keith Loomis, Esq. as "a case where you arc a defendant in".
Then (and this also goes to the overly narrow limiting orthe conflict analysis to
seeing Coughlin only as "a defendnat beli)re me in a criminal case" that Judge W. Gardner
made above) at the 23:20 minute mark, despite judge William Gardner admitting to being
where preViOusly oftltc facr that Coughlin's law license had b'een suspended by this court
on June 7. 2012 judge Gardner notes:
,
Judge GArdner: excuse me Mr. Hazlett Stevens let me just enter one more thing
tor the record on that recusal analysis Mr. Coughlin limits the wording of this case to the
date I have put the criminal camp,laint altcges on number of November 13, 2011 in the city
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MOnON FOR MIS'rRIAL AND MEMORANDUM OF LAW
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of Reno at 121 River Rock St. the' defendant was found in the property after being evicted
un '<ovcmbcr 1,20 II Billy other information I heard about the cases been whatever was
raised in the pleadings filed by either yOU or Me. Hazlett-Stevens, so that being the case.
go ahead and proceed with your examination of Richard Hill"
Interesting how the complaint pleads being evicted as tantamount to a criminal
trespass warning. and Hazlett-STevens impermissibly sought to invoke State v, nichols in
the broadest of senses (criminal trespass? civil trespass? was notice appropritately served
in Nichols? doesn't matter apparently. and Judge Gardner indicates he doesn't care what
service rules apply to evictions. as he \\ ill decide that based upon the facts as developed a
trial. refusing to allow Coughlin to make legal argument in that regard.
in that audio fo the trial. very shortly therafter at the 24:02 mark:
"Coughlin: I'm sorry 1 don't mean minaret to Mr. Hazel Slevens but if! can just
quickly interject her honor with respect what you just said to the extent that I am required
10 broach the topic of any discussions you had with judge Nash Holmes wilh respeclto
these matters
Gardner: I can tell Yl)U that judge Nash owns I have not discussed this with
anybody. We have not. F their have been no discussions between me and the judge about
your case to protect
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And. darn. forgot this. but there actually was a Pam Longoni prepared transcript in
the appeal of\he criminal trespass conviction (but as cr 12-1 0 I 8 may suggest it can be a
good idea to double check Ms. Longoni's transcriptions for the RMC. she is held out as
their "exclusive" transcriptionist, and documentation is provided to appellants that ther
transcript's preparation will nOI even begin until a substantial down payment is made (and
probably won'l, i need 10 check this ... but probably won't be forward to dist coun until full
payment is made. all in violationf ofNRS I 89.030 ... despite whatever civil statute Judge
Elliot cited in denying Coughlin's appeal of the walmart thing udncrlying coughlin's
current suspension of6/7112 ...1n crt 1-2064 ...1
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but, it is really interesting to note How Judge W. Gardner, nuetral arbiter of fact,
recounts the record in thaI trespass case in Longoni's transcript, especially i....1h regard 10
the import ofNRS 178.405 in the context of nrs 5.010 especially and considering the
communications between city atty Hazlett-Stevens. Hon. W. Gardner and then court
appointed defense counsel Keith Loomis in a clandestine status conference thc morning of
trial (totally unbeknownst to Loomis's attorney client Coughlin, 0114/10112) ...
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while alternately citing to Coughlin's being removed from mental hcall COUlt by
Judge Breen. MD as a basis lor denying a motions on 6 18 12. only to then rule as
irrelevant any argument Coughlin made to the basis for that removal (which is all pointless
now, as the 517112 ORder by Judge Sferrazza transferring that iPhone case 10 Mental
Heallh Court was violative ofNRS 178.405 in that the order resolving the 2/27112 ORder
for Competency Evaluation in cr 12-0376 did not even get signed and entered. with a file
stamp until 5191 12 ...so the whole meh deal is void .. but check out Hon Gardners
characterization of tile (rial setting vis a vis Ihe 6 18 12 trial and other key dates, skillfully
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dealt with, yes indeed with respect to the pendecy of an Order for Competency Evaluation
during key times, Coughlin interlineations will be in bold and in parentheses",:
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"Hon, Judge Gardner: On November 13th, 201 \, ML Coughlin was arrested by the
Reno Police Department and charged with one count of trespassing, On November 14'h,
20 II, Mr. Coughlin was arraigned and pled not guilty, Trial was then set for December
13th, 2011.
On November D'd, 20 II, a Motion to Continue was filed by
the City Allorney, a Hill motion is what 1'1/ call it, based on an absent
witness, I believe it was Mr. Hill, not related to the Hill motion.
MR, HAZLEn'STEVENS: That's the original motion, yes.
THE COURT: That was not opposed by Defendant's counsel at
the lime (that would have been RMC court appoint counsel Lew Taite!, whose
business partners NEvada COllrt Services Coughlin was suing at the time incident to their
work for Richard (J, Hill and Casey Baker). And on November 28th, I entered an order
continuing the trial the first time.
The trial was then reset for January 30th, 2012, On JanualY 3,d, 2012, a Motion to
Continue was filed by Mr.Puentes, your attorney at the time. The City Attorney did not
object.
On january 18th, I -well, prior to that, before the ruling on that motion, on January
18th, Mr, Puentes filed a Motion to Withdraw as your attorney.
On Februa,y 2nd, 2012, I scheduled a (inaudible) hearing on the Motion to
Withdraw, The motion was granted, and Mr. Loomis was appointed.
On February 13th, 201Z, you filed, Mr. Coughlin, a Motion to Vacate, a Motion
for Reconsideration for RecusaL
On February 22nd, 2012, an Opposition to the Motion was filed by the City
Attorney.
Trial, then at that point, was ultimately reset for April 10th, 2012,
(that trial setting is tile stamped 317112 in that RMC case II cr 26405, which,
curiously is avoide throughout this recitation of the "docket", which is awfully tough to get
a copy of from the RMC. Now Coughlin's 11/14/12 Disciplinary Hearing before the
Panel and SBN involves three grievances. ng I20204, filed by Richard HJ1L ngIZ-0434,
filed by RMC Judge Nash Holmes, in relation to finding Coughlin in "summary criminal
contempt" despite cooke and in re oliver and the whole "every essential element occured
within the immediate presence" etc" etc. and despite some real slippery shadowy reconting
as rendered stuff about a restroom break, 0 affidavits signed by any Ct. Marshals at to
whatever it was they said to Judge Nash Holme and whatever remixing of the order of
bathroom breaks and search incidents to arrest, and going back to the jail the next day to
retrieve the allorney's sman phone and data card may have actually occurred",butthe
talkign point is this: ON 2i27/121N RCR20 I2065630 ANOTHER ORDER FOR
COMPETENCY EVAl.UATION WAS ENTERED AS TO COUGHLIN. A couple hours
laler, after Judge Nash HOlmes was finally found by her staff. the traffic citation trial in
connection with RPD citing Couglin at Hill's law office for 3 minor traffic dolations II If
26800 was held, despite Judge Nash Holmes admission in her grievance to bar counsel on
3/14112, which became ng 12-04J4 .... the third grievance, strangely stamped as received in
the sBN 3/15/12 with the "5" in the "15" looking a little under the weather, is ngI2-0435,
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and like a baby left on a doorstep after someone rings the doorbell and runs away ...its
pretty murky just how that "three year old Order in a completely unrelated case" as HOn.
W. Garner characterizes it, which he admits to passing from his sister to the other RMC
Judges shorlt)' before judge Nash HOlmes submitted her "hox of matcrials" 10 the SBN
along with her grievance against Coughlin (who.~e filings. to her. represent the singularly
most disturbing picces of legal work she has seen in her 35 years in this business" ..
because Coughlin can be a real Kunstler)
On March 5th. 2012. Mr. Coughlin. you filed a motion actually captioned in the
District Court. but it made itself -it did make itself appropriate to our file.
On March 2(''' you filed another Motion -the City filed a (Page -6- (ofLongoni's
transcript)
Motion to strike your motion based on no service on the City Attorney.
On January 20th. 20 \ 2 (must be referring to the ORder that says "filed in error"
and has a new file stumpe of2/2()/I2. one of several instances of such "filed in error"
restampings in this case and other RMC cases, here is seems to have little important and to
be a simple scrivenor stamper error), I entered an order, number one, denying your motion
that was filed on February 13th, 2012. On March 21st, 2012, I entered a second order
denying your Motion to Dismiss that was filed on March 5th, 2012.
(if you are waiting for Judge W. Gardner to indicate there was an Order SEtting
for Trial this crimina trespass case 011 3i7/12 (setting the first trial date of 4/1 0112 ... at
which a curious order of things went like this ... Ct tinds Coughlin question of competency
regarding Coughlin ...then court grants L.oomis Motion to Withdraw ... huh? nrs 178.405
"stay the proceedings'. not "gram Loomis one of his many. many succesful Motion to
Withdraw in his "work" as a court appointed "defense counsel" for the RMC) ... you will be
waiting a long time, becaues he never managed 10 poinl that out.. .. nor did he point out that
the 5/8/12 slamped "Trial Setting" (setting the 6/18112 trial date) was also violative of nrs
178.405 vis a vis nrs 5.010 (and even without 5.0 lOis it) given the ORer in cr12-0376
wasll't signed and entered until 5/9112 ... but Han. J. Garnder does manage to mention erl20376. just not the fact that all these Trial setting and ORers granting withdraws (similar 01
the one Henry Sotelo, ESq. anothe McGeorge former prosecutor court appointed defense
counsel at the RMC got in 12 cr 12520 during the pendency of Coughlin third Competency
Evaluation ORder.)
And then on April 10th, 2012, I suspended the proceedings based on a competency
issue that hact been raised in tne District Court.(well, actuall it was more than 'raise" by the
2127/12 Order in the justice court that Gardner's fellow RMC judge Nash HOlmes appears
to reference ever so curiosly in her 3114112 greivance against coughlin with the sbn) And
then at that time, at your request. Mr. Loomis was relieved as your attorney.(request is
putting is charitably .. .if L.oomis is more of a prosecLitor than the prosecutor. is one
deciding to go it along, albeit during the pendency of a competnecy order that precludes
any such violation of the attendant stay .. is thaI really a "request"?)
On April 26th. 2012, in District COUrt, Judge Elliott found you competent to stand
trial.
(wcll...isn't the order finding Couglin Competent in that case cr12-0376 actually
tile stamped 5/9/12? doesn't the jail rip peopel offtneir medications during times lick the
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8 day jail stay Couglin gal from apr; 19th. to april 26th. 2012 when DDA Zach Young
committed one of his many numerous violationso ofnrs 178.405 in seeking to have
Coughlin's bail revocked based upon some lies in a letter filed with the court by Lakes
Crossing's Bill Davis and Sally Farmer {class ic was ajail booking area phone call
between davis and Coughlin. recorded by thc jail. we'll se if the produce it. wherein DAvis
claims that he "didn't write the letter" that barcs his signature as a Ph.D. and was filed on
4i17112 in cr12-0376 and cited to extensively by d I0 Judge Steven Elliot (the judge on the
associate 60317. the companion case to the instant 60302) as a basis. along with Young's
nrs I78A05 violative Motion. for ripping a license attorney. on the spot, with no stay.
away Ii'om his practice and client's, with no opposition of any import. zeal, or skiJJ by
wcpd Biray Dogan. and refusing to even consider the legal research Coughlin attempted to
submit to the court vis a vis whether these retaliatory competency evaluations arc "blank
checks" into a criminal defendants entire medical/mental health III PAA protected records.
Top it 011: Biray Dogan. just after an express direction not (0 by Coughlin. announces the
name ofa medication Coughlin takes into the record. in tront of 40 members ofreh public
and bar milling aboll!. and Dogan's boss Jeremy Bosler later refuses to move to strike or
ameliorate in any way Dogan's error. Oh. also the WCPD. and the RJC co-signs this in
some instances. maintains the position that detendnats don't have a right \0 know be
apprised ofvery important filings in their cases by their court appointe counse ... its. uh ... not
a duty to communicate with client's situation or anything ... at least when its a public
defender. and dogan got an $8K raise during one of the worst economic years in our
nations history recently.)
On May 19th, 2012, .ludge Elliott signed an Order linding you competent (actually
it was 5/9112) and remanded whatever case was pending in the Justice Court back to the
Justice Court. and then I reset trial for June 18th. 2012. today's date. (WHOA! HOLD ON
THER JUDGE GARDNER ... about that "and then f resel trial for June 18th. 2012"
biL..don'r you mean you set trial for 6/18112 on the record (which the SBN admits getting,
though Pat Hill, Dr Richard King. cr. I mean Pal King indicates he finds it hard to listen to
such stuff and do much reading or research or anything of that sort) 8ecuase Hon. J.
Gardner set the 6118/12 Trial on 5/8/12. and that was a violation ofNRs 178.405. the fifth
or sixth he made in that criminal trespass case where he swears he was able to be a "neutral
arbiter offact" despite all the conflicts attcndnat to the matters set forth herein.}
On May 7th. 2012, Judge Sferrazza assigned that case in the Justice Court to the
Mental Health Courl. On May 24th. Judge Breen. the District Court Judge, and the Judge
responsible for the administration -him and Judge Blake. one oflhe two Judges. sent the
case back to the Reno Justice Courl. (at least Judge SFerrazza lets cases go when he hands
them over to the MCH. rather then do what the RMC Judges do. which is "stay" the
proceedings, but relain jurisdiction in the RMC rather than transfer it the the MCH ... but
regardless. given the ORder re;olvin~ the 2127112 ORder wasn't shmed and entered until
5/9/12 ... that 517112 Order by Judge SJerrazza was void)
Then on June 5th. you filed the mOlion we're talking about now. including the
Motion to Continue."
(the onc Hazlett-Stevens "wasn't served with", uh huh. Cit)' of Reno Drop box
that front desk securit), at city hall says will work for City attorney's? that one. HazlettStevens? literally every second of the II cr 26405 criminal trespass trial is dripping with
that which really really needs a good careful close inspecli,lO for misconduct, from the
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"substance" of the 6/5/12 Motion. to the violations of the stay.the the arguing things not in
the record in closing by Hazlett-Slevens. the the "civil eviction stull is relevant when the
prosecution needs to coopt it to atempt to leverage a eriminaltrespass warning from
"rendition" (criminal law concept ors 189.0 I0) of an eviction order (no matter how
completely dif1erent the Order(s) may have wound lip being once put through Hill and
Baker's truth factory) to all "civil eviction law ;s compeltely not relevant to this criminal
trespass maller ... i will decide what rules apply as to service of the eviction order by the
facts as developed through testimonY,at tria!.. .. ; don't want to hear you get all far afield
with legal argument about the rules applicable to civil evi tion orders .... " too bad. because
you would miss the rich moments like Casey Baker. Esq. having to admit that, despite his
office biling the landlord $60K in anomcvs fees. Baker was unaware that NRS 40.400
makes applicabe the NRCP. not the JCRCP. to summary evictions in Nevada (and
therefore NRCP 5 and NRCP 6(e), where, as there. no personal service of eviction
order) ..to Hill and Bakers sworn testilTIOny. to the RMc filing OFfices record keeping, to
the failure to stamp in the timely notice' of appeal in crl2-1262. which resulted in a
dismissal oflhe appeal by ... wait for it...Judge Steven Elliot)
COURT: Yeah, I don't know exactly what happened, Mr. Coughlin. I appreciate
that. I'm reading from Judge Rreen's 0rder that "The Defendant be removed from the
Mental Health Program. and lha[ you be returned to the Reno Justice Court for all future
proceedings."
So. whatever happened o\er there. which I'm not privy to. and which I don't think
really is related or relevant to this case, we're going to not delay these proceedings by
sending the case over there.
Finally, that leavcs the issue ofrecllsal. You havc. while not raised in the caption
of the pleading, it is identified in the pleadings you raised. on page two. we've addressed
this issue before in detail.
I've denied that Motion to Recuse. There's nothing raised that even (inaudible)
prevents me from hearing this case and being a fair. detached observer to the facts oflaw.
so that will be denied.
MR. COUGHLIN: Your Honor, if! could quickly enter an objection for the record
on that. THE COURT: Go ahead.
Pa -15
MR. COUGHLIN: Andjust to preface that by saying everybody I've talked to has
indicated you're an outstanding Judge.'Your Honor, and completely fair, so that's definitely
given me a lot of confidence in the Court in that regard.
But I do believe there might be -I don't kn;w ifit's ajudicial (inaudible) (canon,
Ms. Longoni, canon .... thal would be another instance of an appeable issue. like in crl21018 being chalked up to. by the RMC:s Longoni as "inaudible") or something that says
where a Judge has litigants belore him who have a case involving a family member of the
Judge. in some other sphere. I don't know if that's a mandatory recusal. but) did file a
mandatory habeas action against your sister. the Honorable Judge Linda Gardner, in
Family Court in 2009. I was fired from' my job as a domestic violence attorney from
Washoe Legal Services, and I was told~1 was tired because of her -because of the conduct
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by me that resulted in her order only. It's the only reason I was tired. according to Washoe
Legal Services.
I did tile a Mandamus Petition. It was pretty much a three judge panel, and the
Supreme Court felt it wasn't worthy of. I guess. more review or requiring a response.
And then now there is a gri~vancc with the State Bar. I call it -not to be flip. but I
call it kind ofthe immolate conception grievance because nobody can tell me who filed it.
or how it became a grievance.
But that order from 2009 sanctioned me requiring me to pay $\.000 attomey's fees,
l\RS (inaudible) .085. In the context: of my being a domestic violence legal aid attorney
advocating on behalf of my client. a battered woman, trying to get her alimony incident to
a 20-year marriage with two kids, w~erein I was ordered to pay $\,000 out of my pocket,
that's now a grievance.
Page -16Its upon infonnation and belief it became a grievance \\ith the
State Bar because your sister, Judge Linda Gardner. gave the order to you,
whereupon I believe you indicated you gave it to Judge Nash Holmes, whereupon Judge
Nash Holmes gave it to bar counsel. along with a number of other materials dlat I have not
been privy to. either in my attempts to secure them from the tiling office here at the Muni
Court, l1!' Irom bat counsel. Mr. PatriCk Kinney (king).
I've made numerous attempts to get these recordings and these different materials.
So, JUSl to enter that for the record, Your Honor.
THE COURT: Alright. thank you. Mr. Coughlin. And let me just tell you this.
That case goes back to the Family Court. I have no real knowledge, except I have read the
Order. It's unrelated and irrelevant to this case. I have not really discussed the merits of
this case with my sisler who is a Judie in the Family Court.
There would be no reason to discuss that case, and even if that would have
happened, we have not -there's really no nexus between her being a Judge and having
heard a case where you're an attorney' on, and my being a Judge some three years latcr on a
case where you are a Defendant in.
So, the Motion to Recuse is denied. And I think that identifies the issues raised in
your Motion filed June 5th. 2012. It hloks like now we're ready to go to trial, is that
correc!, counsel?
MR. HAlLEIT -STEVENS: The City is ready, Your Honor. THE COURT:
Alright, let's go ahead and call your fiist witness, Mr. Hazlett-Stevens.
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MR. HAZLEIT-STEVENS: The City calls Richard Hill to the

stand.
MR. COUGHLIN: And, Your'Honor. 1 don't know if I'm supposed to intelject this
now. or not. but I believe I did subpoena some witnesses who appear (inaudible) (uh, Pam
Longoni, thats another "inaudible" on another appealable issue, that being the failure to
grant a subpoena where, if that is the case here, Sargnel Marcia Lopez and Officer Chris
Carter were subpoened (apparently they were by the city attorney, and Coughlin asserted
he though he did subpoena them, but indicated some ambiguity or uncertainty in that
regard ... but "inaudible" doesn't quite preserve the appealable issue) .
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THE COURT: Right. and ~ve'li address that at the appropriate time. Ultimately,
Mr. Coughlin is a lawyer. B (not according the the SBN and this Court's 617112 ORder that
Judge Gardner admit, to haveing been apprised of...Coughlin couldn't issue supboenas like
an attorney. post 617!! 2. could he?) You know we lake these -:-Ok Hill. good morning.
MR. HILL: Good morning: sir.
THE COURT: We take these matters step by step by step. There's no other way to
do it. so we'll address all legal issues as they show up in the due course. and pursuant to
protocol at trial.
So, leI's swear in Mr. Hill. (Witness duly sworn). THE COURT: Have a scat, Mr.
Hill. Mr. Hazlett-Stevens. go ahead. MR. HAZLEIT-STEVENS: Thank you. Your Honor.
RICHARD HilL
called as a witness. having been duly sworn.
testitled as follows:
:
DIRECT EXAMINA nON BY MR. HAZLEIT-STEVENS: Q Good morning, can
you please state your name, and spell your last for the record?
Page .18
Page -19THE COURT: You know. Mr. Hazlett-Stevens. and Mr. -let
me make one last comment for the ft:cord.
MR. HAZLEn-STEVENS: Plea.e.
THE COURT: I know that Mr. Coughlin is an attorney. Nonetheless. he's
representing himself.
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Mr. Coughlin. let lIle tell vou what I know about this case to date. I am looking at
a Criminal Complaint that allege;th~t on November 13th. 20 I t. in the City ofReno. at t 21
River Rock Street. the Defendant was found on the property after being evicted on
November 1st, 20 II.
The only other information I'know about the case is that the whatever was raised
in the pleadings tiled. both by you arid Mr. Hazlctt-Stevens.(maybe Loomis and Puentes
didn't liIe anything? Oh, wait. did they attach all of Coughlin's emails to them detail the
Richard IlIIi Judge Nash HOlmes nexus? Really?)
So. \,ith that in mind. go ahead. Mr. Hazlett-Stevens. MR. HAZLEIT-STEVENS:
Thank you. BY MR. HAlLEIT-STEVENS: Q Thank you. Can you please state your
name, and spell your last for the record"
A Richard Hill. H-IC-L.
Q Good, Mr. Hill. I'm going to a,k you MR.
COUGHLIN: I'm sorry. I don't mean to interrupt you. Mr. Hazlett-Stevens. 111
could just quickly interject. Your HOr1,or, given what you just said. to any extent, I'm
required to broach the topic of any discussions you've had with Judge Nash Holmes with
respect to these
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THE COURT: f can tell you that Judge Nash Holmes and I have
not discussed this case with anybody, we have nol. There has been no discussions
between me and the Judge about your ~ase. the trespassing. set for today.
\fR. COUGHLIN: Or any other matters related to Richard Hill?
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MOTION rOR MISTRIAL AND MEMORANDUM or LA W
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THE COURT: Or any other matters. We've never discussed any matters related to
Richard Hill at all.
MR. COUGHLIN: Okay. tind when you said you and your sister had never
discussed anything about me?
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THE COURT: No! related to th is case.
MR. COUGHLIN: r believe earlier you just said you never discussed anything
about me alall. MR. HAZLETT-StEVEl\S: Judge, you've already ruled on this. I'm going
to ask that you THE
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COURT: We have ruled. Let me tell you -let m~ tell you what I've discussed. We
have discussed -I have nO! discussed with Judge Nash Holmes and I am advised that based
on some steps she's taken, there's been a matter referred to the State Bar which is under, if
not -I'm aware thai you have been suspended by the State Bar. and that that's subjecilo
further review.
To Ihe extent that Judge Holmes has had a case in her department, as has Judge
Howard. and ha; myselC we have had discussions. general discussions related to the State
Bar matter. (Judge W. Gardner is referring 10 the three grievances forming the scr 105
Complaint set for a disciplinary hearing on 11114 12. consisting of one grievance by Hill,
one by jUdge Nash HOlmes stemming from a traffic citation trial where the citation was
issued by the rpd outside Hill's office after ther told Coughlin to leave (which he did. but
the RPD wasn't satislied so they pulled him o,;er while he was leaving) in II tr 26800,
where. on the record, Judge Nash HOlmes threatened Coughlin with "IF you say Richard
Hili's name onc more time I am going to put yOU in jail for contempt, do you understand
me!", and where Holmes eventually did find Coug1in gUilty of "summary criminal
contempt" denied a stay to a practicihg ~ttorney askign lor a chance to make alternate
arrangments for his diems, and had Coughlin cutfed, searched, and taken the tile WCDC,
not that gently eithcr ... only to have the RMC Marshal return weI! after an period wherein
the "incident to" part of a "search incident to arrest" could be said to be possible, to
retrieve a licensed attorney's smart phone, micro sd card, and other items ... with all the date
wiped or destroyed therein prior to being returned 10 then licensed attorney Coughlin some
37 days later ...with a chain of custody in between deserving a whole lotta second looks
(Mary Kandaras? anything? Deputy Hodge? Marshals Coppa or Deighton? Deputy
Cheung? How about you WCSO's Debi Cummings, Brandi Berriman, Deputy Beatson,
Deput}' Van der Wall, or Patricia Beckman? An}thing? Deputy Iver? No?s)
As related to my conversations with either my ,isler, which have been very limited
related to you. and certainly none rehtled to your
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casc, except you had a case over here, I've had no discussions with Judge
Howard, Judge Holmes. Mr. Hill, Mr. flazlell-Stevcns.(well, actually the Hon. W.
Gardner did. on the record in the first attempt at a Trial in that trespass case on 4/l Oil 2
admit the he, City of Reno ProseculOr'Hallett-Stevens, eSq. Coughlin' court appointed
counsel Keith Loomis, Esq. did get together in a back room that morning and hash some
stulT oul.. ..but judge Gardner would laler indicate all this stuff was very "planned out" and
done "very carefully" and whatnot) or 'my sister regarding this trespassing case. And that's
by design that was carefully thought out so there's been no discussions.
MR. COUGHLIN: And with the State Bar, t know earlier THE
COURT: 1 have had no convc~sations with the State Bar.
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MR. COUGHLIN: Okay, at our last hearing though you made a statement. I
believe, the disciplinary or the Bar will be meeting next week to make aTHE COURT: I was advised by Judge Holnies that the process involving you and
the State Bar was in the process where they were going [0 make a decision, which
ultimately apparently they did. Thosd were the substances ofthose conversations, but none
were related to this case. and I can teil you that none have had any conversations regarding
the witnesses in this case that have never come up between any of tile counsel. I'm not sure
they even know who the witnesses were quite frankly.
MR. COUGHLIN: Okay.
THE COURT: Okay, thank you.
MR. COUGHLIN: Thank yOll, Your Honor.
THE COURT: Okay, let's go;ahead and proceed. BY MR. HAZLETT-STEVENS:
QThank you. Mr. Hill. I'm going (0 ask you to make sure you speak up and not
trail off your answers at the end. This' is being recorded. so fi)r appellate purposes. or any
other purpose, I'd like to get a good recording of this ..
Page -21 Mr.
Hill, "hat's your occupation or profession?
A
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I am an attorney practicing in Reno. Nevada."
And so on and so of.. Richald G. Hill and Casey Baker seeking to charge the
same rent as they did for "full use and oecupany" as relevant to a claim of right defense to
the criminal trespass charge? Not relevant according to Judge Gardner. RPD misconduct
and Hill and Merliss's lies contributing to false arrest and Hill's perjured sworn testimony
detailed extensively in 6190 I, as is Casey Baker, Esq..'s professional misconduct in doing
in viulation of~RCP II that which Hill chickencd ou! doing in his Declarations of
11121111 and 1120/12, until the neces,'ity and exigency ofhi~ misdeeds and professional
negligence (""rong site surger" cqual~ using summary eviction proceeding where only No
Cause basis pled or noticed, agains commercial tenant, in express violation ofNRs 4.0253
and even this Court's simpliticd instructions in the "I.andlord Tenant Handbook" (reatly
choice how the in,tructions to the form's on lockouts seem to adopt WLS's Sasser,
ASseniblyman Horne and Frierson and Segerblom's wishes as to the "within 24 hours"
languagne being interpreted to be no sboner than "within 24 hours" which, you can be
sure, aint how summary eviction order lockouts are being carried out. Ask NVB Judge
Beesley about Coughlin's ultra sheek tishirt and tie combination under the old biased at
2:00Pm on 3125112 in Cadle Company, v Keller ($1.6 million dollar debt adversary
proceeding) where Coughlin manage to appear (finding a dress shirt was a problem given
Coughlin used the scant 5 minutes WCSO deputies durbina and canniz7aro accorded him
at 1:30 pm ish on 3/15!12 to grab his c~mputers, client', tiles, medications, contacts,
glasses and whatnot after they broke ill at gunpoint and evicted Coughlin, as they do 10 all
citizens of Washoe County subject to Ii, summary eviction order. GAyle Kern, Esq.?
paging Gayle Kern ... cjc rev20 12-0003~4) But the great thing is that Casey Baker testified
on 6il8il2 that
26
;b
A That's correct. Q So. the Fin~ings of Facts. Conclusions of La" and

Order of Eviction found in your favor. Mr. Meriiss's favor, rather, and the date of
eviction was as of October 31" at 5:00
correct? A That's correct. That's what we
p.m"
- 33/39 -
v
I
announced in Court and put on that Findings of Fact. Q And that Order said that anyone
there attcr that date could be removed, is that correct?
2
That was the command given to the Sheriff.

Q
"Shall be removed."
A
Yes.
Page -66Page
3
4
-67Q Did you serve that
docu~lent on Mr. Coughlin in any Cashion? A Notice of

Entry or Order or anything like that? Or was that served by the Court on him?
A The way it works is the Court -attcr the Court enters the Order, the Court
forwards it to the Sheriff. Q Okay.
A And the Sheriff goes out and enforces the order.
Q Okay. now I'm going to draw your attention to the date ofNovcmber 13th, 201
,
1.
14
15
16
17
THE COURT: What was that date again?

MR. HAZI.ETf-STEVENS: November 13,2011, Your Honor.
THE COURT: Okay, give ,he just a second, counsel.
MR. HAZLEn-STEVENS: Certainly. Judge.
THE COllRT: I'm making some notes here regarding some dates.
MR. HAZl.En-STEVENS: And 1'111 going to withdraw that question, Your
Honor, so if you don't want to jot that note down. you don't have to at this point.
THE COURT: Okay. I'm looking at something else, okay. Go ahead. Thank you,
counsel. BY MR. HAZLE1T-STEVENS:
Q I'm going to draw your attention to the date of November 1st, 20 II. Do YOll
recall what you werc doing that day?
A Yes. I was actually off of work that day. I was at home.
-6819
20
21
7.2
23
25
76
Q Okay. A But I was basically on stand-by because I knew that the eviction was
going to haflP~n. Q Okay, and did you actually eventually respond or have to come to the
area of 1~ I River Rock?
A Yes.
QWhy?
A The way it works, again. I'm sorry to keep doing this.
Q Please, please, please, you are educating us all.
A You have to wait for the Sheriff to contact you.
QOkay.
A The Sheriffs Deputies are sent out with several of these
things on the days that they do them, ho\\cver. they do them every day. You can
try to shoot for a specific time. but yo'! are at the mercy of the Sheriffs Deputy's schedule.
Some lockouts take longer lhan others. They try to give you lead time.
I had spoKen with the Sheriffs!Oeputy already, I believe, on Friday the 28th- Q
Okay. A I believe. It \"as either that, or I contacted him On his eell phone. But I came back
in (inaudible) do the lockouts.
- 34/39 -
MOTION rOR MISTRIAL AND MEMORANDUM OF LA \V
,
2
3
4
6
7
12
THE COURT: I'm sorry?\:

."
HIE WITNESS: I came back in so we could do the lockout, to meellhe Shentts
DepUlie;, at the property alleT the Sheriff calls. Q Okay. and so you actually did go to t 21
River ROCK?
\.
Page
\'
A Yes.
Q And were there Sheriffs 'Deputies there;
A r got there Ii rst.
QOkay.
/\ Along with a member of.our staff.
QOkay.
"
A And then two Sheriffs D~puties arrived.
QOkay.
.
/\ And then we had 10 wait for the locksmith.
Q Okay. when the SherilfsUeputies arrived, did they
have any documents in their hand? A I believe they had -y~, they had their copies
of the Findings ~fFact. and Order for Summary Eviction. Q Okay. and do you recall what
the deputies. or one or both ofthos~:dcputies did with the Findings ofFaets and Order of
Eviction?
.
A . .{es":
13
18
19
20
21
22
23
24
:n
28
Now, combine that testimony with the fact that the WCSO Liz STuchell.
Roxy Silve. Deputy Machen. Maur~en, etc., etc. get real uncomfortable when it comes to
discussing just when they "received" either the to!25!J I Eviction Order and Decision of
the IOi27 II I Findings of Fact. Conclusions of Law ....combined the Ihe Rles various
statements respecting just how and y.:hen the WCSO gets those eviction orders. and the
usual custom and practices ... combined with the WCSO's statements about the maintenance
of the faxes. the fax headers. the sin~ular copies of those i'dxes being filed back with the
court transmitting them along with the Deputies AFfidavit of Service (like In 1117111 one
where Deputy Machen swore he "pe'~sonaIJy served" Coughlin, despite his supervisor Liz
Stuche!t having to later admit in wri,ing that to Machen "personally served" means "taped
it to the duor when no one was nome": .. and you know when HIlI testified on 6118112 about
"they taped it to (0 door because youl ran away" that. giyen Baker's testimony that HIll was
not present on that date. 11 II 111, an~ Baker's failure to make any such altegation ...that Hill
was just doing more of the same tired innuendo and baseless accusation. convenientlv
made to disguise yet another situalioh,where his reckless pursuit of fee generation cI~shes
with the rules of professional conduct ,attendant to his privilege to practice law.
A great Judge Sferrazta moment at the 12120111 Hearing on the MOtion to
Contest Per&onal Property Lien ... well.a couple (one. (0 Coughlin: you have filed a Notice
of Appeal, I am diYested ofjursidicti<JR. so you can go an confuse the District Court wit~
those arguments of yours nnw ..... ). bU1,the best one, in response 10 Baker making
essentially the "cherry pick" argument Hill makes in his email below:
"From:
Richard Hill (rhiil(iilrichardhillaw.com)
:'>ent: Sun 11/20111 12:42 PM' To: zachcoughlin@hotmail.com
Mr. Coughlin - you continue lie.
to
\
,,,
- 35/39 -
I
,'
V
,I'
I
"
You & r have spoken se~cral times,

You call & rant at my secretary & then hang up before r can get on the line.
Please go back and re-read,my emails to you.
You will not be allowed t~ cherry-pick the property & leave us with several
thousand dollars worth or,~lean-up.
May r suggest that a good starting point would be for you to arrange a
dumpster and throw all the'crap in the backyard into it??
"
Judge Sferrazza (about any/'anticlpated cherry picking by Coughlin): Well, r think

6
that's what the law is, though, so h'e can."
What Judge Sfcrraila so astutely points out there is the fact that, one, Hill,
Baker and Merliss can only get that which the legislature SCI out in 118A.460... and they
P,
need to cease their unlawful rent distraints abolished by Nrs 118A.520 or otherwise trying
to cram into nrs 118A.460. malevolentlv, with utter baselessness. fraudulentlY, all the
things they want to get out the silUalion' but which the lanlord did not have th~ foresight or
bargaining pow'er to demand be a
of the Rental Agreement way back when.
1 [)
Futher problematic is the fact that WAshoe Legal SErvices employee Lew
li
Taitel (well, RMC fellow defenderiKeith Loomis. Esq. indicated Taitel now works for
WLS incident to the ECR contract WLS has with the WCDA's oflice. which arguably
12
conflicts the \vCDA out of prosecuting in a retaliatory manner via DDA Zach Young of
COllghlin in three separate criminaliinatters currently, all three of which are rampant with
13
police and pr()secutorial misc()nduct (in RJC [cf20 122-063341, [cf20 12-065630, and
} Ii
rcr2012-067980, and all three arrcsts:and the officila misconduct therein.is capture in
audio and video rccordings ... no matler. DDA lach Young presses on headlong into his
assault on liberty, and apparently. Young is really able to do some real broken Held
running in the current atmosphere). \Here's the thing. though: Taitel is business partners
16
withNevada Court Services, which got Coughlin arrested twice between 6128112 and
17
7/3/12 (and Judge L. Gardner's Brother Judge W. Gardner, in conjunction with RPD
Officer Alan Weaver and SArgent Brian Dye and Reno City Attorney Jill Drake) manage
to get Coughlin's bail magnified a ridiculous factor of 10 for a completely fraudulent and
lacking even a prima facie/probable Cause basis for "distrubing the peace" to \\hich the rpd
glommed on a "failure to secure a loa'd on one's vehicle" and a "no proof of insurance"
2G (RPD Alan Weaver says the statute ,,-:ill not allow or a 5 inch high definition pdf of one's
curren! proofof insurance on a smart phone to satisfy the proof requirement...and Dye and
Wca~er. 10 which Judge W. Gardner'agreed. though there exists no "for your own health
and safety" basis for increasing bail ~ he did. magnified Cough Ii's bail from a bondable
$1415 to a "straight cash homey" $threc stacks ($3,000), keeping Coughlin jail from July 3
23 to July 21 st, 1012 (whereupon Coughlin's old high school power forward Jared Swanson,
owner of Western Art & Architcctur<and Big Sky Journal plunked down the lucre to
spring Couglin from the hoosegow ...after weeks of Coughlin tr~ing to get through to
someone, anyone, via the inscrutable ~nd untair WCDC collect calling phone system. the
23
WCDC denied Coughlin repeadtedJy any paper to file any court filings and otherwise
26
impermissibly denied him access to the' courts and his medication. In this environment,
Coughlin asks tor a little more time oo',the Opening Brief and Reply. and will thoroughly
cite to the ROA and provide extremelYlgood legal research 011 the key issues, which will
part
28
)1
ill
,
"
- 36/39 -
MOTION FOR M!SlTRIAL AND MEMORANDUM OF LAW

"
2
3
provide ample opportunity for this C'ourl to clarify points of law in Nevada that this State
needs guidance from this Court on. i
CONCLUSION
The undersigned hereby requhst this Court consider these materials presented herein in
deciding upon this malleI' and or declare a mistrial or appoint an alternate public prosecutor,
5
6
AFFIR!\fATION AND DECLARATION

i
e
9
10
11
12
13
lin. Esq,
Defend' II Co-Counsel tor Coughlin
Zacho
14
is
!
I
16
J7
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20
21
22
24
25
2E
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- 37/39 -
MOTION FOR MIS,TR[AL AND MEMORANDUM OF LA W
~--,
~---;
~'
-----~
~"
PROOF OF SERVICE
2
3
4
"/
On this date. I caused a copy of rhe foregoing document s to be served upon the following by
sending to their registered email address and fax number as found on www,nvbar.ore. and or hand
delivery to dropslot or Iront desk oi'the WCDA and or by placing a true and correct copy of the
foregoing document in the U.S. mail addressed to:
,
Zachary N. Young. Esq.

Washoe COUnty DA
I South Sierra p.o. Box 30083
Reno. NV 89520
Email: z).oung@da.wasnoccounty.us
10
11
12
13
14
15
16
/~----
DATED this Novcmber 13th, 2012: ' (')

o hrn
/
0Wtl'lll...&.!tf,-----Defendant! Co-Counsel for Coughlin
17
19
20
22
23
24
25
2E
2S
- 38/39 -
INdex to Exhibits
I, Exhibit I; relevant materials on a dvd and some papers
3
e
9
10
1l
12
14
15
Hi
)7
20
)1
22
24
213
- 39139 -
MOTION FOR MI~TRIAL AND MEMORANDUM OF LAW
,.
_",,~,t"
,
1
2
3
4
7
8

Plaintiff,
10
Case No. RCR 2011-063341
VB.
11
12
Dept. No.2
ZACHARY COUGHLIN,
Defendant.
1
13
14
ORDER DENYING MOTIONS FOR MISTRIAL AND CONTINUANCE

15
16
Defendant above-named filed a Motion for Mistrial and Memorandum of

and Emergency Request for Continuance Given State Bar Hearing of 11/14/12 and Moti
17
18
19
20
21
Reconsideration of Ruling on Suppression Motion on November 15, 2012. The C

reviewed Defendant's Motion, as weI! as the p~pers and pleadings on file herein
/
cause appearing therefor,

IT IS HEREBY ORDERED that Defendant's Motions for!
/
Continuance are denied.

22
23
24
25
26
t7
/ / -lift
DATED this jfL:7 day of November, 2012.
/~)o
;t:./,
'
/} ////
. t,//;< .
/(~ ,:/1(:q:/
CERTIFlCATE OF SERVICE
2
3
5
6
7
g
LORI TOWNSEND, Secretary to

PETER J. SFERRAZZA, Justice of the Peace
9
10
11
12
13
14
15
16
Name:
Address to which
mailed/delivered:
Zachary Young, Esq.

P. O. Box 30083
Reno,NY 89520
November 16, 2012

date emailedto:zyoung@da.washoecounty.us
_ _ _ _ _ _ _ _.; date placed in county interoffice mail.
17
18
19
20
21
22
23
24
25
26
Name:
Address to which
mailecl!delivered:
Zachary Coughlin, Esq.

1471 East Ninth Street
Reno, NY 89512
November 16,2012
date transmitted via FAX: 949-667-7402

12 NOV 16 Al111: 42
3
4

Plaintiff,
8
9
Case No. RCR 2011-063341
VS.
10
11
Dept. No.2
ZACHARY COUGHLlN,
Defendant.
12
ORDER
13
14
With the exception of the attached subpoenas, all other subpoenas were either
IS
improperly served, improperly issued, unduly burdensome, were for witnesses or matters
16
irrelevant to the trial on the merits in this case, or did not specify what docnments, if any, were
17
being subpoenaed. The attached subpoenas were validly issued and served by mail, all other
18
subpoenas are hereby quashed.
19
The Defendant will need to present proof at trial that the attached subpoenas
20
were properly served with copies of the original certificates from the post office, as well as
21
proof of payment of the witness fees or, in the alternative, proof that the Court ordered that the
22
witness fees be waived.
23
24
25
26
DATED this
-/1f'
,,
day of Novembe

,
STATE OF NEVADA,
Plaintiff,
2Dept. No._ _ _ _ _ __
VS.
SUBPOENA
2e-ch"'-?< SS CO(26-!dLII\!
Defendant.
P
f'J, ~L.
TO:
VV4-t:5= 1\1
You are commanded to appear bpfore tbe Reno Justice Court at One Soutb Sierra Street, Reno, Nevada
on the
IDtMdayof_ NovLmk:.2-Lv
,20
at
o'ciockD....-.M.
to testify on tbe part of
. L.
Failure to appear may be deemed a contempt court and subject you to the penalty set forth in NRS 22.100
and/or NRS 50. I95.
3'60
.Jf.LIA
Dated tbis
"
day of _ _\)~~.:::~,,. ...::...:../~'-).{--:-_ _ _ _" 20 \ d-.

STEVE TUTTLE
CLERK OF THE COURT
By:
~\l~ ~bJ\~,\(,Deputy Cler
STATE OF _ _ _ _ _ _~)
)ss.
COUNTYOF _ _ _ _ _ _~)
I, received tbis Subpoena on the _ _ _ day of _ _ _ _ _ _ _ _ _ _ _ __
,and
personally served a copy of tbe same upon
on tbe
day
of
-------------'
--- - -_ _ _ _ _--', 20_ _.

_____ day of _ _ _ _ _ _ _--', 20_.
Notary Public
,20

STATE OF NEVADA,
Plaintiff,
Dept. No.
1.;
VS.
2~tI- ~JG-~fri/
SUBPOENA
To:_-=L=_--"v.'--'c:::.=-.:n-_::::I....l-rq'-f--!...t...l!\-L~l...-....j:-_ _ _ _ _ _ _ _ _ __
You je..,QOlM}..ande
aPl?elJI be qre the Reno Justice COU?? One Sou~Sierra Street, Reno, Nl<vada
on the
Y_T'_\dayof rvov JLV\I1kJtJt7 ,20
,at
Di:>O o'clock~.M.
to testify on the part of-----;_--;--_ _ _--::-_ _-:--:-:-_ _ _.,--_--:-_-=--:-:---:-::::-::-:-::---c_
andlor NRS 50.195.
.
Dated this
~~ day of _ _Q-'="--'Q-"bu.w::,b~~l..!v:....._-'--_ __', 20~.

STEVE TUTTLE
CLERK OF THE COURT
BY::
~Vlli\AQ! L ~ \'Y\D-./~
l
'I.
Deputy Clerk
STATE OF _ _ _ _ _ _-.J)
)ss,
COUNTYOF ________~)
I, received this Subpoena on the
day of - - - _ - - : -_ _ _ _ _ _ _ _ "20
personally served a copy of the same upon- _ _ _ _ _'--_ _ _ _ _ _'on the

of - - - -_ _ _ _ _, 20_ _,

_ _ _ _ day of _ _ _ _ _ _ _- '
,20_,
Notary Public
,and
day
,i

Case No.
STATE OF NEVADA,
R,c..t2- '2 o ll-0633t-()
Plaintiff,
Dept. No.'_ _ _ _ _ __
VS.
?C!L.. G~ LoV6-&-/~!
SUBPOENA
Defendant.
C.,:l LTC'{\-\
TO:
T-eVV\. PL!=? TOIII
You are ~anded to appear befo~e tpe Reno Justice Cow;( at One South Sierra Street, Reno, Nevada
on the
I ~""dayof_ I\'\O\J-t>fY\\Qfv
, 20fl, at q;:?--,?D
o'c1ockC\....M.
to testify on the part of--;---;--_ _--::-_ _--:--:-:-_ _ _,.--_-:--_-:"-7"":"-:::=-:::-c=-::-::7"'"
and/or NRS 50.195.
:
Dated this
4'" day of_--'()=--::~='.:...:n"-':;Io=_l.::..,V _ _ _

_
-->,
20
STEVE TUTTLE
CLERK OF THE COURT
By:
2!k\.X\C.i..G~ &''Wl." \~
,
Deputy ClerK
STATE OF _ _ _ _ _ _---.J)
)ss.
COUNTYOF _ _ _ _ _~)
I, received this Subpoena on the
day of _ _ _ _ _ _ _ _ _ _ _ _ _,20----' and
personally served a copy of the same upon- -_ _ _ _ _ _ _ _ _ _ _'on the

of _ _ _ _ _ _ _ _ _---',20_ _ ,

_ _ _ _ dayof __~_ _ _ _ _ _,
,20_,
Notary Public
day

COUNTY OF WASHOE, STAIE OF NEVADA
Case No.
STAIE OF NEVADA,
Qc~ '20;/ -ex; 'f5t./1
Plaintiff,
L-
Dept. No . _ _-==......:...___
vs.
2M J- CCJu6-H-l-:~
SUBPOENA
Defendant.
TO:
Rcbev- +: bA-wSC f'1/
You larhc<?~anded to appear befor,ll the)teEo Justice Court at One South Sierra Street, Reno, Nevada
on the
-.;;:,. L'dayof_(lJDVcQ..YY\beJ1-,20~at 2,;"?)O
o'c1ock~.M.
to testify on tlie part of
.
Failure to appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22.1 00
and/or NRS 50.195.
Dated this
4~ay of _ _O=-. .:.~=:.t'-O=D"-,-,\oQy=-.;_ _ _- , , 20 1J.

:
STEVE TUTTLE
CLERK OF THE COURT
BY:&X'\tl~~ ~\:::),\.AYVQ~
Deputy Cler
STATE OF - - - -_ _-.J)
)ss.
COUNTYOF _________~)
I, received this Subpoena on the _ _ _ day of _ _ _ _ _ _ _ _ _ _ _ __
, 20_ _, and
personally served a copy of the same upon
on the
day
of
------------'
--- - -_ _ _ _ _ _ _ _--', 20_ _ .

_ _ _ _ day of - -_ _ _ _ _ _ , 20 _
Notary Public
IN THE JUSTICE COURT OFRENO TOWNSHIP

i
1
Case No.
Rc ~
Dept. No.
STATE OF NEVADA,
'].::;>/1-06351-[ \
Plaintiff,
VS.
-Z~C- ~ /-0u6-HL-'~
Defendant.
TO: AI,,; $ T' tJ
LlCH rt
on the
SUBPOENA
You a,re cmanded to appear before tht; Reno Justice Court at One South Sierra Street, Reno, Nevada
qday of _ _~ ~\Ot,v- ,20J,:b.at
":::>1..') o'clock C\. .M.
"6'
~~~oo~~~
and/or NRS 50.195.
Dated this
~ay of Dt~\;:4"-)/
,20 \:r.
STEVE TUTTLE
CLERK OF THE COURT

By:
&:"-'1f\6-.J:,~\ ~~"~\r--Deputy Clerk
STATE OF _ _ _ _ _ _-')
)ss.
COUNTYOF _ _ _ _ _ _-J)
1, received this Subpoena on the
day of _ _ _ _ _ _ _ _ _ _ _ _ _,,20----' and
personally served a copy of the same upon _ _ _ _ _ _ _ _ _ _ _ _'on the
,20_.
of

_ _ _ day o __________-', 20_,_.
Notary Public
day
SHERIFF
WASHOE COUNTY
Michael Haley
Sheriff
November 6, 2012
Zach Coughlin
1471 E. 9"' Street
Reno NV 89512
Re: Service of Civil Process
WE ARE UNABLE TO PROCESS YOUR REQUEST FOR THE REASON(s) INDICATED BELOW:
,f
,f
,f
,f
,f
,f
The document must be properly formatted; please check with the court.
The Fee for service of each Subpoena Is $17 plus mileage. Please provide 2 copies of each
Subpoena for each recipient
The charge for a Subpoena Duces Tecum for Washoe County Sheriff is $25. This is not a
service fee.
Provide 2.copies of each Subpoena for each recipient with the correct fee.
Please provide a cover letter of instruction for each recipient to be served. Provide the
name and address of the recipIent and their last known address.
Please contact the Civil Section at 328-3310 to obtain the total fee for each redpientyou
would like served.
Other: If you have obtained a ~ fee waiver please provide a copy signed by a judge
referencing the corresponding case number on the document (s).
We do not accept electronically transmitted requests. This office is prohibited from giving
legal advice.
c!l.k1fl-,
Civil Section
911 Parr Blvd
Reno NV 89512
(775) 328-3310
,I
I
I
11
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,(Domestic Mail Only; No In!iuranGe COVfJftJge ProVIded)
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OS a
CERTIFIED MAlE" RECEIPT
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LORI TOWNSEND, SecretarY to

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Name:
Address to which
mailed/delivered:
Zachary Young, Esq.

DeputyDistrict Attorney
P. O. Box 30083
Reno, NY 89520
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November 16, 2012

date emailedto:zyoung@da.washoecounty.us
_ _ _ _ _ _ _ _; date placed in county interoffice mail.
and deposit in US. mail.
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Name:
Address to which
mailed/delivered:
Zachary Coughlin, Esq.

1471 East Ninth Street
Reno, NY 89512
November 16,2012

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Name:
Address to which
mailed/delivered:
November 16, 2012
Creig Skau, Esq.

One East First Street, 3mFloor
Reno, NY 89501
,,
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iI
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Name:
Address to which
mailed/delivered:
November 16, 2012
Mary Kandaras, Esq.

P. O. Box 30083
Reno, NY 89520
date emailedto:mkaruiaras@da.washoecounty.us
Fe .. : ,.thtoughlln
To: 1clf21eHcc8-461.-8eOf-1e.559b
11-19-12
8:21a.
E RENO JUSTICE C01.}RT

, OF NEVADA CONTY OF WASHOE
STA
-OF~EVADA,peti(on
vs.
) RCR2011063341
) DEPT2.
)
)
)
10
zach oughlin:
11
Respondents
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13
MOTIO:\ FOR MISTRIAL A);D OR CONTIlSUA);CE
16
17
13
http! drv.ms/Tt4dYf
msiXmRkVL
coughlin apologizes lor the fOl111.tting and length and IS doing his best but this ,s a natural
22
ct of baT counsel bathing m ,cr I(J6 ll1lmUnlty and completely destmymgany nolloos of falf play
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meld tto the 1111 4d2 DIScIPlInary HeaTIng, JUSU}1n SCR I 19(3) contempt snacnons agamst bar cOUllSCI
2c
for al the attendant due proceed, notic<, and scmee violations arIsing therin
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mclu d herem IS an excusable neglect basIs or gooJ cause for remstatmg the appeal beyond the tact that the
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$250 ding fee wao; pald and tht receipt and or dockt' show it was pt!.ld for thlS Cfl.<;e and an ifp is pending In
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the as oelate 60331
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- 1'71-
MOTION FOR MISTRIAL OR CO>iTINAt:
p, 2
of 12
11-19-11
fro.' ,.che,ughlln
To: 7cJf27e9-fccH67a-8eOf-7e.SS9b
S.llam
Supr me Court has obligation in disciplinary proceeding 10 look ""yond lahel given 10 attorney's
tony' don to true nature or fact" in ~rder til determine whether underlying drcumttanccs. of
con . lion warrant dis<ipUne. Sup Ct Rules. Rule Ill. suW 3. State Bar of Nevada
v. [:1 borne, 1988. 756 P 2d 464. 104 Xcv ll' Attorney And Chent 39
2. lnd etment
4
)
Wher
peliti
been
sus
III ,
the only relcvanllactual aDegalmn oontamed ill DlSclplmary Board's Blfldavll. hied In support of lts
for allomey's temporary suspension from the practice of law, was that a cnmmal indictment had
led against the allorney, ttus sole aHegdtlon, without more, was msufficlent to Justify summary
sion and the nnmediate impo"tlon of temporary restrictlons. Sup.Ct.Rules, Rules 102. subd 4(a),
bd. I Matrer of Monteiro, 1984 1)g4 P 2d 506. lOO ~ ev 440 Anomey And Chent 48
3. So ous crnne
Co.
tt
I U'i '
00
at
me"
t
. sw
w e
""''''''I"""="",,,,,,-,,,,,=,,,,,,,,,,,,=,,,,,,,,,,,t,,"-lo",t""te",ns<"". Sup.Ct.Rules. Rule Ill. suM 2 Sloan v. State Bar

436 . ttom<y And Clten! 39
'1
re ues! to comhinc or consolidak appeals where legally tcnable this appeal with 60331
amendment to case appeal sta1meent and clarification of notice of appeal incident
thereto to indicate that D7's 3130 112 Order in included amongst those appealed.
hereby reselYes all defense under nrcp 12 g:(h) Watver or Preservation of Certain Defenses.
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(1) A fense oflack of jurisilletion over the person. Insutficiency of process, or msuffieiency of service of
proce s is waived (A) if onutted from a motion in the clfcumslances described ill subdivision (g), or (8) if it
is nel er made by motion under thlS rule nOT mduded m a responsive pleadmg or an amendment thereof
penm red by Rule 15(a) to be made as a matter of course
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cfense of failure to state a claun upon which relief can be granted, a defense of fallure to Jom a party
nsable under Rule 19, and an objectton of ["lure to state a legal defense to a claim may he made in
ding pennitted or ordered under Rule 7(3). or hy motion for judgment on the pleadings, or at the trial
ments,
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on
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(3) W enever It appears by suggestion of the patties or otherwise that the court lacks Jurisdiction of the
subje matter, the court shall disml'" the ,ctlon
2Q
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Time to add some more Richard G. Hill. Esq. chestnuts to the lie pile, especially
cons ering Hill's kstimony under oath at Coughlin's 11/14!l2 f>isciplinary Hearing and
the Ii How sworn testimony by Hill from the 6.']8/12 Trial, viewed in cOI~junction with the
state ents Hill made to the RPD Officer Chri, Carter and Sargent Marcia Lopez just prior
to an at the time of the lli 131 11 custodial arr.:st of Coughlin at his fanner home law
offie for trespassing:
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THE COURT. When Mr. Hill is hcre to ask some questions that I think
you've explored the possibilities, and I don't know what else you can offer
the Court in lenns of this case via cross-examination.
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- 2171 -
MOTION FOR ~iISTRIAL OR CO~TI]\;Al~
p. 1
of
To: 7clI17e9-lcc8-161a-8eOI-1ea559b
4
5
..,
3
10
Fr.. : ,acheough)1n
)1-19-11
MR. COCGHLI~: Yes, sir. Your Honor. I'll wrap this up quickly. BY
MR. COCGHI.Il\: Q \fr. Hill. at any time on that day. Novt'mbcr 13th.
did the owner of the premises warn the arrestee to leave the property?
A
I think the message was communicated.
Q
Via what medium?
A
The fact that you were handcuffed and arrested. Didn't
you get the picture?
Q Okay, prior to the handcuffing and the arresting, did anybody say, "You
need to leave the premises?" A I didn't hear that Q ~obody said that? A I
did not hear that, sir. Q Did you say it? A >;0. Q Did Dr. Merli .. ? A ~ot
that I heard. Q Did the police? A 1\0. not that I heard. Q So. nohody that
you heard of warned the person
arrested for trespassing?
Page -1 10-
]1
12
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Coppcrfretti v. Shephard, 271 N.Y.S. 284 N.Y.App.Div.2.Dept.,1934

Tenant held entitled to set a~ide default judgment in summary proceedings
on showing that landlord acquired title under void judgment. irrespective
of tenant's excuse for default or defense upon merits.
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is
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I, Zach Coughlin, declare under penalty of perjury, pursuant to NRS

54.045 that the following numbered statement. are true and correct to the
hest of my knowledge:
I. 1be locksmith who did the lockout on 11 11111 is named Sean
Cheathum of All American Lock & Safe P.O. Box 51869 Sparks, Nevada
894351869 (775) 626-5397. Mr. Chcathum indicated to mer personally
that he arrived to do the lockout that day at, 1111111 at 121 Riwr Rock St.
Reno, :-N 8950 I just about the time the Sheriffs two Deputies and the
two landlord's agents did and that it was getting very close to 5 pm. 5 pm
represented an urgent deadline to the landlord's agents and the Sheriffs
Deputies, by which the lockout must he done. recalled Mr. Ch.atum. Mr.
Cheathum indicated that the lockout occurred no earlier than 4:48 pm and
was fairly sure that it came dowll to the wire in terms of effecting the
lockout prior to 5 pm. Cheathum indicated that he postulated at the time
that the urgent 5 pm deadline was due to a wish by the landlord's agents
and the Sheriff to avoid running into the tenant should the tenant be
coming home from work after a typical 9 am to 5 pm schedule.
Cheathum's memories ofthat day are strong enough to specifically recal
the types oflocks, the uniqueness orthe location (mentioning how it was
near the Harrah's Auto Musuem., the Section 8 Housing to the South of
Court Street, and the Truckee River) and that the back door lock was very
easy to gain entrance through given that a key wa~ broken off in it, which
3171
MOTION FOR MISTRIAL OR CONTINAU
8:21,.
p. 4 01 11
To, 7clI21e9-lcc8-461a-8eOf-1ea559b
From: zachcauqhltn
11-19-11
enable him to open or pick the Jock by merely tnrning a screw driver
pressed to it
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B
Ie
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2, [spoke with Maureen and Rox)' Silva of the Washoe Comty Sheriffs
Otrice on nwnerous oeeassiollS, On more than one occasions Ms. Silva
slammed the phone down on me in anger. However. on other occasions
she spoke at length about the way the \VCSO carries out evictions,
particularly wit respect to the "within 24 hours of receipt of the Order"
language in NRS 40.253, Roxy Silva. Maureen, and Civil Division
Supervisor Liz Stuchell indicated that the WCSO received the "Eviction
Order" on 1111111 at 8:05 am, and that the data entered in there computer
system confirms thi;" Silva, "Maureen" and Stuchell also indicated that
the WCSO does not keep any records of when it receives Eviction Orders
beyond manually inputting the time lhat the Orders are tak~'I1 from the fax
machine to which the Reno Justice Court send, such Orders (and RJC
Chief Civil Division Clerk Karen Stancil has indicated to Coughlin that it
is the usual Cllstom and practice of the RJC to fax Eviction Orders over to
the WCSO the day the are entered or the next day, There is some
confusion over whethcrthe 10/25111 "Eviction Decision and Ord,'("
signed by Judge Sferra:rza on file stamped on that date is an "Order" and it
does appear that M~, Stancil and Bonnie Cooper are correct in their
assertion that the typical RJC "form' eviction order is on a different "form"
or "template" than that 10:25,'12 "E,;ction Decision and Order", Whether
that means that IO!2s:J2 Order was not faxed to the Sheriff in accordance
with the "usual custom and practice" of the R.IC does not seem clear, nor
has anyone with the RJC responded to requests for documentation or
infomlation in that regard. Former IT employee Curtis Harvey may have
some infonnation in that regard. Additionally, the RJC fax appears to
bare an incorrect time stamping fairly regularly, Further, Chief Ci,il
Clerk. Stancil's apparently correcl assertion that the WCSO does not file
anything along with their typical one page Affidavit of Service (which
bares a time stamping of sorts representing, apparently, when the lockout
was conducted."and WCSO's Deputy John Machen's Affidavit of Service
file stamped 11!7!l 1 indicates a time of 4:30 pm for "personally serving"
Coughlin, Locksmith Cheathum disputes Richard Hill's trial testinlOny in
II CR 26405, where Hill indicates the WCSO attempted to "personally
serve" Coughlin the Eviction Order, but that Coughlin "ran away",
Chealhwn indicates Ulere was no indication any tenant ",as at the 121
River Rock location. nor was their any discussion by anyone there,
includign the two Sherift's Deputies and two landlord's agents to that
effect Hill admits to not having even been there for the lockout. Casey
Baker, Esq, testified on 61] 8/12 that he and Sheri Hill were present and
waited with the Sheriff's deputies until "the locksmith finally arrived",
NOTE, Baker's Order of 1O!27112 is void in that it fails to included the
specific language called for in NRS 40,253(5), as the "within 24 hours"
- 4171-
MOTION FOR MISTRIAl, OR CONTINAL'
8,11..
p,
5 of 11
To, lclf11eg'fceS-461"SeOt-le,119b
111912
From' ,aeheoughlin
8,11..
language is not there. and Bakers testified liS to this in II CR 264()5, when
he also te.titied that he did somethign with the WCSO on October 28th,
20 II in connection with the loclout.
2
3
NOTE COUGHLIN FILES T HIS WITH THE CAVEAT THAT, WHILE SOME SECTIONS
:\t" Y BE A DECLARATIOK OR SA Y SOMEYHIGN ABOUT PERlL'RY, COUGHLIN NEEDS MORE

TIME TO CLEAN THIS DOCnm'lT UP, YET THE TMMh'lENT THREAT OF ATTACK .<\'lD OR
"
RET
8
9
IATJON BY THE SB:\', LOCAL PROSECUTORS, OR LAW ENFORCE:\ffi';'T mcrATES

rUNG THIS FILl).IG :\'OW. DCE TO THE EXlGENCIES NVOLVED, WHICH EXISTS
SOL
Y DUE TO TIlEIRMISCONDUCT A:-IDl).I NOWAY STR\1FROMi\1\Y FA1Ll:llli 01\
COU HUN'S PART TO UNDERTAKE DUE DILIGE'CE Di EVERY WAY
lJ
Dock t entry for the U1al court malter 'hIS case was appealed from. ev I I03628 (a Katie. of Appeal was
II
filed, I appears on 7130i12. though C"ughlm may have hIed one Inj3li. where Judge Lllllt, (lardner's
12
broth . (see Mandamus PeUbon by Coughlm agatos! LlIma Gardner In 54844 and the a_hed 8/1711 I
13
reo
I Order by Lmda Gardrer where she c.t-:s to the "I Just outright hac a bias agaInst you" JudiCial canan
14
in 2.1 (a) in expltaning her recusal .and that case prows, amongst other proof thai the address Coughlin was
from was indeed heing used as and held out as the looation for Coughlm's law practice (as was the
1t
the www.nvbar.arg contact information at the tune for Coughlin, for over one year pnor to lha
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ill summary eVlcttOn the subject 01 thIS appea~ along With the record settmg attorney's lees by Judge
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Patrie Flanagan, who refused to recuse hrmself despite he and Coughlin being former co-workers at Hale
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Lane now Holland & Hart) and there eXisting a multitude of baSIS meldent Ihereto for a lindmg Ihat rocusal
was n andator),) shows the unpropriely of the Clerk of Coun dI5missing the appeal for lack of paying a filmg
21
fee.
ugJhin was provided a receipt showing that he had paid the filing fee for 61383. and Coughlin has an
22
IFP P nding in 60331. The docket confirms this in the trial coun matter fmm which both oflhese appeals
stern
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201204.55 PM SNolice!Appcal Supreme Court COUGHLI:\, ZACHAR Y

Entry APPEALFEE PAID FOR THE 73012 NOTICE OF APFEAL lM'\QE AIIACJIED TO JUI, Y
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- S!71-
MOTION FOR
~fISIRL\L OR
CO\,TINAU
p. 6 of 11
To:
lcJf21e~fcc8-!61ageDf-leaI19b
From: zachcoughlln
9:21a. p. 1 of 12
11-19-12
hUp-//www ccwashoe.comipublicfck'-public _qry_doct cp _dktrpl_framcs?
1
?
3
-.
06-S p2012
045 PM
::SNoticefAppeal Supreme Court
---
"----,--
.COUGHLIN. ZACHARY
.:
<APPEAl. FEE PAD> roB THE 7-30-12 NOTICE Of :!,ppEAI. _IMi\GE ATT:!,CIDl) :
: TO JULY FlUNG
7
The Nevada Supreme Court Docket seems to miss the part where Coughlm paid the films fee in
<S138_ and one has towonrler. gIVen RIChard G. HilL Esq.lestifymg before the ~B that he is. member
18
of at oughlin's 11114/12 Dsiciphnary Hearing (largely predicatod upon arrests that Hill directed the RPD to
make given the appeal In 61383 was dISmissed (WIthout a signature by an actual Justice. ) Just days prior
12
there
0713l!2012Filmg Fee . Filing Fee dueFiling Fee due for Appeal 07/31120l 2Notlce of Appeal
cnts - NoUce ot" AppeaVProper Person 11 lot Programhlcd :.ronce ot" AppealiProper Person Pilot
m. Filed certified copy of proper person nOlice of appeal. I 2-241::9
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07/31 2012NoticeiOutgmng - Notice to Pay Supreme Court Filing Feelssued :-.lotice to Pay Supreme (',oUrl
Hm Fee. No action Will betaken on thtsmatter unlll filmg fee IS paid. Due Dale' 10 days E24\33
012OrdefiDispositional- OJ(ler [)lsmiSSlng AppealFiled Order Dismissmg Appeal. To date,
17
t has not paid the filmg rce or otherwise responded to thiS court's notice. Accordmgly, cause
19
appea
109, tillS
appeal IS dUTIlsscd 12-35194
Z""h Coughlm, plamtill. submits thIS hllng (notice' motion iobJectlonj

21
on hiS own behalf. Judge
Doro y Nash Holmes just lied and hed under oath at Coughlin's 11114/ 1~ Disciplmary Hearing, especially
-.0
.0
with gard to her assertion that she,
10 the
traffic CItation trial
In
II TR 26800 that she held on February
23
27th,
I) 12
trom 3;3l!pm to 4:45 pm, despIte she and or the RMC being aware that Coughlin had been
24
to have a competency evaluation by RJC Judse ClIfton's Order of ?!27i12, baring a file stamp< of
25
1:31
... which IS JUst about the time that Judge Nash Holme's judicial assistant announced on the record in
215
urt that nobody With the RMC could seem to tmd Judge Nash Hoimes, and how weird thaI
27
was
hich was just about the time DDA Young and Biray Dogan held their 'clandestine status
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nee'
U1 rcr2012(l65630
case where DDA Young persisls in hi, retaliatory prosecution of Coughlin

- 6171-
MOTION FOR MISTRIAl. OR CO\,TINAl"
To: lclf21.9-fcc8-(61.-8.0f-l.aSI9b
f,CO: lachcoughlln
11-19-12
8:21..
for ca lmg 911 to report police mIsconduct C13usmg Coughlin to perceIve an emergency being present and a
An~'Wo)~,}.'Rl;
to hls safety .. )
\ 78 4IlS iIDd}.'Rl; 5.010 qurre Judge Nash Holmes 10 "stay all
dmgs" when such competency i!iSUs or Orders anSi;!- not u.) do what she did, WhlCh is plunge
headl ng into a retaliatory mtcnt to find somethmg to ConVlct Coughhn for (JLKige "\lash Holme~
"
tr
DISci hnary Hearing before the };NDB and State Bar of Nevada after she wa' coached up by Bar Counsel
to make sure to fmd "by clear and convmceng eVidence" that Coughlm had VIolated some Rule of
. ogrifteda traffic citation matter, for a 'BoUlevard Slop", ie, a "California Roll' into a full blown
sional ('",nJuct or other (Nash Holmes decided to copy and past the whole lot ofRPC's, and then
ded to muse aloud In her 3/1 2/12 continuatIOn of the trallie licket tnal m 11 tr 26S(X) that CoughlIn
1J
had" robably' Violated th!s or that rule but when It came time to Sign an Order, Judge Holmes remixed that
cided that Coughlm had done so by "okar anJ convicing eVidence". This trame eilauon tnal sterns
II
oughlm gOIng tD opposing oollnsd en th< summary mction from Coughlin's former home law office
L2
from
13
(Rich d G. liIll Esq. and Casey Baker, Esq) after he was released from 3 days in jad InCIdent to RIchard G.
Hill's Igning a crmlmal trespass complamt in II cr 264(15 against Coughlin, after Hill and Ius neurologIst
13
Dr Matthew Joel Merhss were able tD he to and WIth the Reno Police Department's Ofticer Clins
Ie
Jr. and Sargent Marcia Lopez about whether anyone Issued (',oughlin a trespass wamll1g, whether the
l'
polie identtfied themselves as law enforcement pnor to the landlordklckmg the doorto the basement down
1S
(the
19
did to "ICk the door down themselves .though, RPD OffIcer ('arter to Coughlm later that day that "Richard
20
HIll p ys me a lot of money so I arr""t who he says to arrest and I do what he says to do" may need some
21
ntore onst<maUon .. though doo't hold your breath waltmg lor Bar Counsel Patnck 0. King, Esq to
lice apparently did not feel strongly enough 1lI their caus< or nght to be undertalang the oe!tOns they
22
ake any, or Reno Cuy Attorne', John Kadllc, Esq. Damel Wong, Esq., or the prosecutor who
cJ
cd all that perlury by Richard G.lIl11, Esq on the stand, Chnstopner Hazlett-Stevens, Esq.(Hazlett-
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's was provlded indisputable Video evidence showmg that Hlil's le.tiony was Ii.s, at the 6,18'12
25
cnmi al trespass Inal preSIded over by Rtv[C Judge WIlham Gardner, whom refused to recuse rumself
26
despi Coughlin SUIng hiS sIster. Judge Lmda Gardner m 54844. and Judge Lmda Gardner filing a gncvance
:c.;
a8am Coughlm In ngI2-0435 (the SBK and)'~"DB held a diSCiplinary heanng on I J!f4i12 despIte the
28
panel ot even being chosen until 10/30/12 don't
WOrT),
though, ChaIT John Echevcrna was ahle to step In
- 7'71-
lI-1OUON FOR MISTRIAL OR COSTINAU
p, 8
of 72
11-19-12
To' lclf21.9-fcc8-101.-8eOf-le.119b
so~u
,"
~,21'.
kly, that before Chair Susich's Order announcing Echeverrta as Panel Chair could be staped to the
proof f semce, much less mailed, elmr Echeverria had domed every Motion Coughlin filed and granted
Ing Bar Counsel Kmg could ask for ,with the added plus that they (Bar (:ounsel Patnck 0 King ""d
,:
ehatr J Thomas Susich:md, perhaps, some others) cooked up a Panel (dospit< the Complaint and
List t out fully in 6190 Lif the Office of the Clerk will file what Coughlin submitted for filing, ,which it
did
on May 24th, 2012 to 60838
\Vhy Bar Counsel Patrick 0, Kmg Esq, andJ Themas Susieh, Esq, of the NvTIETR (conflieted
out,
from umg Washoe Legal Scmces In 21)09" ""d its kind of hard to object to propsed Pand members when
should have been V1.a the mQ.\t<r of Mauroen Cole_ Esq_ \fielden! to her attempts to pment Caughlin
10
the S N does not serle the Complaint under SCR 1\19. then submits fraudulent materials to indicate the SBN
1\
has d ne so. Just as Laura!'eters and Patnck 0 Kmg, Esq dId WIth the 10'9'12 hie stllmp<d Notice ot Intent
12
to T e Default (which Coughlin hC'fcby swears under penalty "f p.,jury tlmt me \'SPS downtown Reno,
13
Station would not give to Coughlin in light of It only havmg $L25 worth of postage printed oot on it
\4
d "PItney Bowes" SB)! style typIcal of all SBC'I mailings (and where, Md this is veTfJed by the
15
16
Peters certificate ofmatlmg attached to that lO'9!12 C'lollce ofIotenl To Take Default, the SRN only
l10/9il2 file stamped NOITD VI8 one method. certified mail.
sent
17
Some mIght call It the "McGeorge ~1afia' but that is. bIt mu<:h, no? However, that law schooL
18
whlc is renown for long fallillg out over two trurds of its class (despite glady taking theli money while the
19
p lasted) may, to some, seem to produce a certl8n type or lawyer or Judge the good POints'
relall
20
ork demonstrated In spado,,,,,the bad pomt<'! WelL some mlghl say the teamwork IS mo;tly directed
21
to re' latIon, Lero sum game playmg. and "fallmg our" anyone who dares to cross them Some mIght say
22
thaL
23
24
25
26
-more cooking up a fine Panel:md Disciplinary Hearing by King,
SUSICh,
the Washoe (',Qunty Shenffs
omc and the Second Judicial Distnct Court, Reno CIty Anomey's OffIce, aod Washoe County District
Arto ey's Office, and SBN: Judge Linda Gardn,."s bailiff (and she was preSc"Tlt faT both days of trial m the
divor matter wherem Coughlm, on behalf of Washoe Legal Services represent<d a domestic vtolance
23
lcb
>
and took a posltJon supported by the maJonty Vtc\\:-potnt In Arnencan law (though \VLS Executive
- 8:71-
MOTION FOR MISTRIAL OR COXfIl\AC
p,
9 of 12
ft~, latht~ugh11n
11-19-11
~,11..
Direc r Paul Elcano claims C.oughlin's performance in the hearing Jusllfled and wa<; the "sole reason~ for
-,
Co
him?) the fact that Coughlm was really tired for a vanery of reasons, and under the typical comparator
analy. is in employment law, whistlehlower retaliatIon laws, hostIle work enVlfonment, dlscnmination and
other aws, .. the way Elcano ran WLS (involved lots of "old boys and girls network' style innmidation and
influe ce rather than any actual managerial or executive skill or rolling up of one's sleaves and Thurnlays
alway competell' devoted to the skeet shootlng range, and practially daily trips from the phannacy to hIS
molh s home to dehver memc.tlons (despite m<&\ phann.cy's offering \hat service for free in Reno ...m
even
lin being fired from WLS which makes convement (maybe that 'big ravor Linda Gardner owes'
e Instance shortly before Coughlm's hnng where Elcano had Coughlin gh,)st wnte a 20 page or so
10
mem andum to the Nevada Department o!'TaxatlOn that may well have managed to get WL~ out of the
]1
bmd
12
taxes n behalf of the pnvate for profillandlord... and lot:. of companng Coughlin to SoabiSCUIt constant
13
critiq os of and enforcements of a 'dre~<code' that applied only to Coughhn, etc .. etc.) ... Anyways, finally,
14
after vcr S months of Coughlin requesting the matelials. the S8N King's arrangeJ to have Coughlm'. SCR
15
105(2 c) fight.' raped a little less than the have been. m gettmg Chalf Echeverna (whom works remarkably
16
fast I dispOSing of all of Coughlin'S motion With a demal ,nd granting all of Kmgs, and don't be fooled .the
17
Charr as appotntcd on October 30th. 20 I", by October 3151, 2012 he was SIgning orders dtsposmg of all of
ndant to it entering a lease where the non.profit 503(c), WLS, would be requited to pay the property
hITS Motions (though upon a cross exammation ofChw Echevern. It became qUite clear he had not
18
19
ctlcal\y anytlung of what Coughlm worked hard on and submitted to the SBN and the Chair (and lhe
1. even more
20
21
mde ce of the acceptance of such semce by the SEN and the Panel.. though now the Panel and SBN are
22
attem ting to "have Jt both ways' and altematel, claim that KIng has forwarded all of Coughlm's filing on to
23
the
24
SOL lass of 1980 Stephen Kent brazenly gave King a pass and mdicated he wouldn't review the exhibits
25
attac d to Coughhn filings anyway, including those containmg "tap" don't Ite' <xcuplatory VideO and audiO
26
<Vide ce (and even where the Panel seeks to lazily rest on the Ianguag< in SCR III about a 'cOllYlCbon is
27
concl SlVe prool" despIte bemg presented With C.laiborne and other authonty (mdudtng n eFR I l.25(3Y.),
23
(c), W Ich Will likely result in the SD:.! and various local judges work being dissectod In fme detail m a
ruling an a motion that he was not sent by any means other then electronic service
cl Members (but King got caught i}'ng about that at the Heanng. to which Panel Member McGeorge
- 9,71-
MOTION FOR MISJRBLOR CQNTIN.-\{':
p,
10 of 11
To: lclfI1e9-fccB-461a-8eOf-lea559h
From: zachcouqhlin
11-19-12 8:11am p. 11 of 12
feden setting given Coughlin's hemg licensed 10 pmcbce patent law before 1be Fnitoo States Patent and
Trade ark Office (USPTO).
Also grounds for a mistrail in that SEN v Coughlm J)"ciphnary )"fatter are apparent where Reno
5
City ttorney Cneg Skau, Esq appears to have lied about Judge Sferrazza ordering that an Emergency Ex
E
olion to Quash Coughltn's Subpoenas (seen both In the disclplinar; proccedmg and m the petty
Parte
7
larce , of an lPhone that Ntcole WatsOn was vldeotaped admJulng some guy lound on lhe ground tn
9
n Reno, and held aloft (and trus started ollthLs whole ordeal wIth local law enforcoment on
9
81201 I) offered tt up, then announced, loudly that he was going \0 "throw lt in the nver" if someone dld not
claim t
11
Any assertion by the SBN that Respondent has actual notice of thIS the NOITD, the DoWSoe, or
12
13
H
1S
1E
anyS plemental to the Designation of WItness", and knowledge of such somehow excuses proper servtce
orp
ess; nus",s the point. The :levada Supreme C<>urt has long acknowledged that nottee of a ltttgatton is
not a ubstitute for proper seIVice of process C H A Venture v G,C Wallace Con.~ulting Engineers.. Inc.,
794 P 2d 707, 709 (Nev, 1990). SU11llarly, Delendant's nobce ofthlS Itttgatton does not excuse PJamttft's
insu cient service and insufficent process proceSb As such the SBN's (and Hill iust testified at the
18
19
lliI4 12 Disciplmary Heanng and aboutmalter<> r<lakd to this appeal even Iherem) holding the I 1/14/]2 in
such matter as to unduly prejuedlcc or provide excu.sable neglect or good cause basIS for any fatlure on
1m's part to move thIS appeal along, But the tJtmg IS. is lhat the Clerk's Office reJected a filtng of
2Ll
Coug 1m's just last week that spoke to the appeal bond (in short, RIChard Hlll. Esq ha.s It., by way of hIS
to comply Wlth )leveda law respectlgn lenanfs depostts,
23
So Judge Ltnda Gardner's April 2009 Order sanctioning attorney Coughltn personally. under I'RS
24
7,085 deSPIte there bemg no servtce by MoGoorge SOL Class of 1985 opposing counsel John Springgare,
25
Esq,
26
by Sp inggate dunng clostng argument about facts Itot m evtdence m support of lus Motton for Sanctions"
27
(and e Order for sancuons by Judge Linda Gardner took the biggest issue wilh Coughlm" sa},ng, upon
23
being ked Ifhe had one of the OYer 10 exhibits that were not bound or previously marked that Spnnggate
a filing roady 21 day safe harlx1f ;';1(CP I 1 Motion for Sanctions, ,butmther an UTlprornptu Motton
- 10,'11-
),lOTION FOR MISTRIAL OR COl\]1NAC
To: lcJfI1e9-fccB-461.-BeOf-lea\19b
so
F,O.: ,acheough11n
11-19-11
8:11am
to introduce at trial CI,.'lUghlm her~by incorproates hy refrence (an mfty trick Bar Counsel King
mana os to do In avoiding doing .ny actual work, MlfCh style, by just .!!achrng extremely suspect
convI "IDS ("cooclu.".. < proof of gutlt" .ccOOng to Kmg. CI",Nne and BurleIgh be damned), and,
King did not actually make or rese-rve dus argument Of C1te to any authority hke the \.11rch case to
what he probably now wishes he had, therefore, seek to find ""Pport to "but the objectIons Coughlm
(;
prese oed for the record as to the lack of notice, speClficlty. factual support for contentions or allegations,
semc, semee of process, suffiCIency of either semce of process (see Gann's argument m 6(130~ .. okay,
ly those to KIng's blurry exhihlts, which w""e ollen prmted on both sides of the ",ge and contained
ent ceruflestes of matlmg) The thIng" Judge Lmd! Gardners Pre-Tnal Order It,elf ruled that elth""
Ym that trial, who sought to introduce more ,han
10
11
](I exhIbit"
would be reqUired to have them bound
ked With an mdex prior to tIla! and a copy thereof proVided to oppsoing counSl:'!\ Yet, upon
12
lin VOICing concerns that are directly relal,d 10 and m support of the rallOnale behmd such an Order
13
Itn IS quoted m the Order as sayIng, 10 response to whether he has some document thaI Sprmggate
:4
to mtroou<o as abOllthlS 12th OJ 13th Exlub,t where Judge Linda Gardners April 2009 Order reads
15
urt notes that at one point, after an exhibit bad been admItted. Mr. Coughlt" could not find the copy
16
d by Mr. Sprmggate m dlscov""Y :'1f Coughlm demanded a copy he proVIded at trial, staung "am I
17
d to be nfling through my papers? My understanthng IS that you are supposed to provide a copy'
asked if he had the copy of the dc~ument, Mr. Caughhn stated, "[ do nat know I cc",ld spend my tIme
18
tal energy looking around for I,.Jr Spnnggate 's document hke I am his "-",,,tant, or we could ask
:9
28
Mr. S ringgate 10 provide a copy at the lllne he is seekIng aunllssion It1:. I beheve the rule states." Again it
21
woul seem the nothrng ill the followmg ,IILR suggest; thai making an objechon once every ten mmutes or
22
so IS,
23
conte pt of court, 6~ A L.IUd 314. further, Ihe DIstrIct Court's stalem en! regardtng factual
:2 ~
a rdte f success arguing objections) is exaggtrated
25
ct10nable Conduct of attorney In connectlon With makmg objectlons or takmg exceptions as

ISSUes
(such as
Another basIS for a mistrial here is all the lies and nonsell'" from the SB:>: and .. anous local
26
gove
27
sutho 'tl' to do sc by the SB", and Panel. Also, Reno City Attorney Creig Skau fraudulently secured
2,
Co
nental offices abcut the Subpoenas Coughlm issued and had served m the manner h< was provided
in's altendnal at in improperly noltce ex parte hearing the dey before the I 1114'12 Disciplinary
- l1i71-
MOTION FOR "nSTRgL OR CO;:TINAC
p, 11
of 71
To, lclfl1e9-fcc8-461a-8eOf-lea5\9b
From: zacbcoughlln
11-19-11 8,11am p. IJ of 11
Hean g in the iphone ca.'\e set for Il/J9 f l2 Trial (how convemently K"'Tnbly prejudlclat to deny Coughlm a
.2
nee t:ither in the Dlsciplmary ReaImg Of that iplKme RJC cao:;;e ). Witness the folloWlgn fraudulent
In WhICh Skau secured CoughlIn's attendance at an Intprcperly notIced heanng betot< Judge
:a (who was also the Judge on the summary evicfloo proceedmg!"Tnal~ that represent.'> such a serious
liabih y to the RJC and arguably should requIte Judge Sferrazza recwing himself. Speaktng o( fonner
WCS Deputy Peter Eastman. asid, from breaking an enlenng into Coughlin's rental from leff\hchols of
tone Masonry. and asSltlOg NIChols in unproperly metmg CoUhlin throUh "olenet 'self help"
\'RS 118A.ltS!) an the attached work Coughllll did for Nichol, ill exchange for the rental, reqUlred
lraudulcntly procurred summary mctton m RJC REv2012-000314 (another rea,on the RJC should
hearing cases with Coughlin a, a cnmmal defendant. but Peter Eastman claims to have fonnerly been
1J
11
Judge Sferrazza's court room deputy m mbal court and that" fnends In the court howie" inJic'.lte lhat Judge
12
3D
13
he an hIS wlfe receIved commumcatiosn from SBN Bat Counsel PatrIck King. Esq that Vlol.ted SCR 121
14
and w ich al", slandered Coughlm. glVCn Eastman's admISSion that Bar Counsel King told the Eastman's
15
that
16
NVB whIch IS patently untrue ... and furth<reviJence of the lengths to whIch Pat King WIll go to sbow hIS
"has It out" [or Coughlin or otherwise 'has a problem with" Coughhn Eastman also admits that
fl Judge Beesley had entered an Order. as "I ~1ay 7th, 2012. barrmg ''''ughl," lrom practlcmg m the
he is a good little atUlck dog for the nch and powerful m Northern 1'C\'~ McGcorgc Mafia
17
]8
inclu d, Richard G HIll, Esq included, etc., etc.) Bur. back to Skau's misconduct From' "Creighton C
19
Shu" <skauc@reno.gov>To: zachcoughlin@,hotmml,comCc:'JeanmeHome," -Home,J@reno.gop
2J
Dale' 1/09/2012 liAS AM Subject. Fwd FW' C""e Ko RCR2fJIl-063341 Dear /vrr. Coughlm, Please be
21
ad,i d that Judge Stemm authomed :;ervlce upon you by emaIL man Order Accordmgly.aulhomed
22
scrvic has already heen effected
23
Also, C,oughlm hereby states under 'iRS 5.1 045 penalty of peDury thal the !ollowmg exchange
occ
ed between Coughhn and SIll\'s 1.aura Peters ,m September 11th, cOl2 at 4:51 pm wherein SIlN',
Laura Peters, whom has and hIlS been by Kmg and Clark repealedly held out as the "Clark of Court for the
26
State ar of Nevada" and in chinge of matters r<iating to the filmg of documents (though Pat King seems to
27
man e to control every aspect of these proceedmgs. from dlreclIng around \').1)8 ChaItman 3usich, to
28
puttin Chair Echeverria where he needs him (tltey got a real routine gom) to directing Clerk of Court Peters
- 12171-
MOTION FOR MISTRIAL OR CO:--iU>lAU
To: lcJf21e9-fccS-461a-SeOf-lea559b
11-19-11
from: zachcoughltn
8:11am
to cff t persornl selVico afme Camp,lint on Coughlm on 9'25112 when Coughlin show<J up for ille
Hear
61711 Order and the 8113112 Pellnon Omghm tiled in 61426. which was served upon the SBN. bOth the
North and South verslon.~ on August 17th. ::OJ:: .me same date that Peters noticed Cooghlm In Writing of
the h
rcquired by me Court's 6-7:12 Order and SCR 111(7)-(8) and SCR I02(4)(d) incident to 60838's
'ng she calendared for Coughlin, admitting it was to be for the "sole purpose" of addresslOg the
convi tim in 60838. King also faIled Kltell the Court in his SCR III PetitIon that Coughlm corttplied with
SCR 11(2) m self reportmg the conVictIOn resuitmg m his supseru;,on m 6OB8 Anyway". here is what was
com
the S N. tiled that W\IS not served upon C(lughhn . (pughllO swears under penalty of perjury that the
.cated between C"ughhn and Peters on 9!l1112. contrary to ille file stamped AffIdaVlt of Peters in
1J
folio ing cornmunciatioru; were made between he and Peters (done lo a rush due to Bar CoOuru;el and Panel
11
Chair
12
rcion and t1autmg of SCR 105(2)(c)

"Coughlin I\ow If I dld get a Compiamt and I need to servc an AMwCl. can I
serve it Just by faxIng It to you?
Clerk Peters' Urn .. yeah you can.
15
Coughlm. I have read the rules. they seem to say you go by NRCP exo"!'t for
(See SCR 105(4)
Peters: .. you Can. but It has got to be stamped.
Coughlm' By who" The fihng office? The State Bar?

17
Pet<!'S By me, I am a Court Ckrk

Coughlin Will you stamp a faxed docurn em JfJ fax .t lo?
Peters. 1 can, but I need to know how I can get It back to you.
19
Coughlm I have a fax. its the me listed on the Bar's webSIte 949 667 1402"
20
21
22
Coughltn
what day IS It me3>1llcd from
If you
guys fiied a ComplalOt?
Peters (one the effect of certified mallmgs afthe ComplalOtsunder SCR 109)
Okay J go 20 Jays from when I get that green card back, I go 20 days rrom after
when I get that hule green card. so if you pICked It up, say last ThlllSday. then I
go 20 days from last Friday.
24
Coughlm: Its not 20days from the file stamped date on the Complamt or
somethmg?
2S
Peters: No.l go 20 days from that oertified receipt. I want you to recerve the
Corttplamt before the tune starts uckmg. rhat's the way 1 do It"
26
28
C..oughJm and if somebudy doosn1 pick up that letter, though, they'll Will send it
hack ilke after I.' days. and then what, you guys Will go 2() days from then? Or
1imagmc you guy'S might even push It '3 httle more. and ~y "no, lts 20 days
from when we maIled It"
- nm~lOTIO))
FOR MfSIRIAL OR COxTINA!:
p. 14 of 11
To: 7c3f17e9-fcci-461.-ieOf-lea559b
11-19-11
fro.: zachcoughltn
8,11..
Pet..:rs' 1 do It from the r~Cclpt of the certlfled copy, ~) if you received 1t

yesteruay it would he 20 Jay:) from today?
Coughhn, from my receipt of the certified copy as evinced by my stgna[ure on

the card?
-'
Peters.- ngbt, as soon as. you Sign it and that shows when yOU got it. that's when
the time starts I don~ ,t'lrtlng the count~ until I get the green card back WIth
your signature saymg you received It ~
Peters- Tom Suslch's only mvo}v.::ment IS scttmg the panel really .. once a
Complamt has bun tiled we have 20 day, or whenever unul we reCeIve the
.Answer and then once we receive the .-\nsw<r then we Set a PaneL. I have the
unclarmed Complamt I got It back September 10th, 2012 you baven't
techmcaUy rec<Ived teh C{)mptaint, even if you may hae receIved the first class
matl ven:;ion We sent
Coughlin are you sure that at some point somebcdy WIth the SB:\ Isn't going to
say "you know what, Zach. by now you have ConstructlV~ notic? of the
C.omplainL" and they will try to hold me to that?
Peters Nobdl' IS gOIng to do that
11
Coughlin Are ),ou sure? TypIcally we plaYlIl' prison rules in bar hearings.
Peters, ",obody IS gomg to do that I am !he one that controls that, and as far as
I know you dIdn't TecelVe the (:ompltant, because I have that certIfied marl
package nght here as ,t was returned to me . as !he Clerk of !he Court of the Bar
I am tellmg you that yeu dId not recieve this Com plaint, because It came back
to me unclaimed .. and so I am gomg to send it back out send It back to you,
and If you plOk thIS up and sign the green card, I wdl not attempt to do a NotIce
of Intent to Take ~I.ult before I ,;ent tillS Complamt back out 'llI certlfied
mati 109 agam, and 1 wi II <end th" back out and stamp It tomorrow and then
when you get It ill the mail and SIgn the grcen card, thai IS when the 20 days to
file
14
10
16
17
Perers trIP' up and sa)' SusIch sets the Panel, but then says the SBN sets the
Panel (which occurred here pretty mcuh given the SBN purl"rts to have mailed
at the Notice of Hearing and DeSIgnation ofWitnesse" and Summary of
Evidnece on IOf12il: (SCR !OS(2Xc) requires the Panel send those essential
filings, yet Kmg and Peters dId In this matter a fullS days before Susich's order
setMg the panel was even signed and stamped "
18
19
21)
21
23
2,
25
26
sub
Ec
pho
Ech
chle
the
atty Ice, aka Pat Kmg, there IS more ot thIS commg, guy. more about what you sa,d and what you
lnefBar Counsel Clark saId abcut Coughhn's nghl 10 "sue subpoeoas and Walev", 01 wItness or
ena fees and the manner of service, etc, etc ~me to come, boys. more to corne, ... And l"'hair
verna WIll want to ask Theresa abcut that purson caUmg th"",,,Is an 'attorney" when answermg the
e for ln' oftlc<-.. whIch has. name plate that sounds and looks more Ilke a venture captial fimL 'The
erda Group", ,so coughlin preservt'T and contmues to preserve hl~ objehon to having hlS case in
Of ense unne
'I' ell sh a d not
e {} call
enfi
the sub oemo; 'ven
ddt
fa
lil
0
sen t b .
ne 1and 01" shan be clerk of court e dJ the
a h
cto
t
27
23
- 14'71-
:-.lOTIQN FOR MISTRIAL OR CONTINAU
p, 15 of 11
3
4
8
9
com 1
WI
11-19-11
Ftom: z.chcoughlln
To: 7c3f27e9-fcc8-167a-8eOf-1e.\19b
. as well s
r ords re uest.<:, and or sub
, due'
'r"l
_( 3 41 which IS
l~h had ''&ftIDOO
co
vee
8:11.. p, 16 of 11
hn i.nto the
l' 's health ..
Further. tn light of the declaration made by the Sfl"l and Peters upon. upon which Coughlin
reas nably reIted, the established p'tt<m and praehce of lhe Sff.\ not ,1arttng the running of deadlines
pur;; t to the semce of item, under SCR 109 until the SBN gets back the Signed green certified mall sItp
mus be accord to the October 27th, 2012 certified mailing return receipt ,lip that, whlle, It IS SIgned by
Cou 1m, itis signed by CDUghlin's then housemate "Juliano" as 'receLved by", See, Pat Kmg."thats
credibihty... te. not sittin ' there wastmg the Heanng Paners ttme arguIng that the audlo transcnpts
Ie prOVIded you and that you had. copIed tor the Screerung Panel an: ~lfn::levant' or "not certlhed" or
less becuase there IS not an prohlbltably e:<penslve cenl1ted trnnscnpt 01 that Heanng to prOVIde
Xl" (and tlus after Pat King was caught Iymg about whether the Apnl :J(~)9 Order he sought to
uce of Jduge Linda Gardners (resulling Coughlin, frring from \l,oLS .whlch Chair Echeverria saw no
ISS" having WLS', ED Eleeno prov ide rtllIe'.Boo of the Order entered some two weeks after the trial
that, contrary (0 Echeverria. remL'(igrt Elcano did not "attend' but merely watch the tape of (and under
K 's analysis, despite paying $35 for the Second ludieta!'s tape of that Tnal, It sttll would not be a
fled copy" The fact that anyone lying about the tape could be cross exam I""d prOVIdes plenty of
fication", doe:m'L it?
11)
11
12
13
14
10
18
19
2J
21
22
"3
25
27
23
shoul
have
deficI
there
Aha, so cute how Pat Kmg, m the oote stamped copy of the "DiSCIplinary File" (which Coughlin
in no way be bIlled for given the deprivatIOn afhis SCR 105(2)(c) righls herein, nor should Couglm
pay for any of this Disciplinary Hearing, paniculary given all the naUce, semce, and process
cies attendant to Pat King's impem11SsIbie attemp'" to cheat CoughItn lmt of h,s due process and
e obtain 8 result King and the SAN do not deserve
So, its really cute how in the D;selp\nmry FIle at 02954 there is lha AffidaVit of Maihng from the
23rd f August 2012, wherein Laura Peters swears. under penalty of perjury thaI
Also, Pat Kmg bronght hIS dog to work and I<t It wander around the halls of the SBN the day 01 the
and he wore cargo pants along With a hornfic tie, then he s"untered up to Coughlin at a urinal and
ed over the "pretty good grub, huh, Zach/'~ Patty Icc wasn't feelin' :)0 chiWr a day or ~o later when
Co Itn was mterf(lgating hIm about the fraud Kmg comm Itted In the hate stamped copy of the
DisCI hoary file, espeCIally VIS a VIS the fact that cunously, all the SEN tihngs except for the two most key,
the C plaint and Fj"t Designation of Heanng Pa",,1 Members (would have been mce to have actually been
that in accord With the rules and the pohcles held out by the SB}; and Justiably relied upon as a
tory challenge would have detmitely been issued for both Stephen Kent, "' well a' Cha" Eehevema
er, nice a men they may be outside the impermissible conflIcts of inkrest they had wluch should have
preve d them from ever srttmg on this Panel So, where Coughlm now files and affidavit (to wh9lever
exten he did not so flle one or a declara\ton or venficalon preVIOusly, whIch is not clear) contesting the
Aug t 23rd, 2012 AflldaVll ofll.falllnghled by Poten;, whIch may be undone somewhat by the October
9th, 2 12 Aflidavtt by Peters that IS mcluded 10 the hie and ttlestamped but for which Coughlm was never
sent a opy or otherwsie served (and the bIg box copy of the :-;Olln of ]()19:12's certifcate of mailmg does
not in Icate that any such affidaVit wa, included therem, SQ, the Disclpl10ary Hearing contains a filmg that
IS file tamped, yet was not sent to Coughlin (and If It was sent 4) ChaIT Echeverria or Chairman SUSlch,
thaCs i$Conduct So King and Pet", and the SBN haH gotten all cute With thIS here hate stampe "copy of
the D clpllnary File" consolatIOn pnze for the SBc; and Pand defenestr.tmg Coughlm's nght under SCR
105(2 c) .. Peers therem ,wears she IS "employed as a paralegl for the SBX That U1 such cspactity Affidant is
Cuto an of Records for the Disciplllle Depattment of the State Bar ofKevada, -" Then Peters goes on to
swear that the "Complaint and hrst DeSIgnation <>fHearin Panel 11embers were ~ on the followmg by
plaey copy in an envelope which was then scald and postage tully prepatd (or .despostted in the US mati
at Rr 0 .. -" __ .Its odd because every oth<r cerufetd mail fihng m that file bate stamped and COPIed to
by the SBN a scant 6 days prior to the Heanng proudly dISplaY' the gr= certllied matling CllIU
\!re IS a dtsundlOn between the retum r~celpt requested" card stock card and the more squansh,
certifi mailing sqU!lTC slip With 8 tracking nurn ber (wluch do<s not invol,ed getttng a signaturdrom the
addre see. So when the SBn sent CougJin on 10, 12!l2 the :\ottce of He.nng (which SCR 109 requires be
111 the same marmer as Complaint (whIch entalis and adoption of the rules Peters set out to Coughlm.
- 15/71~10TIOl\
FOR MISTRIAL OR CQ\]J>lAli
To: lcJf21e9-fcc8-161a-8eOf-lea559b
11-19-12
Fro.: zachcouqhlin
8:21ao
incl . g in their September 2lst, 2012 conversation. so. somehow, in that baw 3taped fil for page02954
is tha Affidavit of Mailing by Pett-is on 8r23fl2 wht!rcin she swear.; th31 th~ ~Comp!:dmt and Frrst
Desi ation of Hearin Panelldem1><rs wet< .erwd on the following by placy a copy ill an envetope whIch
en seald and postage fully prepajd for" .which IS clearly not true and or in accord with Peters
enL, to and representatlosn and agreements with Coughlm on September 11th. 2012 at 4:41pm
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"LAI
Affi
capac
appro
take
25th
A PETERS. under penalty of perjury. bemg first duly swom, deposes and says as follows: That
t is employed as a paralegal for the dJsciphne department of the State Bar of I'evada and in such
y is the cUStodlan of records for the State Bar of2\evacta; That on Septernb..-r 11,2012, at
alely 4:45 pm, Zachary Coughlin called Affiant to confrrrn Ihat a hearmg was still scheduled to
ace on Septem1><r 25.2012 Affiant e"Plamed that the heamg would not take place on September
dthat date had heen scheduled pnar to lhe liling of a formal Complamt Mr. Coughlin reacted as Ifhe
had" knowledge ot a Complatnt Atltanllhen explamed !haL tn tact, a copy ot the ('''''plalO!, sent VI3
eeruh m..1on August 23, 2012, trom the Reno olliee of the State Bar, had been returned and marked
"tmcl imed". Affiant further explained that since service bad not been affected. a new certIfied copy would
go 0 the next day. Affiant requested that when 'v1r. Cooghlm received saId copy. he should return the
paste attached to the mailing and his twenty (20) day period in which to answer the Complaint would
start
mg at that polO!' However, m spealmg to AssiSlant Bar Counsel Patrick King, it was determined
that . onal servIce should 1>< affected upon'v1r. Coughlin Reno Carson messenger servIce was engaged to
attcrn I personal scmee despite 1\>\'- C.oughlin not pr.oVldmg the State Rar WIth. pnysical addrc<s On
Septe her 25. 2012. Mr Coughlin alTIved at the Reno office of the State Bar allegedly cxpeetmg a hearing
to tak place. At that time. 'v1r. Coughlin was agam told. both by Affiant and ASSIsLant Bar Counsel Patnck
Kmg, at no heanng would he taking place that day and that an answer to the State Bars Complamt had not
been <Ived. Alliant personally served Mr. Coughlin With a copy of the Complaint on hIS V~lt to the Bar
oHice on Septemher 25th as WItnessed by Paula CamphelL an employee ot the Stale Uar Mr Coughlin
InsISt that the hearIng which had heen previously scheduled lor that day should be taking place hecause he
neede to 1>< removed from temporary suspensIon. Mr. CoughlIn has also been m'Mlctcd by i\ssislanl Bar
Co
1Patrick King that he camot filo pleadings with the State Bar vIa e-matl, which he continues to
altern l. The Molion to DiSln ISS, which Mr Coughlin now insists should he granted lIS it has gone
cd by the State Bar, was never presented 10 Affiant for filing but was rather emaIled prior to
tIs conversatIon with \1r Cougblm on September 11 th when \1r C:oughlln under no uncertam terms
fiant that he had not yet received the Complaint FFRTllER YOUR AFFIANT SA YETH NOT
thIS 91h day ofOctober. 2012
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SCR 03 7. Hearing panel memhers shall nol particJPru. In any proceedIng In which a judge similarly
situa d would he required to abstain. Any mem ber whos< tenn expires while the membds
pane is considering a complaint shall remain a member wltil its disposition.
8.
' chairs of the hearing pands and screening panels shall deliver reprimands and sign
all
docu enls on behalf of the panel to carry out the pro\'isions of Rules 102(6), 102(7), and
103( ).
9. A rievance received against a member of a disciplinary board and pro""ssed in

aeco dance
with ule I05( I) shall be referred to the other di,ciplinary board.
26
]7
23
So, the policy armounced by SBN PetersAs to that "receIved by' sIgnature on October 27th. 2012
Jult.no", under the established polict., of the Sfl:>l as set forth. by the SflN and Clerk of Court
.
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10
Co rnw e
tab!" ed
s
d i si cid t05 rv \'lac
iI' do t
t . cort eSB:\'
- 16mMOTION FOR MISTRIAL OR COXll:-l:\li
p. 17 of 71
To: 7cJf17e9-fccB-467a-8eOf-7ea559b
from: ,acbeough1ln
11-19-11
8:11am
or
') two
m ts
e c rtifle a' re
b
eei t e
ct'rti
m
vic
n
i
. N tic
nt
ou be nt via < 'lied mail (and Pete... indkated .n such certified mailings are sent in duplicate
...t cia.. mail as well (though, sieangely, the 10/9112 Notice or Intent to Take Def.u1t'. certilicate
iliug indk.te. th.t it was sent via only one method. certlr d mail (ie, not.lso by lirst cia..
..
mal and, curiosly, despite every other SBN liling in the bate stamped Discipin.ry File in SBN v,
Cou hlin having the certified mail .Iip inelnded therein, the .'/OITD rail. to (and this is likely due to
Pat '''% reali,ing (and SCR 109 requires that th. Notic. or Hearing and DoWSoE of
ovid nee,Conghlin could probably pull. Pat King and rer..c to aelmowedge that the 00" Pat King
he a the SBN had a problem in that upon doing a USPS Track and Conlirmlf rece.ved from the
cc'
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9
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R.\1 were 'tcertified" or Otherwlse appropriate far admltting mto eVidence (as to whether they are certifted.
that 'pends who IS dOIng to 'defmmg" of what IS e<rtifiod, but.t also regs the question, why would the
SB be putting to a Screening Panel audrotrarncript< that are not certified? Abo, Ihe bil from the 2127il2
trial n \ I TR 26800 about Whl're Coughlm \ells Judge Nash Holmes 'that's quite a sound byte, Your
Hon r" in response to her stating "[ don't care aboot bnu.,>y_ I don't care about corrupt.on, [ don1 care
abo retahation.. aliI care about is the Boulevard Stop' (need to hsten really closmg to that Trial, or
som how get the RMC and Longan! (whose Sunshlen Reports should have never beon allowed 10 doth.s
He ng, no dISrespect to Ms HummeL Ihough, but a conlhet clearly exlSts, partlculary wher< Coughlm's
ap, I in the convlct!l)n resultmg m hlS current suspension was denied due to the fatlur ofLongonl and the
kM to prepare the transcript evcn though Kevado law required they do so upon Coughhn filign Ius NOllee
of peallllstant to h'RS 189,0 I(l-,(J50 .. that statute is IlOt adviso!) ,1$ is the law_ and DIO Judge Elhol's
men lOrung a clVil statute's ~1.ance on the prepareatlon of appeals. anu down payments thereto does not
eha e that It'" fraud by Longoni and the RMC So, if something IS m.ssing from the R.\JCs $35 audio
ipt that CoughlUl was only able to obtam after draft.ng hIS own mother, Milly Barker, .nto the
pUIS t (the RMC made up excuse aller excuse [or refusmg to fIll Coughiln:s audio transcript request and
cvn bad ils Marhal. start manufactunng gnevances agaInSt Couglin wlth the R.\!C (sec their ridiculous
"gre ance' or letters to the RMC and their ~ven mor~ ndlculous wlnCJdcnt Reports" (even for th~ lumted
?
sed 01 demon.strating whal Kmg and Peters gave to CoughlIn purporting them to u., "leftovers" from
the, creerung Panel on (lc~lber 10th, 2{)lc that RMC Judge WIlham Gardner obnoxIOUSly claImed to know
so ch about to CAlughlm In Court on 4' I0; 12, shonly stler Judge Gardner mmounced that he and
Me eorge Mafia, class of 2(J()6 member Reno Clly Attorney Hallett-Steven's and C'Alughlin's McGeorge
Ma SOL court appointed counsel Keith Loomis, Esq, had a secret meetrng that mornlOg prior to tnallO
som backroom or the RMC where they all had a great time, uh. practlclng therr Im"'_ And what a forced
lifel ss perfonnance it ultimately was when that troupe presented to mdig<nt crimmal defendant Coughlin
and tempted to nav.gate their way through the mutky waters ofviolatmg l\RS 178405 (in lighl of the
2i27 12 Order for Competency Evaluauon in ROCIl 12-065630 thanh. RMC Judges were "ell aware of,
t to thell "at least one meeting" when they bralnstonned how to get Coughhn and the
umcations between Judge :-lash Holmes and the W""hoc Counlv Public Defender and or Birav
Esq" counsel of record [or Coughlin In that ror20 12-065630, ~'hom can \ell you all about h~w
Young violated !>.'RS 178405 m filmg at 2_55pm a fugItive document in seeking to oppose
1m's MotlOn to Appear as ('.o-Counsel, desp.te the OR
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Fir,1 deSPIte Peters Affidavit of Ortoo.r 9th. lOll (here is no proof of servic of that Peters AffidaVIt on
hn, and It it was served on the Panel or Chair, unbeknownst to C.ouglhin, that is an unpennlsSlble ex
p
cammunicahon) being filestamped an mclu<led in the materials that were only.f1nally provide to
CllU lin on Kovember 8th, 20 I ]-()8'55 54
('.0
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atte
affi
Lal
hc c
or 0
to C
,Coughhn one hundred percent ca\egoncally demes Pat King's un:;upported .lIegatlOn "fCoughlin
pting to dodge seIT ice One, the hearsay of Johlmo Lazetich is in the t"nn llf a bilL not a sworn
Vlt. and further, 11 clearly contams mere conjecture on Lazetlch's part J.";..uther, Coughlin setn
Ich and his father',> company Rend Carson ?vfessenger ServIce an emaIl and a VOlee mall askmg what
uld do for them, along with em ails and a fax to the SB:-l offering Ul meet a process serve! somewhere
erwist assist in havmg the Complaint appropnately stJVed. however, King and the SBN chose to lied
in mstead, and go bal:k on what Peters defimttvely declared durnrg the Septemher 1L 2012
- IT71-
MOTION FOR MISTRIAl, OR CO>lTINAlJ
p,
18 of 71
To: lc3f11e9-fcc8-l61.-8eOf-le.119b
2
3
6
7
10
11
2,4
15
16
f,om: zachcoughlln
11-19-11
1:11...
con nation on the telphon~ WIth Coughhn that her uns~rved, yet file stam~ October 9th. 2012
Affi avit """"rt> It is inl<resting that King and Pet..'fS "'Y nethIng about faxmg motions .. consdicring that
Pete s clearly gave Conghlm pennlSSlon to fax file motions (and In accord Wtth other such forms of
olec onie fihng, Coughlm's fa.~ tiled motions, and arguably email filed ~!olions (mcludlng the skydnve
11m: 'Iles a!ached thereto should be mede a part of the record and the lile and the Panel should be provided
Wtth !hem and remmded that they have a duty to review them ThiS IS true, espeCially tor anytlung pnor to
the, eptemher 25th, 2012 emall by Kmg I'UIportmg to retlis< email fthng (and arguahly, at that pOint, it
was 00 late for King to change the rules of procedure set forth by Laura Peters and or Susich's or the
Pan's failure to oppose such filings by Coughlin. REgardless, the file as Klllg haJ tt bate stamped and
prov ded to Coughlm at such a very late Slage (Kovember SIh, 201 Zupon Ihe fl!$1 .Itemptto deliver it fTOm
Si
ThlCUl11enl Processing ('.oughlin received it an SIgned for it, and thereby his SCR 105(2Xe) right to
ct "up to 3 days prior to the hearing" w"" VIolated. espectally COnsIderIng Coughlin was continually
ref ed the opportunity to Inspect such recorda as the SB:'-I at every stage smee Pat King's phony offers to
ano such in March :::012. .Further, the bote stamped Fonnal Hearing File SBN v Zachary B Coughlin i.
mis ng a number of cdldvd exlubits that Coughlin submitted for filtng. Pat King admits to just chooslllg to
rem ve them from the fIle and or fail to copy the COI.nmlttcc on them. whIle at the same tlme: maintaming
he a d the SBN and Peters have demonstrated Fldehty In their >tated practlce of provldmg everythmg
Co
In tiles to the Panel. AddlUonaly, Peters Atltdam lS qUtte traudulent One clearly a MotIon to
Dis iss dated September l71h, 2012thot Coughlm has. fax confirma~on of and also email to Bar Counsel
and ustch was not "created prtor
The Monon to DismISS lax hied on September 17th, 201 I should be tile stamped an Included In the
file. Why else would Laura Peters Alhdantnot Indtcato sometmg contrary to Congblttts sworn assemon
that was given penntssion to fax file by the SBN? Regardless, Coughlm's hadn deltvered :vlotion to
DI tSS ofCctoher 15th, 2(112 (or It may have been (\."lober I6th, 2012, gl>en Coughlin mMed hts self
imp' sed deadhne of dvhvenng to the SBN a Molion to DismiSS by midnight of some night, and sent Clerk
PEt and ematlthc next day indlcatmg the proof of scmee should be adjusted in that reg",d Further the
Cha assessment that C()ughh nfaIled to file a "vt'ofJed response or answer" or that such "may not contam
an ing stated upon mfromatton and belief" tS contesl<d and Just flat out wrong Cooghlm's signature on
pag 61162 on thc Motion for ORder to Show Cau.<e may be a bit htgh ahove the signature hnc (though
the i ! IS Op<rdtiYe in ekctronlc filmg, which the SBN gal'e Coughlin p"rm"",ion to do.
Judge IAnda Gardner IS a lIfelong prosecutor turned Judge, hke her brother RMC Judge William
17
r, like his fellow 1<.\1C Judge whom he admitted passed tbe April 2009 Order sanctIoning Coughlin
18
in C.oughhn's fiong from 1\LS m 60302 (and a ~4anJamus filed against Linda Gamder by
19
hn m 54844, and a gnevance filed by both Judge Lmda Gardner and Judge DOTOtlly :'-lash Holm"
(also lIfelong prosecutor turned Judge lIke Judge Kenneth Howard too) (on behalf of all afthe RMC
21
Judge) against Cmlghiin in both NGlJ-04.14 and NG IJ-IJ435. WhlCh along with the Richard G, Hill, Esq.
griev ce (Rich was Just fulfilling hts RPC 8 3 duty. y'all . don't hate) mNG 12-0::04, SBN Bar Counsel of
23
the N rth Pal King whipped up in a SB'-: v Coughlm Complaint, that he purports tohav. <erved under SCR
109 v a certified Inailin of 8:23'12 that was returned to the SBl\, and t,l which SBN Clerk of Court Laura
25
Pet
mdIcated to Coughlm would absolutely. under no CIrcumstances, ever b~ used as a return ot or proof
26
of so Ice of the Complamt agamst Coughlm given the fact that she herself receIved It as returned to send on
27
9/101 2, and especially wher< she told Coughlin he coudl rely upon h<r then ind,cahon that she wc>u!d, in
28
accor with the SBN's pattern and pracnce and estabhshed pollCtes, resend It once agam the following day
- 18.. 71-
MOTION FOR MIS TR L:\L OR CO;>:,J1NA! T
p, 19 of
To: 7clf11e9-fccS-461a-SeOf-lea559b
V13
ce tified mail, and only upon thatmailmg not being met
S
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c,
""
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Wlth it
8:21..
signed centfed mail signature of
1m's would the SBN send out a :\'otlCe: ollntent tc Take Default. sewed m the same manner as that
:;
3
111912
from: chcough!!n
v:hl
w"-< attempltd Wlth the C',omplamr .tself Of course, Pat Kmg attempted to cheat the s)'Stem by
.11 those SBNCoughlin agreement, into hes. hocause .f there is one thing Pat King will not stand for
petition or a leve! playing f,dd Kmg recoils from such ilk' a vamp". from" coming sunrise
SCR Rule 110. Subpoena power, productlOn of documents, Wltncsscs, and prclnal
proceedmgs.
1 Issuance of ,ubpomas by hearing panels and bar counsel. Bar counsel and a member
of
a hearing panel who IS also a state bar member, m matters under mv~stlgatlon by clther,
may
administor oaths anJ affJrmanons and issue amI compel by subpoena the attendance of
WItnesses
and the production of pertinent boob. papers, and documents. The attorney may also
compel by suhpo"". the attendance of wltnesses and the rroduclton of pert.nent books,
papers,
and other documents bel are a heanng panel Subpoena and \ntne&s lees and mlleage
shall be the =c " m a ~"\n'" ~=.
2 COnfIdentiality stated on suopoena Subjectto the proVlSlms of Rule 121. subpoenas
shall clearly indIcate on their face that tht'y are Issued in connection With a confidential
investigation
under tIl",e rules and tmt it lS regarded as contempt c)\' the supreme court or
grounds for disolplme under these rules for a person subpoenaed to m any way breach
iIle c{mfJdentiahtv
of the invcstigall~n. It shall not be regarded as a breach of confidentiality for a
person subpoenaed to consult w,th counsd or to answer questions asked by bar counsel
or the
attorney to deteon me the facts known by the wltnesf';,
3 Attachment of person lOr lilJiure to obey subpoena or produce documents Whenever
;:lny person subpoenaed to ap~ar and glVl~ testnnony or 10 produce books, papern, or
other
Jccuments as requlfed by subpoena. or requested to pruvide documents pursuant to
Rule
78 S(1)(b), rduses to appear or toshfy before a hearlng panel, or to answer any pertinent
or
proper questlons. or to provide the requested documents, that person shall be deemed m
contempt
of the disciplinary board, and the eh.,r of the d,sc.plmary board shall report the fact to.
district judge of the county m which the hearing is being held or the investigation
conducted,
The diStrict court shall promptly lssue an attachment m the form usual m the court,
dJrecled to
the shenff of the county, com manding the sherIf[ [0 attach such person and bnng such
person
forthwith before the coun On the relurn of the ,tlnchment and the production of the
person
atteched, the dlStnct court shall have JurlSd.ctlon of the matter; and the person charged
may
purge himself {" herself of the conK'll1pt in the same way, and the same proceeding:;
shall be
- 19/71-
MOTION FOR MISTRIAL OR COYTINAC
p,
20 of 12
ia: lc3!11e9-!cc8-161a-8eD!-1.aI19b
,too: zacncQughltn
had, and the same penalties may be Imposed. and the same puni~hment mtlicted a..'{ in
the case
of a wltness subpoenaed to appear and gJve evidence on the trial of a civil cause before
a dlStrict
court of the State ot Ntvada
4. Contest at subpoena A contest of a subpoena shat! be heard and dctcnmned by the
chatr
of the appropriate dJselplmary board.
5. Restnction on JlSCOvery Di;ro,.ery by the atlOrney. other thaa under Rule 105(2)(c).
not permrtted prior to hearing, except by the order of tht chair for good cause upon
1
2
3
"
mOllon under
Rule 103(5) or Rule 103(6).
6 Prehearing conferlmcc At the dlscn~tlOn of the chaIr, a prehearing conference may he
ordered for the purpose of obtaimng admisSIOns or otherwISe narroVling the issues
presented
by the plead!ng:;. The conference may he hdd bef(lte the chaIr or the cha~'s desIgnee
7. Depos!tIon In heu of appearance. WIth the approval of the chatr. testunony may be
taken
by deposlhon or by commlS3!On If the witness IS not subject 10 subposna or IS unable to
attend
or testIlY at the hearing because of age. illness. or other mfmmlly.
% Conhdenttahty of rl<pOSltion Depo.SltlonS lire sublect to the protectIVe requirements
18
"
12
and
conlidentIalily prov Ided In Rule 121.
CREDIT(S)
Added, ell Feb 15.1979. As amended, eff. lan 2, 1996; ~fur 1,2007
LIBRARY REFERENCES
Attorney and Chent 47 I.
WeslJaw Top!c No 45
C J S Attorney and Chent 73, 89.
13
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15
16
17
18
19
-Judg Beesley's testimony on Il!14;]2 IS curious in hght of the sohd thumbs up he gave the no remporary
'Ion getling Stephen R Harr",.
2J
2:
In
57507. and the tact that Judge Beesley was hard pressed to proVIde
e detatl in support or hIS strong contentions that Coughlin's work and filings before hem
In the 1'-<'VB
Coughlin not competent to practIce there. Coughlin IS a :\atlooal !\.lent l- mali,t who was ranked
22
2:5
10th . his class at a top 80 law school. has been a lIcensed Patent Attorney. and passed the Jul12001 State
24
Bar 0
~~
Boyd chool of Law In August 200 l would. even rake thatexammatton, meanmg he passed It after lus
26
seeon year of law sehooL Further. tile attached lj~ng:; by Coughlm before Judge Beesley In the "VB
X1
clear! demonshaw a skIllleve! beyond the baseline cQmpetency required 10 practlce therein, somethmg all
23
them e ImpressIve g!V(:n they represent the very fIrst two or three bankruptcy cases Coughlm ever tock on
~evada's
Bar Exammatlon a year before these matnculatIng as full tlme $tud(:nts with rum to l.T\1.Vs
- 20rnwmON FOR MISTRIAL OR Co.,\TIK,W
10: 7c3f17e9-fccB-!67a-B.Of-7.a559b
11-19-11
From: zachcooqhlln
8:11..
It is 11 emIly a textbook example of a solo attorney ::>taitmg out and not takmg on too many cases, suffiCIent
2
to be ble to extncate himself and hL'i cltent's from
fO!,
eVl!n the
mru,'t unexpected calamIties and Clfcumst.'1J1Ces
upon them by the mlsconduct of otbers (mcludmg haVLng Judge Reelse)", McGeorge SOL 1977
ate RMC Judge Na.sh Holmes (who was sued for wlfetappmg attorney Milftin Weiner or Crowley,
Esq.), whom unlawfuny and, apporently m conjunctIon wlth her form., cowork~ at lhe WCDA om"" (and
NND Panel Member xlary Kendaras was intimately mvolved In tbe process. In fact WCSO Deputy
7
Made me refused to return the ""'BIt phone and sd card to CoughlIn eVen amr Judge :issh Holmes' Order
the WCSO do so . with Madehne IndJcatmg ,he needed to get Mary Kandaras' permIssion rust
cornpl)"ng Wlth Judge ~ash Holmes order (limny, didn't see Madelme geroog hemmed up WIth an
1J
mcarceration and summary criminal contempt charge there ) shortly am, (and Pam Wumore, Esq.
11
ere and heard all of thl~ though her partnership or sharing of an office with McGeorge SOL ]985
12
pringgate, Esq (opposing COflSel in 54844 April 2009 Judge Linda Gardner sanctJ(J11 order getting
13
lin fired in 60302 from InS) may prevent too clear a recounung Then WCSO lJeputy Hodge got
14
in a, ub, story. about whether the mIcro sdcard was mcluded in the materials booked and then to the
IS
mater als released'" Coughhn's tnend, whom pIck, them up on 2128:12 (mterestlngly. C'.oughlm's smart
phon and micro sd card were booked into Coughlm's propeny upon tntake at tbe jad .. but a full day later the
l7
R..'v!C larshals returned (and Marshal Scott Coppa seemed to communicate and mten! to do so to WCSO
13
Dep" . Cheung when he pulled him asIde mto a back room in the saliy bay dunng the conclusion of the
19
RMC larshals transporting Coughhn to the WCDC ,,2!27i12 .Then Marshals Coppa and Marshal
20
Town end retaliated against Coughhn's valid complaInts thereto (and other cnticisms of the exton! to whih
21
C IS a nlOnument to a lack of transparency or separa~on between the court's Departments and the
22
tiling office) by tiling a nonsenSlCaJ crillc"m of Coughlm's clothm ohmces when vISiting. mani
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tlmg office counter to check on a traffic cItatIOn with the ~Il" .wlnch Klllg promptly mentioned to
1m m a dehberately misleadmg way, vIa King's 3/23!l2 .n1311 to Coughlin (King plays little g!lJl1es
< momk., "Clerk 01 Court" ...King, Manl)71 Tognoru IS not a "Cieri: of Court" .. neither IS Cassandra
n.. and neither King nor Second Judicial District Clerk of Court Joey Orduna that hke1y wound up in
27
Judge Flanagan lSSutng a rash rulmg on 3i3(Ji12 dlSposmg of Cough1m's appeal
28
appea of the summary conVIction from Coughlm's former hom
In
- 2]171 -
MOTION FOR MISTRIAl, OR COXTINAC
the RIchard G. Htll, E'q
p, 11 of 71
To; lclf11eS-fcc8-461.-8eOf-le.559b
Froo; z.chcoughlln
IHH1
8:11am
(so as for cooking up a Panel.. Susich and King gol Pand ChatT John Echeverria, whom had 10 admil he and
;,
WLS' Paul Elcano were boyhood ohwns and that both went to Stanford linty""ity m J966 (add to that the
tact
sums, along with Elcano in 603(2) and Reno CIty Attomey Pamela Roberts, Esq (whose prosecutonal
mIse duct In pulling on petjured testlOmny by \Val-Mart', Thoma, Frontino and the Reno Sparks Indian
s Kameron Crawford (asserting thal. custodial arrest and search meld'nt th",eto was pennissible,
1\1<3 171.1255 on some assertion that Coughlin faded to prOVIde 1-.is drivers license, .. even where
p, 11 of 12
s herself was given the "!ntel1ogatLon Room" VIde", by \Val-Mart showing Coughlin giVIng hIS
went to Hashng' Law School along WIth \\ry,S's Caryn StemlJCht (whom Coughltn IS
hcen.<>e to Otlker Crawtord, whereupon Crawford coptes down the mformatlon therefrom onto the
to
t Echevema
Ane' Report and Probahle C",use sheet and radios into his dISpatch \.{\ughlin's Nevada dnver'. been.e
r.. add to that the fact thaI CoughJm's detention intake property sheet Itsts that he was booked into jail
11
12
with 's Nevada dnvers license and Officer Crawford and Thomas FrontInG. hes are clearly exp<Ased,
13
whic Pamela Robert's PurPosefully allowed them to lell in her retahatory rush to get a conviction shortly
iii-
after
c back out of a written agreement to a cantLnuance, ,and where Judge Howard specifically based his
1=-
re!u
I to grant Coughlm a conunuance upon hI') mistaken.'lncorrect bt!hefthat It was C'...oughhn whom was
16
respo SIble for the 1l!14!J " Trial date heing conttnued Judge Howard had to admit, later. on the record,
17
that h was mistaken In that regard (so mstead of declanng a mistna~ Judge Howard Just admtncd Ius
18
mista e and proceeded WIth puttIng Coughlm in Jail for 3 days for NRS 22,030 "summary contempt" despite
)9
Judge Howard havmg tailed tu gram Coughlin's motion for counsel. even thoogh the l\evBda Courts of
2G
Linn d Jurtsdictlon Bench Book points oul that Atg",.mg<r is mandatory authonly, and therefore.
21
appat ted counselts Tequlfed where even the posslbt!ity 01 )"\ ume e.XIts In 1us pre-ttla\ Order denytng
22
itn. SL'(th Amendment Right, Howard ruled thai Coughlin was not entItled to counsel even where he
23
had e ablished he was inmgent (and eVIcted just days pnorthercto) b<causc ptl tIme JS not the typical
2,
sente co" for first otTense shophfting of a de mmimis amount offood However, il is important to note that
2"
Judge Howard did not nde out the posslbrirry of )011 time, and there tore AtgneISmger applies, Further, Judge
2D
How d, who had been occupying the R.\1C Bench for 14 years at thaI pom\, announced during the rendItion
2 -;
of hiS OnVICtion order that, not only was the summ ary contem pt com:lctlOn not appealable (and. of course
23
no sla would be availalbe .the RMC ha\ing a perogauve toexpedlle matters befort It an all (so much so
- 22171 ~10I!Ql\
FOR MISIRIAI. OR CON'aNAl:
l
r
To: 7c3p7e9-fcc8-467a-SeOf-7e.559b
11-19-12
Frea: zacncouqhl1a
8:21..
e Howard kcpt a supPOsodly finanCIally strapped City ofRC'Tlo Staff ofRMC ~larshals and RMC
that J
Court Staff in court on overtime pay until 9 00 pm at night in rus mad rush to conclude the petty larceny
tnal, rst oltense, ot a de minimIS amount ofjood, from a megaconglomerate COrp(V3tlon. where the arrest
was ade In violation ofNRS 171.1255, bytrilYJl pobce, on land that pobce force's employas (the Reno
<;
Spar' Indian Colony) ronl to Wal-\1art. Judge Howard refused Coughlin (then a hcenso:d atlorney whose
prope y ngh~ his law license, lUlder the Foun<enth Amendment. would nec=arily be imperiled upon an
SCR I 1(6) 'senous ofiense" convictIOn (>l<ahng a grape would mvoked that rule accordmg to Pat
King. though Stephen R Hams steaJu~ S740_000 from hiS diems and u.,mg it on hookers and designer
products dld not, nor did It re5ult m a temporary suspenslOn either. and It didn't pn:,,-ent Judge
10
Beesl y Irom Singing the pratses of Stephen R Harris, Esq
1\
phon
\2
10
57507 even where an Improperly nouced
10 testJOny by Judge Beesley at Coughlin's DiscipIlmary Heanng saw Judge Boesely (who had to
at he had a longtime long partnership relationship with someone Coughlin IS smog. Washoe Legal
12.
Sem e's Karen Saba, Esq , whom admitted to Paul Eleano that she could never, and would never work with
1,1
Cary Sternlicht, Esq., finding her personality so odio"" and detestable though Ms. Saba had no issues
15
e.'<pee 109 Coughlin to cheertiIlly bare the brunt of such while he worked as a domestic VIolence attorney at
16
W1.S. Also Judge fleesley IS. close friend of Paul Eleano's, attending a very mtlmate West Fourth Street
11
Btstr invite only WLS party m 2008 at Eleano's Invitation Upon Coughhn cross exammg Judge Beesley as
1B
to jus what he was baSIng Ius sudden (and never boofore had Judge Beesley actually made and nIling or
19
oth
20
NVB. .so it was a zero to trash Coughlin as a DISCiplinary Hearing approach by the measured, ImpaniaJ
21
Junst eesley, who graduate from McGeorge SOL 10 1979, nght between two other WitnesseS al Coughlm's
22
I lil4 12 DISCiplinary lIe.nng cook-off thrown by Chair Echeverna and Pat Kmg (whom wore cargo pant;
23
to wo k that day, whereupon he asked lhe Panel to disbar Coughlm based upon a petty larcony convictIOn of
L4
a can y bar, a criminal trespass convction that only saw a SCR 111(4) P'lltlon (ie, King had to admit it did
25
not
26
27
~3
IS< VOICed any consternatIon whatsoever to Coughlm about hIS work respresenting client's before the
lilY as a "senous offense" despite hiS tryLng to fmd leverage by threatelng to fde an SCI< 111(6)
for
) even where opposing counsel in this summary eviction from Coughlin's fonner home law office
Iymg an onlawt\l! rent distraInt under:lR.~ 11 SA 520 to exculpatory VideOS and matenals that would
demo strate Coughlin's innosence and tht fact that on occs,<;ions previous to the 9i9/12 arrest, mcludmg on
- 23171 -
MOTION FOR MISTRI:\L OR CO,\TINAU
p. 14 of 71
To, lcl,f11e9-fcc8-461.-8eOHe.559b
July
From, "thcoughlln
11-19-12
8,21..
,2011, West 7th St Wal-Mart Assistant Store Manager John Ellis and 1111"'< yet 10 he indentified AP
A&,a ate specir.caly told Coughlin that they would retaliate against him Vta an abuse of process (of course
Judge Howard ruled that, even .1 they dJd. that was not rekvant) (supplemen.ed to Kmg" DesIgnatIon 01
Witn ses 4 days hefore the lleanng of 11!14i12, along WIth Ju?se Beesley, de,pJte ne.ther having anything
';
to tes fy to that Pat King d.d not know about for over six montha .. .its jU,t tha~ Pat King got real worried
e fact that he violated SCR 121 by commumcaung to Coughlin's then client and or his WIfe, Peter
"
7
East
prohi Ihng Coughlin from practicing m the Nevada Bankruptcy Court for the District of Nevada (which.s
absal tell' not true. and even If Judge Beesley had actually wanted to at that Ume . he would not have the
and Pam Eastman that Judge Beesley (McGeorge SOL. class of 1979) had Issued an order
1)
RUthO 'tl' to ... but there IS plenty of <VIdence tbat Judge Beesley had no such mtentian towards any such
11
Order at the time of the May 7th, 20 12 commumcation by Peter Eastrn an to Coughltn that revealed that Bar
12
Co
13
"susp ded from practiCIng in the Bankruptcy Court" m light of Judge Beesley ent,rmg an Order so
14
prove hng Coughlin from dOIng so. King, dunng a meeting with C.oughlm and King's boss, Ouef Bar
15
Coun ,.1 D3Yld (;Iark on ,4ugust 17th, 2012 (a three hour meetmg) grew llus!ered upcn C.vughlm querymg
16
hIm a lus qUl7,ZlCal stated intent to have Coughhn disbarred whence ('.ough"n asked Kmg JLL't what sins
1,
d such a mollvc ... amongst the tirst two things K.ng mentioned to Coughlin and Clark was the fact
18
NVIl Judge Beesley had entered an Order prohibmng Coughlin from practleing in Bankruptoy
el Patnck O. KIng bas told the Ea5lman's that their then attorney, Zaehary B. Coughlin. Esq , had 1le<n
.Tht. was 'news" to Coughltn, whom bad never been served any such Order, and bad never heard
19
Co
2U
any s ch thing besides from his former chents (the Eastman's, whom were extremely late in making a
21
r at payment' to Coughlm m exchange tor hIS hard work and respresentatlon orPetef
22
n) .Shortly atief Coughlm was told of Bar Counsel's v.olatton of SCR 121 Incident to Judge
Beesl y (~lcGeofge School of Law, ciass of 1979) preSldmg ovef the Cadle CompanY". Robert Keller
24
adv. ary proceedig in N\'B (l 0-05104) Coughlin filed a MauDn For Conlinuance wherein he attached
2S
mater als revealtng that Judge Beeskys ~1cGeorge School of Law classmate. Reno Municipal Court Judge
Dorot y Nash Hahnes (McGeorge School "fLaw 1977) had violated K."dalaw in purportmg to rule that
27
NRS 2.010 was "the mlsdemeanor of cnmmal contempt" (actually, cnmmal contempt ill Nevada LS fOlmd at
~4'71
MOTION FOR MISTRIAl. OR CO>lTINAI.J
p, 25 of 12
To: 7cJ!11e9-fcc8-467,-8eOf-7e.159b
From: !acbcoughl!.
11-19-11
8:11a.
NRS 99.340 "but !hat statute doesns't specifically allow [or, "summary' findmg of guilt, so, imk"rid, Judge
Nash olmes too !he bJts she hleed out of Ie then renamed It }.l{S 22,010
3
NRS 12,010 Acc' or omissIOns constitutmg cQnt<mpts, The following acts or omiSSIOns shall be
deemed cont<mptl.,
L Disorderly, comemptuoll' or insolent hd,avlOr toward the Judge wh,le!he Judge IS holding court,
or \.-'T1g<lgcd in joolCial duti~ ar chambers, or toward masters or arbItrators while sitting on B
reference or arbitration, or other judicIal proceeding
2 A breach of the peace, OOt:,1erous conduct or Violent dlsturbanc:e In the presence of the court, or
in iL<; immcruate victntty. wnding to lntenupt the dthl course of the tnsl or other judicial
proceeding
.1 Disobedience or resistance to any lawful wn~ order, rule or process ISSUed by the court or Judge
at chambers,
4 Disobedience of a sub[X>eoo duly SflVed, or refusmg to be swom or answer as a wItness
10
5, RescUltlg any person or property in !he """tody of an officer by vIrtue of an orJer or process of
such court or Judge at chambers
11
6 DIsohedlence of the order or direcuon of the 0000 made pendmg the trial of an 3CUOO, m
speaking to or in the presence of ajuror concerning an action In which the juror has been
irupaneleJ to determine, or in any maMer approaclung or interfering with such Juror with the intent
to mt1uence the verdIct
12
13
14
7 Abusmg!he process or proceedings of !he court or falsely pretending to act under the authority
of an order or process of the court
\5
lE
17
18
19
20
::.IRS 22,030 Summary punishment of contempt committed in immediate view ami presence of
court affidavit or statement to be filed when contempt committed outside lftlmedmte VIew and
presence of court; dJsquahfication of Judge
1. If a contempt is commnted ill the imm~diate \o'lew and presence of the court or Judge at
chambers, the contempt may be pumshed summarily Hthe court or judge summarily punishes a
person for a conlem pt pursuant to dus subsectIOn, the court or judge shall enter an order that
(a) Recites the facts cOIlstl1ulIng the contempt in the immedIate VIeW and presence of !he court or
judge,
(b) Fmds the person guJ\ty olthe contempt. and
21
(c) Prescnbes !he punishment for the contem pt
22
2, If a contempt is not committed In the Irnml."wate VIew and presence of the court or Judge at
chamber;, an affidavit must he presenIed to the court or Judge of!he facts constituting the
contempt, or a ~tatement of the facts by the masters or arbitrators
24
25
26
3. Except as otherwlSe pro\' H.l.~d in this Su..hsectlon, If a cvntt'mpt LS not committed m the illlmediate
view and presence uf the court, lhe Judge of the court m whose contemptlhe person" alleged to be
shall not presido at lhe tn.1 of the comempt ewer the obJectlon o[the pelSDn. The pnwlsiorn of dus
subsection do not apply m'
(a) Any case where a fmal Judgment -:If d","fce of !he court is drawn tn question and such Judgment
or decree was entered III such court by a predecessor judge them,1f 10 years or mare preceding the
bnngtng of contempt proceedmgs for lhe vlOlatlCn of the judgment or decree,
(b) Any proceedmg doswhed in subsection 'I of NRS 3.223, whether or not a family court has been
23
established in lhe judicial dL<tnct

- 25m-
MOTION FOR \flSTRlAL OR CO:\TI~All
p, 16 of 71
,To: 1cJWe9-fcc8-467a-ieOf-7ea559b
froo: rachcoughlln
11-19-12
8:21..
NRS 199 340 Cnmina} contempt Every person who shall commit a Contempt of court pfan, one
ofllle following kinds shaJl be gUIlty of a misdemeanor
I, Dlsorderly, contemptuous or insolent beruwlOf committed durmg the sItting of the cour~ in its
Immed1ate view and presence, and directly tendmg to mtemJpt Its proceedmgs or to impair the
respect due to Its authority,
2. Behavior of like character m the pr~nce of a referee, while actually engaged ill. a trial or
heBl1ng pursuant to an order of court, or m lbe presence of a jury whIle actually SItting in the tnal
of a cause or upon an inquest or other proceeding authonzed by law;
3. Breach of the peace, nOIse or olller dISturbance dITectly rendmg to mterrupt the proceedmgs of
a court. jUI) or refer!!\,:,
4. WIllful dIsobedience to tbe lawful process or mandate of a court;
5 ResIstance, willfully offered. to its lawful process or mandate,
6 Contuma.cwus and unlawful refusal to be sworn as 1:1 Witness. or, after bdng sworn, to answer
HIll' legal and proper mrerrogatory.
1J
7. Publtcation of a false or grossly inaccurate report of Its pro=dtngs: or

1l
8...>.ssummg to be an attorney or onicer of a court or actIng as such ",thout authonty.
2.2
But, actually, contrary to Judge Beesley's SWOrn testImony at the 1], 14/12 DiSCIplinary HearIng,
13
Judge Beesley could bave somebow rwed in a mann~r seeking to regulate Coughlin's appearnnces before his
10
16
17
13
19
Co
or providing, in any manner whatsoever, some indication to Coughlin as to any sort of displeasure
WIth
oughltn'S perlormances l1teretn (WhICh Judge Bees/ey a/)so/urel)' never dld) pnor to Judge Beesley
(upon being supplemonted to the Designation of Wllnesses Itst four da), pnor to lIle I li}4!12 DISCIplinary
Hear g related 10 Coughltn's lawsuit against WLS and Paul Elcano (~icGeorge SOL. Class of 1978, and
there
St.:phen Smiley (McGeorge SOL, Class of 19S0, whom, ther[or<, was neccssanly a class mate of
28
udge Kelllleth Howard C"kGe,"ge SOl, class of 1981 .and speabng of Panel Mern ber Kent .he
21
at Coughlm contmuously throughout the 11/J4!12 Dlsclplmary Hearmg and upon Pat KIng beIng
22
23
e a classmare of both Judge Beesley and Judge :-.lash Holmes, In addItion to a class mate of Panel
cau
10 several he, that day (Kmg told the panel an Order, the one that got Coughlm fired from Washoe
etviees over three years ago hut whIch suddanly became a grievance when teh RMC Judges decided
elT hIt pIece on Coughlin's life and law hcense because they got scared that their Court and the
25
26
27
23
Muru tflallty that owns Il, and the police force and Marshals that is levorages agaimt the ciuzenry to collect
a tax "gm>ed as justice (and the RMC had $7(x)K orso turn upmlssin' m 2(lll, and explamed that away by
say
the shortfall was do to data <ntly errors and stull) was a certIfIed copy wben It was noL no matter,
- 26m -
MQ110N FOR MISTRIAl, OR CO:STlNA\.i
p, 11 of 71
, To: lc3fl1e9-fcc8-461a-8eOf-leaI19b
11-19-11 8:11am p, 28 of 71
ICoa: l!chcoughlln
Elcan 's boyhood chum and rcHow Stanford '66 alwnni Panel Chalf Eche\"ema allQwed E1cano to provide
tion of the Order in hght of Elcano claiming to have "rmewed the video tape of the Trial" (wluch
Echev
a !ned to femIX mto "having attended the Tnal' that led to CoughlIn tilIng. Mandamus Pet.tron
agam. Judge Linda Gardner In 54844 l\llnch was odd con5ldenng that Chalf Echeverria refw;oct to admit
~)
mto e }fjencl! the cl!rtified copy of the audio of th~ 11 TR 268()O traffic cltation lnal on 2i27/12 eouglin
offere mto evidence (Chair Echevemn refused to allow Coughlin to t<Stl1}1n to it "'iug a certified copy or
othe
COUIt fter months 01 the RMC and Judge Nash Holmes r<fusmg to let Coughlin purchase a copy of it That
ceruf, d copy was to '" used to unpeach the hes by Judge Nash Holmes 10 the trattie eMtJ(1n tnal Holmes
,s. even look at the cd ilself whieh CoughlUl had to have hr, mother buy from the Reno MunClpai
1'1
held
spite her adm.rung (see the 3!14'12 gnevance ago,"st Coughlin Judge Nash Holmes sent to the SBN
1]
"on b half of all the ~\!C Judges". wroch is odd b<cau.\. one of those Judges W,Uiam Gardner tried to
12
prete
13
4!101 Z....though he did manage to violate )I~) 178.405 numerous other times romself (including the 3/8/12
14
trial s tting, and teh March 8th, 2012 Trial Settmg the matter for 6118112 d<"plte the Order on the
15
Com
teney EvaluauOI1 not havmg been srgoed and entered unhl <;!9/12... yet Judge Kash Holmes
1E
co
tly ..elo, to play hype man to some alleged "authority' and profound Imowlodge she feels she
he wasn~ aware of that, and just barely contained himselffrom holding the trespass tnal on
posse ses with respect to mental health care and competency ISSUes in general. Tell that to her 3!14f12
19
19
28
21
22
23
gnev ce to the SB?\, wherein she manag<s to write:

"This letter constitut a [annal complaint of attorney misconduct and'or
dJsability against Zachary Barker Coughlin The accomPan\1l1ll box ofmats:rials
demonstrates some of the problems with the practlce of !hi, attorney
experienced by myseJf and the otllfr Ibm judges m Reno MunIcipal Court My
two mool .....nt Orders In what should be a simple tratlie c,tatron case are selfexplanalOry and are mcluded, together w,th cop.es of massive documents Mr.
Coughlin has fax-filed to our court in this case. Audio rteordings oflwo of my
hearings in this Dlatter are al$O included. He fluled to appear for the second one
th1S past Monday I haY< another tratlic case pendrng rnal w,th him that was reasSlgoed to me based on our Department 1 Judge bemg out tor surgery, ~.
"'mg
multiple addl"tfMcs for Mr Coughlm and can't seem to locate hlm between ca.'jes
25
26
27
23
very <a5!1y. We art setting that case for trlal.nd attempting 10 serve him at
the most rtcent oddr", "'. haY< (1422 E. 9th SI #2, Re",,;>IY 89512),
aUboUlh I beard today hr may be liying in his nbjclr sowrwhere \Ve do
have an address for his mother. however. as ,h< recendy posted part ofa fine
for him Judge Ken !loward Deportment 4 had case on Mr Coughhn late last year
that is now on appeal to the Second Judielall.llstrict Court Judge Lmda Gardner,
Department 2, also has a matter cuncnlly pendmg in his court With Mr Coughlm
as th defendant I have enclosed some copres of documents from those matters,
- 27'71-
MO'DON FOR MISTRI AL OR COO"TI?!IW
To: lclEl1e9-fcc8-461a-8eOf-leaSS9b
,
You will the full cooperation of myself the other judges, and the staff of
Reno Municipal Court In your pursuit of thi' matter. Mr Coughlin has poSitIoned
htrnself as a vexatlOu5 htigant m OUT court, antagonizing the staff and eVen our pro
temp Judges on the most sun pie trallic and mIsdemeanor maUers.! do thtnk thIS IS
a case of some urgency and I apologIze tor taktng two days to get thIS package to
you', our IT person was III and could not make the copIes of the audIOS of:vlr
Coughlin's hearings until ttlday, and I f<lt It w"' Important that the audios be
mcluded in the matenals to be consIdered by the State Bar. On February 27,201
Mr. Coughlin told me he wa, actIvely practicing law and had appoinrmenls with
chems I do not know if that was trUe. but if so, he could be causIng senOllS harm
to the practice of law m Northern Nevad. and could be Jeopardizmg som ..",e',
frt~dom or property inli..>rcsts Please contact me if you ru:cd any other
mionnahon ~y direct line IS 775-334-3823 and my cell phone is 775-250-0330'
,
"
3
9
10
12
13
15
l6
17
13
19
2U
21
22
23
24
25
26
28
11-19-11 8:11im p, 19 of 71
in chronological order. ~amply because they appear to demonstrate [hat he IS

quickly decompensating in his mental status Our staff also mede you some audio
tapes of Coughlin hearings in Departments 2 and 4.0 you can hear for yourself
how this attorney acts m court You can se hts behavior in my traffic cltatlOn
ca.~ does not appear to be an 1'>OlatOO inCident
11
Frrna: zachcoughlln
are c
the
was
Judg
And regardless ofwhetherthe materials the RMC's Nash Holmes provided King
rtilled (good gawd they should be considering what it is she is t!)ing to do with
,Coughlin was entitled 10 have them admitted for the purpose ofshowing what King
rovided by Nash Holmes with "the full cooperation of' her and "the ohler three RMC
s"
AT the II! 14il2 Hearing Judge Nash Holmes lied when she testified that she
"s ed asking Coughlin questions about whether he was recording the proceeding or
whe er he had a recordign device and he immediately go all sneakity and then said no, he
was ot and didn't have a recording device, then he switched up his story and said that
was, ct this, a "Fifth Amendment" thing ... thcn he immediately asked to go to the
reslr om, and I let him, but ORder Ry!C Marshal Harley to go with him, and refused to
allo Coughlin to take an)1hing with him evon his yellow legal pad, and Marshal Harley
repo ed to me that Coughlin disassembl~d a smart phoue or recording device in the
reslr om and hid parts of it there, which the Marshals later discovered after Coughlin was
hand uffed and arrested, and I think Coughlin probably Ikd about whether he was
iug the proceeding, so I fOUlld by "clear and convincing" evidence thai Coughlin
ed all these rules of professional condlJ(,1 that I conversed with Bar Counsel about,
am not tr}ing to take Bar Counsel's place or nothin" but I am just tryin' a chip in an
part to make the public safe from this "attorney" whose writing is the most
Irigh coing and unorthdox display of immense, in1ll1ense talent that I have ever had the
misf rtune of having been SUbjected to... " (Chair Echeverria was terrified of the proscpct
ofth cook off, cr, Disciplinary Hearing being recorded, and rcfll~cd to allow Coughlin to
do Sl, lying that it was being record by the court reporter, though now Sunshine
Rep ing, whose reporte CarollIununel did the tnmcribing, is saying no recording was
mad ,and thai, yes RMC "exdusi.-e"transcritpinist Pam Longoni is amongst there
yees and that (and this combines with Judge Linda Gardner's current and then
on the April 2009 trial being the deputy assigned the the 11114112 Disdpinary
g (what did I tell you? Can Patty ke stacks a deek for hisself or what?
y SUsich, too. You just don't mess;with the NV DETR or Maureen Cole, right
- 28/7] -
MOTION FOR MISTRIAL OR CO~Tl~AY
To, 1cJf21e9-fccH61a-SeOf-leaI19b
Fnm' mhcoughl1n
11-\9-12
8,21.&
y?). See attached matelials related to the RMC and Longonis continuously
lng Nevada law in ~RS 189.010-050 regarding the preparation of erintina!
ts transcripts on appeal.
6
7
o
o
10
11
12
14
16
17
18
19
SCRIPTS ON APPEAL/OTHERS CASSA~DRA JACKSON lnterint Court

. 'su-ator J'UST Jili ROPEI { Chief Marshal - Depanmcnt of !lJternativc Sentenc
ing I you wish to order a transcript of your procmings in the Reno '<luniapal
Cou you may do so by contacting Pam Longonl at (775) 5311-5251. The following
info ation is provided to assist you in placing an order for a transcript: J. Orders
will
ulre the date of the court appearance, Iype of proceeding, (trial, arraignment,
etc.) department number in which the proceeding was held, and also include the
app priate deposit as indicated below. Pa}11lent may be made by cheek or money
orde . No transcript will be prepared until the required deposit is received. - 7.. ,e
Appeal transcripts are billed at $4.10 per page, which Ineludes an original (to
be Ii cd willi District Coort), one copy for the appellant, and one copy ror the
opp ing counsel Transcripts Ilrdered fill' purpuses Ilther than appeal, where Ilnly
one 'opy and original transcript Is required, are billed at $3.00 per page. 3. Depus!ts.
Dep its required are as foHows: $75.00 for arraignment/sentencing; a minimum
dep it 01$2(10.00 for any trial transcript; and a minimum depusit 01$500.00 for 'Very
len y trials (those lasting more than three hours). NO TRA~SCRIPT IS
CO SIDERED TO BE OFFICIALLY ORDERED, AND CO\rnENCEMEIW OF
T
'SCRIPTION WILL NOT BEGIN. U~TIL RECEIPT OF THE REQUIRED
DE SIT. 4. Follow -up on Transcript Preparatillu. You wiD be notified when your
lI'Sn eript has been prepared. If the actual cost of the transcript is less than the
smo nf of the deposit paid, a lefund will he issued with the transcript. And, likewise,
any ulstanding balance due after completilln of the transcript must be paid before
the riglnal is tiled with District Court Ilr any copies released. 0 refunds Ilf deposits
will e gWen for transcripts once they han been prepared and no responsibilily wiD
be
eu ror the dismissal of any -appeal by District Court because no Original was
r.Ied due to non payment of an out- !and ing balanee due. 5. Questions. Pam Longoni
will e happy to answer any qustions you may have'
2;)
Panel ChaIT flat (lut refused to lot a "ngle piece of eVidence be admitted that would In any way call
22
into j tlimacy the convictions at ISsue III that Disciplinary Heanng. Supreme Court has obligatIOn in
mary proceeding to look beyond label gIven to attorneys convlctlon to true nature of facts, in order to
24
me whetheflIDderlytng ClTcumstances of conviction warrant discipline. Sup.Ct Rules, Rule Ill, suM
3. Sta e Bar 01 Kevada v. Claiborne. 1988.756 P.ld 464, 104 Nev. 115. Attorney And Chen!392.
26
ent Where lhe only relevant factual .llegation contained m DlSclphnary BoorcYs affidavit filed m
27
of its retition for attorney's temporary su..~n,\lon from the practIce of law, was that a cnminal
23
- C9mMOTION FOR ~fISTRlAL OR CO'iTI'iAC
p. 1G of 12
To: lcl\11e9-fccS-461a-BeOf-leaI59b
indlc
11-19-12 8:11am p, 31 of 11
trom: zachcoughlln
cnt had been filed against the Httomey, this !')Ole allcgatJon, without more, was insufficient to justlfy
y suspensir)fl and the immediate imposItion of temporary restrictions. Sup CtRules, Rules 10:2, subd,
4(a), II, suM 1. :'latter of MontelfQ, 1984,684 P 2d 506, 100 :-lev 440 AUorney And Chent 483 Senous
cnme ttomey was not convlcted of "se;rious crime" witbm meamng ofru[e regarding attorney suspenslOn
attorney dIU not engage m anj cnminal conduct whatsoever, did not engage In a consplmcy, and
y entered plea of nolo contendere to nonexistent offense Sup Ct Rules. RUle Ill, sul:xL 2, Sloan v
State ar of Nevada, 1986, 726P.2d 33(), 102 Nel'. 436 Attorney And Clten! 394. Su.o;pension ofruleIn
mtere t of JustIce, Suprem e Court suspended cowt rule reljUiring itto vrdersuspensJOIl of attorney upon
:)
[eeel
of certlficate of hIS conVICtion where attorney was lmpeached federal Judge, who was arguably
1:)
beyo
Supreme C--Ourtls Junsdtctmn, and attorney had voluntanly refrained from practice onaw after hlS
11
reieas from mcarcemtion, pendmg re,olulion of diSCIplinary proceedmg Sup CtRules, Rule III State Bar
12
ofKe ada v Claiborne, 1988,756 P.Jd 464, 104 Nev 115 Attorney And Cllent39
13
Fwther, SBN Bar Counsel King hed continuously to Coughlin, every step along the way, In the
14
disci
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follo mg, where Kmg wrote 10 Coughlin about two grievances and an
16
gnev ces include supporting eYldence mthe form of audIO of your conduct in court proceedings I am
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enclo ing w1th tIDs letter copies of a grIevance letter. from the "\funlclpal Court and a copy of an Order
18
WI1U.~w!"'-'''''IUP!ease respond to allegahons
19
matter King's lies are too numerous to fully detail here, but, one was with rogard to the
orti
~Ordcr'l
he had received, "The
pertaming to your conduct I wII! make 2ymlable foryout
documents and audio record
'." KlI1g lied for months about this
d offer to "make available for your renew and inspectIon the sUPP:.lrting document, and audIO
21
rcco ings". Simply put, Pat King is a cheap cheater. lie cheal-, constantly m Ins role as Bar Counsel,
22
ng and descreattgn SCR 105(2Xc) at every turn, lying constantly to OpPOSing counsel and
23
dent', (KIng told Coughlm thai DaVid Clark had given Coughlm pernllsslOn to Issue subpoenas lor
the D clplmary Hearing, suspended anomey or not, only 10 then file Ex Parte \1otlons to Qua.'h the
1%""" by a licensed attorney
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Subp enas based upon theIr not being
20
Parte
27
Clear " stogIe smokm'Boss Hog Echeveni had failed to r<VIew the multitude of malenals Coughlm
28
provi' cd him. And clearly Kmg had hed (and in fact. once caught doing so at the hearmg, was reduced to
and Chatr Echeverria grants King's Ex
otions the day they are filed .but admits to having not even bothered to rend those filed by Coughhn
- 30171 -
MOTW FOR MISTRIAL OR CO'l'I1XAC
To, lclf11e9-fccB-461a-8eOf-leaS59b
From, zachconqblln
11-19-11
8,11a.
ddling funously) to Coughhn (as did Peters) when they ,,-\Sorted that everythIng C"ughbn filed WIth
2
the S N was c"l)jed and proVided to all the Panel Members (whose addresses the SBN refused to provide to
Co
SCR 05 King was caught at the Heanng upon eross exammation by Coughlm. haVIng to admIt that he did
not pr VIde the CD,DVD's that Coughlm attllCheu to hIS varlOlL, fihngs Panel ~!ember Stephen Kent
respo ded by announcing that he dld not care th.:'tt Kmg li~ about copying the Panel me,mbers on the
cdldv s aUllChed as exhibIts to Coughlm's tiling and that even d' K1l1!l had so attached those cd!dvds, Kent
woul 't have review them anywas However. 1980 graduate of McGeorge School of Law Stephen SmDey
Kent. sq (a perlect chOice by Kmg and Suslch lor the Panel gIVen the apparent cormechon to MIke SmIley
1m, as dJd tbe SBN refuse to proVIde any set ot rule< of procedure that the Panel had adopted under
1 :l
Rowe Esq (whom COughhn named m a gn,vance related to the fraudulent conduct by the SBK mcident to
11
his ap lication for admission) and the acl that, a McGeorg" SOl. 1980 graduate would necessarily have
hes to Judge Howard (t>.lcGeorge 'Sl), KellhLoomlS (McGeorge '82. and for whom the gnevance
12
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Co
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Holm s, McGeorge '77. Judge Beesley, '"IcGeorge '79, \VLS's Paul Elcano, McGeorge '78, etc., eW" Kent,
15
besld s glanng at Couglhm throughout the DISCiplinary Hearmg also attempted to take the spothght otIthe
16
he
17
admi ed that King and the SI:lK had faIled to proVide copies of the exhIbIts Coughlm attached to hIS f!lings,
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despi the SBK havmg agreed to do so and represented to Coughlin that it would. Kent announced,
flied against Kmg disposed of with great quICkness and shallow ratronale), as well as Judge Nash
Coughlm hadjlL't caught Bar Counsel King andelerk Peters m when the Panel members and King
Iy. that he didn't care If K1l1!l copied hIm or the panel on the attachments to COughlm's fti1l1!lS or that
19
s indicated to the Panel that he was so cOP),1l1!l the Pand on the cntrrety of Coughlin'S filings. yet did
2U
21
In
not
. t out that he octuaU, was not, chOOSIng to eXCIse the dvdicd attachments to those lihngs (and It does
clear !'hat Kmg even dId m foct have teh SBN copy the Panel member Of! all of Coughlin'S filings.
22
where Laura Peters had prCVlously told Coughlm he could file by email or fax. and that the SBl\
23
24
waul never att<mpt to assert that the 8/23i12 certified malhng would be proof of or return of semee Once
25
theS N makes a representation, SCR 1(19 goes OUl the window. and It IS shameful !'hat Pat Ktng was fully
26
awar of that representation, and ct}-signed by his September 25th, 2012 attempts \0 get Coughlin to show
27
up
23
the SEN for a he-armg that. was m

.)tICed and calendared to Coughlm and Suslch tor 9/25/1:2. .only for
refuse to hold the hearing, and mstead seek to jam f'I bunch of other matters into a "combo-hearing"
- 31/71-
MOIIClli FOR MISIRI:l.L OR CONIINAl.i
p, 31 of 71
Fro., z.chcoughlin
, To, lcJ!21.9-lccB-461.-BeOf-l 559b
11-19-12
1,21..
inelu ng pending cnminal charges in vIolation of Monteiro Furhter Burletgh wa.~ vtoJated mever way due
proce wise, and the Panel outright l10uted Nevada Law by r<fusing It) reeogmze Claibomed. And so
how the dtSmls.')31 ofthts appeal
IS
not s.lgned by a JUSllce. and occursJu5t m lime (or the
Imary Hearing. (to go along wah Mlchad John"'n apparendy checkmg hIS tWill<!' or f.c.book
on his smartphone for most of the day .the only Panel member. who displayed any profesoionalism
at all ere Clark Vellis, Esq. and laymember Karen PearL though it was enl1rely inappropnate for any of
them
a
9
agree to sit for the hearing at all given the per .. nolattons of SCR 105(2)(c), and thus, the total lack
'ction to hold such a lteanng. He IS hternlly the cheapest, SleaZIest attorn,,), I have ever come across
III
my hfe .andlhave dealt WIth Richard G Blll, Esg and Casey Baker, K"l Pat K,ng is literally more
erous than anyone I have every wlmessed In my lIfe He has thlS DiscipJtnary Heanng thmg sewn up
III
tnt where he revels in SCR I 061mmumty so much w that he brazenly ties at every turn, and
11
12
ges, and often forces "Clm of Court!lnvestigator" Laura Peters to lie as well, whICh she does readily
13
and 0 en (telling Coughlm that she had the authont)' to and dJ so grant Cuughlm the nght to tssue and lteve
14
serve subpoenas without peying wimc" fcc~ and further, that Respondenes ,.,ver pay witness rees in these
15
D,sel hnary Heanngs (good luck iigmng out whIch rules apply, as clearly the NRCP do not, gIven ChaIr
16
mas utter disregard for the NRCP and all ofSCR 105(2Xc), Iyptcally done wltJle Echeverna cackles
17
des menaCingly at the RDspondent, plays grab ass WJth hrs boyhood chum Elcano. and smokes a big
1S
old
, Boss Hog style dunng the nurn erous 'Ibreaks" be in.'Si'5ted were a better use of the time for a
g than affordlng Couglm an opporturuty to, say. ask Judge Nash Holmes quostJon about her
19
tion in the "clandestine status conferii:n~e~ on 2/27:12 wherclIl the Order for Competency Evaluation
2:]
partie
21
was d cered to Coughlin In rcr2012-065630 or the "strategy sesslOns" and "meetmgs" the RMC Judges and
22
court ppointed defenders (like LoomIS and City Atlllflley Ha7Iet1Steven~Esq admit 10 havll1g With Judge
23
\\,,11
Gardner in the mornmg, secrot 10 Coughlm prior to the .vI 0, 12 Trial date m the trespass matter
was set for Tnal by Loomrs and the RMC on 3(Sill at a time when both tyhe RMC, Judge W.
2~
r, Loomts. and City Attorney HazlettStevens Im<w full well that thm was the 2;27!l2 Order for
25
26
Com teney EvaluatiOn pending agamst Caughlm m RCRZO 12-065630 (and NRS 178.405 VIS a VIS !'-'RS
27
S.QIO
28
In combmatlon wtth
Judge Nash Holmes accustatlOn "on belte!f 01 all RMC Judges" m her 3!14<li
ce agamst Coughhn (and Judge W Gardner lied on the record dunng the ApnllOth, 2012 "Trial"
- 32'71 -
MOTION FOR ",llSTRlAL OR CO;";TINAC
p, 33 0111
To: 7cJ.f11eHcc8-167.-8eBHe.559b
ce letter the the SBK mentioned any "<Xlmpetency"

dIS
ISSUes
related to CoughlLll. Perhaps what is so
mg IS the extent to whlch these Judge::; hes Rrc so easily dlsproven, mdlCatmg they have very httle
for the idea that this judiCial S)'!item will e"e, take them to task for so dOIng (and he refused to allow
8:21am
and; otion Hearing in I I CR 26405 when he alleged that none of Judge Nash Holmes Order; or her
11-19-11
From: zacbcooghl!n
Co
1m m ore than and hour and a half to put on hIS case. most of which was. of co"""'. W!!sted listening to
rna rule as rrrelc\'ant or inadml$Slble every single pIece of eVIdence Coughlin sought to mtroduce,
even cerUfied copy of the aucho of the Trial n II TR 26800 that would prove that Judge Dorothy Nash
Holm s lied and hed durmg her testimooy. Not only did Coughhn have the audio cd that King fmally gave
to h
seR Rule !OS. Procedure on receipt of complaint.

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2. Commencement offonnal proceedings. Fonnal

disciplinary proceedings are commenced by bar counsel
tiling a written complaint in the name of the stal~ bar. 1lte
complaint shall be sufficiently d~ar and specific to infonn
the attorney of the charges against him or her and the
lmderlying conduct supporting the charges. A copy of the
complaint shall be served on the attorney and it shall direct
that a verified response or answer be served on bar ooulL~el
within 20 days of service; the anginal shall be filed with
bar counsel's office. The time to respond may be
extended once by the chair for not more than 20 days
for good cause or npon stipulation oflhe parties. In the
event the attorney fails to plead, the charges shall be
deemed admitted; provided, however. that an attorney who
fails to respond within the time provided may thereafter
obtain pennission of the appropriate disciplinary board
chair to do so, iffailure to file is attributable to mistake,
inadvertence, surprise, or excusable neglect.
(a) Challenges to and ad hoc appointments of panel
members. 111C complaint shaH be served with the list of

members of the appropriaf<> disciplinary board. TIle
attorney, or each if more than one, and bar counsel may
exercise five peremptory challenges each to the people on
the list by deli wring such in writing to bar cotltlsel on or
bdorc the date a response (0 the complaint is due. "
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- 33.71 -
MOTION FOR MISTRIAL OR CQKTINAl-
p. 34 of 71
, To, lc3fl1e9-fcc8-l61a-8eOHea559b
f,oo: zachcoughlln
11-19-11
26
(COlJGHLI:'-I HEREBY EXCERCISE HIS RIGHT TO

PEREMPTORIl ,Y REMOVE PANEL CHAIR
ECHEYERRlA AND McGeorge SOL Class of 1980
Steph~n Smiley Kent (and anyone who went to McGeorge
for that matter, or even applied there) (whose classmates at
McGeorge include RMC Judge K~'lmeth Howard, who
denied Coughlin even one continnance in the first offense
petty larceny ofa de minimis l1mollllt offood from a WalMart at a lime when Coughlin was besieged wilh an
1lIl1awfui summary eviction from his former home law
oUice. and had an impermissible NRS 40.253(6) violating
"rent ~scrow" deposit ofS2,275 required by the RJC just to
preserve Coughlin's right to litigate at the 10/25 112 "Trial"
Date (the RJC, noticed in wTiting the parties on the fact that
that was a "Trial" date in light of Jndge Sferra72a'S ruling at
the 10113!l1 summary eviction proceeding based upon a
No Cause Notice only (ie, non payment of rent was not
pled, making Hill and Bak,,'T's use ofthe summary evi.'Iion
process violative of nevada law against commercial tenant
Coughlin, particularly where Coughlin held the address out
(0 the public IlIlder SCR 79 as his law office, where filings
such as the one on 8/1 OJ 11 by Coughlin on behalf of then
client Robert Bell (in the matter that Judge Linda Gardner
recused herself from citing judicial cannon 2.11( a) (just
admitting a tlat out bias against Coughlin) as the ba,is tor
doing so) in fvll02864 and the a,socialed TPO
demonstrate via the 121 River Rock address in the caption
for then attorney Coughlin that the location was Coughlin's
law office, and that Coughlin was a commercial tenat, who
possessed a law license al the lime and where il is not clear
the "home oUice" exception to any requirement to have a
Cily or STate business license, particulary where CougWin
was making less than S28,500 pcr year. attach in any way ...
Coughlin objections to Panel Chair Echeverria's
participation go beyond the evident impartiality
demonstrated in all his various quick fire approvals of
King's Motions (including Motions to Quash Subpoenas
that fail to recongize the lies King and the SBN told
Coughlin with Respect to Chief Bar COllllsel Clarks, Kings
and Clerk of Conrt Pelers representations to and
agreement, with Couglin vis a vis the application and
inkrpreation ofSCR 110. "Suhpoena power. production so
documents, wilnesses. and pre-trial proceedings" ...
28
Challenges to any member for cause under Rule 103(7)

shall be made a~ soon as possible after receiving either
actual or constructive notice of the grounds for
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- 34/71-
MOTION FOR MISTRIAL OR co."TI~AlJ
8,11..
p. 35 of 71
To: lcJf21.9-fcc8-161.-8.0f-l,.559b
F,om: zachcoughlln
11-1H2
disqualification, and shall he made by motion to the chair

in accordance with these rules. In no event v. ill a motion
socking the disqualification of a member be time ly if the
member has already heard. considered or
ruled upon any contested matter, except as to grounds
based on fraud or like illegal conduct of which the
challenging party had no notice IIntil afkr the contested
matter wru, considered, Any challenge that is not raised in a
timely manner shall be deemed waived.
10
12
13
15
16
The chair may make ad hoc appoinhnents to replace

designated panel members in the ewnt challenges or
disqualification reduce the nnmb.. to less than the number
required for the hearing panel. Ad hoc appointees shall be
suhject to disqualification under Rule 103(7) and any
remaining peremptory chaUenges unexercised by either
the attorney( s) or bar c{)unseh\ hearing panel as fmally
constituted shall include a non-lawyer.
H(b) Assignment for hearing; venue. Following senice of a
I'tsponslvc pkadju&:. or upon failure tv plead he
matter shall be assigned by the chair of the disciplinary
boan! to a hearing panel.... "
There has not even been senice of the complaint yet!!!!

Peters 1019/12 Affida"it and Coughlin's ...arious filings
and 11119/12 Affidavit establish that conclusively.
]7
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25
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(c) T"une to conduct hearing; notice of hearing;

discovery 01' evi!l.enrs a1'fti,nst attorney. The hearing
panel shall conduct a hm ring within 45 days of
assignment and give the attorney at least 30 davs'
written notice oftts time and place. The notiq shaH be
served in the samf maMer as the complaint, and sltall
infonn the attorney that he or she Is entitled to be
represented by CJlUnsel_ to cross-examine witnesses. and
to )!l'esent evidence. The notice shan be accmnpanied by
a summary prepared by bar counsel of the evidence
against the attorney. and the names of the witnesseS bar
counsel intends to call for other than impeachment,
together with a brief statement of the facts to whlclt
each will !e.til". all ofwbicb may be impected lID t93
days prior to the hearing, Witnesses or .,.idrnce. other
than for impeacltm.nt. which became known to bar
counsel thereafter. and which bar counsel intends to use
at the hearing. shall be: promptly disclaored to the
attorn.v. For good cause shown. the chair may allow
- 3501-
MOTIO>! FOR MISTRIA.!, OR CO;.;rJDIAU
8:11am
p. 36 of 12
To: 7cJ\11eg-fcc8-4tila-8eOf-7ea559b
2
3
5
7
11
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2:J
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Fro.: zachcoughlln
11-19-11
additional time, not to euced 90 days. to conduct the

heannl:.
(d) Quorum; time for decision of pand; vOles required to

impoHe dil>cipline. Any five members Or the panel shall be a
quorum. The hearing panel shall render a written
decision within 30 days of the conclusion of the hearinr:.
nnless post-hearing briefs are requested by either bar
counsel or the attorney and allowed by the pane! or
requested bv the chair. in which event the decision shall
be rendered within 60 days ofllle conclusion of the
hearing. The decision shall be served pursuant 10 Rule
109( 1). accompanied by the panel's findings and
recommendation, all of which shan be tiled with bar
counsel's office. A decision to impose or recommend

discipline requires the concurrence offourmembers of the
panel.
COUGHLIN REQUESTS A LEGI11.\IATE
OPPORTUNITY TO peT A MORE APPROPRIATE
VERIFIED ANSWER OR RESPONSE ON FILE IN THIS
MATTER .. ,FCR11IER, COUGHLI\' IIEREBY
REQUEST AN OPPORUlNITY TO SUBMIT A POST
HEARING BRIEF...EVEN TIlOUGH TIlE HEARING
HE STILL REQUESTS BE STRIKEK OR VIEW .\fORE
AS A INTRODUCTORY MEETING.. A,\D COUGHLIN
REMIND THE COMMrnEE THAT UPON THE
HEARlNG DATE OF 1I14i12 BEING Rl:U AS VOID
FOR LACK OF DUE PROCESS, NOTICE, SERVICE,
PROCESS, JURISDICTION, E'I'C ... THE PAl'\EL WILL
SOON RUN UP AGAINST THE "WITIlIN 45 DAYS OF
ASSIGNMENT'DiCTATE
(e) Rules of evidence; support of panel's decision. 'The rules
applicable to the admission of eVIdence in the district
courts of:\'cvada govern admission of evidence before a
hearing panel.
Evidentiary rulings shall be made by the chair of the panel,
if one has been dcsiglJated, or hy the chair of the
appropriate disciplinary board prior to such a designation.
The findings of the panel must be supported by clear
and conlincinll evidence. And under SCR 104(3) and
SCR 103(7) Coughlin seeks to have SBl'i King removed
or conflicted out of this case for an the greivance
drurnmJng up, for his impennissible communications
with Coughlin's then client's the Eastman's in early
may 2012, for feeding Judge Nash Holmes the "by clear
and convincing evidence" standard inserted into her
- 36171 -
MOUO>! FOR MISTRIAL OR CO:\,UNAU
8:11il1l p, 31 of 11
10:
From: zacbcoughlln
7cl~11e9-!ccB-ma-BeOf-7ea559b
11-19-12
8:21am p, 38 of 72
3112/12 Order transmogrifying the trafticat case to a a

summary diselplinary hearing (and her testimony on
11114112, you comdd teU, was already anticipating the
jeers and offering mea culpas in that regard, or at least
caveats to spare. ..
1
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(f) Court reporter. All fonnal hearings shall be reported by

a certified court reporter, which cost may be a~sessed
against the attorney pursuant to Rule 120. Any party
desiring to have any other disciplinary proceedmgs

reported must arrange in advance for a certified court
reporter at the [larty's own expense,
S
9
18
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Zac Coughlin, 1D.

Patel t Agent, USPTO
1471 E, 9th st.
NV 89512
d Fax: 949-667-7402
oughlin(alhotmail.com
12
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Nov mber 17th, 2012,
RE: lTIGATION HOLD NOTICE REGARDJ)JG EVERY RECORDI'\G,

IX J'\1ENT, DRAFT OF ANY SORT, OR PIECE OF DATA COLLECTED WITIl
RES ECT TO THE ILLEGALLY HELD DISCIPLINARY HEARJ)JGOF 11:14112 AT
THE STATE BAR OF "lEV ADA, AT WHICH CAROL HUMMEL WAS TIlE COVRT
RE RTER OF RECORD AND FOR WHICH IT HAS BECOME KNOWN THAT PAT
KIN T HAS A COPY OF THE RECORD OF THE PROCEEDING ALREADY A]\;D
THE EFORE HAS BEEN GIVEN YET ANOTHER IMPERMISSIBI.E ADY Al\'TAGE
RE IRING ANY RECORDINGS, ROCGH DRAFTS, WRmEN TRANSCRIPTS,
OR UDIO TRANSCRIPTS BE IMMEDIATELY TURNED OVER TO COUGHLIN
NO CE OF CONFLICT BETWEE:\ ZACH COUGHLIN AND SUNSHI"IE
REP RTING SERVICES GIVEN S1JNSHINE'S ADMISSION THAT PAM LONGONI
IS 0 ITS STAFF AND MS. LOKGONI'S D1RELECTION OF HER DUTIES IN 11 CR
2217 , WIllCH RESULTING IN A D1S,\HSSAL OF COUGHLIN'S APPEAL IN CR11
206 AND TIlE CURREKT TEMPORARY SUSPENSION OF COUGHLIN'S LICENSE
TO RAeTICE LAW IN 60838
24
John .ter Echeverna, Esq, Panel Coo".

2. 5
21,
26
Eche
9432
Reno
Tel 7
rna Law OfficelEchevema Group

ubJe R Blvd.
,\V 89521
57864800 Fax 775786480S JE(d:)iLORE,\O com
State or of ,'levada. Oftice of Bar Cousnd

- 37171 -
MOTION FOR MISTRIAL OR COKTINAC
, To:
from: lachcnughlln
ltJ~11e9-fttB-46)i-BeOf-)ea559b
2
3
Davi Clark, Esq, Ch,efBar Counsel

Las \ gao: 6UO E Charleston Blvd
Las \ gas,:-JV 89104 Phone 702-382-:200 Fax 702-385-2878
Patrie O. Kll1g, A"",stant Bar Counsel
9456
4
11-19-11 8:11am p, 39 of 71
ublc R Blvd, SUlI< B
Ren NV 89521 Tel: 7753294100 Fax: 775-329.0522
5
6
De Chair Echeverria, Panel ~lembers. and SBN Office of Bar Counsel,
Please provide to me immediately all materials (including the sowld recording) of

the 1 114112 Disciplinary Hearing that Pam Longoni coworker and Sunshine Reproting
Sen 'os employee, CCR Carol Hummd was the CCR on althe State Bar of Nevada from
appr ximmely 8:30 am to approximately 6 pm. As you are aware, I have a conflict with
Pam ngoni that likely Yo ill entail substantial litigation, to whatever e~ient there is not
y litigation ongoing. Please review the attached materials tor more explication in
gard. However, while r am not purporting to give you legal advice, I believe it was
wro for that firm to work the II! WI2 Disciplinary Hearing. I am writing to request to
be gi en immediately. and absent any sort of pa,ment or agreement whatsoever, all
mate 'als recording, transcribed, reported. or otherwise collected in any way by Sunshine
Rep ing Services and or Carol Hummel atthat lli14:12 Hearing and any other materials
conn cted thereto, including correspondence or agreements with the State Bar of Nevada,
the orthem Nevada Disciplinary Board, and the Panel (induding Panel Chari John
Ech 'erria, Esq. and the Echeverria Group) in addition to the material, Pat King himself
s
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2:)
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DUE TO MR. KING'S A.l'J!) LAURA PETERS TIlREATS OF ABCSE OF

PRO ESS (INCLUDING CALLING THE POLICE FOR SPURIOUS REASONS OR
peR DING A PROTECTION ORDER. I .'\.\1 HEREBY SERVING THE SBN, KJ:\G,
PE ,RS, A:-ID PANELCHATR EClIEVERRIA A STAY AWAY ORDER OF MY
OW . ANY ENTREATIES ONTO MY PROPERTY, WHICH IS MARKED WITH A
LA E "NO TRESPASSING" SIGN, :V1l'ST BE APPROVED IN ADVANCE M'D
RE IRE A PHONE CALL PRIOR THERETO AND EXPRESS APPROVALY BY
ZA COUGHLIN AND ONLY ZACH COUGHLIN. FURTHER, COUGHLIN
HE RBY DEMANDS THAT ALL OF HIS FA.'\ FILINGS BE FILESTAJo.IPED AN!)
TH r A COMPLETE COPY OF THE RECORD AND DISCIPLINARY FILE BE
PRO 'IDEO TO COl)GHLI"I, INCLUDING HIS OWN FILINGS, AND TIM T THE
SBN COMPLY WIT!I TIlE STATES RUoES AKD POLICIES IT ARTICULATED TO
CO lHUN ON ITS OWN BEHALF AND ON BElIAL!' OF TilE PA;\EL AND
BO D AND PANEL CHAIR. BY PROVIDING COMPLETE COPIES OF
EVE YTHING COl-GHUN HAS SUBMITTED (lNCLl'DING THE CDIDVDS
A
CHED AS EXHIBITS) TO ALL PANEL MEMBERS.
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28
I anI indigent. severly so, and the State Bar of Nevada and Chair Echeverria, some
ml say, are fraudulently attempting to take away my Fourteenth Amendment property
righ my law license, chieny through their numerous violations of SCR 105(2)(c) and and
- 38171-
MOTION FOR MISTRIAL OR C<iTINAl'
- !
, To:
lcJfl1e9-fccH61a-8eOf-lea559b
From: zachcoughlln
11-19-12 8:2Ia. p, 10 of 11
any ther due process rules, law, or conceptS they can desecrate, 'lbere simply was no
,colo Ie basis for ruling thal r \Va., not ""rmined to record the proceedings",although,
?
nei :r the OCR nor ;-;'RCP appear 10 haw any rules either prohibiting the recording of
3
Disc linary Proceedings (made applicable via SCR 105(4), unless UN Panel has enacted
som unpublished rules that it has so far refused to give me, as is the case with the SBN.
4
FliR ER. TIlE SBN AND :--INDB PANEL A.'1D ITS CHAIR, AND HIS L-\W
OFF CE AND ECHEVERRIA GROUP ARE HEREBY PLACED ON A LITIGATION
S HO NOTICE, PAT KING MAKES CCTE JOKES LIKE "WHA1'8 A LITIGATIOI\
6 HO
NOTICE",,,ITS S011ETIIING TIlAT WILL SUBJECT YOC TO CONTlOMPT,
PAT NEVERMIND YOUR ILLUSIONS RESPECI1NG SCR 106 AND YOUR
7
"UN IMITED IMMUNITY"",MR, KI:-.lG.1 AM HEREBY ONCE AGAIN PLACL'lG
YO ON NOTICE TIlAT LlTIGATION IS LIKELY TO ARISE REQliIRI:-.lG YOU TO
8
MAI:TAIN AND n:RN OVER AT SOME PONT TIlE MANILA ENVELOPE THAT
9 TIlE SBN PLACED INS1:FFICIFXT POSTAGE 0:--1 IN MAILING OUT ON 1O!91]2
(OR T LEAST PRINTING THE RED PITNEY BOWES POSTAGE TIlEREOx ON
10 TIl 'DATLAND PLEASE RLALlZE, 111lO SBx DID NOT SEND TIlAT NOrm
BY I IRST CLASS MAIL IN ADDITIO:\ TO A CERTIFIED ~lA1WiG",PROBABLY
11
SO E TACTICAL DECISION BY KING TO GAl\, A\, ADVANTAGE, CHECK THE
CER 1FICATE OF MAILING,,, THE LITIGATION HOLD \'OTICE EXTExDS TO
12
ALL CALL RECORDS BETWEE:\ THE SBN IN A'IY WAY WITH CHAIR
lJ
ECI' VERRIA OR OTHER MEMBERS OF THE PANEL, INCLUDING ACTIVITIES
NV LVING LAURA PETERS, CHAIR ECHEVERRIA'S STAFF LEFT COUGHLIN
HAP ONE CALL IN RESPONSE TO HIS INQt:IRY REGARDING A MUNDANE.
I, NO, -SUBSTA:--ITIVE :\fAITER (DEENA, NOT TERESA, AND yoe WILL WANT
TO EVIEW NRS 199,340(7) REGARDING So:\lE RECE"!T DEVELOP:\lETISJ,
16
AN DEENE COMMCNICA TE IN NO CNCFRTAIX TER\lS TIlE CHAIR WOL'LD
NO SPEAK TO COUGHLIN, EVEN TIlOCGH HE IS PROCEEDlXG WITH SELF
11
REP SENTATION AND IT IS MORE THAN COMMON FOR RESPONDENTS
CO 'SEL TO REGCLARL Y COMMDilCATE WITH mE CHAIR, 11iAVE READ
:8
AL THE DECISIONS AND GRABBED THE RECORDS ON APPEAL PLEASE
19 I)"llv DlATELY PROVIDE ME A COPY OF ANY PROCEDt:RAL RUES THE
BO. RD HAS ADOPTED INCIDENT TO SCR 105 AND EXPLAING WHY THE
;'8
10/9, 2 AFFIDAVIT OF LAURA PETERS IS FILE STAMPED, YET WAS NEVER
SEN TO COl;GlILIN, PLEASE FURTHER E.XPLAIN WilY TIlE "D1SCIPLI.'IARY
)1
FI "HAS BEEN DOCTORED TO EXCLCDE TIlE GREEN CERTIFIED MAIL
,,2 TA
FOR THE COMPLAINT (WHICH USPS TRACK & CONFIRM REVEALS WAS
NE'It .R SIGNED FOR BY COUGHLIN, AND IN FACT, JUST AS CLERK PETERS
n AD lITED ON SEPTEMBER 11T1-1. 2012 AT 4:55 P\f, WAS RETUR:-.lED TO SEND
AN SIGNED FOR BY THE SBN ON 9!J Oil L PLEASE HAVE CLERK PETERS
24 FIL OUT A NON FRAUDULENT RETlJRN OF SERVICE OR PROOF OF SERVICE
:'5
OF E COMPLAlI\T REFLEC'I1NG HER DlOCU\R.1\T10:\ OF SBN 1\."ID PANEL
RUI S AND POLICY TO THE EFFECT THAT THE 3.'23:12 CERTIFIED MAILlKG
':6 WO LD NEVER BE PUT FORTH AS PROOF OF SERVICE OF THE
CO PLAINT...,WIJ[CIl LEAVES THE SB:-.J AND PANEL TO EXPLAfIJ WilY KING
c'
eNI TERALLY ALTERED THE DlOCLARATIONS :\IADE BY PETERS TO
28 COL 'HLIN RESPECTING TIlE PROCWURAL POLICIES AND ADOPTED RULES
1
- 39171-
MOTION FOR MISTRJc\.L OR CO;-;'TINAU
, To: 1cl\11e9lcc8461aSeBIleaSS9b
3
9
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111912 8,21am p, 41 of 12
AN PRACTICES OF THE BOARD, SBN, AND PANEL IK THESE ])JSCIPLIKARY

PRO EEDINGS, INCLUDI"IIG HER ATTESTATIOCli THAT SHE HAD AUTHORITY
TO EPRESENT TO COUGHLI"II THAT NO TIME DEADLINES WOULD RC"II FOR
AN EVENT WHOSE SERVICE REQUIRE[) COMPLlAKCE WITH SCR 109
(ME NING ALL MATTERS MEKTIONED IN SCR 105(2)(C). MEANING THE
NO CE OF THE HEARING WAS DEFICIEl\T GIVEN COUGHLIN'S SIGKATURE
IND CATES A DATE OF 10.27/12, IE, FAR LESS THA:\ THE "AT LEAST 30 DAYS"
BEF RE THE HEARIKG MAY TAKE PlACE (17 DAYS IS NOT EVEK CLOSE),
AN THE Designation of Witnesses and Summary of Evidence is not listed in the
certi cate of mailing, nor is it file stamped upon a review of the bate stamped filed box
that omehow took 7 days to copy (because Pat King needed to go back through it and
rem 'e the certified mailing slips for which the SBN had not secured a signature trom
Cou lin, including the NOITD (hecause the SBN placed insufficient postage thereon, and
Tim, counter attendant at the Downtown Reno Station would not release that 10/9/11
NO! D unless Coughlin paid the SBN"s postage, which he clearly is not required to
do". 'urther, the Supplemental DoWSoE was not served in accord with SCR 109
cons enng the policies, rules. and practices the SB>';, NNDB. and Panel held out to
Cou lin and upon which he justitiably relied. Basically, the entire hearing must be
thro 'n ouL mistrial, reeusal of Echeverria and Kent. and King is conflicted out too,
My issues with Ms. L,mgoni related primarily to her hanging up onllle on more
than ne occasion in December 2011 when I was attempting to comply with the dictates
she
the Reno MUnicipal Court put forth to criminal appellant's, including ones like me
who 'ere indigent at that time,
ESS
the r
vital
pote
gctti
I need the materials I am requesting above immediately, n\lF. IS OF THE

NCE with respect to a number of actions I must take to preserve my rights, and even
ughest draft of the transcript and the audio recordings made that day are completely
0 my protecting my rights, I believe you would be substantially mitigating your
tialliability by having these emailed to me immediately, though you should consider
g counsel from your own attorney in that regard,
and
mail
TR
duri
only
as d
RM
189,
Further, I believe your fiml and or Ms. Longoni may still be required to prepare
ovide to me the transcript for 11 CR 22176, (I am providing you via a cd/dvd in the
d a link to a SkyDriw contalling tbe audio therefor) as well as the transcript for 11
800 (a notice of appeal was filed on Y7! 12 and again sometime thereafu:r, and
that time the RC\! contiuued its illegal practice of holding ~!s. Longoni out as the
'ourt reporter it would release the audio recordings to (certified or not), and further,
onstrated by the attached handout given to all criminal defendant appellants by the
, Ms, Longoni and the R.\IC maintained a practice that was violative of NRS
30:
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Fro;: mhcoughl1n
NRS 189,030 Tran,mission of transcript. other papers, sound

recording and COpy of docket to district court,
18
- 40;7]-
MOTION FOR MISTRIAl, OR COKTINAC
10: 7clfl1e9-fcc8-461a-8eDf-lea559b
From: mhcouqhlin
11-19-11
8:11am
I. The justice shall, within 10 days after the notice of

appeal is tiled, transmit to the clerk orthe district court the
transcript of the ca~ all other papers relating to the case and
3
4
5
6
a certified copy oflhe docket.
2. The justice shall give notice to tile appel/ant or tho,)

appellant's attomey that the transcript and all other papers
rdating to the case have been filed with the clerk of the district
court.
3. If the district judge so requests, before or after receiving the
record. the justice of the peace shall transmit to the district
judge the sound recording ofthe case.
9
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12
1S
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I am prepared to move forward with respect to pursuing whatever lawful action I

may c in connection with thiS impermissible connict of interest (which I bdieve I can
prov you knew full well about) in addition to the misconduct by :VIs. Longoni in
COM ction with R\1C 11 CR 22176. 1\ic" touch having Judge Linda Gardner's courtroom
depu work the hearing.
Coughlin hereby demands that the SB1\ comply with the agreement and rules
requ ing tile SBN reveal tbe nanles of the Screening Panel members from the hearing on
ut 4/ lOil2. Pat doesn'l get around to saying he meant the "Clerk of Court" of a
en! in the R:VIC. even though the Order is from Dl4 of the Second Judicial
Dis ct Court (wbose courtroom deputy worked the 1J!14! 12 Disciplinary Hearing along
with ne ofPant Longoni's coworkers ... Carol Hummel (no offense to :V1s. HummeLl
hI
Pat King and or Susich here. as King is now backing out of an agreement to
indi c who was on the Screening Panel and the Panel for the Hearing was obviously
hand picked to arrive at the most bia~cd crowd available or possible.
21
3. Review by supreme court.

22
23
25
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27
(a) Time and manner of appeal. A decision of a hearing

panel shall be served on the attomcy. and service shall be
deemed Notice of Entry of Decision for appeal purposes.
Exc~pt as provided in Rule I05(3)(b) a decision is final and
effective 30 days from service. unle,s an appeal, is taken
within thal tunc. To the extenl nol inconsistent with th.:sc
rules. an appeal from a decision of a hearing panel shall be
treated as would an appeal from a civil judgment of a
district court and is governed by the Nevada Rules of
Appellate Procedure.
- 41:71-
:VIOTIOi' FOR MISTRIAL OR CO'{UNAl:
p. 41 of 71
, To, lcJll1e9-fcc8-461.-8eOf-le.559b
From: zachcoughl1n
11-19-11
8,11,.
(b) De novo review of public discipline. Except for

disbarments hy COllsent pursuant to Rule J 12 or a public
reprimand agreed to in writing by the attorney pursuant to
Rule 113, a decision recommending a public reprimand,
suspension or disbrument shall be amomatically reviewed
by the supreme court. Review under this paragraph shall be
commenced by bar counsel forwarding the r~ord of the
hearing panel proceedings to the court within 30 days of
entry of the decision. Receipt oflhe record in such cases
shall be acknowledged in writing by the clerk of the
supreme court.
2
3
5
6
7
The attorney and bar coutL~el shall haw 30 days from the
date the supreme court acknowledges rereipt of the record
within which to file an opening brief or otherwise advise
the court of any mtent to contest the hearing panel's
findings and rcc'Ommendations. If an opening hrief is filed.
briefing shallthcrcafkr proceed in accordance with :--IRAP
31(3). Extensions of time to file brief.s are disfavored and
will only be granted upon a showing of good cause. 111e
parties shall not be required to prepare an appendix. but
rather shall cite to the relXlrdofthe disciplinary
proceedings. If no opening brief is filed, the matter will be
submitted for decision on the record without briefing or
oral argument.
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11
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15
4. Rules of procedure. The chain;, after consulting with

their respective disciplinary boards. may adopt rules of
procedure, subject to approval by the board of govemon;.
IE
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1. In general
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21
22
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24
2S
26
Viol lions of professional ~onduct rules not charged in attorney disciplinary complaint
coul not be considered by Supro)ll1e Court. Inre Discipline ofSchaefc'f, 2001. 25 P.3d
191. 17 Nev. 496_ modified on denial of rehearing 31 PJd 365, certiorari denied 122
S.O. 1072, 534
U.S. 113!. 151 L.Ed.2d 974. Attorney And Client 52 SO COCGHLIN OBJECTS TO
KIN' AND ECHEVERRIA'S ATrEMPTS TO -[URN mE I lil 4r1 2 HEARING IN
TO ME Sl'M\{ARY DISCIPLINARY PROCEEDIGN FOR DECLARA11O).l
M INO L\J mElR PRESENCE. WHEmER LEVERAGr-IG PAST FILINGS
REB A.NDEDOR NOT..
2. D e process
2)
:'8
Proc dure in which Board of Governors. the body responsible for finances of bar
asso iation. fUllctiolled as factflnder in disciplinary proceeding against attorneys.
- 42(71-
MOTION FOR MISIRIALOR CONTIl\AC
p. 43 of 71
To: lt3f21e9-fccS-461a-S.Ufle,SS9b
Fr~:
zachcDugblln
11-19-11
8:21am
invo ing cost. which were substantial and which were recoverable by state bar only
upon finding of misconduct. violated due proe,"" Sup,Ct. Ruks, Rules 85, 85. subd, 2.
86, S Ibds, (14. 7, 12), J()4, subd. 7 (1978); U,S.C.A, CoustAmend. 14, \-Iatter of Ross,
1983 656 P.2d 832,99 Ne\,. 1. rehearing denie<l668 P.2d 1089,99 'Nev. 657. Attorney
And lien! 54; Constitutional Law 4273(3}
lndi
their
wou
desp
sub
'dual memb.,'1'S of disciplinary board had no personal financial stake in outcom.; of

.Iiberations and no executive responsibilities for finances of state bar which
be inconBistent with due process requirementl; for disciplinary proceedings.
e potential for recovery by bar of fines and costs. Sup.Ct.Rules, Rules 86, 103,
,1. 3; U,S.C.A.Const,Amelld.
14, urleigh v, State Bar of Nevada, 1982,643 P.2d 1201,98 :\ev. 140, Constitutional
Law 273(3)
State cannot exclude person from practice of law without due process oflaw,
.A.Const.Amend 14. Burleigh v, State Barof1'evada, 1982, 643 P,2d 1201,98
Nev,
e,s .
nstitutional Law 4273( I)
11
]3
ce of a profession is valuable property right, of which one cannot be arbitrarily

de ed. U,S.C,A,Const.Amend, 14, Burleigh y, State Bar of~evada, 1982,643 P.2d
1201 98 Nev,
14
:'..2
1S
I violations by attorney must be proven by dear and convincing evidence. In re

line of Schaefer, 2001. 25 P,3d 191. 117 Nev. 496, modified on denial of
ing 31 P,3d 365, certiorari denied 122 s,Ct, 1072. 534 e.g, 1131, 151 L.d.2d
ttomey And Client 53(2)
16
13
19
21
22
In b
proc
Sup.
III
disciplinary matters, higher degree of proof is required than in ordinary civil

edings; clear and com~ncing evidence must support any findings of misconduct.
t.Rules, Rule lOS, subd 2(e). In rc Discipline of Draklllich, 1995. 9()& P.2d 709.
ev. 1556. Attorney And Clienl 53(2)
In
nnining questions of fact. bigher degree of proof is required in disciplinary
matt ban in ordinary civil proce~dings; standard is whether findings are supported by
clear and convincing evidence. Sup,Ct.Ru\es. Rule 105, subd, 2(e). In re Discipline of
Stu ,1992,837 P.2d 853,108 Nev. 629, Attorney And Client 53(2)
2')
24
26
27
To d
disci
sup
v, S
669.
termine questions of fact. higher degree of proof isrequired in attorney

linary matters, tltan in ordinary civil matters; standard is whether tindings are
rred by clear and convincing evidence. Sup,Ct.Rules. Rule 105. suhd, 2(e). Gentile
te Bar of Nevada, 1990, 787 P,2d 186, i06 Nev, 60. cct1i"rari granted 11 J s,Ct.
98 U.S. 1023, 112 L.Ed,2d 662, reversed 111 S.Ct.2720. 501 C.S, }O30, llS
L,E 2d 888. Attorney And Client 53(2}
5. R ommendation of board
28
- 43171 -
MOTION FOR MISTRIAL OR CQ~TINAU
p, 14 of 71
, To: lcJf.l1e9-fcc8-161a-8.0f-l.a559b
1
2
3
11-19-12
From: zachcongblln
8:11..
Alth ugh recommendations of disciplinarv panel are persuasive, Supreme Court is not
boun by panel's findings and recommendation, ami must examine record anew and
ex ise independent judgment. in attorney di~ciplinary proceeding. In re Discipline of
Scha fer, 2001, 15 P3d 191. 117 Nev. 496, mWified on denial of rehearing 31 P.3d
365, ertiorari denied 122 S.C'!. J072, 534li.S. 113 1, 151 LEd.2d 974. Attorney And
Clio t 57
Dis linary board's recommendation is not final and binding upon Supreme Court, even
thou h attorney has consented in writing to Board's decision. Sup.CI.Rules. Rule 105,
subd 3(b). Matter of Kenick, 1984, 680 P.2d 972, 100 Nev. 273. Attorney And Client 57
,
"
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Hi
Atto ey was not entitled to continuance of second hearing date in attorney disciplinary
proe edings to obtain counsel. on basis that second hearing was reset for January 4. not
later the month, and attorney not able to find new counsel because no one wanted to
wor on his case over the holidays. where attorney stated on the record that he needed no
mOfe than one week's notice of the continued hearing. and was aware from "!ovcmb.,,"I' 17
that e needed to find counsel immediatelv, attornev was notified no laler than
,
Dec ber 6 of new hearing date. and even from December 6, attorney had four weeks to
obtai new counsel and to prepare for the continued hearing. In re Discipline of
Scha fer, 2001. 25 P.3d 191, 117 Nev. 496. modified on denial of rehearing 31 P.3d
365, ertiorari denied 122 S.Ct. 1072, 534 U.S. 1131, 151 L.Ed.2d 974. Attorney And
Cli 54
~
ASSCMING THERE HAS BEE"! SERVICE OF THE Cm,1PLAINT,

WHI H HAS NOT BEEN SHOW, COUGHLII\ REQUEST HIS FIRST
CO, TINUANCE ...
Sup. t Rules, RULE 105, I\V ST S CT RULE 105
1/
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NRCP RULE 12. DEFEl\SES AKD ODJECTIONSWHEN AND HOW PRESENTED BY PLEADING OR
MOTIOI\--1fOTIOl\ FOR JUDGMEl\T O\'
PLEADINGS
22
(a) When Presented.
23
(1) A defendant shall serve an answer within 2() days after

being served with the summons'and complaint, unless
otherwise provided by statute when service of process is
made pursuant to Rule 4(e)(3).
25
23
Coughlin was never serVed with the Summons and

Complaints under SCR 109. and Bar Counsel cited no
authority to support it. apparent, contention that merely
mailing a c~rtitied mailing purp?rting to included the
- 44i71 -
:"1011ON FOR MISTRIAL OR COl\'I1NAC
p,
45 of 12
To: lcJfl1e9-fcc8-161a-8eOf-leII19b
,
1
2
6
7
3
9
JC
11
From: lachconghl!n
Complaint is sullie!ent, especially where, as here. Bar

Counsel and the SHN made representations Coughlin wa'
permitted 10 reply upon to the 'ellec that the 8i23!12
certified mailmg Bar Counsel asserts would newr be
offered as proof of or return of service.
(2) A party seryed with a pleading stating a cross-claim
against that partY shall serve an answer thereto within 20
days after being'served, 'l1,e pl~intiff shall serve a reply to
a counterclaim in the answer within 20 days after service of
the answer or, if a reply is ordered by the court, within 20
days after service of the order. unless the order otherwise
directs.
(3) lhe State of Nevada nr any)olitical subdivision
thereof, and any officer, employee, board or commission
member of the State of Nevada or politkal subdivision, and
any state legislator shall tile an answer or other responsive
pleading within 45 days after their respective dates of
service.
12
c3
IS
10
(4) 111e ,,,rvice of a motion permitted lInder this rule alters

these periods of time as follows, unless a different time is
fixed by order of the court:
CAl if the court denies the mOtion or "oSUlOnes its

disposition until the trial on the merits, a respoosive
pleading shall be served within 10 davs after notice of
the court's action;
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"
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11-19-11 8:11am p, In nr 11
<.1tair Echeverria's Order purporting to require

Couglin tile averitied Response in less time than allotted
upon lilly purported ruling ~ Coughlin's Motion to
Dismiss, makes holding the Hearing 00 llf14/ll and
and Order cOlUlected thereto.void (even whether Bar
Counsel has perpetrated a fmud in standing hebind a
certificate of mailing that is knows is not true as to ~
October 9th, 20ll certified mailing only (ill contrast to
practically everything else the SB:" mailed, according to
its certificate's of mailing, the SBN sent the 10912
Notice of Intent to Take Defanlt by certified mial only,
ie, it was not sent >ia Ilrst claSs mall as weD).
(B) if the court grants a motion for a more definite

statement, a responsive pleading shall be served withm \0
days after service of the more defmite statement.
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MOTION FOR MISTRIAL OR CQ:\TIN AU
To: 1,)f?le9-fcc8-461a-8eOf-lea559b
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Flom: zachcougblln
11-19-11
(b) How Presented. Every defense, in law or fact, to a

dalm for relief in any pleading, whether a claim.
counterclaim, no.8-claim, or third-party dalm, shaH be
asserted in the responsive pleading thereto if one is
required, except that the foUowing defenses may at the
option oflbe pleader be made by motion: (1) lack of
jurisdiction over Ihe subject malter, (2) lack of
jurisdiction over the person, (3) insufficiency of process,
(4) insufficiency of service of process, (5) faDore to state
a claim npon which relief can be granted, (6) failure to
join a party under Rule 19. Amotion making any of these

defenses shan be made before pleading if a further pleading
is permitted. :>10 defense or objection is waived by being
joined with one or more other deren~cs or objedions in a
responsive pleading or motion. If a pleading sets forth a
claim for reliefto which the adverse party is not required to
serve a responsive pleading. the adverse party may assert at
the trial any defense in law or fa.:t to that claim for relief.
If, on a motion asserting the defense numbered (5) to
dismiss for failure of the pleading to state a claim upon
which relief can be granted. matters outside the pleading
are presented to and not excluded by the court, the motion
shall be treated as one for SU1lU1lary judgment and disposed
of as provided in Rule 56, and all parties shall be given
reasonable opportunity to present all material made
pertinent to such a 1I10tion by Rule 56,
Couglin presented all the above hoJded defense and

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

enumerated (1)(6) in subdivision (b) of this rule, whether
made in a pleading or by motion, and the motion for
judgment mentioned in subdivision (c) of this rule shall he
heard and determined before trial on application of any
party, unless the court orders that the hearing and
detennination thereof be deferred until the trial.
(e) Motion for More Definite Statement. If a pleading to
which a responsln pleading is permitted is so vague or
ambiguous that a party cannot reasonably be required
to frame a respollSive pleading, the party may move for
a more definite statement before inkrposing a
responsive pleading. The motion shall point out the
- 46/7J -
MOTION FOR MISTRIAL OR CO:\IINAU
8:21am p, 11 of 11
To: 7cJfl1e9-fcc8-467a-8eOf-lea559b
6
7
10
11
12
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IE
Ftoo: ,achcough]!n
defect' complained of and the details desired. If the motion

is grdl1tcd and the order of the court is not obeyed within 10
days after notice of the order or within such other time as
the court may fix. the court may strike the pleading to
which the motion was direeted or make such order as it
deem;; just.
(I) Motion to Strike. Upon motion made by a party before
responding to a pleading or. if no responsiw pleading is
permitted by these rules, upon motion made by a party
within 20 days after Ihe service of the pleading upon the
party Of upon the court's own initiative at any time, the
court may order stricken from any pleading any insufficient
defense or any redundant, immaterial, impertinent, or
scandalous matter.
(g) Consolidation of Defenses in Motion. A party who
makes a motion under this rule may join with it any other
motions herein provided for and then available to the party.
If a party makes a motion under this rule but omits
therefrom any defense or objection then available to the
party which this rule permits to be raised by motion. the
party shall not thereafter make a motion based on the
defense or objection so omitted, except a motion as
provided in subdivision (h)(2) hereof on any of the grounds
there stated.
[As amended; eflective September 27,1971.1

(h) Waiver or Preservation of Certain Defenses.
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(1) A defense oflack of jurisdid ion over the person,
insufficiency of process, or insufficiency of service of

process is waived (A) if omitted from a motion in the
circumstances described in subdivision (g), or (D) if it is
neither made by motion under this rule nor included in a
responsive pleading or an runendment thereof permitted by
Rule J 5( a) 10 be made as a matter of course,
2E
(2) A defense offailure to state a claim upon which relief

can be granted, a defense offailure to join a party
indispensable under Rule 19. and an objection offailure to
state a legal defense to a claim may be made in any
pleading pennitted or ordered under Rule 7(a), or by
motion for judgment on the pleadings, or at the trial on the
merits.
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(3) Whenever it appears by suggestion of the parties or

otherwise that the court lacks jurisdiction of the subject
matter, the court shall dismiss the action.
1-3
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- 47f7l-
MOTION FOR MISTRIAL OR CO:-.JTINAC
ll-lH2
8:21am
p, 48 of 12
, To, 7c3(17e9-lccB-461a-BeDf-lea559b
Froo, ,.chcouqhlln
11-19-11
HI..
http://sdrv,msrn4dYf
2
3
Also available at that link is the tran~cript from the criminal trespass Trial on 6118112
Hill and Baker testify, before Judge L. Gardner's (whom recused herself from a
oughlin represented Robert Bell in, filed August 11. 2011, which further proves that
lin was a commercial tenant practicing law at the 121 River Rock address,
ling pled in Coughlin's Tenant's Affidavit and set forth repeatedly ad nausuem
hout the trial court case, which Hill mistakenly alleges. in his lie filled testimony at
the c 'minal trespass tria!, that Coughlin "did not plead" that he was a "commercial tenant"
12
trial court eviction case. Wrong, Mr. Hill, 'Ihe record is quite clear that Coughlin
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did,
d Judge L. Gardner's recusal (and Judge Flanagan's Presidency of the SBN during
is
a pe ad of time in which Coughlin now has pending grievances against members of the
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Char Cler and Fitness Committe further complicates matters and augured for a recusa!, , .
beyo d the apparent bad mouthing of Coughlin by Judge Flanagan and Coughlin's former
13
firm, where they were hoth a part of at the same time in 2005, to the CBX (unless the CBX
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is ly' g or bluffing, which is entirely possible. as anyone who has ever met a bar counsel
71
caul tell you) is just another r"<lson why rccusal was appropriate. Additionally, the
lock ut pursuant to the eviction Order, whether the Eviction Decision and ORder of
Octo er 25th, 20 11 or the Findings of Fact, Conclusions of Lw .... oflOi27.:11 (depending
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on h, w one view NRS 40.253'. "within 24 hours" dictate) "as either performed to early or
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too I ter, and therefore the Order wa' stale or
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void t time WCSO Machen and Baker conduted the lockout. (too early tmder the analysis
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resp ting the application, via nes 40.400 ofNRCP 5 and NRCP 6 requiring 3 days for
- 48:71-
MOnON FOR MISTRIAL OR CQl\'TlNAU
p,
49 01 71
From: zachcDugh11n
To: 7cJf,17eHccB-467a-8,Of-7ea559b
8:11am
g for "constructive service" of such and Order. and ""yond that the Second Judicial
1
2
11-19-11
Dis ct Court appears to have refused for filing from Coughn a filing that may have
opel' ted as a MOtion to STay under NRAP 8 sometime ""tween October 26th. 2011 and
Nov mbcr 2nd 2011 in CVII-03051 or CV 11-03126, in violation of Whitman, Sullivan,

5
Don ho and NRCP 5(e)'s dictate against clerk's rejecting filings regardles of what a local
rule ay,) or the lockout was conduct too late in light of the testimony by Baker
cone ruing how and when the wCSO received the lockout order or .ith.r oftbe eviction
(Baker indicated his office relied upon the usual practice of the RJC to transmit it to
10
the
eso, but curiously the RJC seems to now assert is has no record of slich a
11
12
trans ission, and the WCSO is lawyering up when it comes to such inforulation.
13
He
an Y. Style Line Greetings. Inc., 289 So.2d 876
14
La.
pA.Cir.,1974Where eviction proceeding was taken under advisement and judgment
1.,
ction wa., rendered on following day and out of presence of counsel, statute
16
ing that if court finds

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lesso or owner entitled to relief sought. court shall render immediately a judgment of
evict on
ord 'lIg delivery of possession of premises to lessor or owner had not been complied with
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and j dgment was invalid. LSA-C.C.P. art. 4732.
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RIchard G. HIli. Hsq and Casey Baker, hsq(who has now convenIently absconded hack to
Ken
ky now that his he< have imperiled Coughlin's law hoens. (see Coughlin's recent filing in 61901 and
6083 for more e:-"'Plication thereot) fruled to com ply Wtth Nevada law respectmg the return ot C-Ough)m's
seeun Jdamage!cJeaning deposlt (S500 for .socuntyidamage, $200 for "cleaning" deposit, wnh the Standard
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Renta Agreement givmg Coughlin certain optwns thereto). Coughlin is mdigent (largely due to the fraud of
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Bake Hlil. and thelT chent Dr Matt ~1erJis,. MD) and asks thlS Court to recogntze that the f",lure of the
land] d to comply wnh Kevada law VIS a vis the ltemizallon or return wlthm 30 da)~ of the dePOSlts should
- 49:71-
MOTION FOR MISTR1A.L OR CO!,\TINAl!
p. 50 of J1
, To: lcl!11e9-fccS-461a-SeDf-lea559b
From: zachcoughlln
lH9-12
8:21am
fulfill ny $500 bond on appeal and then some Further, the Reno Jushce Court lS ,till refusing ill return the
$250 "ushl;n deposited with it in cDmpl ..nce With :-IR8 118A.3S(1 and I i SA 385 (fur1her. It" not clear
3
how JCRCP 72 or 73 could apply to summary eVlchon (even ones hke thiS one that were notIce. In wntIng,
by th RJC, a, a "TTlal" after Judge Sferrazza had ruled that Coughhn had met hi, NRS 41).253 burden to
prove here Wrui a ~genuine Issue of matenal fact~. both at and followmg the I U!J3f t I "summary eVIction
proce dms" and during the first part. at least, of the 'Trial' which curiously transmogrified Imo. apparentl)'.
ng other than a Tnal when Baker managed to pornt out, the consequences thereof Regardless,
S
lin filed a Nottce of Appeal on October 18th, 2011 (and see also the appeal and associated general
amplamt m the [)tstnct Court). Abo, court clerk's MIChelle Punlee and or l.on Matheus seemed ill
1C
to file in a document from Dlughhn sometime between October 17th to )iovember 1st, 20ll that may
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uably operated as a NR"J' 8 "-lotion to Stay, In violatIOn of the dictates in 'le\'ada law against court
12
clerk' unilaterally refusing to fik thing'. like in Whitman, Sullivan, Dohono, Barnes, and thelT progeny.
13
Fur1h r,
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'low the SEN Intends to hold. hearmg on November 14th. 2012 pIlIlIuant toils SCR 105
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ainl agatnSl Coughlin wherein all ;ubpoen. by C"ughhn are sought quashed, eVen where the SBN
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t Judge Dorothy 'lash Holmes will appear by phone to answer questton (but apparently not testilY,
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and s e hasn1t recused herself trom the two matters she ha.s Coughlm a.:; a cnmmal defendant before her m)
Itn totally object' ot Judge Nash Holmes phorung 1t In, "'P"cially where her 3n 4112 gnevance to the
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ng12.0434 and the possIble ghostgrievancing done in ng12-0435 (in concen Wlth RMC jUdge W.
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Gar
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atlem ts to allow RMC W Gardner to avOld recusmg himself from the richard hill signed cnminal trespass
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comp int in 11 cr 26405, .It may be nece$aty to check up on nne Judge w, gardner's 2127/12 order
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transf mng JUTt<;dlCttOn ot the 'nchard hdl mcuced JMuary 12th, 2012 custodml arrest ot coughhn fOT
r and his sister "''DC Family Dlurt Judge Unda Gardner and SBN's Pat King and Laura Peters m
iayw ktng m RMC 12 cr 00696 (and camider ailihe copymg and or eraSing of Cough1m's laptops,
smart hone~ and data Cllrds incident to all this arrests under State v Dmz, including the in court arrest on 11
2\'.5
ith nne Judge howard in RlvIC 11 cr 22176 (which resulted in this Court's 617!12 tern pcrary
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sus
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mars Is (marahal harky lied during the SITA and lssued wr<cuvc to another marshal to go repeat his lie to
lon of Coughlin's law license) (summary contempt for saying "wow" ..and the 2127112 arrest by reno
- 50,71-
MOTION FOR ~USTRIAI. OR GONIINAC
p. 51 of 12
To: 7cJ!11e9-fcc8-461a-8eOf-leaI19b
From' ,achcoughlln
11-19-11 8,11am p, \1 of 11
Judge ash Holmes findmg a smartphonc during a SIT A does not entitle Harley to bark out "got tell judge
2
llilsh alme; Coughlin lied! He w", recordmg', or for judge 1\ash Holm"" to lalOr. m the tape from the
3/12/ 2 hearmg
phon
In
In
11 tr 26800 to mdlcate some ma~halt told her he saw Ccughnilis.';essmhtmg a smart
the bathroom stall (thlS would have been before Judge :-lash Holm"" even asked C<>ughhn any
quest' ns regarding rccordmg or recording device; whatever she meMS by "recordmg device" (wouldnt
every .plep brought with any defendant or I.wyor \l., a "w:oro.illg dice" undor Judge Holmes apl"'fent
7
analy IS?) to tesufy wIth regard to Respondent's conduct ill connectIon WIth Cas. No, II-TR-26800 12 tn
Reno uniClpal Court
Incident to Judge "ash Holmes "summary CrimUlal
lJ
contempt" Order against Coughlin within the traffic

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citations issued to Coughlin outside Richard !Iill's law

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office after Coughlin showed up to get his ;"jarshal harley
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violating the courthouse sanctuary rule, on behalf of wcso

deputy machen, whom hill sent to the 2/27112 trial
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regardmg the richard hill traffic citations of IlIISill to

serve coughlin the ORder 10 show cause for the 3123112
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Hearing in the richard hill evi~"1ion appeal in cvll-OJ628,

based upon a fraudulent motion to show cause and
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declaration filed by IIiIL his associa/< Casey Baker, and
Hill', ttusy licensed contractor, NBl's Phil Stewart

to havmg been informed by the Washoe County PublIc Defender's OffIce of the Order for
ncy EvaluatIon directed Ie Coguim m RCR20l2-06'630 (the retaliatory "mISuse of911" custodial
d prosecu(lOn Incident Ie an art""( made by the same RPD Sargent Slfre, on I;WI2, who ordered
arrested by then trainee Officer Wesley Leedy (whom applied exc"""ive force to c,'ughlin, out of
and p"ar to any sort of warrung, along wub another chshonora ble and shameful RPD Otlicer TravIS
- 5Ji71-
MOTION FOR MISTRIAL OR CO;'\TINAC
To: 1cJ!11e9-fcc6-467.-SeOf-)ea559b
from: I.<hcoughl!n
11-19-11
S:11..
Look, all captured on video tape as well (though Panel Chair ruled all of that inadmissIble as well .though
2
that p ding jaywalking prosecution was not ruled Irrelevant or dl>missed form King's Complaint
Some ow, Chalf Echevema accepted Kings argument that VIdeo tapmg of events did not provlde rehable
evlde ce of what happened... rathcr. banng Rlcbard Hlil and the McOemge Mafia cmoe m an wTech ,hop on
a car r of Coughlin's thot was many yean; In the making (and all III Nevada mine you. from kmgdergarten
law school) (m February 2009 Eleano had admitred to C.oughhn that he asked several Judges,
mg Master Edm oroon and Judge Lmda Gardner what they thought of Coughlm's work before them
t both ofmose Judges gave Coughlin a positIVe review .. ,and at that time Elcano also stated that 'and
Judge Lmda Gardner owes me because I dld a bIg. btg lavor lor her a long tIme ago ,.50 II she say's your all
1J
en,' Elcano has also finally managed to get \\lLS's fmgers m the pIe that IS the EeR program that
11
en; with the Washoe County DIStrict AUorney's Office WIth in denying indigent cnminal defendants
12
IXth Amendment Rights (an R.\1C Court appointc<i defender, Lew TatteL was onglllally Coughlm's
13
led counsel in the Donme and '.Jane conflIct yet no recusal cnmmal Ires!",ss complamt SIgned by
1;
d HIll (whom also got Coughhn subject to a custodial arrest for 'jaywalking' on January 12th, 2012,
15
t to HIIlI)1ng to RPD Otlicm that roughlm :'has lost hIS appeal" (though the appeal was not deCIded
16
until. 13\)/12 . Further, lhll filed a Declaration on 1,2t}!12 m that appeal ('\,]]03628 wbch clearly contams
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nume ous hcs when revIewing the Video tape of that incldcnt....and 61901 further prOVides VIdeO evidence of
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t to which RIchard G Hill. Esq "allowed to rerrorize the citizenry of Wash"" County WIth his hes
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bo lltigatlon taCtlS, all WIth more than a Imle enabhng by a cadre oflocal Judges) and the court
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led defender for Couglin (KeIth Loomis, Esq. Mc\1lX)rge SOL, Clas, of 1982) who has managed to
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a paycheck willie twIce rdilstng to advocate on Coughlm's behalt (garnermg two Orders grantIng h"
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awol by R\1C Judges, one,
In the
cnmmal trespass ca."" (61901) that Judge William Gardner refused
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to ree se himself on, sremming lrum Richard G. Hlil,Esq Iymg to and WIth the potic< m II CR 26405, even
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whe! Judge Gardner then had a pemll1lg grievance ,gainst Coughlin (NGJ2-043S. wherem Judge Nash
,'5
Holm, filed one on "behalf of all the RMC Judges, from wh,," you will have OUt full cooperauon" and
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assi' co in carrymg out a scheme to discredtt and d<>lroy Coughlin that they "planned out" "very carefully"
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(Judg Nash Holmes hed dUTlng Coughlm's II,'! 4i12 Dlsclplmal), Heoflng when she testlfJed under oath that
23
she h
(because of some unattnbuted hean;ay that Panel Chair Echevema would not let CAlughlrn ask
-
5~nl
MOTIW FOR MISTRIAL OR COXTll\' A!J
p,
53 of 11
To, 7c3f1].9-fccB-467a-8.0f-l 119b
It"", lachcoughlin
11-19-11
8,11..
foHm up question.') on) 'jheard Coughlin likes to record things" and that upon her questioning about whether
he wa r<cording fu< proceodings and (~ had a recording dev lee Coughlm during that traffic tIcket tnal,
:3
Holm s testifIed that Cough 1m uumedJately grew very shltfy and unc~)mtortable and :;!iked to be allowed to
use th restroom, whereupon Holmes ordered RMC Ivfarshal Joel Harley to follow Coughlm mto the
ba
recor ing deVIce m the bathroom and leav ing portion of it in fu< bathroom, which the RMC Marshal
dISCO
Two, udge J\ash Holmes lied under oath when she testifieJ that she asked Coughlin any questions
whats ever about recordmg devIces or recordmg the proceedmgs pnor to the ONE rcstro(')m break that Judge
om, whereupon Judge Nash Holm .. testified that Marshal Harley wltneSSi CoughndisasS<ll1bling a
ered later) One, than," god damn Ite CoughlIn did not disassemble anythmg In the bathroom,
10
Nash Iobnes allowed before she had Coughhn arrested for the trm1sdemeanor of crlmmal contempt. NRS
11
22.01"
12
AFT
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certifi d audio of the Tnal clearly reveals there was on., and only one restroom break and that, clearly,
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Judge -ash Halites asked Coughl1O questions related 10 recordIng or havmg reoordmg deVices only AFTER
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that 0 e restroom break Judge Nash Holmes clearly hed dunng hertestlll10ny 10 that regard, seekIng to
16
rewnt the orders of events in an attempt to suggest that she interrogated Coughlm (sua sJX1nte, of course, as
Judge I\ash Halite> lied during her>wom testimony in ,.ying thal the onerestroom break carne
she tnterrugated COughllO about whether he had an recording dey IceS or was recording The
17
ont, wherein she mIXes In her expen,n.es as a prison warden type With her lIfelong devotion to
:s
prosecutor, wiretapping attorneys, etc ,etc ,;"k Henry Sotelo, Esg , the R.\!C defender that says he
19
law for awhile completely gIven what a temhle taste was left 10 his mouth after working under her '
2J
he was the Washoe County DistnctAttomcy In 1993-19% orso ,or ask the Wash"" Ccunty Deputy
21
who Coughlm overhead, dunng one ofius several trips to the Courthouse (It wasn't Cummmgs, and It
22
wasn' the Hawanan one, but Lt was the other one) r<veal the extent to which he felt Judge ,am Holmes was
Iy out o[her mtnd and inordinately punitiVe, sentencing a youth whOJl1 she had the week previous
2:J
24
"put i some hug a thug progrdl1l" to six monlhs in Jail following his reappeamng before her one week later
25
after aving bee arrested for "Ja)'Walkmg", (As to her 2(2&'12 and 3/1:.'12 Orders speakmg to the
pt convICtion" actually, Judge :;ash Holme; JuSt chose the most penal aspects o( a vanety of
26
27
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cnm
1 and CiVll
contempts statutes, along WIth making a pastiche ot the-cse sanctlons r(quinng the least
cess attendant thereto, and also managaed to transmognfy the "Simple traffic cttatlon tnal ll mto a fuJI
- 53171-
MOTION FOR MISTRIAL OR COI'TI!'iAC
p, 51
of 11
To: 7c3f17e9-fccB-467a-BeOf-7ea559b
11-19-11
rco.: ,acheoughlln
B:11..
blow isciplinary Hearin& whereupon on Ft:bruary 12th. 20I~: shl! took another bite at the apple (not
satisfi d with her 1':8111 Contempt Finding and Ord" of Sanctions or the fact that she and her Court
promi d Coughlm's mother that hcr payng S1()!) 00 would get Coughlin rel""sod one day early on the
unfa
Tart< lied when he .. : (BOOM. Coughlin didn't oven gello firush his sentence .. Judge Nash Holilles
imme lately found ('",ughlin in contempt and had him cuffed, and laughed at tit< idea of grantmg any sort of
stay tallow Coughlltl, then a licensed attorney, and opportUnity to make ammgements for hIS client's
intere
"sad ned hIm' to thtnk of the 3 day contempt mC8rcerallon that he hlffiselt ordered upon Coughlm to start
lJ
"able 5 day Jail sentence she ,,,dered to start Immediately after Coughlin Idlfied that "RPD Sargent
Is to
avoid being prejudiced Judge Kenneth Howard, CVlcGeorge SOL, '81), while noting that it
Imme ately following the 111.10/11 rendlbon of the conncbon of petty larceny of a 'candy bar and some
In
11
drops" (at the Wal-Mart lhat is on land rented from th.lndian Colony, in an atTost made by tribal
1:2
polic for a misdem.anor-Wal-Marts Thomas Frontino tesbfied that neIther he nor anyone WIth Wal-Mart
13
made citizens arrest on 9/9/11 of Coughlin) that VIolated the law m that l\1{S 171.1255 forblds tribal police
14
from
IS
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21
22
23
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25
2E
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akmg arrests other than those lot gross misdcm ",nors and felonies.
whom appears to be relared to
el Smtly Rowe, Esq, a person whom Coughlin had mdlCated would mvoked a contllct upan a showmg
of su lelen! connection thereto ... )
cLERK OF cOURT Laura Peters (the SBN has filed not proof of service of the
ns and complaint sufficient to satisfy SCR 109 in view of the representations made
by t State Bar of Nevada, including those by Laura Peters on the phone and in'M'tting
to C ugh lin and found in Peters Affidavit on file in this matter. The first aUeged certified
maili 9 of 8123112 is not suffICient to show service ooere Peters herself (and this is
spok n to in her affidavit) represented that the SBN would not be attempting to use ~ to
proo service of any sort of the Complaint, but rather, Peters would send, soon after
Sept mber 11th, 2012 a certified mailing copy of the SCR 105 SBN v zach Coughlin
com laint to Coughlins SCR 79 address, and that the complaint would not be deemed
serv d or by the SBN, nor muld the SBN attempt to represent in any way that ~ had
bee served, until zach coughlin had Signed the return receipt requested and or certified
lette signature card and it had been received by the SBN.
2. 11 14112 hearing go forward, ooich it clearly should not, at least not in its current
unb' rcated, due process violating, unnoticed, no service of the 10/9/12 NOtice of INtent
to T ke Default, no "at least 30 days" service 'of the Designation of Witness and Summary
of E idence BY THE PANEL NOT BY JHE SBN. BAR COUNSEL, OR JHE CLERK
OF H
, under SCR 105(2)(c)
an v. Style Line Greetings. Inc., 289 So.2d 876
28
- 54171 -
MOTION FOR MISTRIAL OR
co~mlAl;
p,
55 of 71
To: 1cJfl1e9-fcc8-461a-8.DI-1ea559b
La.
2
11-19-11
FrOlll: mhcoughlln
8:11am p. 56 of 11
pA.Cir.. 1974Where eviction proceeding was taken under advisement and judgment
of e' ction was rendered on following day and out of presence of counsel, statute
ing that if court tinds
or owner entitled to relief sought, court shaJJ render inunediately a judgment of
evic'! on
orde .ng delivery of possession of premises to lessor or owner had nol been complied with
and j dgment was invalid. LSA-C.C.P. art. 4732.
lQ
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13
14
15
16
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is
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22
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7.7
Dea Bar Counsel and Panel Members,

Pleas ftnd attllched my Emergency E, Parte ~1otlOn (perhaps not "ex parte' glVen Bar '.ounsel was
proVI
it) Also, please note, the October 9th. 2012 certIficate of mailing by the SB?' for the Noltce of
Intent to Take Default was never served on me in any way shape or form untIl I reCeIVed the copy of the
"entir ' lile fonm SICrra Legal Duphcating The State Bar of Kevada knows tillS They put the wrong postage
on
certified mail envelope contammg the'1oticc oflntern to Take Default Vv'hen I wern \0 pick it up
"Tim' USPS counter attendant at the Vassar Postal Station here in downtown RollO refused to allow me to
plck that certified mailing given that iswasabout $500 ddicient in postage I did nat have $5.00 and It is
not responsIbIlity to pay it, as far as I know. In facll have asked the Bar and this Panel to allow me to
proce d tn fot1l1a pauperis In this matter, and am domg so again here am flat broke. 1 have B 1996 Honda
Ace
rent a room for $300 a month, have less tilan.$200.in my bank account, no stocks, no bonds)
I hav been mlslead or hed to by the SBK in numervus ways m this proceed mg. I was told I could issue
nas despire being a suspended attorney (and there is case law that says even when suspended, one is
"attorney") I was told I would not be reqUIred to pay subpcena rees I was told the Au,,"1l;;\ 23rd, 2012
certifi d maIling would absolutely not be U&d to prove proof of somee of the ,,,,mplaint In thIS matter, SIlN
v Co lin Yet a revIew of the tiles reveals that the SB:.I and Panels onlv Return of ~efVIce (and see SB:.I
Ethlc Committee Member Joseph Garil\s tecent Bnd In 00302 seekmg t<> dismISS my enurc wtcngful
termi tion lawsuil against Washoe Legal Services) for a reallfonie example orj..,t why the hearing on
Nove ber 14th, 2012 must not go forward. It is fraudulent for the State Bar of Nevada to ;;\Ipulate with me
that
Augusl 23rrd, 2012 certified mmiing of lhe Complamt is alleges was sern and that Clerk of Court
Pet admIts to having received back on September 10th, 2012 would never 00 cned to as effectlllg service
of the Complamt upon me or otherwtse put forward as proof of return of service etc :.low the SBK seeks to
get ar und the mcom,mentlact tha~ lJ1Swad 01 holdmg my he.nng on September 25th, 2UI2 (Ckrk Peters
told e it was on too calendar, 1 was noticed of It in wrilmg, 1 agreed to that date for the Hearmg amongst a
choic of dates, etc. ) Bar Counsel King att<mpted to shove a document he alleges was the Complaint in my
suit J kGt, then perSIsted m ordenng Clerk \)f ('-Ourt Pe}er:> (whom Kmg al1ematety chnms to have
separ on from and no authonty OYer With orJenng her not to fllc my Monon to Di:)mlss, attemptmg to
reneg n stipluatlons and representalLons made by the SilK, etc) Further, It IS "Tong for Clerk of Court
Pete to be sIgI1mg the certIficates of maJlmg for both the SHK and for the Panel Chair. Addltlonally. under
SCR 05(2)(0), it IS the Panel that must send the R""pondent the NOllce of Heanng "at least 3IJ days" prior to
the Haring date, and that :-.Ioti must melude wllh it the DesigI1lltJon ofWltnesses and Summary of
Evide ce, and it must be served In the same manner as the Cctnplmnt It is nnperml&<ihle for Pat King to
altem t to mail out the )Jotl of the Heanng and De'iignation of WItnesses weeks bafore !he Panel is even
anna cod (how can you jlC<'lsibly be pretending to take your duty as a Panel member senously when you are
es"," aUy shOWing up the day of the t\~'t game, skippIng all the prachces and prNes",n games. we all
saw h w that turned out for Bre! Farve in hIS last season. It IS appallIng to me thal Y"u mtend to hold this
hear glven these blatant VIolations of SCR l05(:i(c). but when you add 10 that !he fmodulent condUCl of
Pat K , In ladmg to amend rus and or Clerk 01 ,ourt Petas certIl;..te of maihmg or return of service for
- 55.71 -
MO'OON FOR MISTBIALOR Cmm:;AC
To: lclf17e9-fcc6-467a-6eO{-7eaI19b
1
?
4
J
6
7
8
3
1J
11
12
13
flom: lichcoughlin
11-19-12
8:21am p, 11 of 12
the ported certified mailing (and, oonuary to the SBN's established proletlce detailed in lhe certificates of
mall' [ havereview upon finally beIng granted a copy of the "file", though, the rule says [ gcl to go to the
SBN' offlces and revlew wtam things 'up to three days"" not have Pat King and Laura Peters lnllnufocture
some
about why [am not allowed at the building or otherwise VIOlating my nghls (whIch IS
some Ing Ktng.nd Peters do everyhme they get caught vwiatlng the rules) Further, r have heen (and some
mtgbt say thts was largely by d"i>1gn) Jammed mto having thIS J)lsclplmary H=tng 00 }.ovember 14th,
2m 2 impenmsslble prOXlIntty to the petty larceny trIal In rcr2fJl I -06334 I (see Monuero for why It IS n~t
even ppropnate for KIng to be seektng to force me to prejudLce my defense In that malter) on ~ovember
19th, 012, in Depa!1ment 2, before Judge Sferrazza, whom presided over the sllIllmary eVlctLoniunlawful
detal 'Trial~ from my fonner home law office that the crimmal trespiss arrest, jaywalking arrest (Kingfs
Bint doesn't manage to specIfy that the January 12th. 2012 arrest was for JaywalkIng outstde my
home law oiftce shortly after my coUecung video eVIdence revealed the Iraud attendant to Hill's
tor hang used my own plywood to board up the back porch of the property ",Hill, also, at that time,
d got a TPO that was based largely upon an outright lie, ie, thai I "climbed up on" the conlractor Phil
's truck) I believe lhis Panel should r<VIew (f cannot affor the $35 to $70 for the VIdeo of the two
on Hill's Motion for Order to Show Cause of January 20th, 2012 (the Orderto Show Cause was
serv by RMC Marsm hal Harley, despIte what WCSO Deputy Machen saId he personally served in hIS
atllda ,It (Machen also hed abcut personally servIng the eVIctIOn lockout order for HIll, .nd HII1l!ed at the
tres S trial when he "'stlfred that Machen' posted it on the door becaues you ran away". Hi II also bed at
trial hen he alleged the Reno PD announced Ihem:selves as law enforcement and ISsued a lawful order to
emer form the basement prior to the landlord kJckmg in the door, and Hill also lied about whether anyone
that y warned ('.oughlin to leave the property pnor to HIlI's slgmng the criminal complamt to affecl a
rusto la\ arrest for criminal tresp""')
Addl nnally j moved recently, and updated my SeR 79 address in comphane< with that Supreme Court
ell WIthin the 30 daj~ of my moving, Further, I filed an offiCIal Chang, of Address With the USPS,
14
t caused delays rn rece!Vmg my mail incidentto the typical forwardmg procedures of the lSI'S, and I
15
e yellow sUckers on the envelopes to prove Ll Further, besIdes submItting an atltcl.1 Change of
16
fom to the Vassar StattOn on October 5th, 2()12, Olughhn wrote the SBN on October 14th, 2012,
17
vided his new 1471 E 9th St mailing and physical address, in add~ionto updatIng the onlme portal
18
NV CLE Board even prior to thal all In compliance with SCR 79
28
21
22
"We evertheless conclude that discipline orders appearing in the Nevada Lav,yer rray
be ci d to this court for the limited purpose of providing examples of the discipline
impo ad in similar fact situations, This approach has also been taken by several other
cou . n22
n22 e, e,g" Berrran v, City of Daly City, 21 Cal. App, 4th 276, 26 Cal. Rptr, 2d 493,
496 ,5 (Ct. App, 1993); Marez v, Dairy/and Ins, Co" 638 P,2d 286, 289 n.2 (Colo, 1981);
Man erfeld v, Kravitz, 539 N,w'2d 802, 807 n,3 (Minn, Ct. App, 1995): Leisure Hills of
Gra Rapids v, DHS, 480 N,w'2d 149,151 n.3 (Minn, Ct. App, 1992),"l.A!.!B.
24
25
Then there IS Judge Hardesty beIng a one oflhe three Justtcesslgmng the 6/7/12 Order that
26
ly suspended Coughlin's law license over a conviction for petty theft of "a candy bar and some
27
dr()PS~ (despIte the rec~ntly reinstated Stephen R Hams. Esq not havmg a temporary su.<>pension
23
eVen here he adnntwd to, upon bemg forced to by his wife law partner, mIsappropriating some $740,000
- )6,'71-
,\fOTION FOR MISTRIAl, OR CONTINAU
To, 7clI27e9-fccH67a-8eOf-7e.559b
and
From: zachcouqhlln
11-19-11
8,11..
mg it on.. {!'lVD Jlldge Beesle)"s, a Bankruprey Judge in Fedora1 <..ourt who has a specializatJon in
"Crell tor's Right>.' listed on fus contact page at www.nvbarorg, (McGeorge Law School ciass of 1979,
3
mean g he attended Wlth Reno MunICIpal Court Judge Dorothy Na~h Holmes name was supplmeneted to
the D 5Ignatlon of W,tness hy a ~ovemher 7th, 2012 frlmg by Bar Counsel Kmg .whlch means Couglhin
dId
have much notrce at all that Beesley would tesufY. NeIther did, apparently, Judge Beesley, as, for
one
Tying as to whelher a man shoudl retain his lnw license and the Judge berng willmS to so weigh in
WIth
fitllUve opimons (even where a multirude of conlficts of tnterests where present that should have
argua Iy precluded h1l1\ [rOOl so dams \ll\der the canons of his profession. Nash Holmes!Mco"orge
conne tron. Karen SaboiBeesley PecklCA)ughhn ,umg Washoe l.egal Services! Beesley close personal fnend
oiEI no's angle) Judge Heesley sure dldnthave much In the way of 'peClfics to support hIS strong
11
Optnl
'. N facl he seemed to tnp up on thmg.> ,.ther "'Ill' and w~h tc' '"gue It all way whar Coughlm
"2
press
for specifics One thing that seems parIJeu1arly untoward is the extent to which Judge Ikelsey fruled
l3
to, in ny way, mentton the extremely noticeable filrng (made acceslbk to all vta the RECAP plugm on
14
Fire
10
are al lost exactly the same age) Dorothy "ash Holmes tllegally conflscattng an pro" attorney defendant's
for those using Pacer, wherein Judge Be<~ey's ?\!cGeorge Cia" mate (they were une year apan and
aft" any period for her Marshals to conduct a 'search mCldent to
16
hone and micro sd data eard, well
17
and without any warrant or Order made available t{) Coughlm was mentJoncd and extensive
19
19
g documentation was prOVided for 10 the adversary proceeding IO-05Ill4 Cadle Company v. Keller.
Furth r, Coughlin dlspalyed a profound level of professlonaltsm in connectlon With the John Gossin
;:0
ary proceeu1l1gs, particulary where Coughlin owned up to the extem to which the rules of court as
21
Yapphed m the NVD make one attorney or record regardless of whether the agreement between
22
attorn y and client" of an 'unbundled semces" nature, and regsrdless of Gossin h,mself telill'lg Coughlm he
23
Otlltoring the case on Pacer, dtd not want Cooghhn to work any forther on the case, ett:. Gcssm soon
24
25
Regardless, a review of Coughlms filrng m the three ~VB CflSes wherem Coughlin praclice before
26
Judge Beesley wili reveal extremely comptenet work,' Perhaps what Judge Beesley was unable to eluctdate
SpeCI cally in support of his conrentrons (which, again, sought to accomphsh through a leveraging of the
28
Coe
obc/mental health care apparatus that which is not supponabk through more stralghforward means)
- 57171 -
MOnON FOR MISTRIAl. OR CO:iTINA!J
p. 58 01 71
To: lclf11e9-fcc8-467a-8eOf-lea559b
Fro.: ,.cheoughlln
11-19-12
8:21am
IS tho Judge Beesley's McGeorge SOL Class of 1977 cla:;s mate, K\1C' Judge Dorothy \lash Holmes'
2
extre ely questionable c,mduct and ruhngs In K\1C 11 TR 26800 on 2:27il2, 2128:12, and 3fl2/12
(re,
pban ofTnal m 'plte ot '>'RS 178.4()5 and ,,'RS 'i ClIO and Holmes' own ",sessment alToughlin',
! health" issues In hoth her 2l28!J 2 Order and here 3:12, 12 rummatlODs rendered and subsequent
ctory Ordor signed. in addition to the). 3i13'12 (various other orders b)' Judge ~ash HOlmes, and
3/14i 2 (grievance letter to SB);"), and IOW12 (again, Judge ~ash Holmes refuses to follow NRS 189010-
strikUlg another attempt by Cough 1m to have ,the fact that a summary COlll<mpt order is a final
appea ble order,!ll1d therefore the K\fC and Judge Nash Holmes, once again. are pennittaJ to skirt the law
Wlthr spect to the Court, under li'RS 189.030 bemgrequtred to order the preparation o('the CTlmmal
;'0
t's transcnpt (and certamly. If Judge Nash Holmes WiShes to ISsue a "mi'idemeanor of crimmal
11
pt" conviction m a summary [awon (based upon unattributed hearsay by "same ~furshal" whom,
12
can
13
cond t allegedly occumng outsIde the presence of fue court be conslered (good tlung for Marshal Joel
14
Harle
15
thlS c tegoncally lalse non-sense about Cooghhn "dIsassembling a smart phone" or recordmg deVice
16
res
17
'to the
dictates ofNRS 22 030 dId not have to sIgn an atlidavit to have a contempt findmg for
because Cifuer he is lying or Judge Nash Holmes is lying some more, specifically wlth respect to
In the
and leavIng part of It fhere (the impitcat1t)n beIng, glVen Judge Nash Holmes hes about the order of
sponte mterrogat1t)n of Coughlin regarding rcoordmg ISSUes and Coughlm ncedmg to use the
13
restra ill-Ie. Judge Nash Holmes lied, under oath, on lli14il2 when she said Coughlin's request to use the
19
restro m came oniy AFTER she began her interrogatlOll about recording or recordmg dmcc. whiCh, if
2;)
Chair eh.verna would have allowed Coughlin to enter the certilied copy h< had to have rus mother buy for
21
him ( cuase the RMC thncc rejected Coughlm's attempts to buy one hlmselt, and m tact. Judge ~ash
22
Holm, attempted to levy some unfathomable sanction or sua sponte d"bannent about some plddly
23
nonse so related to Coughlm's filmg of an In lOnna pauperIS apphcation (truly a low, even here.. especially
2~
whet Judge Nash Hohn" alternately wntes bar counsel on 3114112 a greivanee directed \0 Coughlm where
25
shem tians, Via some unattnbuted hearsay (which seems to be a common theme runmng through Judge
2b
Nash olmes work) that) USlog an AffIdavit that wa;frorn November 22, 2011 ina March 2012 fllmg (IFP
27
Orde typIcally last 6 months, ').0
28
interl' eatmg a d:dl'erent ca~ number on that notanzeO. lFP or ('...oughhn's addmg llRequesl for AudIO
.,"
And to whatever extent Judge :\a.'ilJ. Hoimes seeks to make CoughlIn's
- ssm\10110>1 FOR MISTRIAL OR COKTINAC
p, 59 of 72
To: 1clf11e9-fcci-461a-8eDf-Jea559b
11-19-11 8:21am p, 50 of 12
FrOB: zachcoughlin
Reeo ing ofTnal in II TR 26800" onto that rFP as tantamount to conduct "'pportmg her de!me to sua
spon disbar Coughlm.. wellt.. Coughlin wond"", why th.t Hug-a-Ihug program was not given more of a
chane before. Judge Na.-;h Holtne$ went an ~StX months In ();)unty tor Jaywalkmg~ ('In hlm. CoughlIn's
flien Geof Giles, Esq (bIg ups to the MJtSjld here m Reno, including Raflk Heeku". a member of the
Mush center's board of directors and everyone there who was so kind m gIving Coughlin. place Ie go for
food
recov r from the Lenathan wrath of the Rcno \{unlc!plll Court and the McGeorge Mafta's, some might say,
"appr ach") may have said it best when he mentioned somethmg.bout "me communny college professors of
d plea,ant company, durmg theIT celebration of Ramadan, no less- mcident to Coughlm attempting to
me Ie at tamhcape "
1J
Also Panel Chalr Echevetn. IS running the Panel lIke a thug, baSically. See WLS's attorney Joe
l1
Gann argument respectmg Coughlm's nght to ms~t on techmcal oomplumce wlth s,epitCe rule:>; ,NOw
12
what
13
and E cano (even though lois of stuff was Said by both that damage. the S8,,', case and only further drives
14
e McGeorge Mafia meme, and lhe extent to which Kmg and Echevema cheerfuly defile any
t mean! It mean that tlte S8); and Kmg and Peters do not get to put on tesumony by Judge Beesley
15
con(,,'e IOn of due process that might attache to a Dsiclplinary Hearing (to which they set.'m to drag along
16
Clerk elm" ,what is she ,uwosad to do' Get tired like (' oughhn at WLS" See Cary'll Sternllchl', approach
17
at the earmg on the Objection to Master Lmda Gardner's Recommendations
18
Vaxe anlS IPO deal FV08-U3380, "here she filled tn for Coughlin, whom took issue 'nth then Master
19
Linda Gardner making Orders in TPO's where opposing. counsel was RIChard Mol'lzo, Esq., that purported
In
the the Santlago v.
to rul on the title to vehicles. despite );RS 33 018 seeming to clearly lack any junsdlCtJOnaJ baSIS for her to
21
do so particularly where the vehICle was bemg given to the accused abuser, and further where that Order
22
was cmingly later recharacteflzed as an "agreement" ... uh, no, So< a similar "lhis ORdor IS an agto<ment
so no
24
~als Will
be allowed from
1t
evw the 12'26112 one you tiled, Cough ImP thl"> summary eVlct!on
"Tnal appeal (from which thIS 613~3 atty fe<s C1f$42, 050 al'peah stems ) mc\dentto th< 12iCJJ!11
g (six weeks late because Hill (but what aooul Casey Baker, ES4 .. wh<' has abscondad to Kentucky
Rich to face the music') had to go on a six week vacation, a ract about which he claimed to be able
27
26
01 the RJC lIltO not complYing WIth "'RS 40.253(7)-(l). Coughlm hereby asks this court to stop the
tnal
WI9/l2 m rcr201l-063341 (the 'phone case presided over by JUdge sferrazza, whom managed to
- 59171 -
\1OTION FOR MISTRIAL OR COxUNN;
To: lclf?leS-fccB-461a-BeOf-leaI19b
confi
Flom: 2achcoughlin
11-19-12 8:21am p, 61 of 12
te all of l."Dughlin's subpoenas on the aus.pu.:es that Skxu's fraudulently noticed ~x part motion
:;:
provi ed suffiCIent grounds too" but then faile-d to return any ofthern to Coughlin tn tlffie to have them
serve tor the 1\l19:J 2 hea,.mg and entered an Ordertha\ purports to ta,e away trom (\)ughlm the nght to
have
zza of 10-/221]2 in 063341 J- So. while Coughlin lIkes and respects Judge SfeIrdZZB, he must recuse
5
6
him
rved subpoenas Issued propertly und<,. a readmg that doesnt include the rendered order by Judge
ffrom that contmuahOn onrial m 063341 on J]!J9!l2

Also, both Echevema and Pat Kmg are ",,",-ing t<, take a page out of the Judge Kaw Holmes
"Con mpt Statute Pasbche Cookbook" to accomplish their nefarious alms, mc!udJgn dlsobeymg the
ing authority by trying to "preserve for the record' and "adJnitting for the 111l1lted purpose of establish
lin's 'altering' a previously filed document, where Coughlin. in complete exasperation at Echeverria
11
12
stratmg the hlghest posSible- level of e'lndent lmpartlal1ty 1n ruhng me-levant or not proptrly
authe iested every single thing Coughlm offered mto,cv'idence
1]
A>. 10 Coughlin's mabIlity to get Echevema to adm,t anythIng mto eVidence tor any purpose oIher than tn
14
sup
of some Summmy Diselp\mmy Hearing vlOlalioo of the RPC thaI Echeverria sought \D enler III an
15
Order In violation of Schaeffer (when Echevema was nol grunscmg notJc,,"dbly and telegraphing displeasure
16
to Co ghlin at Coughlin mere mention of the mItigating quality nflocal Jaw e-nforcement misconduct or that
l'
of me bers of the judiCiary orprosceu\!on team ... much kss Echevcmas verbally suggest that Coughhn
18
about the permiSSion to do so found in Laub and instead cease comparing his case to Stephen R
19
Esq', (despIte the fir<' ground to conslenng Judge Beesley's lmproprly nottce (no Signed green car
/0
dmallm m compliance With the requirements of SCR 109 considerIng Laura Peter's al1J1Ouncmg of
21
the
22
es on September 11th, 2012 and subsequent mdications of assent to electronic servICe by the nndb,
sbn.
d panel and declarnbon cfthe rules .ltendnat to lhe runntng of time vis a vis matenals required
.!'3
under S07 109, incident to a certIfied maIling (ie, Peters announced the SB" and Panel would only
24
e running of such I1me perIods upon the date'oo which Coughlin" stgnature was made on one of the
25
Itied ma!lm return recetpt requested card, and gIVen the SB!\ can't show as much for the
26
Suppl mental notice announcIng the DeSlgn&hon fo WItnesses of Judge Beesley or WLS's Elcano
27
(Eche 'ema seemed to tndim\e he ilid rot lJJ\<!erllimu wha1 Coughlin v.",s refernng to when Coughlin
28
sugge
that given he was stUng wls and clcano In 6030c, and gann was deano and wls's attotney of
- 6f>.71 -
MOTION FOR MISrR.I!\L OR CC!TINAC
To: 7cJ(27.9-fccB-467.-BeOf-7 559b
From: ,.chcoughl!n
11-19-12
B:llam
fecor there, that questioning deano may ~ tantamC)lDlt'to commumcahonc; with reprC5I!n[t."<.i parties (uollars
ts eleano has nol told &ann about this. and Coughlin didn't have the tIme to given the "jUdge
sferra
12
Auhtonze me to serve you nalIce of the ex parte emergency heanng lO quash your subpoenas on
at judge sferrazza..:; himself seemed to approve ynur uSing In connection wlth utllizmg such
as on 10.'22112 in rcr2011-063341' by Reno Cit)' Attorney Cmg Skau(who. "omcally sought 10 ex
5
;)
part q ash Coughlin's subpoenas based upon insufficiency of procedural rules compliance grolUlds even
whe, he was apparently Iymg about Jduge SFe!T1lzza grantmg !um the authonty to seNe Coughlin notice of
the h
comp 109 WIth suhpoenas. Just ask the SEcond Judic,.1 Olstnct Court and WCOA's omc., whom
by emalL.and or of the I Iml2 order by JOOge ,feraz"," L'1C.1 government really doesnt like
ed until ll! 13112 at4 46 to even [ax Coughhn nOlice of its intent to fai 110 appear at the ll! 14:12
10
W31ti
11
Disci linary Hearng (despite the fact that the b"is [or such objections by Watts-V,"I (and thats another
12
thmg. is that the Watts-Vial whom is a 2nd Judlc131 judges staff member' ls the JuillClal AsslStanl
13
Tow end in the RMC connected to Ihe Marshal Townshend? Is Sargent A Vansmo of the RSIC connected
14
to De a Avansino? We know ccomm 911 dispatcher jessica duralde is married to rpd NICk Duraldc, the
1')
office who ,Heeled the wrongl"l, admlttedlyretahating "how's that?" arrest on 8i2.)!11
1E
that s rted all this off ... and thai jesSIca dur.. lde was on duty that day and thai weda Jim lesh, failed U1
17
proVI
IS
(Judg Sferrazzaoffering the scant tune Coughlin's case in chief was accorded. whIch amount 10 I18th of the
19
total
28
Eche rna (and hIS med mal background provIdes y<l another SpeCIOUS connection to Ekano via the
21
tlpano ayu case E1cano constantly remmsces about..) grew more and more frequent once the Heanng turned
22
to the me allotted to Coughhn's c",e in chler ). a coup\< people name Cummings In the WCSOWCDC,
23
cC., e
24
In
ror2011-063341
the materials or response from kelley odom and ecomm Incident to the 1013,'12 subpoena he sent her
mg time of the on the record portion of the proceedIngs (and the stongie breaks "Iloss Hog"
!lut as to Kmg,nd Echevemas altempt to make the OlC,cipll'lflry Heanng one where some summa!)'
2S
anal conduct ORder may be issued <an allegatlo~ that coughlm "altered a prevrously filed document"
26
ughable from Echevema whtrt:: Coughlin 1& alleged to have scratch out and ornotated hIS doing so a
27
p on the 10/31/12 Pre lleanng Memorandum of Law, and mterhneat<d that the documenl was now
28
tled. "Declaration" or something ,inHlar In an exasperated attemtp to gel somctbign anything, into
- 1i1!71 -
MOTION FOR MISTRIAL OR CQN"11N AU
p. 62 of 72
10: 1c3fl1 e9-fcc B-161 a-BeOf-1.a559b
11-19-11
'ro., zachcouqhlln
B,11..
the r ord in that ng12~0204 ca'iC Vlola1jons of professional conduct rules not charged in attorney
disci mary complaint could not be conSidered by ~upreme Court In re DiSCIpline of Schaefer, 2001, 25
:<
PJd 91, 117Kev 4%. modified on demal of rehearing 31 P 3d .165. certioran demed 122 S Cl 1072, S34
U.S. 1131. lSI L.FAl2d 974 So, If \he SB~ and Echeverria want to charge coughlin with some vlOlahon
there, 't will r~quire due proctss. and they must refrain from a Nash Holmslan trcU1Sll1ogrificatlon of one type
of pr eeding into another type wholly unsupportable under the law GUdge :.lash Holmes sought to make a
, tram
cilatlon trial a full blown "Summary DlSclplinary Proceeding" un II
t[
26800, whereas Echeverria and
ek to tum a DIsciplinary Proceeding that they have rIgged to cheat C"ughltn out of every smgle due
s protectton posslhle Into a "Summary DIsciplInary Proceeding~ . whIch doesn't even eXIst In ~evada
10
law
SCI( 102(51' maybe ..but not a Summary DISCtplinary Proceeding Order FindIng Coughlin to have
11
J" a Previously Filed Document iust because ChaIr Echewria was flummoxeJ by the ingenuity of
12
m in getting mto the record all that stuff on the cdidvd's and m the rwo different "Declarattons" or
13
Iy titled submissions unto evJdence that had those cdfdvd's attached to them .. (and the panel and nndb
's assent to electronic service makes required that the materials In the SI...'yDrive and via email
15
enls, as well as \he cdidvd's Coughlin proVIded be mcluded m the record on appeal)
16
17
Plus, it was wrong for Chair Echeverria to deny Coughlin the right to record the
11/1 112 Disciplinary Hearing and Couglin HEREBY PLACES THE STATE BAR OF
18
19
~E\i
ADA, SUNSHINE REPORTING SERVICES, CAROL Hl ~[MEL, LINDA SHAW,
PAT KING, LAURA PETERS, THE NORTHERN NEVADA DISCIPLl~ARY BOARD

21
AN ITS PANEL ON XG 120205 ET AL ON A LIl1GA l10N HOLD ~Ol1CE.
22
23
2,
25
0-
Also, nd of odd that :-JVB Judge Beesley d.!dn~ mentIOn the 3/31J1I2 (hey. thats the same date Judge
Flana n disrnissedCoughhn's appeal oflhe summary ~vlctton i"Trial~ from his former home law office.
tilmg y Couglm in Cadle Company v Keller whereun Coughlm attached as exlnblts that pesky tiling of 3
. 0
notic of appeal by coughlin agaInst the R.'vlC and City ATtorney and Judge Nash HOlmes following rus
28
releas from 5 ays summary incarceratJon, no stay (though Judge :Jash HOolmc5 sw-e docs care about those
- 62:'71-
MOTION FOR MISTRIAL OR C();,\TINAU
p. 63 of 71
11-19-11
From: zachcoughlin
To: 7cJfI7e9-fccB-467a-BeOf-lea55Yb
8:11.. p. 64 of 71
clien, In be sure, right" she wouldn't, nor would Jduge Howard, be seeking to get back at Coughlin more by
altern ting to alT'.mge greater damage them LkJasdll,
3
4
lIt is ~ategorkally false for Jud~ Nash Hobues to assen, in the audio rerord on
5
6
3/12 2 the order of events and when she asked Coughlin her questions about
~o
aske CougJin and when, and what his responses were, and when some allegations by
. g, oonsidering when a restroom break took place an exactly what it is she
"the Marshal" were made, what they consisted of, etc.. on 3112/12 in 11 tr 26800 the
1e
audi transcIipt reads 7 minutes into the audio record the RMC provided the SBN:
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15
16
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Judge Nash Holme. (;\l h): It .pp..... to me in this case that th. defendant i> sorr.ring from
som xtreme form of mental ill,",,,, during the trial I asktd the defendant attormy
repeatedly if he wa. recording the proceedings h. denied that vehemently a few times and
then h. quote look the fifth a f.w other lime. and then he request,d to be excused to go to the
bathroom and the Manbal later r.ported to me tb.t while the eentloman ..... , in the
bathroom he disassembled
It
recording device in his pot;ktt and took the memOry out of it
and it was lot... found in that uh. by the Marshal no one else had g<I!! inlo the bathroom
and that was ",moved and it was put into hi'lJO!:1!ession at tb. Sheriffs oIIice and when they
hook.d hjm joto jail for the contempt char.. that
booked into eyj!\eoo and I asked the
Sheritl's office to hold that into .vid.",~ I believe he has "iolated Supreme Court Rule
Z29(2)(B) which was amended by ADKf 440. August1s~ 201l......
w'"
One Coughlm did nol do anythmg of the sort indicated by Judge ;';ash Hohnes (by way of
unattnl>uted hearsay, ilk. her car ,I..,plng allegattons 10 her 31 14!l2 lelte"e Coughl1o to the SBl0
above
NRS 178 405 should have prevented lIIl}1hmg saId or done by Judge ~ash Holmes following her
smtement at the 7 minute mark that "It appears to me m tJus case that the defendant IS suffenng
from someextreme lorm 01 menial tllness.' Funher, lhat wluch Judge )\ash Holmes had
oornmuflIcatl:!-d to her pnor to the start of Trtal on 2.127/12 to 11 tr 26800 needs to be testified to
under oath, rnther [han have Bar Couru;el
[0 half baked "can't ask the judge about her mental
processes" loophole, as he has done
.".m
City Attorney Ormaas sure Muld be made to explam her statements on the record regardmg
whether the citation or rep:>rt m 11 tr 26800 <x)ntained any mention of retaliation. giv~n she was
lookmg right at il and given what she ,ald in court. Also, the wlllilpcrmg wlth !o.lmshal Harley, and
the btl, about Coughlm reportmg 10 Omlaas what RPD OFhcer Carter ,aId to Q)ughhn lfl 61901,
and Ormaas's responses thereto on 2:27/1 2, and, Dan Wong, dItto rn an earlter heanng on that
matL:tr'. ,
26
27
28
Snnp put, there was no quesnorung by Judge :-<ash Holmes of Coughlin as to whether he was recording
anyt g or whether he pussessed a 'recording deViCe' ""Ill AFTER the one and only restroom break Judge
Nash lolmes mentions on the audio record And that sua sponte interroganon of Couglin occured
- 63!71 -
MOTION FOR lllSTRIAL OR CO::-<TINAli
To: lcJ,fI1e9-fccH61.-8eOf-le.,19b
',.a: ,.chcouyhlln
DIAYELY AFTER THE RESTReX)"j BREAK A BREAK I'\ '>''HlCH J(~)(lE NASH HOL!vIES
REfl SED TO ALLOW COUGHLIN TO TAKE HIS YELI.OW LEGAL PAD WITH HL\f AKD WHICH
2
3
1J
11
13
oec
D &I!ill, COCGHLr:.I MADE A VERBAL PRESERVATION ON THE RECORD OF THE

WHI ERNG 11\ EACH OTHER'S EARS BY CITY ATTORl\'EY .-\LLfSON ORMAAS AJ\TI
\fAR HAL HARlEY (WHO SEEMED A1'11', UPSET ABOll'[ SOME OF THE QUESTIONS
COU HLIN ASKED THEM IMMEDIATEL Y BEFORE THE TRIAL (l)l:RlKG THAT PERIOD OF
TI
WHERE JUDGE NASH HOLME'S ASSIST ",'IT INl)ICATED, m; TffE RECORD IN Ol\'E OF
THE THER CASES ON THAT STACKED DOCKET. THAT Jurlge Nash HolrncsJust couldn't be found.
and h w odd that wa.... which IS odd, consiJ<ring what was gomg on m II cr 22176. II cr 26405 12 cr
0069 and 11 tf 26800, and rcr20 12-065630 and rcr20 11-063341 at the time (lots of reasoru; for and
mdlC Ions that local law enforcement and prosecutors and pubhc defenders wt..'fe non too happy WIth
Co
In and consider the 2124/12 email vacating the 2!27112 status conference between young and <logan
that n Ither YOung nor Dogan WIsh \0 t.,My aoout.. but whIch ""ems to have been held anyways after a
writte commumcation of it!i being reset \\-'as transmitted to Coughlm by Dogan, wherem. durl11g the time
Judge, -a,h Holmes couldn't be found (maybe she was at one of the group rnetinll-' amongsl Judges about
Co 1m that RMC Administrative lodge William Gardner referenced on the record in 11 CR 264051
Intere mg the NotlC< 01 Appeal In 61)302 was tilod that same day 100_ 2-'27!l 2) Dogan got hIS ORder lor
Com I<ney EvaluatIon a/Coughlin In ,cr2()U,(JE,%,M"pparcmly m !eta\ta\lOn for Coughlm's fthng of
2i2!! 2, and DDA Zach Young was :<1111 smarting f"lIn a fihng by Coughlm of approxtmately 11/281\2,
wme resultd in Young promptly amendIng hIS complaInt in rer2!) I 1-063341 10 add a charge that was
duph Ive, even where YOung failure to aIlege theft or possessingirecdvmg "from another' under Staab
make rus so chargrng Coughlin in that iPhone case Y'RPC 3.S VIOlation, winch is YOung's specialty,
appar nlly. That, and Halating NR" 1n 405, wh,chYOung dId by fihng in rcr~Qll-063341 wrth ",'lamp of
2iS5p a fugibve document ofms own, an Oppo,ruon to Coughlin', or the We-PD Motion to Appc<ll' as
CoCo sci on 2i27;12 .. nevemllnd YOung tried to hold a TRl.A.L on 5'7/12 1!I that ClISe despIte the Order
tindl CoughlIn competent In or 12-0376 Ihdn'I even get $Igned and entered until 519il2 .. dItto the Trial
of5i8112 m RMC 11 or 26405, the criminal trcsp3.% case. NOt much respect for nrs 178405
within NR, 5.010) here tn Ncrlhem nevada.
15
Co lin didn't received the 2i281 12 Contempt ORder in l! If 26800 until July 2()12 .. but did file a ~;otlce of
Appe 1317112 .. desPIte ',ummary crim,nal contempt' b<mg a final appealable order. Judge Nash HOlmes
conti s to refuse to fotlow},'RS 189 \111)'()50 (so Coughlm has to type the transcnpt, yay
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e that ctmtempt commItted m a tnal courtroom can under some ClfCuntstanCes be puntshed surnmsnly
by
trial jurlge See C,ooke v. United States. 267 U.S. 517, 539 But adJudtCBtton by a trial judge of a
conte pt ccmmltted In his immediate presence in open court cannot be lJkened to the proceedings here For
we he d In the Ohver case that a person challled With contempt before a 'one-man grand jury' couM nol be
sum
ily tned [3491.8 131 13RJ The power of a trial judgeto pUnIsh for Hontcmpt commItted In his
tmme iate presence in open In re Oliver, 333 U S. '257. Sixth Amendmenl RighT to Counsel of Coughlin
viola d In both I I cr 22176 and II tr 26800. also orders no suffiCiently detatled or capable of being known
how t comply with. not suffiCIent '''''frung, Vlolat Houston v Eighth Jud,cl3l District G'ev )
23
24
25
26
23
See,
is why In Re Oltver and Cooke r"'luire all elements of "summary cnmlTtal contempt' occur" 111 the
"Imm illate presence" of the Court lvlaybe -'1arshal Harley and some other Marshal have mIsled Judge
Nash lOimes, or maybe somethmg worse IS gOIng on'here_. but what Judge Nash HOlmes so,d on the
recor Ing is enurely mIsleading an IrtacCUtllte, ,fnotanoutnght he (again, maybe nota he by Judge Nash
Holm s, maybe she" repeatIng a Ite, but regardless her reliance ,on unattribute& hearsay tS distrub'ng an
map opnate, partlCUJary where she not only purports to 1S::;~ a "summary crimmal contempt'l conVICtion
again an attorney, but also where Judge Nash Holrnes appears to try to \ntnsmogrlfy what she sees as "a
stmpl traffic citatton triall< mto a full blown SCR lOS diSCIplInary h~ng where she IS both Bar (~W1sel
and
Panel .That Mar.mal needs to sigr an affidaVlt. under NRS 2202<> and Judge :-':ash HOlmes ought to
have put somliung on the record, unoer oath, I1l response to Coughhn's rcc<nt subpoena (and SB>I Pat
- 64171 -
:'lOTIQN FOR fl,fISTRIAL OR COlSTINAC
To,
7c~fI7e9-fcc8-467.-8eOf-7ea559b
from' zachcouqhJln
11-19-12
a,21..
King 'ish"" to let Judge Nash HOlmes phone in her testimony. and it f<ooobly won't even be sworn
2
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,
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testim ny. but rather jlL,t some musIngs by JuJge Nash Holmes purporUng to make 'rulings" rmding 'by
clear d convincing evidence" all sons of things outside her JUflsmction) on I1J14! 12. on, Partlck 0 King,
SRN ar Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
1loel Harley, Marshal Deighton, Judge Nash HOlmes, Judge \Vtlham Gardner. ludge Gardners
slratlve ASSIstant LIsa Wagner. who can't qune tind the NOtice 01 Appeal CoughJm taxed to her
Ie llOder the RMC Rules) on June 28th, 2012 in II CR 26405 (the app",,1 was dlSmlssed llOder an
89.010 analysis by Judge Elhot, whol!1 also got Coughlm appeal of the II cr 22176 conVIctIon
result in this C{Jurt's 6,7:12 temporary slISp"",,ion Order in cr 11-2064, which was denied based upon a
clVll eparation of transcript down payment rule. in thai cnmmal appeal, where the RMC has a thing in
place ith this Pam Longon! that violates Kev.da law in that It refused to give Coughlin the audio cd of the
trial f r some time, insisting only Longoni would be allowed to Iranscnbe It and thai the transcript's
prep a\lon would absolurely not stan llOtti a down payment was made. Plus, even where Coughlin caved to
the P iIllent demand, .. Long<lni rep<atcdly hung up the phone on him and otherwise ignored lns
ications (there may be an ISsue of the email Longoni holding out to the public issuing a
eback" ..but she needs to sign an affidavIt as to whether she put Coughlin on a blocked hst, and upon
anon and behet; Coughlin taxed hiS request to the number the R~K: held out for her on her behalf
11
12
13
14
15
3" ..w
need
for K
Apnl
any
In her March 14th, 2012 grievance agamst COUghllO to the SBN (now NG 12-0434, and perhaps.
35, dependIng upon whom you ask and what King mo-.", hy 'Clerk of Cnurt' hecause in King's
ema,l to Coughlin he apparently Identities Ms Marilyn Tognoni" 'Clerk of ('oUlt of Department
aever, wouldn't it be Second JudiCIal District CoUlt Clerk of Court Joey Orduna Hastings that would
send FamIly Court Judge Linda Gardner's April 2009 Order sanctioning Cooghlin to the SBN's King
now apparent conrention that the NGl2-0435 "ghost gneyance" conslstmg of Judge L. Gardner's
(fJ9 Order was not filed by the MfC Judges" Oh. Clerk of Court Orduna Hastings') Do you have
to sayaooutthlS') JuJge Nash Holme's 3114' 12 grieyance to bar cOllOsel r<ads
10
chary Barker Coughlin, Nevada Bar Ko. 9473

18
Dea Mr. Clark:

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[7
This letter constitutes a fonnal complaint of attorney misconduct aodlor disability against
lac ry Barker Coughlin. 'Ibe accompanying box of materials demonstrates some of the problems
with e practice of this attorney being "".-perienced by myself and the other three judges in Reno
Mun' ipal Court My two most recent Orders in what should be a simple traftic citation case are
sclf~
lanatoryand arc included. together with copies of massive documents Me. Coughlin has
fax' cd to ow- court in this case. Audio recordings of two of my hearings in this matter are also
ioelu ed. He failed to appear for the secood onc this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on owDepa ent I judge beiog out for surgery. We h~ve multiple addresses for Mr. Coughlin and can~
seem 0 locate him between cases very easily. We are setting that case for trial and attempting to
sCIVe him at the most reeenl address we have (! 422 E. 91ti SL ~2 Reno NY 89512), although I
hear IDday he may be living in his vehicle somewhere. We do have an address for his mother,
how 'er, as she recently posJed part of a fmc lOr him.
28
- 65171 -
\10TlON FOR MISTRIAL OR CONTINAL'
p. 66 of 11
To: 7clj27e9-fcc8-467a-8eDf-7.a519b
From: zachco'ghlln
11-19-12
8:21311
Judge Ken Howard. Department 4, had a case on Mr. Coughlin late last year that is now
eal to the Second Judicial District Court. Judge Bill Gardner. Department 2, also has a
currently pending in his court with Mr. Coughlin as the defendant. I have enclosed some
of documentll from those matters. in chronological order. simply because they appear to
Irate that he is quickly decompensating in his mental status. Our staff aL,o made you some
tapes of CAlughlin in the him and him and him and him and him and him and him him and J
im and him and him and him and him in Departments 2 and 4 so you can hear for yuurself
how 's attorney acts in court. You can see his behavior In my traflic c.tation case does not
appe to be an isolated incident.
6
7
It is my understanding that Reno Ju,tice ('1)urt also has a matter pending on this atwmey.
idal Assistant was contacted by the Washoe Public Defender in Febtuary when I had Mr.
lin Jailed for Contempt of (1)urt and they stated that they represent him in a Gross
eanor matter in RJe. I have no other information on that.
12
Iitig
13
Ira
14
ta
the
IS
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was
and
You will have the full cooperation of myself, the other judges. and the staff of Reno
.ipal CAlurt in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious
nt in our court. antagonizing the staff and even our pro temp judges on thc most simple
c and misdemeanor matters. I do think this is a caseof some urgency. and I apologize lor
g two days to get this package to you; ourIT person was ill and could not make Ibe copies of
dios of Mr. Coughlin's hearings until today, and I relt it was important dlat the audios be
ed in the materials to be .omid.Ted by the State Bar. On February 27. 2012, Mr. Coughlin
e he was actively practicing law and had appointments with C\ionts.1 do not know if that
uc, but if so, he could be causing serious harm to the practice of law in Northern Nevada
auld be jeopardizing someone'. freedom or property interests. "
lRuI 120. Costs; bar counsel contlict or disqualification.

1.
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mey subjected to d1sc1pline or seeking reInStatement under th~ rules may be a'isessed the costs. in
in part, of the proceeding, includmg, but not limited to. reporters fces. in\,csngatlOn fees, bar counsel
and s Ts salanes, Witness expense::), sen Ice costs. pubbcatlOn costs. and any other lees or cnsu. deemed
reas . ble by the panel and allocable to the proceedmg.
2
II; ~
any reason, bar counsel is dlsqualilled or has a coul1ict of interest, the board of
gove
Ol's
shali appoint an attorney, ad h~, to act in the plow of bar counsel.
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'-"
"'
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- 66171-
MOTI()]I; FOR MISTRIAL OR CQ;\TINA1;
p. 67 of 12
To, 7cl{21e9-fcc8-461a-8eOf-lea559b
11-19-12
fr .. : ,achcoughlln
8:21.. p, 68 of 72
Coughllil is truly severly indigent at this point and requests, to whatever
exte t 8IId IFP has not already been granted herein, 8IId Order allowing him to
3
proc ed In Fonna Pauperis

,msflHdYf
5
6
Dock t entry for the Inal court matler thiS case was appealed form shows the Impropnety of the Clerk of
sml~smg
til< appeal for lack of p.ymg a fllmg f
-201204:55 PM SKollCefAppea\ Supreme Court COUGHUK, Z.ACHARY

Entry APPEAL FEE PAlD FOR THE 7-30-12 NOnCE OF APPEAL - IMAGE ATTACHED TO JUl,Y
10
11
http !/WWW ccwashoe,comlpublicickJlublic _qry _doct.cp . dktrpl. frames'}
12
backt "P&case .id=CV\ I-03628&b<gin date"&tnd ,.da10=

. 06S p.
,'S"Iotice/Appea\ Supreme Court
COUGHLlK.IACHARY
2012
15
16
04:5 PM.:,_ ..
- .. _ -.. :APPEAL FEE PAID WR THE 7-30-12 NOTICE OF APPEAL -l~1..AGE ATTACHED TO
..
"tXt
';}1JLY F1LIKG
'L~
. ,
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19
06-3 p-20n
2J
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"Payment Receipttd
,045 PM
'Ent
A Payment 01'-$3400 was made on rewpl DCDC375290
22
ooncJusjoo
23
pit... reinstate Ihe appeal and or granl ifp stat... or provide time 10 submit a proper ifp as
24
bar < un.el dearly is gunning for. Punel Order thal.nlaU, Coughlin paying back lhis uneon<ionabl.
"eI his .Iated
26
altor <y ree award prior 10 ..instalemont, and that is if Bar Counsel Put King doe.n"
27
wish
28
awe I given the drcumstan.... 10 whatever ntenl Co~ghlin faOed to liIe timely notice of appeal
have Coughlin disbarred, hrth.r.the Districl Court', 3/30/12 Order should be added to this
- 67171-
MOTIO)\,' FOR MISTRIAl, OR CO"iTINAC
iu,
lc3~11e9-!<c8-461a-8eDf-1eaI19b
FIca: lacbcougbl1n
11-19-11
8:11..
th.... o,'S should the nolic_ orapp1ofthe jusl;"_ court',12121111 Order Resolving Cough6n's
Nove ber 17th, 2011 Motion to Cont... P...onal i>rop<rty Li.n consdiering the RJC failed 10 file
,tam in Conghlin" timely 12126/11 noli of appealth.rrto in rjt revlOll-OOl708, a, therjt did in
4
anot r summary evictmn from a tommertial 'tase involving coughlin's fonner hom! law ornce in rjt
,
I
r_V20 l-000374.. .further R>,JC Ju... Nash Holmes has similarlv refused to follow the rules on
.....
I
6
ilting appeals in 11 TR 26800 ( a .as. whe_ Rlthard Hill had RMC Marshal Joel Harley violate
ouse sanctuary doctrin. where Harl.y persOnally served CoughHn noli.e 01 the 3/23112 order to
au hearing in the district court appeal
lin alr.aqdy had. District tourt app<al in this matter in evll-OJJl6 orcvll-OJOSl...thus
oft!'i' matter (and really, on Ottoher 19th, 2011,
11
maid g void the entire appeal in <vll-03628, p<rhap'), I INCORPORATE BY REFERENCE ALL
,
~IY
TRLICLY AV A1LARLE FINDI:-T~<; ON NE\,ADA SUPRnlE COCRT WEBSITE nus
12
YE
10
LIKE KING lNCORPORATES EVERYTIUGN U:>01>ER THE SU" VAGUELY MENTIONE
DIN RIEVANCES TlIAT ARIiN'T EVIiN ATTACHED TO IllS COMPLAINT BICAUSE TlIliY
ARE 00 HIDEOUS TOO SEE THE UGIITOFDAY,APPARE.'ITLY... WHlLE KING GOES
16
ARO Jl'o1> TRYL"IG TO GET .TUDGES TO FIND By'THE ETHICAL \lOLATION DISCIPINARY
,
PR EEllING STANDARD OF "C!,EAR AND CO:'<WCI:'<G EVIENC" so HE AlI1> THl': PANEL
17
AND '1'1 BACK, IGNORE CLAIBOR'lE, AND dULL WITH TIlAT SCR 1lJ(5) APPROACH.
15
is
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2)
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24
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27
ou
c,v
- 68,71-
)'fOTION FOR MISTRI,AL OR CO'illNAC
p. 69 uf 11
, To,
7cJfI7.9-fccH67a-8.Uf-lea559b
'
11-19-11
8,11.. p. 10 of 71
~--~/ " " ,

I
I
,/
I / _----------'
/
L/
,
AFFIBMA nON Pursuant to NBS 239B.030
1
".
4
The ndersigned does hereby affinn that the preceding document does not contain the
3
SOC}
security number or any person. The assertions herein arc made, pun,uant to NRS
53.0 5 under penalty of petjry and based
up~n
my first hand knowledge of these matters,
exee t to perhaps a very, very few aspects oi' a a very few assertions which are made upon
info
ation and belief.
Dated this Novemher 17th. 2012"
~/-----.:
/~'I /'--'---~--'
1J
I'
.-
is: Zach COughlin signed
11
~2
Zach Coughlin, Esq.

13
RESPONDENT
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2::
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- 69/71-
MO'lJON FOR ~nSIRIAL OR CClliTINAU

,
, To, 7cl!17e9-fcc8-467.-8eOf-],,119b
F
tOO, ,.cheoughl!n
11-19-11
8:11..
Proof of Senicr:
I
is date, I, Zach Coughlin electronically served a true and correct copy of the
ing document to all registered elilcrs,:and to those whom are not I placed a true and
t copy of the foregoing document in Ihe usps mail on Ihis date:
I
A PETERS A~D SBN A~D !\NDV PANEL APPROVED FAX FILING LONG
SEE MY DECLARA'110C-; HEREIN .6.ND HER AI'FIDAVlT Of 1019/U THAT

FILE STAMPED Bln:NEVEIl. SERVED O~I,--- __-----------f
/,,,..-
./
D THIS: Dated this Novembe~ 17Ih;-io12
'e
t/
(s! Zach Coughlin

Zaeh Coughlin.
RESPO~DNET
I I
- 70m ,
MO'fl()N FOR MISTRIAL OR CONTINAlj
P, 71 of 71
;.
10: (,Jf11e9-fccB-461.-BeOf-leaI19b
rIal: zachtongblln
11-19-11 8:11a. p. 11 of 11
-.--------------------------------------------
2
3
I. E ibit I: various relevant materials.
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- 71.'71-
MOTION fOR MISTRIAL OR CWiTINAC
I'
\
IN THE JUSTICJtt:~Jl~RENO TOWNSHIP,
COUNTY OF WA~He~SPATE OF NEVADA

EN EL TRIBUNAL Q,W., W,Q::\TUIlQ .Q.E LA CORTE DE RENO,
EN Y PARA EL CO~ 6~ vr~~ESTADO DE NEVADA
STEV TUTTLE
RENO J I~COl1RT
BY_-!:=.:-:-__
EL EST ADO DE NEVADA,
OEPUTY
Plaintiff,
Case No. CitationIRCR 2011-063341
Demandante,
vs.
Zachary Coughlin,
Defendant.
Acusado.
Address:
ORDER TO ATTEND
ORDEN PARA ASISTIR
1471 E. 9'h St., Reno, NV 89512
Direcci6n:
008: 9/27/1976
Fecha de Nacimiento:
YOU ARE ORDERED to attend and complete the following:
USTED ES ORDEN ADO a asistir y completar 10 siguiente:
Due By
Pagar a mas tardar el
DUI School Level PLEASE SELECT A CHOICE

Escuela de Conduccion B.jo I. Influenci. PLEASE SELECT A CHOICE
Due By
Victim Impact Panel

Panel de Imp.cto la Victima
Due By
Domestic Violence Program PLEASE SELECT A CHOICE

Program. de Violencia Intrafamiliar PLEASE SELECT A CHOICE
Due By
Pagar a mas Iardar el
Anger Counseling Program PLEASE SELECT A CHOICE

Ter'pia de Control de Temperamento Nivel PLEASE SELECT A CHOICE
Due By
Self Help Meetings (A.A./N.A. Meetings):

JunlaS de Autoayuda ( Junlas de Alcoh6licos Anonimosl Narcoticos Anqnimos):
Due By
PLEASE SELECT A CHOICE:

PLEASE SELECT A CHOICE:
l2'J
Due By
Alternative Sentencing Division (775) 327-8381. I S. Sierra Street. I" Floor, Reno. NY
89501. Report for Probation by 11/2112012. Hours Mon.-Thurs. 9:00 AM - 3:00 P.M.
Departamento de Sentenci. Altemativa (775)327-8381, I S. S,elTa Street, ler Piso.
Reno. NV 89501. Reportese para Libertad Condieional para
. Horarlos de Lunes
a Jueve. de 9:00AM a 3:00PM
Due By
0
[ZJ
ReVised April 2011
To appear for Courts Counseling Compliance Program (CCP) on:

Comparecer a Programa de Cllmplimiento De Consejerio (CCP) el :
Due By
Due By
1-2 year.
,
,
12120/2012
Public Defender Reimbursement of

Contact Washoe County Collection Division,
(775) 328-2552, P.O. Box 1113011001 E. 9" Street Bldg. D Room 120, Reno, NV 89512
Reembolso por servicios de Defensor Publico
contacte al Departamento de
Rec.udacion del Cond.do de Washoe. (775)328.2552, P.O. Box 1113011001 E. 9" Street
Bldg. D Room 120. Reno, NY 89512.
Other: To obtain a Mental Health Evaluation and provide proof to the Court.
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DueBy
Pagar a mas rardar el
Due By
Due By
Paga, a mas tardar el
Evaluation
Evaluacion
Parenting Class
Clasespara.padres .c, .. -- i \ "u{,'
Restitution~of
,ducby
: Contact Washoe County District Attorney DiversIOn
Program Office,J775) 789-7171. 1 South Sierra St. South Tower, 4'h Floor, Reno, NV
"; .
89501.
Indemnizacion de
,para el v' . Contacte al Deparramento de Cheques
Fraudulenios de I. Fiscalia del Condado de Washoe, (775)789-7171,1 S. Sierra Street, Torre
Sur, 4to Piso Reno, NY 89501.
YOU ARE RESPONSIBLE FOR PROVIDING THE COURT WITH YOUR CURRENT ADDRESS WITHIN 10 DAYS
OF ANY CHANGE.
USTED ES RESPONSABLE DE PROVEER SU NUEVA DlRECCION A LA COFE iNTRO DE DIEZ DIAS DE
CUALQUIERCAMBIO.
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YOU ARE FURTHER ORDERE~(~ enroll Within 10 days and appear alcohol free. ("/,,,,11< ~ S:O<?<f il
ADEMAS USTED ES ORDENADO a-iilscribirse denrro de 10 dlas l( co,(,!,arecersin de alcohol. I'~ {::!~' j
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cj \ v / <(~ N.2'/ /1etAAJ> SV ) < ~ l' ':\"1'--\
Upon successful completion, you are responsIble for producing a eompletlo'ltlcertificate to the Court on or before the I \"
due date. Failure to comply with any requirement of your counseling program(s) may result in the issuance ofa bfnch wfrrant f~r ~'f.D(
your arrest (A $25.00 late fee will be assessed to each program(s) not completed on the due date).
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Despues de completar COil exito, usted es responsable de presentar un certificado de finalizaclon .1 Tribunal para a . I J.~
antes de la fecha de lermino, EI incumplimiento can cualquier requisito de su prograrna(s) de consejerf. podria resultar en expedii1' 'Y
una orden par su arresto. (Se aplicar. un recargo de $25.00 por cada programa(s) que no sea(n) terrninados para 1. fecha plazo). CO> YldJ<i'l1
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DATED this 20th day of November, 2012.
FECHA dia
de
, 20
PETER J. SFERRAZZA
Justice Of The Peace
Department # 2
Juez de Paz
Numero de Departamento
I have read, understood and received a copy of the above Order.
Yo he leido, ente dido rccibido una copia de 1. Orden.
Pecha:
EFENDANT'S SIGNATURE
---
(ft1RMA DEL ACUSADO

RENO JUSTICE COURT
One South Sierra Street

Reno NV 89501
(775) 325-6500
RCVI~cd
A\m120t t
P.O. Box 30083

Reno, Nevada 895203083
Fax (775) 3256510
?v7'OII, ~
Case No.
, 1''2,?'f!
K{ IS /011- ()'O ) ) L
Department No.
'
F\LED,
2011 NOV 20
cr-Vf.
PH~: 59
TurtlE
In the Justices' Court of Reno To~Q~$73~~~

County of Washoe, State ofN~faaaN:FuT;;-******
Plaintiff,
The _ _ Plaintiff

OF PROCEEDINGS
Defendant has requested an audio copy of
proceedings of the following:

1)
Hearing Date_,_ _I_I+-fI+C,-t--!+"C==--_ __
2)
Hearing Date ---'-'-+-"=--"'f--"=~---
3)
HearingDate _ _ _ _ _ _ _ _ __
4)
Hearing Date - - - - . - - I c - - ' - - ,
Date
l \ /2.) (C.
_7< GiS
Address
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Plaintiff
VDefendant
$35.00 fee due at time of request. Please provide a mailing address if you wish to
aVe the CD mailed to you.
Call (775) 325-6575 with any questions.
In the Justices' CQ\\1ittO~O Township, County of Washoe
l1-t'~M of Nevada
2m NOV 21 AM 7: 51
The State of Nevada, eY-L.,...'_... __
fPlRftlhrf,
vs.
<_ __
Case No.: RCR 2011-063341
Misdemeanor Judgment
ZACHARYBARKERCOUGHLm,
Defendant.
The Defendant on November 20, 2012, plead not guilty, was tried by the
Court and was found guilty of CT. 1. PETIT LARCENY, a violation of WCC
53.160 and 125.050 and CT. II. POSSESSION OF STOLEN PROPERTY, a
violation ofNRS 205.275, Count II conviction merges with Count I for purpose of
sentencing. No Cause appearing why judgment should not be pronounced,
It is ordered and adjudged by the Court that the Defendant is sentenced on
Count I to serve ONE HUNDRED EIGHTY (180) days in the County Detention
Facility, with credit for EIGHT (8) days time served, SUSPENDED for an
indefinite period of time not to exceed TWO (2) years on the following conditions:
1) Defendant is to obtain at his own expense a Mental Health Evaluation and
provide proof to the Court by December 20, 2012; 2) Defendant is to take all
prescribed prescription medications; 3) Defendant is not to consume or possess
unauthorized drug andlor alcohol; 4) To violate no laws; 5) Defendant is released
on Probation to the Department of Alternative Sentencing for remainder of
sentence; Defendant ordered to comply with all DAS requirements.
It is further ordered that the Defendant be detained and brought forthwith
before the Court by any duly sworn peace officer of the State of Nevada if the
Defendant violates or fails to fulfill any condition of sentence ordered herein 'or if
the Defendant violates or fails to fulfill any condition of alternative sentencing in
which the Defendant is allowed to participate by any agency of the state or local
government.
Dated this November 21,2012.
Case No.
RQl,201l-063341
P rWV 26 lid 8: 34
Department No. _...;2=--_ _ _ _ _ __
S I;:\'; idTTi [
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nElic
COURT
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IN THE JUSTICE COURT OF THE sT1TE' "Nj(f~itD"""'-'-A
'!HE srATE OF NEVADA
Plaintiff,

OF PROCEEDINGS
vs.
ZllQUIRY BARKER COUGlLIN
Defendant.
--------------------~/
The
Plaintiff
1)
Hearing Date
November 8, 2012
2)
Hearing Date
November 13, 2012
3)
Hearing Date
4)
Hearing Date
NOV611ber 26
Date
Zachary Barker Cbughlin

Na.me
1471 E. Ninth St.

Addrtss
Reno, NV 89512
City, State, Zip
949-667-7402 (telephone and fax)

Contact telephone Dumber

Judge Sferrazza waived $35.00 fee.
,20 12
Case No. Rrn2011-063341

Department No. _...::.2_ _ _ _ _ __
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IN THE JUSTICE COURT OF THE STATEBb'fNc.ro:,

,,'1':1.rtlr:-IN AND FOR THE COUNTY OF WASHOE
'mE STATE OF NEVADA
Plaintiff,

OF PROCEEDINGS
vs.
ZACHARY BlIRKER CDUCRLIN
Defendant.
f
The
Plaintiff _ _ Defendant has requested an audio copy
of proceedings of the foUowing:
I)
Hearing Date November 8, 2012

,
2)
Hearing Date November 13, 2012
3)
Hearing Date
4)
Hearing Date
No_venV:ler 26
12_
Date _ _ _ _ _ _ _ _ __ _ _-', 20__
Greig Skau, Esquire

Name

Address
City, State, Zip
Coutaet teJrpbone Dumber

Please Indicate if you wish to have the CD mailed to you.
FILED
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To: 7cl,17e9-fccB-467a-BeOf-7ea559b
11-16-12 4:54pm p. 2 of 6
From: !achconghlln
Zach Coughlin
Reno, NV 89512
Td and I'ax: 9496677402
suspended attorney pro per defendant
1471 E. 9th St.

3
IN THE RENO JUSTICE COURT

COUKT'{ OF WASHOE: STATE OF NEVADA
8
TATE OF NEVADA,
PLAINTIFF
)
)
)
) RCR20 II -06J34 I
) DEPT2
10
11
.ACHARY BARKER COl'GHLIN:

DEFDIDANT
13
14
15
16
17
EMERGENCY EX PARTE MOTIO!' FOR EXTENSION OF TIME TO FILE ylOTION

FOR NEW TRIAL: MOTION FOR MISTRIAL: MOTIO\' TO STRIKE: MOTION FOR
ARREST OF JUDGy!E\,T
19
POINTS AND AllTl!ORrnES

FACTS
21
22
"IRS I 78 394
No person to b. compelled to h. witness agam.\1 hll",df or herself on wm inal action,
or \0 be unnecessanly re'Ir'med TlME:.rn.S 178 412
Enlargement 1\1\3 178.478
~1ot,on;,
.ftida,' US. ~RS 178 482
Additional tim!! after service
by matL TTv1E NRS 17& 472 r"omputauon, In c~)m puung any penod of tim I.' tnc day of the act or event from
26
which the des>gnated pcnod of Ume begins to run ,hall not be mcluded Th"Ia" day of the penod so
27
computed shall be meluded, unless it is a Saturday, "Sunday, or" noo)ud,elal day, on whlch event the penod
28
- 1'7-
EMERGENCY EX PARTE MOTIO~ FOR EXTEl\SION OF 11ME TO FII ,EMOTION

FOR NEW TRIAL: MOTION FOR MISTRIAL: MOTIO,\l Tll STRIKE: MOTION FOR
ARREST OF JUDGYlE'\"T
'I
To: lclfl1e9-!cc8-161a-8eOf-lea559b
trol: mhcougblin
11-16-11 4:14pm p, J of 8
"
runs untiJ the cnu of the next Jay whIch i::, not a S.aturday, a Sunday, or (l nonjudlctul day When a periQd of
2
hme presenbed or allowed IS Ie", than 7 da)~. mtermedlate Saturdays, Sundays and nonjudIcial days shan be
excluded m the comput.tlon. (Added to NRS by 1961, 1451) XRS 178 476 Enlargement When .n act IS
requIred or allowed to he done at or within a specifIed Inne, tilt- court for cause shown may at any time m Its
di$cretlon, 1 With or \iI'lthoul motion or notice, order the penod enlarg~d if request therefor is made before
the expiration of the period originally pre'!.Cnbed Of a'i extended by a preyious order. or 2 Upon motion
<
made after the expiration of the specIfied period permIt the act to be done If the faIlure to act was the result
of excusable neglect
Ebut the court may not extend the time for taktng any actIon UJ1kr ;.rRS 176515 or
176525 except to the exlent and under Ihe condItIons staled In those ,""cttons (Added to 1'>'RS by 1967,
10
1451; A 1969, 10; 1985, 63) NRS 178478 !\loMns; aff1davlt' I A WrItten moMn, other than one which
iI
may be heard ex parte, and nOllce of lbe hoaring thereof must be served not laterthan 5 days before the time
12
specIfied for the hearmg unie" a dltlorent period is fexed by rule or order oflhe court For cause shown such
13
an order may be made on ex parte appltcatlon. 2 When a motIon is supported byaflidant, the affidavit must
14
be served WIth the motion; and opposing affIdavits Ina} be served nOlles:; than 1 day befor< the hearing
15
Wlless the cow1 pennlts them to k served at a later tlm~ 3 A certificate ot service mustacconlfQny each
16
motIon filed (Added to NRS by 1967, 1451, A 1991,3(1) NRS 178.482 Addmonal tune .ftersemce by
11
mati. Whenever a party has the nght<" lS required to do an act within a pr=ribed perted after the service of
13
a notice or other paper upon the party and the notice or other paper !S serv,d by mail. 3 oays shall be added
19
to the prescrIbed penod. (Added to NRS by 1967.1451)
20
httpllsdrv m,,'Tt4dYthttp il.,drv ntsXmRkVL
21
22
23
24
27
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candor to the tnbunals, .check \hatceTt of semce on 01' L"he Tibals lli7!l2 faxing toCoughlm at 949 667
7402. one, fax to coughlin not sufficient sm lee .. two. she dIdn't fax anytlung to coughlIn, three, cert1ficate
of servIce does not mention it beIng served <m DDA Young.. yet DDA Young had it attbe \ I, \91\2 Tnal
date In RR2011-063341 (the one where his only 'proof' " to the idenbt)' or nalllre "fthe thIng allegedly
stokn was some "venpIC" thing that he DDA Young took dJrectll' out of the police report .. where DDA
Young then demonstrated" lack of candono the tnhun"1 In alleging It was not part of the pobce report,
espeCIally where DDA ,ouglll to exclude the IVllns S\ll)ments, Supplemental Declaration, and
subsequently produced "Narralwe" (whIch DDA lilrthcr demonstrated. lack of candor to the tnbuna11l11d In
dealtngs wlIh opposing coun<;el by purporting the narratIve to have b~en mc!udt'd In the Imtlal discovery
propounded ... wluch It was not then there IS the tact that the RJC p\lf]lOl1S 10 have lax Coughlm two
different Orders on 1l!16il2 speaktng to the various motIons to quash subpoena., but that, however. the RJC
seems to have, uh, accldentally fa.-wd the same order twice, th~r~fore prcludJcing coughhns case wnh respect
to Ius not having been served the second order a SIngle lune, but mth" h;, havlIlg been served the 12/16111
- "2/7-
EMERGENCY EX PARTE MOnOl\ FOR EXTENSlON OF TIME TO FILEMOTlON

FOR NEW TRIAL: MOTION FOR :'vIISTRIAL: MOTIO?\' TO STRIKE: :VfOTION FOR
ARREST OF ruDGxlENT
To, 7clf27e9-fccB-467a-ieOf-lea559b
2
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5
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'7
9
10
11
12
13
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15
16
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19
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21
22
23
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28
Froa, zichcoughlln
11-2~-11
j,llpm p,! g! 6
filed rcr2fJll06314 'Order PenYIng MOtH'<1S for MlStrial and Continuance" (w,lh a fik ,!amp of 11 A I AM)
n,1CE, while the "Order" baring a fik stamp ,,[ II .42 am on 1C' WII m rcr2(1] 1-063341 was never faxed
to Coughlin, despl~ the Certificate of Scmee l,fRJC Lori Townsend indicating It lVas the digitally
venfiabl< receipts on Coughlin's end prove othen\'lSe. and YOll ARE HER.'SBY PLACED ON A
LITIGATION HOLD NOTICE W1TH RESPECT TO ANY A1\1) ALL FAX LOGS BY EITHER THE
WASHOE CO\f.-JTY PLllLlC DEFE:ER AND REl\O JUSTICE COURT. OR THE RENO CITY
ATTORNEY. OR WASHOE (X)U:-::TY mSTRICT ATTORt-:EY'S OFFICE AS TO MY FAXES.
EMAlLS, OR OTHER TRANSMISSIONS P1cRPORTL\lG TO BE DEL! VERED OR SEXT TO lACH
COUG~ AT ZACHCOUGHLIN:wllOTWIlL CO\1 "-'\1) OR ZACH COUGHLIN'S FAX l'<1JMBER
AS LISTED \;l\'DER SCR 70 AT \VW l\'\'BARORG OF 949 667 7402.
Further, Coughltn's attachcdmenlS (mcludmg th(lSC on rugital medta diSCS) have ,-uddenly gone missmg or
the RJC lS apparently allegtng they W<rc never there BaIliff Maldonada on 1l!lS'12 took Coughlin's filing
from the fihgn olliee d.:sk where Coughlin had left them for filing With Robin Baker, and ventured out
towarda the R\1C (Coughlin had gone to personally deliver a copy of those filigns to \vCDA Z, Young) .. so
the cham of custody is problematIC .
ADD TO THIS .1>c.,\Y Al\1) ALl. FAX LOGS (NrERESn::G WHAT CURTIS HARVEY HAS TO SAY
ABOUT THINGS) TIlE RENO mST1CE COi7RT AND WASHOE COUNTY SHERIFFS OFFICE (AND
THE SAME WAnS VIAL NA,'vlE COMES U]' ON "IOTIO}\S TO QUASH AS It-: JUD1CIAL
ASSISTA'lTS IK THE RJc..H\1M11M)i ,LIKE THE TO\\-:\SEND NA'\1E CO~1ES UP IN RJC
JUDGE'S SEC"RETARIES M1l RENO :'vlARSHALS IN TIlE R."'I<:'. LIKE THE MARRIAGE BETV,'EEN
MAfERlAL Wn\'ESS ARRESTNG OFFICER RPD NICK m'RALDE .AND ECO"j\j'911
LllSPATCHER WORKING THAT "IGUT 1V110SE VOICE [S APPARE\TLY 0" EXHIIJIT 2 FRO~
THE063.l41 TRIAL DlSPATCll TAPES, illS WIFE. JESSICA DlJRALDE.
.ADD TOTHA1 THE FACT THAT THE 1<\0 JllSnCE COURT FAlLBDTO COMPLY WITH
COUGHLlN'S SUBPOENAS FOR THE 11i14;1~DlSClPLll\ARY HEARlJ\G AT THE STATE BAROY
)lEVADA (THE ONE WHERE THE SBN ANn PANEl. TRlEDTO PilL A P.\RJvllRCH ON
COUGHLIN BY liSlN(; SCR 11 I(5)'S "IF A JlilXlE SIGNEIJ AN ORDER ITS CONCLUSIVE PROOF
OF A CO,,\1CTfON, SO \\1i'LL HAVE HER CO~1E J\' Al\1) TESTIFY TOO A)'n ALL!JI)E TO
\f.-JSWOR.'1 HEARSAY (LIKE BY RMC lvLARSHAL HARLhY ABOUT SOME "DISASSEMBLING A
RECORDlKG DEV1CE AND HIOlNG IT 1"1 THE llATHROOM" No;:';SENSE THAT IS PATENTLY
FALSE) AND THEN CLOAK THE JUDGES LIES IN A IV ARM CURTAIN OF JUDICIAL
IMMUNITY.
Judge Sferrau.a, in hIS order as rendere-d alluded to matter.; (OVictlOn cases RJCrev2011-001708, where the
RJC r.tled 1u or refused to filed Coughlm" 12126(11 NotICe of Appeal of the Order following the 12i2l111
Hearmg on Coughlin's Iii 1611 I Molion to C0111est Personal Property Lien (tb< one Coughlin IVa, denied for
over 6 weeksdasplte :-''RS 40. 253 (1)-(8) requinng one WlthO' 10. days be heard by the RJC and Coughl.,
was the only one who showed up (he checked m wllh RJC Chle\' Baililf S<Z<ton, on umc, on 11121il1 tor the
htarmg Co~hhn was ncticed 00 C' notlcc Jll.\1 as good under
li
The problem fOT the RJC under GlaZlcr v, .Iu.<Uce Court and Lippis V JustlCC Court IS that. while the Judges
may enJoy immunity, the Court docs not. nor does Its staff or admmistrators, St, where the RJC notices
hmdlord and tenant in writing of a "Trial' on IO!C5ill in the Richard G Hill sumtnOlY evictIon "Trial"
debacle. and that ",tting is violative of:-JJCRCP 109 ,"'pe<ting the 20 days required between ""lVIce oftha
summons aud complaint and setting of a 'tnal on the merit,', the Court h.<exposure, Same goes for failing
to flie the Kotiee of Appeal Coughlin submitted, 'worn.tely, In accordance With the rules in RJC
Rev2011-000374. on March 16th. 2012, m resp:ms. to the March 15th. 2\)j) Order by Judge Schroeder (and
the clerk's VOK~ on '\he- audlO '!ape of that summary evichun procC"cdmg m r~v20l :;;-OfJ0374 (~excuse me
Judge Schroeder, I know you wanted to do that olher ca.", fifS" hut Coughlin is nc,t here yet, so 00 you
wanna rush a default through on rus case" or somethIng awfully Similar to that, ) reveals an express
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EMERGE'iCY E.'I: PARTE MorIOl\' FOR EXIENSIO'i OF mm TO F1LE\fOTIO~

FOR KEW TRIAL: MOTION FOR MISTRIAL: MOTION 1D STRIKE; MOTION FOR
ARREST OF JUDGMEKT
To: lc3fl1e9-fccB-467a-BeOf-7ea559b
F,M: zachcoughlln
!I-16-l1
4:54pm
lntcntion to try to hlu-riedJy secure a d1!H1Ult agamsl ~oughlm. even though the fa.x headers say the summary
evictionordcr was faxed at 8 ~4 am am for a hearing noticed for 8.30 am which makes such an
2
So, while the WCDA OffIce and ~ry Kandarns mIght want a con\'lCtion of Cough1m m DC rov21111-063341
(and the SIlN's Kmg always eOF,)" a good SCR 111(5) shon workday. to be sure). UIS not so cl= Us
worth It to the Reno Justice Court. tts Judges, Adm InlStratlon or Statt, nor worth tile appearance ot the
JUdtClary "being pushed around' as Judge Chfion apparently mdicat<d to Judge SfenrnzZlI during the
conference they had (at Clerk Tami announced m Coun to Young and Coughhn) wherem ImpennlSSlble
extra Judicial dtscusSlOflS resulkd in an unpennisSlble etIect bemg had on die ruling in ,eI'2011-063341 (not
to mention Cit)' Attorney Skau", fraudulent assenion of an Order by Judge SferrdzZll authorizing Skau to
secure Coughlin's attendance at the 11 :13112 Heanng, via scmee "by ematl", to say nothing of the
impermiSSIble ex l"'rte communICatIOns o""unng between the RJC, WCD,\, WepD. and Reno CIty
Attorney on lli8112 (especially conSidenng the ImpennlSSlble rel.as< of Coughlin's smart phone and micro
sd ctlfd to the R.\1C Marshals, as admitted to by WCSO employ,,",s m ea51ly provable was, to the Reno
Marshals, a full da, after Coughlin's smartphone and micro sd card wac booked Into Coughlin' secured
propeny at the weDe. (therefore, not at alia """"ch ,"cldent to arrest" "winch IS h>o bad, considering all
that Dm7 would a!low )
CONCurSlO'i
1i
please reim!.te the appt'al and or grant ifp ,tatus or pro,ide tim. to submit a propt'r ifp as
J?
"'r counsel dearly is gunning ror Panel Order th.t entail, (oUl!h1in pa}ing "'ck this unconcionable
13
attorney ree award prior to reimlatemcnt, and IhlIl is if Bar Counsel Pal King do..n~ get his stated
14
wish to have Coughlin disbarred. Further, Ibe District Court's 3/301t2 Order should be added to thl.
15
appeal given the tir<um.lance.. 10 what,,'.. extent Coughlin railed to file a timely notice of appeal
16
thereto,.s should the notice of appeal of the justice court's 12121111 Order Resolving Coughlin's
November 17th, 2011 !\lotion to Contest Personal Propl'rty Uen consdi<ring tb. RJC failed to file
18
stamp in Coughlin'. timely 12126/11 notiee of appeal thereto in rjc r.vlOll-001708, as the rjc did in
19
another summary eviction from a t'fHIlmfrciulleust' involving coughlints forme-r homt law offite in rjc
20
revl012-000374 .. ,further RMC Jndge Nash Holmes has similarly ref.ud to foUow the rul on
:2:1
transmitting appeals in 11 TR 26800 ( a case whee Richard 1IU1 had RMC M....hal J..lliarley violat.
22
courtho.... sanctuary doctrine whee< Harley penonally served Coughlin notice of the 3123/12 order to
show caus. hearing in the district court appeal of thi, matter (alld r.. lly, on October 19th, 2011,
Coughlin alrqdy had. District court appeal in this matter in cvll-03126or rvll-OJ05L.thus
making void the entire appl'a1 in <vl1-03628, pl'rhllJl"),
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EMERGDfC EX PARTE MOTlOK FOR EXTENSION or m,tE TO FlLnIOTlO)!

FOR t\EW TRIAL: M01lO)! FOR \!ISTRIAL; \lOTIO:\ TO STRIKE: MOTION FOR
ARREST OF JUDGMENT
p, 5
of
. To: 7tlfl1e9-fccS-461a-SeOf-leaSS9b
11-16-11
FIom: z.c'coughlin
4:S4jl1l p. 6 of 8
AFFIRMATION Pul'SlIant to NRS 2398.030

2
The undersigned does hereby afflnn that the preC\!ding document does not contain the
DECLARATIO:\'
The assertions herein are made, pursuant to 'l\RS 53.045 under penalty of perjury and
7
8
9
hased upon my first hand knowledge of these matters, except to perhaps a very, very few
aspects of a a very fe\\ assertions which are made upon infonnation and belief.
Dated this November 26th, 2012,
11
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IS!
___ __ 'H_--"',-~
lach Coughlin_ sign)ld electronically
Zach Coughlin
1,)
Defendant
i/
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- 517-
EMERGENCY EX PARTE MOTION FOR EXTENSION OF TIME TO FILE MOTION

FOR I\'EW TRIAL: MOTION FOR ~llSTRIAL: MOTIOI\' TO STRIKE: ~IOTION FOR
ARREST OF JtJDGME:\T
To: lclt21.9-fcci-!61a-ieUf-I IS9b
[roo: chconghlln
11-1HZ
4',\4pil1
CERTIFICATE OF SERVICE:
Pursuant to ~RCP 5(b). I do hereby certify that. on this date. 1. Zach Coughlin I
deposited in the United States mail at Reno. Nevada. in a sealed envelope. postage
prepaid. a true and correct copy of the foregoing ~fOTION FOR NEW TRIAL: MOTIO~
FOR MISTRIAL MOTION TO STRIKE: MOTION FOR ARREST OF .nIDGMENT
and or electronically served (via electronic method of transmission previously given
express permission to utilize by those with requisite authority to provide it. upon which
Couglin reasonably relied and or relies):
7
ZACHARY N, YOnw. ESQ.
Washoe Cotulty DA Office
Address: 1 South Sierra
'I')
P,O, Box 30083
Reno, :NV 89520

11
Phone ]l;umber: 775-328-3200

Fax number: 775-325-6703
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Email: zyoung@da.u-3shoecounty.us
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Admit Date: 1O!2012004
IS
Law School: McGeorge School of Law

DATED THIS: Dated this ]l;ovembcr 26th. 2012
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is! lach CQughljll'--

!/",
'
Zach Cought"" '

'-.,)
Defendant
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2~
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- 60-
EMERGENCY EX PARTE MOTION FOR EX1ENSION OF TIME TO FILE'.fOTION

FOR NEW TRIAL: MOTION FOR ;..nSTRIAL: MOTION TO STRIKE; MOTION FOR
ARREST OF JUDGMEKT
p, 1
of
. To,. 7dE21e9-EtcB-461a-BeOf-lea559b
From: ,acncougnlln
11-16-12
4:14pm
INDEX TO EXHIBITS:
'-
I. Exlubit I' variolls relevant materials
s
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7
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1::
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1')
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24
2B
- 7:7-
EMERGENCY EX PARTE MOTION FOR EXTDISION OF m,!E TO FlLE~IOTION

FOR NEW TRIAL: MOTIO)J FOR ~fISTRIAL: MOTION TO STRIKE: MOTION FOR
ARREST OF n fDGME\,T
p.
of 8
To: lc3f21e9-fcc8-461a-8eOf-le.559b
fr .. , lachcoughlln
FACSIMILE
Date:
11/26/2012
To:
From:
7c3f27e9-fcc8-467a-8eOf-7ea559b45d5bgeneraI693298
zachcoughlin
Subject:
11-26-12
4:,4p11
p, 1
of 6
Received:
To: d"b6826-1b82-!lfd-8ddf-l01bbfl
<tOIl:
lichcougbl1n
Nov 26 2012 D4:55pm

11-16-\1 1:11pm p. 1 of 8
FILED
1
2
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4
20!ZHOV27 PH 12: 18
Zach Coughlin
1471 E. 9th St.
Reno, NV 89S12
Tel and Fax: 9496677402
5
6

COUNTI' OF WASHOE; STATE OF NEVADA
9
10
TATE OF NEVADA,
PLAINTIFF
s.
) RCR2011-063341
) DEPT2
11
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ACHARY BARKER COUGHLIN;

DEFENDANT
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EMERGENCY EX PARTE MOnON FOR EXTENSION OF TIME TO FILE MOTION

FOR NEW TRIAL; MOTION FOR MISTRIAL; MOTION TO STRIKE; MOTION FOR
ARREST OF JUDGMENT
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POINTS AND AUUIORITlES
20
FACTS
21
No pernon to be compelled to b. Witness against himself or haself in criminal action,
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NRS 178.394
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or to be unnecessanly restramed. TIME NRS 178.472
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Enlargement NRS 178.478
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by mail. TIME NRS 178.472 Computation. In computing any period of time the day of the act or event from
26
which the designated period of tim. begJns to J1JI1 shall not be included. The last day of the period $0
27
computed shal! be included, unless it IS a Saturday, a Sunday, or a nonjudicial day, in whlch event the penod
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Computabon.I\'RS 178.476
MotionsffidaVl1s. NRS 178.482
Additional time after service
- 117 ~
EMERGENCY EX PARTE MOTION FOR EXTENSION OF TIME TO FIl ,EMOTION

FOR NEW TRIAL; MOTION FOR MISTRIAL: MOTION TO STRIKE; MOTION FOR
ARREST OF JuDGMENT
Received:
To: de6b68!ti-lb81-llfd-6ddf-1Ulbb!2
From: z;cbconghl1n
Nov 26 2012 04:56pm

11-!ti-12 \,SSpG
1
2
I
I
runs untillhe end of the next day which is not a Saturday, a Sunday, or a nonjudicial day. When a period of
time prescribed or allowed IS less than 7 days, intermediate Saturdays, Sundays and nonjudicial days shall be
excluded m the computation (Added to NRS by 1967. 1451) NRS 178.476 Enlargement When an act IS
required or allowed to be done at or within a specified tim the coW'! for couse shown may at any time in its
discreuon: I. Willi or willlout motion or notice, order \he period enlarged if request therefor is made before
lIIe ""Piration of \he period originally prescribed or as extended by a previous order; or 2 Upon motion
made after the expiration of the specified period pel1l1it the ad to be done if1he failure to ad was \he result
of oxclmble neglect, Eoot \he coW'! may not extend \he time for taking any ""tion underNRS 176515 or
176525 except to lIIe extent and under the condJuons stated in those sectIOns. (Added to NRS by 1967.
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1451; A 1969. 10; 1985,63) Jo..'RS 178 478 Motions; affidavits. 1 A wnttenmotion, oIherthan one which
11
may be heard ex parte, and notice ofllle hearing \hereof mwt be served not later than 5 days before \he time
12
sperified for \he hearing W1less a different period is fixed by rule or order of the coUll For cause shown such
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an order may be made on eK parte application. 2. When a motion is suwoned by affidavit, the affidavit must
14
be served willi \he motion, and opposing affidaVIts may be served not less than 1 day before the hearing
15
unless the court pel1l1its lIIem to be served at a later time. 3. A cerUlicate of serVIce must accompany e""h
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motion filed (Added to NRS by 1967, 1451. A 1991, 303) NRS 178.482 Additional tnne after service by
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mail Whenever a jXIrty has the right or is required to do an act within a prescribed period afitr lIIe service of
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a notice or other paper upon the jXIrty and the notice or oilier paper IS served by mail, 3 days shall be added
19
to the rcescribed period. (Added to NRS by 1967. 1451)
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http://sdrv.mslTt4dYthttp:lIsdrv.mS'XmRkVL
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condor to lIIe tribunals, .. check that cert of service 00 01' Leslie Tibals 1117112 faxing to Coughlin at 949 667
7402 .one, [ax to coughlm not sufficient service .two. she dIdn't fax anything to coughlIn. three, certificate
of service does not mention it being served on DDA YOUllg .. yet DDA YoUllg had it at the 1l1191l2 Trial
date in RR2011-063341 (\he one where his only 'prooF as to the identity or nature of \he thing allegedly
stolen wa> some "vtripic' thlllg that be DDA YOUllg took directly 001 of the pelice reporLwbere DDA
YOUllg \hen demonst:roted a lack of candor to lIIe tribunal in .Heging It was not part of the police report,
especially where DDA sought to exclude the Wliness SlBtemenlS, Supplemental Declaration, and
subsequently produced 'Narrallve' (which DDA further demonstrated a lack of condor to the tribonal and in
dealings With Opp<>Iing coWlSCI by purportmg the narranve to have been mcloded m the mibal dlscovety
propmmded .. whIch it was not then \here lS the r""t that the RJC purpor1s to have fax Coughlin two
different Orders on 11116112 speaking to \he various motions to quash subpoenas. but that. how-ever, \he RJC
seems to have, uh. accidentally f""ed \he same order twice, \herefore ptejudicing coughlins case willi respect
to Ius not havlllg been served the secend order a smgle:time. but rather his havlllg been served the 12/1611 I
- 2/1-
EMERG:lCY EX PARTE MOTION FOR EXTENSION OF TIME TO FILEMOTlON

FOR NEW TRIAL MOTION FOR MISTRIAL: MOTION TO STRIKE; MOTION FOR
ARREST OF JUDGMENT
p,
1 of 8
Rae.i,ad:
To, de6h6816-1h81-!J!d-Srldf-161bbf1
ltlv 26 2012 04:56pm
FrOl' rachcoogblln
11-16-11
4,55pM p, 4 of 8
filedrCl2011-06334 "Order Denying Moti<lllS for Mistrlal and Continuance' (with a file stamp of 11:41 AM)
TWICE, while the 'Order' banng. f11. slamp ofll :42 om on 12116'11 in rcr201l-063341 was never faxed
2 \0 c.,ughlin, despite the Certificate of Service' of RJC Lon Townsend mdicating it was... the digitally
verifJable receipts on Coughlin's end Jl'ove otherwise, and YOU ARE HEREBY PLACED ON A
3 LITIGATION HOLD NOTICE WITH RESPEcT TO Ao."f'l AND ALL FAX LOGS BY EITHER THE
WASHOE COUNTY PUBUC DEFENDER AND RENO JUSTICE COURT, OR TIlE RENO CITY
4 ATTORNEY, OR WASHOE COUNTY DISTRICT ATTORNEY'S OFFICE AS TO ANY FAXES,
EMAILS.OROTHERTRA..\.SMISSIONS PURPORTING TO BE DELIVERED OR SENT TO ZACH
5 COUGHUN AT ZACHCOUGHUN@HOTMAlLCOMANDORZACHCOUGHLIN'S FAX NUMBER
AS USTED UNDER SCR 70 AT WW.NVBARORG OF 9496677402,
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Further, Coughlin's attachedrnents (including tho.. on digital media discs) have suddenly gone missing or
the RJC IS apparently alleging u.:y were never there. Baihff Maldonada on 11115112 took Coughlin's filmg
from the filign office desk where Coughlin had left !hem for Eling with Robin Baker, and ventured out
towards u.: RMC (Cooghlin bed gone to pe!SOn8lly deliver a copy of those ftIigns \0 WCDA Z Young). ..oo
the chain of custody is problematic ..
ADD TO TillS ANY AND ALL FAX LOGS (INTERESTING WHAT CURTIS HARVEY HAS TO SAY
ABOn THINGS) TIlE RENO JUSTICE COURT AND WASHOE COUNTY SHERIFFS OFFICE (AND
THE SAME WATTS-VIAL NAME COMES UPON MOTIONS TO QUASH AS IN JUDICIAL
ASSISTfu'ITS IN THE RlC. HMMMMN,LIKE THE TOWNSEk.'D NAME COMES UP IN RJC
JUDGE'S SECRETARIES AND RENO MARSHALS IN THE RMC, LIKE TIlE MARRIAGE BETWEEl'!
MATERIAL WITNESS ARRESTING OFFICER RPD NICK DURALDE AND ECOMMI91I
DISPATCHER WORKING THAT NIGHT WHOSE VOICE IS APPARENTLY ON EXHIBIT 2 FROM
THE 063341 TRIAL DISPATCH TAPES, HIS WIFE, JESSICA DURALDE ..
ADD TO THAT THE FACT THAT THE RENO JUSTICE COURT FAILED TO COMP!.Y WITH
COUGHUN'S SUBPOENAS FOR THE 11114112 DlSClPUNARY HEARING AT THE STATE BAR OF
l\'EVADA (THE ONE WHERE THE SBN AND PM'EL TRIED TO PULL A IN RE MlRClI ON
COUGHLIN BY USING SCR 111(5)'S "IF A JUrX:lE SIGNED AN ORDER ITS CONCLliSIVE PROOF
OF A CONVICTIO:-l, SO WE'LL HAVE HER COME IN AND TESTIFY TOO AND ALLUDE TO
UNSWORN HEARSAY (LIKE BY R.l>,fC MARSHAL HARLEY ABOUT SOME 'DISASSEMBLING A
RECORDING DEVICE fu'ID HIDING IT IN THE BATHROOM" NONSENSE THAT IS PATENTLY
FALSE) fu'ID THEN CLOAK TIlE JUDGES LIES IN A WARM CURTAIN OF JUDICIAL
IMMUNITy....
.
Judge Sferrazza, in his ardar as rendered alluded to matters (eviction cases RJCrev2011-001708, where the
RJC failed \0 or refused to flied c.,ughluis 12126111 Notice of Appeal of the Order following the 12121111
Hearing on Coughlin's Ill! 6111 Motion to Contest Personal Property Lien (the one Coughlin was denied for
over 6 weeks despiIe NRS 40.253 (7)-(8) requiring one withm 10 days be heard by the RJC...and Coughlin
was the only on, who showed up (he checked in wlthRJC ChtefBailiffSexton. on tune, on 11122111 for the
heanng Cooghim was noticed on ("notice' Just as good under
I
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The problem for the RJC under Glazier v. Justice C.ourt and LIPpis v. Justioe Court is that, wlUle the Judges
may enJoy unmumty, the Court does not, nor does its staff or administrators So where the RJC notices
lancIlord and tenant in writmg of a "Tnal' on 10/25/11 'in the Richard G. Hill ~mary eviction 'Trial"
deboer., and that settll1g IS violative of NJCRCP 109 ,especting 1I1e 20 days required between service of the
summons andcamplamt and scttmg of a 'lnal on the ments" ... the Court has exposure. Same goes for failing
to me the Nouoe of Appeal Coughlm submItted, .ppr~ly, in accadanoe with the rules in RIC
Rev2011-000374, on March 16th, 2012, in response to the March 15th, 2012 Order by Judge Schroeder (and
the clerk's vOIce on the audio tape of that summary eviction proceedll1g in r,v2012-OOO374 ('excuse me
Judge Scl.-oeder,. I know you wanted to do \hal other CilSt fITs\, but Coughlin is not here yet, SO do you
wanna rush a default through on his casc' or somethtng awfully SImilar to that .. ) reveals an express
28
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23
24
25
26
EMERGENCY EX PARTE MOrlON FOR EXTENSlON OF TIME TO FlLEMOTlON

FOR NEW TRIAL; MOTION FOR MISTRlAL; MOTION TO STRIKE; MOTION FOR
ARREST OF JUDGMENT
,
Received:
To, de6b6816-1b81-41fd-8ddf-l01bb!1
From: zacheo.gbl1.
IIov 2S 2012 04:51pm
11-16-11
1:11pm
intontion to try to hurriedly,.""". a default aguinst Coughlin, even though the fax headers say the summary
eviction order was faxed at 8;24 am am for B he1!ring nouced fIX 8;30 1Illl .. which makes such an
5
6
7
So, while the WCDA Office and Mary Kandarss might want a convICtion of Coughlin in IJc rev2011-063341
(and the SBN's K\l\g alwaY' enJOYs a good SCR 111(S) short workday, to be sure) ...it" not so clear ,ts
worth It to !he Reno Jusuce Court, its Judges, Adm\l\!SImuon or Statl~ nor worth the appe8Illl\Ce ot'the
Judiciary 'being pll'lhed around' as Judge Cliftoo apparently indicated to Judge Sferr=a during the
conference they had (at Clerk Tami announced in Court to Young and Coughlin) wherein impetnlissible
extra judicial discussiom resulted in an impermissible effect being had on the ruling in rev2011-063341 (not
to meonen City Attorney Skau's fraudulent assertion of .n Order bY Judge Sferrazza authorizing Skau to
secure Coughlin's attendaoce at the 11113/1 2 Hearing. via service 'bY email', "to say nothing of the
impermissible ex parte communications occuring between the RJC, WCDA, WCPD, and Reno City
Attorney on 11 18112 (especially COJ\Sldering the impermissible release of Coughlin's smart phone and micro
sd card to the &\.fC Morshals, as admitted to byWCSO employees in easily prov8ble was, to !he ReM
Msrshals, full day after Coughlin's smartphone and micro sd card were booked into Coughlin's secured
property at the WCDC ,(therefore, not at alIa 'sosrch incident to arres\ ... whtch is too bad, corISldering an
that Diaz would allow.... )
CQNCWS!OJ'{
10
pi.... reins13l. the appesl and or grant ifp status or provide time to lIUbmlt" proper Ifp as
12
bar coumel clearly Is glPlning (<II" a Panel Order that entails Coughlin paying back tills _ondonabl.
13
_mey ree aW1lrd prior to reinstatement, and thaI Is If liar Counsel ht KIng doesn't get his stated
14
wish to bave Coughlin disbarred. Furtber, tho'Distrlct Court'. 3/30112 Order should be sdded to this
15
appeal given the cir<umstanees, to whatever tttent CoughUn r.Oed to m timely nollce of appeal
]6
thereto, as should the Dolke of appeal of the juStice court'sllfll111 Order Resolving CoughUn'.
17
November 17th, lOU Motion t. Contest PeI'SOlllll Properly lien cOJUdlering the RJC faDed 10 me
18
stamp In Coughlin'. timely 12126111 noll.. of appeal thereto in rJc ...-.2011-001708, as the rjc did In
19
another summary eviction from" t1lII1m.n:ilIll.... illVolving ooughIln'. ronner home law office in rje
20
re.zOU-000374... further RMC Judge N..b HoI...e. has similarly refused to follow the rul.. on
21
transmitting appea" In 11 TR 16800 ( ..... wllfe RIchard RDI had RMC MII..hal Joel HlIrley vIolat.
22
eourtbouse sa...tuary do<trine wbere HlIrley personally served Coughlin notice oHhe 3123112 order 10
23
show
24
..........-....... "";~(-........::~--.......
25
26
cau hearing in the district court appesl of this matter (and really, on Ottober 19th, lOU,
Coughlin alnaqdy had a District court appeal (n tbis malttr in <vU-03126 or
27
28
- 411-
EMERGENCY EX PARTE MOTION FOR EXTENSION OF TIME TO FIL,MQTION

FOR NEW TRIAL: MOTION FOR MISTRIAL: MOTION TO STRU MOTIONFOR
ARREST OF mPGMENT
p, \
of 8
it
Received:
To: de6b6826-lb81-47fd-Bddf-JOlhbfl
FrOB: zachcoDghilD
Nov 26 2012 04:55pm
J
"
FACSIMILE
Date:
11/26/2012
To:
de6b6826-1b82-47fd-8ddf"701bbf20ecdfgeneraI693298
zachcoughli n
From:
Subject:
11-16-11 4:55pm p, 1 of 8
Received;
To: !r6b6826=lb82-!7fd-8ddf-7Dlbbf2
From: zachcoDghllD
Nov 302012 11:45am
FACSIMILE
Date:
11/30/2012
To:
From:
de6b6826-1b82-47fd-8ddf-70 1bbf20ecdfgeneral693298
zachcoughlin
Subject:
II-JO-11 11:44am
p. I
of 117
Received:
.10: de6h!m-lh8Hlfd-8ddf-l01hhf1
Fro.: za~hcouqhl1n
Nov 30 2012 11:45am

11-JO-l1 11:44a.
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de6b~826-1b82-47Ed-8ddf-701bbfl
From: zachcouqhlln
Nov 30 2012 11:55am
FACSIMILE
Date:
11/30/2012
To:
From:
de6b6826-1b82-47fd-8ddf-701 bbf20ecdfgeneral693298
zachcoughlin
Subject:
11-30-11 11:13am
p. 1 of 5
Received:
To: de6b6816-lb81-11fd-8ddf-l0Ibbfl
1
2
Nov 30 2012 11 :55am

From: zochcoughl1n
11-30-11 11:530.
p. 1 of 5
Document Code:
Zach Coughlin
1471 E. 9th SI.
R~no. NV 89512
Telephone and Fax: 9496677402
pro per defendant denied his Sixth Amendment Right to Counsel

IN AND FOR 11IE COUNlY OF WASHOE, STATE OF NEVADA
STATE OF NEV ADA;
)
)
)
Plaintiff,
) CASE NO: RCR2011-063341
Ie
vs.
11
12
13
14
) DEPT. NO: 2
ZACHARY COUGHLIN;
)
)
)
Defendant.
------------)
NOTICE OF APPEAL
15
16
COMES NOW, ZACH COUGHLIN, and files this NOTICE OF APPEAL on his own behalf
17
l8
as to any and all Orders (inlcuding those as to by Judge Sferrazza and or any RJC Judge presiding
19
over any aspects of this case in Judge Sferrazza's abscence, and it is based on the argument and
20
autborities herein, and the attachments and filings on record and or submitted for filing with this
21
court and requests the transcript be prepar~d at public expense and in accord with nrs 189.030 given
22
that nrs 4.14(a) only applies to civil cases.

FACTS A:-iD LAW
24
25
APPEALS TO DISTRICT COURT

\ppeal by Defondant
28
NRS 189.010 Appeal must be taken within 10 days. Except as otherwISe provided in NRS 177m 5. a defendant m a
crim IOHI actIOn tned before a .1uslice of the peace may appeal from the final judgment therein to the district court of the
- 1/4 -
NOTICE OF APPEAL
Received:
To: de6b6816-1b81-41fd-8ddf-1Dlbb!1
FeOB: zachconghlln
Nov 30 2012 11:55am
\1-)0-12 l1:ilam
p. 1 of i
county where the court of the JustIce of the peace is held_ at any ~me WIthin 10 days from the time of the rend,llon of the
judgment.
[1911 Cr. Pmc. 662: RL 7512, NCL 11309)-(NRS A 1995. 1536)
NRS 189020 Nollcc of intentIon to appeal Filing ,md service, slay of judgment pending appeal
I. The party mtendtog to appeal must ftle wIth the Jus~ce and serve upon the dlStnct attorney a nollcc enlltled m the
achon, sentng forth the character of the judgmen~ and the mtentlon of the party to appeal theretrom to the dlStnct court
5
6
7
10
11
12
2 Stay of judgment pendmg appeal is governed by NRS 177 !OS and 177 115.
[1911 Cr Pmc 663; RL 7513; NCL 11310)-(NRS A 1967, 1467)
NRS 189030 TnmsmlSslOn of transcnp~ other papers, sound recording and copy of docket to distJlct court.
I The jus~ce shall, wltlun 10 days atter the notIce of appeal IS tiled, tnmsmlt to the clerk at the dIStrict court the
trartsCnpt of the ca;:e, all other papers relating to the case and a certified copy of the docket
2 '1 he Jusbce shall give notice to the appellant or the appellant's attorney that the !ranscnpt and all other papers
relatmg to the case have been hIed WIth the clerk of the distnct court.
3 If the district judge so requests, before or afrer receiving the record, the justice of the peace shall tnmsmit to the
dIStrict judge the sound recording of the case
[I911 Cr. Prac 664; RL 7514; NCL 11311)--(NRS A 1973,631; 1979, 1512)
NRS 189 U35 Procedure where transcnpt defective.
I Except as prOVIded m subsecllon 2_ If the dlStnct court tmds that the transcnpt of a case winch was recorded by
sound recordmg e4U1pment IS materially or extensively defectlVe, the case mlL'5t be returned for retrial m the justIce court
from which it carn e.
14
15
16
2. If all parties to the appeal stIpulate to bemg bound by a partIcular transcnpt of the proceedmgs In the jushce co~
or sbpulate to a partICular change m the transcnpt, an appeal based on that transcnpt as accepted or clumged may be
heard by the distJict court WIthout regard to any defects in the transcript.
(Added toNRS by 1979, 1512)
NRS 189050 Action to be judged on record. An appeal duly perfected transfers the action to the distnct court to be
judged on the record
18
(Part 1911 Cr. Prac. 666; RL 7516, NCL 11313]--(NRS A 1979, 1512)
19
}''RS 189.060 Grounds for dISmissal of appeal; enforcement of judgment

I. The appeal may be dISmissed on either of the tollowmg grounds:
20
21
22
Ca) For fadure to take the sarne in time.

(b) For faIlure to appear in the district court when required.
2 If the appealts dismissed, a copy of the order of dISmISsal must be remitted to the JustIce, who may proceed to
enforce the judgment
[Part 1911 Cr. Pmc. 666; RL 7516, NCL 11313 J
24
NRS 189065 DlSm ISSlII for failure to set or reset appeal for hearing
25
I. An appeal must be d1sm issed by the district court unless perfected by application of the defendant, wlfum 60 days
atier the appeal IS filed in the Justice court, by hav Ing it set for hearmg
27
2 . If an appeal has been set for hearing and the hearing is vacated at the request of the appellant, the appeal must be
dismISSed unless application is made by the appellant to reset the heaTIng within 60 days aner the date on whIch the
hearmg was vacated.
28
(Added to NRS by 1965.376, A 1985, 57, 972)
- 2/4 -
NOTICE OF APPEAL
Received:
To: de6b6816-lb81-47fd-8ddf-70Ibbfl
fro., zachconghl1n
Nov 30 2012 11:56.m

II-3D-II 11:53am p, 4 of 5
NRS 189.070 Grounds for dismIssal of complaint on appeal. Any complamt, upon motion of the defendan~ may be
JlSmissed upon any of the followmg grounds.
I. That the justice of the peace did not have JurisdIction of the offense.
2 That more than one offense
IS
chargeJ in ~my one count of thl! complamt
1 That the tacts stated do not constItute a publtc onense

5
6
CONCLUSION
'7
"Ihe undersigned hereby request this Court consider these materials presented herein in
8
deciding upon this matter,
10

11
12
I declare, pursuant to NRS 53_045, under penalty of perjury under the laws of the State
13
of Nevada that the foregoing Is true and correct and that this document does not contain any
14
social security numbers, pursuant to NRS 239B.030, an affinnation to that effect this hereby Is,
15
16

17
]8
19
?o
:.?1
)s/ Zach CoufUJlin

Zach Coughlin, Esq.
DefendantJ Co-Counsel for Coughlin
22
23
24
25
?6
27
28
- 3/4 -
NOTICE OF APPEAL
Received:
To' de6b6816-lb81-41fd-8ddf-10lbbfl
tram: zachcoughl1n
Nbv 30 2012 11:56am

11-30-11 11,53ao
p. 5 of 5
PROOF OF SERVICE
2
6
7
8
9
sending to their regis1ered email address and fax number as found on www.nvbar.org, hand delivery
to drops lot or front desk, and by placing a true and correct copy of the foregoing document in the

Washoe County DA
1 South Sierra P.O. Box 30083
Reno, NV 89520
Email: zyoung@Jda.washoceounty.us
10
11
12
13
14
15
16
17
Jim Lelsie, Esq.

P.O. Box 30083 Reno, NV 89509
Email: jleslie@Jwashoecounty.us
BarNo. 4925
One California Ave
Reno, NV 89509
(715) 331-4800
18
19
~o
?1
/s/ Zach Coughlin

Zach Coughlin, Esq.
23
24
25
26
27
28
- 4/4 -
NOnCE OF APPEAL
Received:
. To: de6b6826-1b8Hlfd-8ddf-l01bbf2
From: zachcougblln
Nov 30 2012 11:51am
FACSIMILE
Date:
11/30/2012
To:
From:
zachcoughlin
Subject:
11-30-11 11:56am
p. 1 of 5
Received:
To: detib6816-lb81-47fd-8ddf-l0Ibbf1
1
2
~ov
30 2012 11:51am
From: Hchcoughlln
II-3D-II 11:5tiam
p. 1 of 5
Document Code:
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512

STATE OF NEVADA;
)
)
)
Plaintiff,
) CASE NO: RCR2011-063341
10
vs.
11
) DEPT. NO: 2
12
13
)
)
)
ZACHARY COUGHLIN;
Defendant.
14
-----------)
NOTICE OF APPEAL
15
16
17
18
19
20
authorities herein, and the attachments and filings on record and or submitted for filing with this
21
court and requests the transcript be prepared at public expense and in accord with nrs 189.030 given
that nrs 4. 14(a) only applies to civil cases.
13
FACTS Al'lD LAW
24
25
26
?i
Appeal by Defendant
28
NRS 189.010 Appeal must be taken within 10 days. Except as otherwise proVIded in l'<"RS 177.015. a defendant in a
criminal action tned before a justice of the peace may appeal from the final judgment therein to the district court of the
- 1/4 -
NOTICE OF APPEAL

Received:
To: de6b6816-lb81-47fd-8ddf-70Ibbfl
From: zachcoughl1n
Nov 30 2012 11:57am
11-30-11 11:56am
p. 3 of \
county where the court of the JustIce of the peace is held, at any time within 10 days from the time of the rendItIOn of the
judgment.
[1911 Cr. Pmc. 662; RL 7512; NCL II309]-(NRS A 1995, 1536)
NRS 189.IJ20 Nobce of mtenhon to appeal FIling and service; stay of judgment pendmg appeal.
1 The party Intending to appeal must fIle With the jusuce and serve upon the dIStrict attorney a nobce enhUed m the
aclion, settmg forth the character o!"the judgment, and the intentIOn of the party to appeal therefrom to the district courl
5
6
2 Stay of judgment pendIng appeal is governed by NRS 177 105 and 177 liS
[1911 Cr Pmc. 663; RL 7513; NCL II310]-(NRS A 1%7, 1467)
I\'RS 189030 Transmission of tmnsc"pt, nther papers, sound recordmg and copy of docket to district court.
8
9
10
11
12
13
14
15
16
17
I The Justice shal~ Within 10 days aller the notice at appeal IS tiled, trnnsmlt to the clerk of the dIStrict court the
transcript of the case, all other papers relatmg to the case and a certified copy of the docket.
2 The ju.'lice shall give nolice to the appellant or the appellant's attorney that the transenpt and all other papers
relatmg to the case have been hied with the clerk of the diStrIct court.
1 If the distnct Judge so requests, before or after receiving the record, the justice of the peace shall transmIt to the
district judge the sound recordIng of the case
[1911 Cr. Pmc. 664; RL 7514; NCL 11311]-(NRS A 1973,631; 1979, 1512)
NRS 189.035 Procedure where transcnpt defective.
I. Except as provided In subsectIOn 2, If the district court fmds that the tmnscnpt of a case winch was recorded by
sound recorcimg equipment IS matenally or extensively defecttve, the case must be retwned for retnsl m the justice court
from which it came.
2 If all parnes to the appeal stipulate to being bound by a partIcular transcnpt of the proceedrogs In the Justice court,
or supulate to a particular change In the trnnscnpt, an appeal based on that trnnscnpt as accepted or changed may be
heard by the district court without regllfd to any defects in the transcript
(Added to NRS by 1979, 1512)
NRS 189.050 Action to be judged on record An appeal duly perfected transfers the action to the district court to be
18
[Part 1911 Cr. Pmc. 666, RL 7516; NCL I I313]-(NRS A 1979,1512)
19
NRS 189.060 Grounds for dismissal of appeal, enforcement of judgment.

I The appeal may be ,hsmlssed on either of the followmg grounds:
20
21
22
?3
Ca) For failure to take the same in time.

(b) For faIlure to appear in the district court when required.
2. If the appeal IS dismISSed, a copy of the order of dISmISSal must be remItted to the justice, woo may proceed to
enforce the judgment
lPart 1911 Cr. Pmc. 666, RL 7516; NCL 11313]

i'>'RS 189.065 DISmISsal for faIlure to set or reset appeal for heanng.
25
26
?7
28
I An appeal must be dism issed by the district court unless perfected by application of the defendant, within 60 days
after the appeal IS filed In the jushce court, by hav Ing It set for hearmg
2 If an appeal has been set for hearing and the hearing is vacated at the request of the appeUant, the appeal must be
dL<m Issed unless application is made by the appellant to reset the hearing WIthin 60 days after the date on which the
hearmg was vacated.
(Added to NRS by 1965,376, A 1985, 57,972)
- 2/4 -
NOnCE OF APPEAL

Received:
To: de6b6816-1b81-41fd-8ddf-10lbbfl
1
2
3
trOll:
m~conq~lin
Nov 30 2012 11;58am
11-30-11 11:16am p. \
of 1
NRS 189.070 Grounds for dlsm issal of compla1l1t on appeal. Any complaint, upon motion of the defendant, may be
dISmissed upon any of the followmg grounds:
That the justice of the peace did not have jurisdiction of the offense.
IS
charged in anyone count of the complamt
3 That the tacts stated do not constitute a public ollense
CONCLUSION
8
9
deciding upon this malter.
10

11
12
13
of Nevada that the foregoing is true and correct and that this document does not contain any
14
social security nwnbers, pursuant to NRS 2398-030, an affinnation to that effect this hereby is.
1')
16
DATED this 28th of August, 2012;

17
18
19
20
?1
. /s/ Zach Coughlin

Zach Coughlin. Esq.
/,2
24
25
.27
28
- 3/4 -
NOnCE OF APPEAL
Received:
. To: a.6b6826-lb82-47fd-8ddf-70Ibbf2
frOB' mh,oughl1n
Nov 30 2012 11:59am

11-JO-12 11,16am p. I of 5
PROOF OF SERVICE
2
3
On this date, I caused a copy oflhe foregoing document s to be served upon the following by
sending to their registered email address and fax number as found on www.nvbar.org, hand delivery
to drops lot or front desk. and by placing a true and correct copy ofthe foregoing document in the
U. s. mail addressed to:
5
6
7

Washoe County DA
1 South Sierra P. O. Ilox 30083
Reno, NV 89520
Email: zyoung@da.washoccounty.us
10
11
12
13
14
1">
16
17
Jim Lelsie, Esq.

P.O. Ilox 30083 Reno, NV 89509
BarNo. 4925
One California Ave
Reno, NV 89509
(775) 337-4800
18
19
;'0
21
22
lsi Zach Coughlin
Zach Coughlin, Esq.

24
25
26
27
28
- 4/t -
No-flCE OF APPEAL
Received:
To: de6b681.6-lb81-41Ed-8ddE-101bbll
From: z,thcoughll
Nov 30 2012 11:59am
FACSIMILE
Date:
11/30/2012
To:
From:
de6b6826-1 b82 -47fd-8ddf-70 1bbf20ecdfgeneral693298

zachcoughlin
Subject:
11-30-11 11:18..
p, 1
01 1
Received:
To: de6b6816-1b82-47fd-8ddf-701bbf2
2
3
4
rrom: z.chcooghl1n
Nov 30 2012 11:59am

ll-l0-12 11:\8..
p. 2 of \
Document Code:
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
IN TIlE JUSTICE COURT OF RENO TOWNSHIP

6
7
STATE OF NEVADA;
)
)
)
Plaintiff,
) CASE NO: RCR2011-063341
10
vs.
11
) DEPT. NO: 2
12
13
)
)
)
ZACHARY COUGHLIN;
Defendant.
-----------------------)
NOTICE OF APPEAL
1 ';
[6
17
18
19
20
authorities herein, and the attachments and filings on record and or submitted for filing with this
21
court and requests the transcript be prepared at public expense and in accord with nrs 189.030 given
that nrs 4.l4(a) only applies to civil cases.
23
FACTS AND LAW
24
25
26
27
Appeal by Defendant
28
t--l<S 189 010 Appeal must be taken witlun 10 days. Except as otherwISe provided In 1'<1<3 177.015. a defendant In a
erim mal actIOn tried before a Justlce of the peace may appeal from the final judgment therein to the distnct court of the
- 1/4 -
NOTICE OF APPEAL
T~:
Received:
de6b6BI6-1b81-41fd-8ddf-l01bbfl
Nov 30 2012 12:00pm

From: zachcoughlln
II-3D-II 11:58am
p. 3 of 5
county where the court of the justice of the peace is held, at any Ume within \0 days from the Ume of the rendition of the
judgment
[1911 Cr Prac. 662; RL 7512, NCL 11309]-(NRS A 1995, 1536)
.J
I'<RS 1891120
No~ce
of inl<ntlOn to appeal Filmg and service, silly of judgment pendmg appeal.
I The party intendIng to appeal must lile WIth the jusUce and serve upon the dlStnct attorney a nollce entItled In the
actton, setting forth the character 01 the Judgment, and the Intenhon of the party to appeal therelrom to the dlstnct court.
5
6
2 Slay of judgment pending appeal IS governed by NRS 177 !OS and .111112.[1911 Cr. Prac. 663; RL 7513; NCL 1131 OJ-(NRS A 1967, 1467)
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court
",
8
9
10
11
12
13
14
15
16
17
I The Jusllce shall, wnJun 10 days after the notace of appeal IS tiled, transmit to the clerk at the dlStnct court the
transcnpt of the case, all other papers relating to the case and a certified copy of the docket.
2 The JLL,tice shall give nolIce to the appellant or the appellant's attorney that the transcript and all other papers
relating to the case have been filed With the clerk of the dlstnct court.
3. If the district judge so requests, before or after receiving the record, the justice of the peace shall transmit to the
distnct judge the sound recording of the case.
[1911 Cr. Prac. 664; RL 7514; NCL 113I1]-{NRS A 1973,631; 1979, 1512)
NRS 189.035 Procedure where tnmscnpt defectIVe.
I Except as proVided In subsechon 2, If the dlstnct court finds that the transcnpt of a case which was recorded by
sound recording equIpment is matenally or extensively defectIve, the case must be returned for Tetnal m the jusbce court
from which it came.
2. If all pames to the appeal shpulate to being bound by a partIcular transcnpt of the proceedings In the Justtce court,
or stipulate to a particular change In the transcnpt, an appeal based on that tnmscnpt as accepted or changed may be
heard by the district court without regard to any defects in the transcript.
(Added to NRS by 1979, 1512)

NRS 189.050 Action to be Judged on record. An appeal duly perfected tnmsfers the action to the district court to be
18
[Part 1911 Cr Prae. 666; RL 7516, NCL 113I3]-{NRS A 1979, 1512)
19
NRS 189.060 Grounds for dismissal of appeal: enforcement of judgment.
?O
1 The appeal may be dismissed on either o!"the lollowUlg grounds:

(a) For failure to take the same an time.
(b) For failure to appear in the distnct court when reqUIred.
22
2 If the appeal is rusmlssed, a copy of the order of dISmISSal must be remitted to the Justice, who may proceed to
enforce the judgment.
.23
[Part 1911 Cr. Prac. 666; RL 7516, NCL 11313]
24
I\RS 189.065 m,mlSsal for faIlure to set or reset appeal for heanng.
25
?6
27
28
I. An appeal must be dism issed by the distrIct court unless perfected by application of the defendant, within 60 days
after the appeal IS filed in the jushce court, by haVing It set for hearing.
2. If an appeal has been set for hearing and the hearUlg IS vacated at the request of the appellan~ the appeal must be
dISmISsed unless application is made by the appellant to reset the heanng within 60 days after the date on which the
hearing was vacated
(Added to !'IRS by 1965,376, A 1985, 57, 972)
- 2/4 -
NOnCE OF APPEAL
T~:
Received:
de6b6816-1b81-41fd-8ddf-10lbbf1
1
2
From: mhcoughl1n
Nov 30 2012 12:00pm
ll-l0-12 11:18am p. 4 of 5
t-:'RS 189070 Grounds for dismissal of compl.lIlt on appeal. Any complalIlt. upon motion of the defendant. may be
dlSm ISsed upon any of the followmg grounds:
That the justice of the peace did not have Jurisdiction of the offense.
IS
charged In anyone count of the complamt.
1 That the tacts stated do not constitute a pubhc ottense

5
CONCLUSION
8
9
deciding upon this matter.
10

11
12
13
of Nevada that the foregoing Is true and correct and that this document does not contain any
14
social security numbers, pursuant to NRS 2398.030, an affinnatlon to that effect this hereby is.
15
16

17
18
19
20
21
22
24
25
27
28
- 3/4 -
NOTICE OF APPEAL
Received:
T?: .de6b6a16-1b81-47fd-8ddl-l01bbll
Nov 30 1011 11:01pm
F,O.: !.chcoughlln
11-]0-11 11:58..
p. 5
01 5
PROOF OF SERVICE
2
sending to their registered email address and fax number as found on www.nvbar.org. hand delivery
to dropslot or front desk, and by placing a true and correct copy of the foregoing document in the
5
6
'I
8
9

Washoe County DA
I South Sierra P. O. Box 30083
Reno, NV 89520
10
11
12
13
14
15
16
Jim Lelsie, Esq.

P.O. Box 30083 Reno, NV 89509
BarNo. 4925
One California Ave
Reno, NV 89509
(775) 337-4800
18
]9
20
21
22
I for Coughlin
24
25
27
28
- 4/4 -
NOTICE OF APPEAL
Recei~ed:
To: de6b,816-1b81-47fd-8ddf-l01bbf2
Nov 30 2012 11:40am

trw,
lac~coughl1n
.11-30-12 11:3h.
FACSIMILE
Date:
11/30/2012
To:
de6b6825-1 b82 -4 7fd-8ddf-70 1bbf20ecdfgeneral693298

zachcoughlin
From:
Subject:
'
p, 1
o! 19
Recel~ed:
To: de6b6826-1b81-47fd-8ddf-7Dlbbf2
fro.: zochcoughlin
Nov 30 2012 11:40am

.11-30-11 11:380.
;62, Successive prosecutions; former joopardy, ;63, --In generaL 64, --Mistrial,
proceedings after, 65. --Offenses against ditTerent sovereignties or governmental units. 66,
Collateral estoppeL 67, Pr['trial proceedings in generaL
5
6
8
9
10
11
12
13
14
15
16
17
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19
20
4568. Preliminary examination, hearing, or commitment. 4569. --In generaL 4570.

--Timeliness. 4571. --Conduct of proc;cedings. 4572. Grand jury. 4573. In generaL 4574.
Composition. 4575. Conduct ofproccedings. 4576, --Evidence and witnesses. 4577.
Appearance and testimony of accused. 4578. Charging instruments; indictment and
information. 4579. In generaL 4580. --Neglect or delay. 4581. Form, requisites, and
sufficiency. 4582. --Relation between allegations and proof; variance. 4583. Amended,
successive, and superseding instruments. 4584. Arraignment. 4585. Pleas. 4586. In
generaL 4587. --Guilty pleas. 4588. --Other particular pleas. 4589. --Change of plea;
withdrawaL 4590, --Plea agreements. 4591. Pretrial dismissal or discontinuance. 4592.
Disclosure and discovery. 4593. --In generaL 4594. Evidence. (I). In generaL (2).
particular items or information, disclosure of. (3). --In generaL (4). Witnesses. (5).
--Agreement~. (6). Duty to collect, find, or obtain. (7). Duty to conduct or allow testing or
other analysis. (8). Duty to preserve. (9). Requests for disclosure. (10). Time and manner
of disclosure. (II). Proceedings concerning disclosure. 4595. Grand jury testimony and
proceedings
45%. --Notice of defense. 4597. --Other issues and applications. 4598. Trial in generaL
4599. --In general 4600. --Rightto fair trial in general, 4601. --Course and conduct of
trial in generaL 4602. Summary trial and convi~'!ion; bench trials. 4603. Public trial 4604.
--In generaL 4605. --Publicity. 4606. Recordation; court reporters. 4607. Joinder and
consolidation. 4608. Severance. 4609. Time of triaL 4610. ---In general. 4611. -_.
Adequacy of time to prepare; continuance. 4612. +-Undue delay; speedy triaL 4613.
Presence and appearance of defendant and counseL 4614. --In general 4615. --Clothing.
4616. --Custody and restraint. 4617. Judges. 4618, --In general 4619. --Selection and
assignment. 4620. --Qualifications. 4621. --Impartiality; bias and prejudice. 4622.
--Removal; recusaL 4623. --Conduct and comments. 4624. Prosecutors. 4625. --In
general. 4626. --Appointment, qualifications, and removal. 4627. Conduct and comments
of counsel; argument. 4628. --In general 4629. --Prosecutor. 4630. --Defense counseL
4631. Use of petjured or falsified evidence. 4632. --In generaL 4633. Failure to correct
false testimony, 4634. Questions oflaw or fact. 4635. Instructions. 4636. --In general
4637. --Particular issues and applications.
23
24
25
26
28
4638. --Presumptions, inferences, and burden Qfproof. 4639. --Degree of proof;

reasonable doubt. _ 4640. Verdict. 4641. --Ill general, 4642. --Directed verdict. 4643.
--Verdict forms. 4644. --Special verdicts. 4645. --Inconsistent verdicts. 4646. New triaL
ADDENDUM OR SUPPLEMENTAL OR AMENDED MOTION FOR NEW TRIAL
AND MOTION FOR ARRET OF JUDGMENT AND NOTICE OF NONSERVICE OF
DOGAN'S llJ7J12 PVRPORTED FAXING OF HIS MOTION TO OUASH SUBPOENA
AND OF CITY ATTORNEY SKAU'S FRAliDULENT REPRESENTATION
REGARDING BEING GIVEN PERMISSION TO SERVE COUGHLIN BY FA.'{ FOR
EX PART INIPROPERLY NOTICED 11113/12 HEARING
p, 11
of 19
Received;
To: de6h6826-1b81-41fd-8ddf-l01bbf1
s
6
7
Nov 30 2012 11:40am
From: Iachcoughl1n
.11-30-12 II:J8am p. 11 of 19
4647. Cwnulative errors. 5. EVIDENCE AND WITN ESSES. 4650. In generaL 4651.
Right to present evidence in generaL 4652. Reception of evidence in general 4653.
Presumptions, inferences, and burden of proof. 4654. Admissibility in generaL 4655.
Improperly obtained evidence; suppression. 4656. Identification evidence and procedures.
4657. --In general 4658. --Out-of-court or pretrial identification or confrontation. (I). In
generaL (2). Lineups. (3). Show-ups. (4). Photographs and drawings. 4659. --In-court
identification. (1). In general, 1 (2). Effect of improper pretrial idenl fication. 4660.
--Determination of admissibility; . j suppression. 4661. Statements, confessions, arid
admis _ jsions. 4662. --In general. -j4663. --Voluntariness, compulsory testi- I mony, and
selt~incrimination in gen-"jernL 0 4664. 0 Circumstances under which 'i made;
interrogation. (I). In generaL (2). Particular cases. 4665. --Recordation. 4666.
--Silence. 4667. Determinati
10
11
12
13
14
15
third party statements confessions and admission

sions, and admissions.
1669. Other acts and offenses.
1670. Hearsay.
1671. Other particular kinds or items of evi'
dence.
'672. Witnesses in general. 1673. --In general.
f674. --Competency and qualifications.
1675. --Examination.
1676. --Sequestration.
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18
4677. Right to present witnesses; compulsory

process.
19
4678. Confrontation.
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4679. Cross-examination.
4680. Credibility and impeachment. 4681. Opinion evidence.
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22
4682. --In general.

4683. --Expert testimony.
4684. Defendant as witness.
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4685. In general.
4686. --Credibility and impeacbment. 4687. --Silence.
AND MOTION FOR ARRET OF Jl JDGMENT Ai'll) NOTICE OF NONSER VICE OF
DOGAN'S 1117112 PURPORTED FI\.'XING OF HIS MOTION TO OUASH SUBPOENA
AI'ID OF CITY ATIORNEY SKAU'S FRAUDULENT REPRESENTATION
REGARDING BEING GIVEN PERlvIlSSION TO SERVE COUGHLIN BY FAX FOR
EX PART INIPROPERLY NOTICED 11113/12 HEARING
Received:
To: d,6b6B16-lbBl-47fd-Bddf-70Ibbf2
~v
Fro.: zachcoughlln
30 2012 11:41a.
.11-30-12 11:3B..
4688. --Defendant's right to testify.

46&9. Interference with witnesses.
4690. Vouching for witnesses; bolstering.
4691. Judicial questioning of witnesses.
4692. Immunity and privilege.
4693. Weight and sufficiency of evidence.

4694. Degree of proof; reasonable doubt.
6. JUDGMENT Atel SENTENCE.
4700. In general. 4701. Treatment of defendants following con'

viction but before sentencing. -1. 702. Propriety of sentence in general.
10
11
-I. 703. Discrimination or vindictiveness in gen

eral. -1704. Matters considered in sentencing. H05. --I n general ... I. 706. --Presentence
report. 4707. Credits.
POB. --Evidence and witnesses. 4709. Sentencing guidelines.
12
13
14
-'710. Statutory minimum or mandatory sen

tences. -'711. Multiple sentences; concurrent or con
secutive terms
19
Further sentencing shouold have been bifurcated, the DAS arrangment subjects coughlin
to unreasonable governmetal interference, search and seizure, patent agent practice unduly
compromised confidentiality of clients, etc.
In general.
4714. --Right to hearing in general.
4715. --Course and conduct of proceed
ings in general.
4716. --Notice; disclosure and discovery .
20
4717. --Bifurcation.
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4718. --Time for proceedings; continu

ance.
4719. --Presence and appearance of de
fendant and counsel.
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4720. --Judges.
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4721. --PrQsecu tors.

DOGAN'S 1117112 PURPORTED FAXING OF HIS MOTION TO QUASH SUBPOENA
A,J"lD QF CITY ATTORNEY SKAU'S FRAUPULENT REPRESENT AIION
REGARDING BEING GIVEN PERMISSION TO SERVE COUGHLIN BY FAX FOR
EX PART IMPROPERLY NOTICED 11!l3/12 HEARING
p. 13 of 19
Received:
To: de6b6B16-1bB1-47fd-8ddf-701bbf1
1
2
4
5
Nov 30 2012 11:42am

from: zachcoughl1n
\\-J0-11 11:380&
4722. --Conduct and comments of coun

sel; argument. 4723. --Instructions. 4724. Resentencing. 4725. --I n general. 4726.
--Reconsideration or modification.
4727. Presumptions, inferences, and burden
of proof.
4728. Degree of proof; reasonable doubt.
4729. Habitual and career offenders.
4730. Probation and related dispositions.
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4731. --In general.

4732. --Conditions. 4733. --Reconsideration, modification, or revocation. (I). In general.
(2). Notice and hearing; proceedings. 4734. --Suspension of sentence.
4735. --Supervised release.
4736. Penalties and fines. 4737. RestiMion.
4738. Alternative dispositions.
4739. Pretrial diversion and intelVention. 4740. Execution of sentence.
4741. Capital puniShment; death penalty. 4742. --In general.
4743. --Persons eligible.
4744. --Matters considered.
(I). In general.
(2). Evidence and witnesses. 4745. --Proceedings. 4746. --Execution of sentence.
16
18
19
22
24
25
26
27
28
8. APPEAL OR OTHER PROCEEDINGS FOR REVIEW. 4765. In general. 4766. Right

to review. 4767. Timeliness. 4768. Record. 4769. Course and conduct of proceedings.
4770. Standard and scope of review. '4771. Determination and disposition. 4772. Death
penalty cases. 4773. In general. 4774. Proportionality review. 9. DISADVANTAGED
PERSONS. 4780. In general. 4781. Incompetency or mental illness. 4782. In general.
4783. Determination of competency or sanity. (I). In general. (2). Necessity; right to
hearing. (3). Course and conduct of proceedings. (4). Presumptions, inferences, and
burden of proof. (5). Degree of proof; reasonable doubt. 4784. Commitment pending
competency determination. 4785. Administration of drugs. 4786. Capital punishment;
death penalty. 4787. Indigency. 4788. In general. 4789. Expert assistance
Presumptions and burden of proof. 42. Admissibility. 43. --In general. 44. -Intent. 45. --Identity of property. 46. --Value of property. 47. --Ownership of
property. 48. --Taking, asportation, and appropriation of properly. 49. --Identity,
presence, and acts of accused. 50. Incriminating circumstances in general. 50.5. -Possession by accused of implements for commission oflarceny. 51. --Possession
AND MOTION FOR ARRET OF JUDGMENT AND NOnCE OF NONSERVICE OF
AND OF CITY ATTORNEY SKAU'S FRAUDULENT REPRESENTATION
EX PART IMPROPERLY NOTICED 11113/12 HEARING
p. 14 of 19
Received:
To: de6b6816-lb81-41fd-8ddf-10lbbf1
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9
10
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13
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Hov 30 2012 11:42am

fro.: "'hroughtln
11-l0-11 11:l8,.
by accused of property stolen. (I). In general. (2). Explanation of possession. 52.

--Matters of defense. 53. --Rebuttal. 54. Weight and sufficiency. 55. --In general.
56. --Corpus delicti. 57. --Intent. 58. --Identity of property. 59: --Value of
property. II. PROSECUTION AND PUNISHMENT.{Cont'd) 60. --Ownership
and possession or custody of property. 61. Situation or place of taking of property.
62. Taking and asportation of property in general. (I). In general. (2). Consent of
owner. 63. Conversion, secreting, withholding, or appropriation of property. 64.
Effect of possession of property stolen. (.5). In general. (I). Presumptions arising
from possession in general. (2). Conclusiveness of presumptions. (3). Remoteness
of possess ion. (4). Exclusiveness of possess ion. (5). Identity of property. (6).
Explanation of possessiori. (7). Possession accompanied by other incriminating
circumstances. (8). Sufficiency of proof of defendant's possession. 65. Grade or
degree of offense.: ' 66. --Attempts. (C) TRIAL AND REVIEW. 68. Questions for
jury. (I). In general. (2). Intent. (3). Possession of property stolen. 69.
Instructions. 70. --In general. (I). In general.' (2). Instructions defining offense.
(3). Applicability to issues and evidence. 71. --Intent. (I). In general. (2).
Existence at time of taking. (3). Taking for temporary use or purpose. (4). Taking
under claim of right. 72. Nature and value of property. 73. --Ownership and
possession or custody of property. 74. --Situation or place of taking of
propertyPROSECUTION AND PUNISHMENT.(Cont'd) (3). Evidence
admissible under pleadings. (4). Variance in generaL (5). Variance as to time and
place of taking. , (6). Vari:lllce as to description of property in generaL (7).
Variance as to description of animals. (8). Variance as to description of money,:
currency, treasury certificates, and bank notes. (9). Variance as to ownership of
property in general (l 0). Variance as to ownership of property by principals,
agents, partnerships, and joint or several owners. (II). Variance as to possession
and custody of property. (8) EVIDENCE. 41. Presumptions and burden of proof.
42. Admissibility. 43. --In generaL 44. --Intent. 45. --Identity of property. 46.
-- Value of property. 47. --Ownership of property. 48. --Taking, asportation, and
appropriation of property. 49. --Identity; presence, and acts of accused. 50.
Incriminating circumstances in generaL 50.5. --Possession by accused of
implements for commission oflarceny. 51. --Possession by accused of property
stolen. (1). In generaL (2). Explanation of possession. 52. --Matters of defense.
53. --RebuttaL 54. Weight and sufficiency. 55. --In general 56. --Corpus delicti.
57. --Intent. 58. --Identity of property. 59: --Value of property.60. Ownership and
possession or custody of property. 61. --Situation or place of taking of property.
62. --. Taking and asportation of property in generaL (I). In general (2). Consent
of owner. 63. --Conversion, secreting, withholding, or appropriation of property.
64. --Effect of possession of property stolen. (.5). In generaL (I). Presumptions
arising from possession in generaL (2). Conclusiveness of presumptions. (3).
Remoteness of possession. (4). Exclusiveness of possession. (5). Identity of
DOGAN'S 1117112 PURPORTED FAXING OF HIS MOTION TO OUASH SUBPOENA
AND OF CITY ATTORNEY SKAU'S FRAUDULENT REPRESENT ATION
REGARDING BEING GIVEN PERIvIlSSION TO SERVE COUGHLIN BY FAX FOR
EX PART IMPROPERLY NOTICED 11113112 HEARING
p. 15 of 19
Received:
To: de6b6816-1b81-41fd-8ddf-l01bbf1
'1
8
9
10
11
12
Nov 30 2012 11:43am

From: zachconghlln
.11-30-11 11:38am
property, '(6), Explanation of possession, (7), Possession accompanied by other

incriminating circumstances. (8). SulIiciency of proof of defendant's possession. '
65. --Grade or degree of otfense. 66. Attempts. (C) TRIAL fu'lD REVIEW. 68.
Questions for jury. (I). In generaL (2). Intent. (3). Possession of property stolen.
69. Instructions. 70. --In generaL (I). In generaL. (2). Instructions defining
oHense. (3). Applicability to issues and eviqence. 71. Intent. (I). In general (2).
Existence at time of taking. (3). Taking for temporary use or purpose. (4). Taking
under claim of right. 72. Nature and value of property. 73. Ownership and
possession or custody of property. 74. --Situation or place of taking of
property. PROSECUTION .A.ND PUNISHMENT.(Cont'd) 75. --Taking and
asportation of property in generaL (1). In generaL (2). Consent of owner. 76.
--Conversion, secreting, withholding, or appropriation of property. 77, --Effect of
possession of property stolen, and of explanation thereof. (I). In general (2).
Applicability to issues and evidence. (3). Issues and evidence requiring
instructions as to possession of property. (4). Explanation of possession. 78.
--Matters of defense. 79. --Grade or degree of offense. BO. --Punishment. 81.
Verdict. 82. --In generaL 83. --Finding as to value of property. (D) SENTENCE
AND PUNISHMENT. 86. Form and requisites of sentence. 87. Nature and extent
of punishment. 88. --In generaL 89. --Mitigation on restitution or recovery
13
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receiving stolen property or possession charge:

I. Nature and elements in generaL 2. Property and stealing thereof. . 3.
Knowledge of theft and intent. 4. Receipt, possession, and concealment of
property. 5. Defenses. 6. Persons liable. 7. Indictment or information. (I). In
generaL (2). Knowledge and intent. (3). Description of thief or person from whom
received. (4). Allegations as to theft. (5). Description, value, and ownership, or
possession of property. (6). Issues, proof, and variance.. 8. Evidence. (.5). In
generaL (I). Presumptions and hurden of. proof (2). Admissihility. (3). Weight
and sufficiency in generaL (4). Knowledge of theft and intent. Trial and review.
(.5). In generaL (I). Questions for jury. (2). Instructions. (3). Verdict. (4). Review.
10. Sentence and punishment.
)1
CONCLUSION
22
Please take note ofthe attache materials, which arguably justifY a new trial or
arrest of judgment.
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fu'lD OF CITY ATIORNEY SKAU'S FRAUDULENT REPRESENTATION
EX PART I:VIPRQPERL Y NOTICED 11113/12 HEARING
p, 16 of 19
Rece ived:
To: de6b6816-1b81-47fd-8ddf-701bbfl
fro.: zochcoughlln
Nov 30 2012 11:44am
11-l0-11 11:380m
AFFIRMATION PUl'lIant to NRS 2398_030

2
'Ibe undersigned docs hereby affinn that the preceding document does not contain the
3
4

DECLARATION In lieu ofaffidavit as coughlin
10
cannot afford a Notary
The assertions herein are made, pursuant to NRS 53.045 under penalty of petjury and
based upon my first hand knowledge of these matters.
Dated this November 30th, 2012,
11
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13
lsi
Zach Coughlin
14
Defendant
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ADDENDUM OR SUPPLEMENTAl. OR AMENDED MOTION FOR NEW TRIAL

DOGAN'S 1117i12 PURPORTED F,,,"XING OF HIS \fOTION TO OUASH SUBPOENA
AND OF CITY ATIORNEY SKAU'S FRAUDULENT REPRESENTATION
p. 17 of 19
Received:
To: d.6b6826-1b81-41fd-8ddf-l01bbf2
8
9
.11-]0-12 11:]8am p. 18 of 19
~Elmt'U;,:\TE Ot' ~ERVICE;
Nov 30 2012 11:44am

From: mhcoughlln
Pursuant to NRCP 5(b), I do hereby certify that, on this date, I, Zach Coughlin I
deposited in the United States mail at Reno, Nevada, in a scaled envelope, postage
prepaid, a true and correct copy of the foregoing NOTICE OF RELEV ANT
DEVELOMENISNQIl~EQE SALlEN~E ill JUDGE SfERRAZZA ANO RE IN
COUGHLIN'S SBN FORMAL DISCIPLlNARY COMPLAINT AND PARTICIPATION
BY TIlE IU~ THEREIN DESflTE CLAIMS OE REFtJSING TO PARTICIATE
GIVEN PRESIQINQ OVER A ENDINQ MA I I ER BY R1C NOTICE QE
NONSERVICE OF J)(X1AN'S 1117112 PURPORTED FAXING OF HIS MOTION TO
QUA:::!!::! :::!UBfO!;;NA AN 12 01:' ~In ATTORNEY :::!KAl!'S fRAUDlJ!.ENI
REPRESENT{J.TION REQo1.RDINQ BEING QlVEN PERMISSION IQ SERVE
COUGHLIN BY FAA FOR EX PART IMPROPERLY NOTICED \Il13/12 HEARING
and or electronically served (via eledronic method of transmission previously given
express permission to utilize by those with requisite authority to provide it, upon which
Couglin reasonably relied and or relies):
10
11
ZACHARY N. YOUNG, ESQ.
12
Washoe County DA Office
13
14
P.O. Box 30083
15
Reno, NV 89520
Phone Number: 775-328-3200
16
Fax number: 775-325-6703

17
18
Admit Date: 10/20/2004
19
20
DATED THIS: Dated this November 30th 2012
21
?2
/s;JCO~~hlin ---
Zac
23
<;~
D . endant
24
2S
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ADDENDUM OR S!.!~PLEMENTAL OR liMENQED MOTIQN EOR NEW TRIAL

ANl2 MOIIQN FOR ARREI QJ::' JUQQMENI AND NOTICE QI:' NOl:lSERVI~E OF
DOGAN'S JlI7/I2 PURPORTED FA.
XING OF HIS MOTION TO QUASH SUBPOENA
fu'lD QF ~IIT ATTORNEY SKAli'S ERAlJDW,ENI REfRESEI::iT ATIQN
REGARDING BEING GIVEN PERMISSIQN 10 SERVE COllGHLlN BY FAX FOR
EX PART IMPROPERLY NOTICED 11/13112 HEARING
Received:
...:e__
To: de6b1iB26-1bB2-_47_fd_-S_dd_f_-7_01_bb_f2 _
_
Nov 30 2012 11:44am
p
g
-Fr-OM_:_'_"_h_CO_u_hl_l_n_ _ _ _ _ _......l-l_l-_l0_-_12_11_'_lB_am__,_1_9 of 19
INDt;X '[0 J:;XHUUTS:
2
3
4
I, Exhibit I: 251 pages (printed and displayed as 2 pages per slteet to reduce bulk of filing
and lessen impact on RJC fax machine and resources, respectfully submitted, and with
apologies for inappropriate conduct due to stress and lack of sleep and misconduct of
others,
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DOGAN'S 1117112 PURPORTED FAXING OF HIS MOTION TO OUASH SUBPOENA
ANP OF CITY ATTORNEY SKAU'S FRAUPULENT REPRESENTATION
REGARDING BEING GIVEN PEIUy\ISSION TO SERVE COUGHLIN BY FAX FOR
Received:
To: denb6826-1b82-41fd-8ddf-l01bbf2
ttOl\', 1"~toughl1n
Nov 30 2012 12:01pm
FACSIMILE
Date:
11/30/2012
To:
From:
zachcoughlin
Subject:
11-30-12 12:00pm p, 1 of 3
Received:
To: de6b6826-lb82-41fd-8ddf-10lbbf2
From: zachcoughlln
Nov 30 2012 12:02pm
11-30-12 12:00pm p. 2 of J

STATE OF NEVADA
Case No. RCR2011-063341

Dept. NO.-2-, _ _ __
Plaintifl)Landlord,
MOTION TO PROCEED
IN FORMA PAUPERIS
Vs,
ZACHARY B. COUGHLIN
---
Defendant/Tenant.
MOTION
Rased on the following affidavit, (name) ZACH~.oUGHLJ_L~ requests this court for pennission to file
a (check one):
[]
Lawsuit or eviction notice.
,Ah'D FOR PREPARATION OF TRANSCRIPT ON APPEAL AND ALL
['IX
Defense to laWSUIt or eVlclton notice OTHER COST, FEES, OR BONDS TO BE WAIVED DUE TO
without paying court costs or sheriff fees and alleges <ii1a'1i'h~' ftalNlifiWribus claim or defense, yet lacks sufficient
financial ability to pay the costs to proceed.
AFFIDAVIT OR DECLARATION MADE UNDER PENALTY OF PERJURY
PURSUANT TO NRS 5].045:
STATE OF NEVADA
) ss:
COUNTY OF WASHOE
I, (name) ZACIIARY B COUGHLIN

declare under penalty of petjury that the
statements of this affidavit are true and that the responses I have made to the questions regarding my ability 10 pay are
true:
I)
I am the (check one) D plaintiff Dl:defendant D landlord D tenant.
2)
I wish to file with this court a (check one) D lawsuit or eviction notice If defense to lawsuit or eviction
notice. OR CRIMINAL PROSeCUTION AND SUBSEQUENT APPEAL FROM ANY AND ALL CONVICTIONS
ORDERS IN ANY WAY CONNECTED TO THE CRIMINAL PROSEUCTION
3)
I believe in good faith that I have a valid claim or meritorious defense, namely (state briefly yonr claim or
defense andlor attach the document vou wish to file if this motion iSllranled):
INCORPORATE BY RF.F'EREllCE ALL
ARGUMENT~ MA.DE
TN FiLINGS WITH THE -('!OURT AND OR MATE1iTALS SUBMITTED FOR FILING
OR
BUT
PERHAPS SUBSEQUENTLY STRICKEN AND ALL MOTIOSN FOR NEW TRIAL OR ARREST OF JUDGMENT OR OTHER SUBMISSIONS
BY COUGHLIN OR HIS PREVIOUS ATTORNEY.
4)
I cannot pay the costs of this action, as I lack sufficient income, assets or other resources.
5)
There are ___ _ persons in my household, including myself. (If any household members are
5
dependent upon you for support, state their ages and relationships to you: I RENT A ROOM IN A HOUSE FOR
$310 A
6)
~ONTH
AND THE OTHER LIVING THERE ARE STRANGERS TO ME AND WE SHARE NO FINANCES
My total household monthly income is $ ITS VARIES, I AM A RESEAR.f~JUlfc&t~ii'fm:itff'?i'JH~Mg~, HAVE

~
sources:
A MAttRESS BuSINESS AND 00 ODD JOBS
My wages
APPROXIMATELY
$500
PER
MONIH
Wages of employed household members NO CONNECTION TO ME $-._ _ _ _ _ _~
AOC
General Assi stance
Social Security
SO
'~~~~~c_=
o
$
$
I NEED
STAMPS
TO APPLY FOR POOl)
Received:
To: de6b6816-lb81-47fd-8ddf-701bbfl
Nov 30 2012 12:02pm
F,OD: ,.chcoughl!n
11-30-11 11:00pm
Retirement Benefits
p, 3
of J
$_-S_ _ _ __
Child Support
Unemployment Benefits
Worker's Compensation
Rental Income
Other benefits or income
$,-----$_$,-$,-----
7)
The following represents a complete list of my assets and their value (!fyou do not own the described
items, write "none". Do not include clothing and ordinary household furnishings. If you have loans on
any of the items, notice the purchase price and loan balance):
Loan
Purchase
Balance
Price
Value
mo
Car (describe)
1996 I:onda accord ll'k mil"j'
pa1.d off
dont recall
---------------Second Car (describe) ______________ )
Mobile home, house or other
Real estate (describe)__
Bank accounts (describe'- __________ )
Other (describe)
)
8)
My total household monthly expenses are:

Rent
Utilities
Food
Child Care
Insurance
Medical
Transportation
Other (describe)
TOTAL MONTHLY EXPENSES
310
$
$
$
$
150
100
$
$
$ 100
$------>'a"~ft1y
6QQ
t eel are the above 1S trup- under penalty of perjury to beat
9)
desire to have a hearing before the Court~s matter.
of my knowledge In lieu of affidavit as r

cannot afford a notar pursuant to nrH '13.045.
november 30th. 2012
Dated:
Signature:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Address:
TeIephone:
This _ _ day of
1471
and gax 949 667 7402
e .
9th
st. reno
89512:
___________
,20 _ _ ,
Notary Publicilleputy Clerk
ORDER
o
Motion GRANTED. The Clerk of the Court shall allow
to commence or defend such action without cost and to file or issue any necessary writ, process, pleading or paper without
charge. This Order shall expire six months from the date below_
IT IS FUR TIlER ORDERED that the Sheriff or any other appropriate public officer within the State make
personal service ofany necessary writ, process, pleading or paper without charge for
Motion DENIED.
DATED:
JUSTICE OF TIlE PEACE
FILED
iZach Coughlin
2
1
1471 E. 9th St.

Reno, NV 89512
Td and Fax: 949667 7402

COUNTY OF WASHOE: S1 ATE OF NEV ADA
8
g
'TATE OF NEVADA,
PLAINTIFF
)
)
)
1 (j
) RCR2011-063341
S.
) DEPT 2
II
12
ACHARY BARKER COUGHLlN;

DEFENDANT
II
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ADDENDUM TO MOTION FOR NEW TRIAL REVEALING FURTHER CONFLICTS

REOUIRING RECUSAL OF BOTH THE RJC AND THE WCDA OFFICE
18
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SHEPP v. STATE, 484 P.2d 563 (1971); "Count 3 charged Shepp with having received
20
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property stolen by him during the commission of the burglary charged in Count 2. Since
a thief cannot receive from himself the fruits of his larceny, the jury must be
23
instructed that it could convict of either burglary or receiving. [ 484 P _2d 565 ! but
not of both
26
FACTS
?8
-
\/19-
UPDATE MOTiON FOR NEW TRIAL AND MOTION TO ARREST JUDGMENT
Coughlin submits this on his own behalf.

STATEMENT OF TO: THE STATE OF NEV ADA, Plaintiff; and TO: THE OlSTRICT
3
ATiORNEY'S OFFICE:
"
10
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1 'J
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1~
J6
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Perhaps one of my biggest complaints about the ineffective assistance of counsel by

Mr. Leslie (and to a much. much lesser extent that of Mr. Goodnight) relates to
Leslit:'s failure to utilize any of the work I did to prt:p this case. For instance, Leslit:
whiffed (perhaps intentionally so) on the extent to which RPD OHicer Duralde and
Rosa could not have n:ccived the dispatch text of II :27: II pm reporting Goble's sinee
proven fi'audulent "someone just socked a minor" 911 call to Eeomm/Dispatch ... so,
Officer Duralde and DDA Young are stuck with anything the Officer could "hcar" on
the Dispatch recordings (and those proyided by City Attorney Skau provide a basis for
mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is
suspiciously devoid of anything for the 6 minutes in which the detaining and an'est
occurs (and further. DDA Young and the State were served a request for discovery by
Goodnight in Nov<:mber and subpoena which required production of those "dispatch
logs or recordings .... " Y el DDA failed to. Then he put on testimon and made
argument that this "report from dispatch of a possible fight" was the mainjustitication
for the pat down and search incident to arrest and led to a justification for not
excluding anything" discerned incident to the pat down" ... the only problem is is that
Duralde and Rosa already are marked as on the scene by 11 :26:00 pm, and therefore
could not have read the text screens in their vehicles to recicved the text only 11 :27: 11
pm dispatch entry about "someone just socked a minor". Further. the extent to which
Coughlin's 911 call is not reported accurately at all further underscores the unfairness
of depriving Coughlin the right to cross examine Duralde and the dispatchers.
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A review of the Ecomm cd provided by Reno City Attorney Skau,

in what I believe was his response to Judge Sferrazza ordering him
to produce in response to my subpoena duces tecum to Kelley
Odom and ECOMM (Emergency Dispatch Services) reveals what I
believe may be misconduct. Two of the 911 calls are missing.
There is no audio of any RPD-ECOMM/Dispatch communications
between the 11 :28: 17 pm mark and the 11 :36:27 pm mark ... which
is disturbing, considering the RPD and Ecomm did not know I was
tilming/recording the arrest. Had I not captured a recording of the
arrest, how little would have the dispatch logs, witness testimony,
and Ecomm recordings revealed ... any how many things revealed by
- :U19-
UPDATE MOTION FOR NEW TRIAL AND MonON TO ARREST JUDGMENT
the arrest recording contradict what Ofticer Duralde put in his

2
Supplemental Declaration and Narrative and the two witness
statements'? Further, where Zarate does not allege to have seen the
3
phone light up to Duralde or in his Witness Statement, come Trial
1
time, Zarate, on 8/29/12 does testifY to seeing the phone light up in
" Coughlin's pocket...but wait...yeah, that's it...he saw it light up from
6
all the way across the skate park ... but wait...come November 19th, .
I
2012 he changes his story and decides he saw it light up from "2 to
3 feet away from Coughlin" .... There a movie floating around
8
somewhere out there that does a time line of all these calls, all these
'J
videos, superimposes the dispatch logs on the text with quotations
10
and citations to sworn testimony by these witnesses ... etc. And one
problem for DDA Young and Duralde is found in the State's
11
2121/12 Opposition, on page 5, wherein Young writes: "Tn the
12
instant case, the pat-down search of the Defendant was proper
13
under the totality of the circumstances. Prior to arriving, Officer
14
Duralde learned that the scene involved a loud disturbance with
possible fight, thereby immediately raising the concern of weapons
15
and the safety of all those present." And, of course, Officer
16
Duralde responded splendidly to Coach Young's, er, DDA Young's
17
training regime and sang the "possible fight...report from dispatch
18
of a possible fight" tune all the live long day ... which was the basis
for the reasonable suspicion for the pat-down (and Judge Sferrazza
19
did change his Suppression Motion Ruling at the Trial
20
somewhat...altering it to make less obvious the extent to which
21
Young was repeatedly allowed to enter hearsay into the record, both
22
in the Suppression Motion Hearing and at Trial, whereas Coughin
never could get that darn Nicole Watson admitting to hearing the
23
"man with a six pack threaten to throw the iPhone into the river"
24
capture on video and audio recordings into the record ... despite
2'5
Duralde testifYing to a multitude of double hearsay (and not even
26
capture on a recording so close in time to the arrest and at the very
27
same location, involving the mqjority of the players in the arrest
itself.. ).
I
- 3/29-
UPDATE MOTION FOR NEW TRIAL AND MOTION TO ARREST JUDGMENT
.~
2
6
7
R
g
10
11
12
13
15
16
l7
It was in the same 11130111 email from WCPD Goodnight to Coughlin that induded
Ihe Narrative by Oftict:r Duralde (which has, in the footer of the 4 page document, a
footer indicating a "printed on" datt: of 11/28! 11
Zarale's testimony respecting the scant stutcmcnts he actually made to Offict:r Duralde
reveal the extent to which Ofticcr Duralde paints on to witness statement more
spcci fic, particularized facts in support of the ohjcctives he has, which here, were
motivate by a retaliatory intent and Ihe "thrill" of "busting" and attorney whom dared
to answer one of the officer's questions by asking a question seeking clarification as to
Coughlin's constitutional rights .... which clearly is not a permissible basis to support a
finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the
Officer's did not receivc Ihc text from dispatch reporting Goble's second 911 call
wherein he fraudulently alleged that "someone just socked a minor" (referring to the
instance where then 18 year old Austin Lichty (who is captured on the video of the
momcnts(lile named: VID_20110820_232423 austin lichty templeton goble zarate chan
rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in
length) lying in asserting that "I'm 17 ... I'm a minor!", so, contrary to DDA Young's
assertion in his 2/21/12 Opposition to Goodnights 2/14/12 Motion to Suppress, both
Goble, Lichty, and Zarate all have motivations apparent which preclude them from being'
deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted to
in his testimony at trial to being aware of, the "gross inconsistencies" Goodnight pointed
out between the hearsay and double hearsay Duralde testified to at trial after "refreshing
his recollection" upon a review of either his "Supplemental Declaration" (an attachment
to the probable cause sheet, DDA Young would allege) and or his "Narrative". Which
begs the question .... how was it not misconduct by the State and prejudicial to the point
of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing
on
18
19
20
But here is the biggest problem for the RPD and the State ...the screen lock that Goble
and Templeton testified to (the password for the phone) ... and when Goble alleges
Duralde gave him back the phone ... and the call into the iPhone at 11:33 pm from Officer
Duralde's phone ... and the call from the iPhone b
21
22
23
24
25
26
27
Perhaps the worst thing for the State and the RPD here is that two
hostile witnesses (in addition to Coughlin's various statements
related thereto, during his testimony and on the media admitted into
evidence) testified that RPD Officer Duralde committed
misconduct by lying about the purported order or point in time in
relation to the arrest and search of Coughlin and Duralde's first
coming into possession of the iPhone, Goble testified that Duralde
removed the phone from Coughlin's pocket and that Duralde had
- 4/29-
1
2
1
,1
'J
8
g
10
11
12
13
14
1S
the phone with him when he tirst presented to Goble to ask question
related to the phone and to verify ownership of the phone (which
would include gathering the phone number for the iPhone, which
necessarily would mean that Duralde's allegation of only searching
Coughlin after performing some call to the iPhone and hearsaying it
vibrate (even though multiple witness (Templeton, Zarate, Goble,
Lichty testified that they heard no such buzzing or vibrating of the
phone, hostile witnesses all) Goble testified that Duralde already
had the iPhone prior to Goble conferring with Duralde or otherwise
giving Duralde any phone number to call in an attempt to verify the
phone revealing an incoming call LED display scree light up alert
(Goble's statements that the phone would "light up" and that he, as
Duralde quotes him in the Narrative, "could not hear the phone
I have 30 days from the date of conviction to report a conviction to
the State Bar of Nevada and the United States Patent and
Trademark Office (USPTO) for these two convictions "possessing
or receiving stolen property" and "petty larceny" under SCR III (6)
and 37 CFR 11.25(3).
16
\7
18
19
20
21
22
n
24
26
27
20
[note that WCPD Jim Leslie, while still attorney of record for me
on this cases RCR2011-063341, had served (see attached) a
subpoena on ECOMM and Kelley Odom on 10/03/12. Given that
Mr. Leslie was not relieved as my counsel until at the earliest
10/22/12 (so Judge Sferrazza's contention that Coughlin "has had
forever to get his defense ready in this case" and that "no
continuance will be granted on account of the formal disciplinary
hearing before the State Bar of Nevada" being scheduled just 5 days
prior to the 11/19/12 resumption of trial in rcr20 11-063341 (and
despite Judge Sferrazza indicated some canon preventing him from
testifying at the formal disciplinary proceeding ... that didn't stop
063341 being specifically pled in the SBN NG 12-0204 SCR 105
Complaint in SBN v. Coughlin, as was Judge Clifton's case in
RCR20 12-065630 ... and that didn't stop RJC Judicial Secretary Lori
Townsend from sending into the SBN Coughlin's 2/12/12 filing in
- 5/29-
UPDA TE MOTION FOR NEW TRIAL AND MOTION TO ARREST JUDGMENT
that Judge Clifton case rcr20 12-065630 and offering to send into
2
the SBN Coughlin's 2/15112 filing in 063341). Add to that the fact
1
that Coughlin never received from Leslie Goble's call records until
Lesl ie finally released them 0 October 30th, 2012 ... and it really is
" not accurate to say Coughlin had "forever" to prepare his case.
'i
Coughlin had to pull together a defense in his formal disciplinary
6
hearing before the SBN despite the SBN gipping him out of every
7
aspect of SCR 105(2 )( c) (ie, not 30 days notice of the hearing on
11114/12 after service of the Complaint and Designation of
8
Witnesses and Summary of Evidence is affected pursuant to SCR
g
109 and SCR I05(4) ... But the point is, if the RlC and both of you
10
want to be associate with a Schaeffer style Mirch-ing, then this may
be your chance. But you won't be able to say you didn't have
11
plenty of opportunities to put this thing aside, because there are a
12
multitude.
L
13
14
It is my understanding is that ECOMM and Kelley Odom had 15
I" days to respond to the Subpoena duces tecum .... Mr. Leslie's failure
16
11
18
19
)0
21
22
n
24
25
26
27
?8
to turn over anything to me in the "hand off transmittal" he insisted

upon (despite a digital transmission being required per the Order of
Judge Sferrazza, I believe) requires some explanation.
So to requiring explanation is the fact that the cd provided by Reno
City Attorney Skau in an apparent good faith attempt to comply
with Judge Sferrazza ordering him to comply with the subpoena
duces tecum and or tum over any relevant dispatch recordings
pertinent to the arrest and events surround it of 8/20fll leading to
rcr20 11-063341 , does not contain the second 911 call made by
Goble (using Austin Lichty's cellular phone, 775 233 8593, which
Goble is seen in the attached still frame picture culled from a video
Coughlin took of the moments prior to the arrival of the RPD, being
handed by the "man with the gauged ears" Lichty referred to as
"Peanut" despite Lichty, Goble, Zarate, and Templeton testifYing
that they do not know that man and did not know him prior to that
- 6/29-
\JPDA TE MOTION FOR NEW TRIAL AND MOTION TO ARREST JUDGMENT
night at all....Coughlin respectfully demanded of the RPD Officers,

, at the time of his arrest, that they gather the identity of the "man
3
with the gauged ears", however, Officer Duralde et al refused to
(claiming Coughlin's allegations of their having attacked him and
'1
attempting to steal his bike and or dog, reach into his pockets, and
'J
push him up against oncoming traffic on the Center Street bridge
" were "unsubstantiated"). Oddly, in the attached still frame, it is
7
quite clear that "Peanut" is seen handing Goble the phone belonging.
to Austin Lichty that Goble utilized to make his two 911 calls that
8
evening, the first (if the tile name time stamping on the ECOMM
9
recordings is accurate ... ) taking place beginning at II :22:52 pm
10
(though the ECOMM text logs reveal an E91 I entry of I I :23:36 pm
(its unknown whether the exact time a 91 I call comes in is
11
designated on the "Calls for Service Inquiry Response" Coughlin
17
was provided recently). The EComm text logs reveals a second
13
E911 entry for the 775 233 8593 number (belonging to Austin
14
Lichty, but passed to Goble by "Peanut" with the gauged
15
ears ... yeah, these are the guys taking my law license away from me
for at least 5 years, ifnot forever .... and DDA Young ... over some
16
alleged "skater sets his iPhone down on the concrete in the middle
II
of the ice rink plaza downtown on 8/2011 I at 11 :20 pm ish in Reno,
18
"man with a six pack of beer" picks it up, offers it up, receiving no
response threatens to "throw it in the river if someone doesn't claim'
19
it immediately" whereupon Goble's friend Nate Zarate apparently
20
(according to RPD Duralde's Narrative of unknown origin date")
21
told Goble he saw Coughlin pick it up off the ground (as Duralde
22
recounts hearing from Goble in his Narrative)
23
contain the 911 call by Coughlin
24
2"
26
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday,

August 20. 201 J I J-28- J J PM Source- ID = 1706334 J duralde i'll be out on him" one
can hear Officer DuraJde indicating he will "be out on him on the Center Street
bridge" after he has left his squad care and is shortly to appear in the video Coughlin
tilmed of the arrest. title:
- 709-
Ihen, OHiter Rosa is proven to be on the bridge and not in his squad car reading texts from dispatch n the
following time stamped file: "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20,201111-26-30 PM
Source_IO
= 12 RPD
Rosa saying charles 396 on the other end"
Further, Officer Duralde's arrival on the scene IS notated in the dispatch log at the
4
S
Its not at all clear why Goodnight only apparently reteived then forwarded to hIS client on November 30th,
2011 the "Original Supplemental" containing Officer Duralde's Narratlve l that is stili of indeterminate date of
origin (there are a number of "date of printing" variations ... ).
6
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011112252pm to 112530pm 911 by Goble dISpatch Weese log lare of phone susps as left on post
8
I)
lighting up in sups pock RP screaming at susp

2, 082011112620pm to 112740pm 911 by Goble dISpatch Montgomery logs rp call back're someone just
socked a minor, waive that cop down 10 10 with open line
11)
3, 082011112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling
II
re stealing phone people cheenng cops
12
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD amving
(and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm.
13
mark as indicated by the Ecomm recordings and dispatch logs .. ,
14
1. VID_20110820_232413 your allan tape now gable and friends,3gp 8 seconds long
15
2, VID_20110820_232423 austin lichtv templeton goble zarate chan rpd iphone assaulMg and batte,,! Coughlin
lusrt prior to RPD rcr.3gp 46 seconds
are here then call disconnects
16
3, VID _20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
17
18
And the AT&T call records forthe iPhone reveal only four calls occurred In or out during the relevant time
frame:
19
20
24
26
2 f3
Goble's AT&T records:

4408/20/1111: 21P 0:2117753786673177552794400:0017755279440
4508/20/11 1I:26P 0:21 1775378667317755279440 \1:\1017755279440
46 08/20/11 11 :33P 0: 12 17752303726 17755279440 0:\10 17755279440
4708/20/11 II :36P 0:01 17755279440 177523037260:00 17752303726
Goble messed up at Trial on 11119/12 and let slip that "and that's when Tanner called the
phone .. ," Previous to that. DDA Young had successfully kept every single witness from
specifically identifying who made what call and when and where to any extent
whatsoever, Nobody could remember nuthin'. But. Goble is a self involved twit, who
snaps his fingers "Oh, that's Colton" 8 feet from Judge Sferrazza and swaggers out of the
court room. And Leslie refused to seek admission of the misconduct of a prost!cution
witness __ .. Goble. batterying Coughlin with a lit cigarette, that Coughlin capture on tape, on
June 5th. 2012 .. ,and email DA Gammich. DDA Young, and some others about at II :38
pm on 6/7/12 .. ,and had his law license suspended in 60838 four hours later by a 3 Justice
- 3119-
.,
')
'i
8
9
10
11
Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful
termination suit against Washoe Legal Services",und you might not like me for that suit,
but if you look at the circumstances of my tiring therein (I was hurrying to finish a nonprotit gets stuck with the building's private landlord's property taxes appeal due on 31 10112
for Paul Elcano, and had a Trial before Judge Linda Gardner in a divorce case on
3/12/12",and the attached materials do demonstrate that I did plenty of research
beforehand,,", just had some issues printing it out and bringing it with me (my legal
assistant couldn't figure that oUL. Wl.S took 6 weeks to cut a check for subpoena fees""the
usual),,,
Somehow at the Hearing on the SuppressIon Motion DDA Young was able to get into evidence e)(dusively
hearsay testimony (often unattnbuted to anyone in particular) to support his win on the "sufficient probable
cause to support a search inCIdent to arrest" despIte NRS 171.136 forbidding such an arrest (where Duralde
obviously overcharged the alleged crime as a "felony grand larceny" ... even making smug commentary about the
"certain benefits of charging this as a felony" and saying "oooh, that's a felony", both matters that Leslie
insisted refraining from getting Into while he was attorney of record, and further, despIte Coughlin complVing
with NRS 174345 (even splurging on the return receipt requested to go along with the certified mall for
Duralde) Coughlin was denied the right to cross examine the arresting officer ... which IS too bad considering his
Narrative alternately claims that Goble told him they
12
DDA Young's complaint fails to alleged someone other than Coughlin stole the property,
which it must, to support the receiving or possessing stolen property charge.
13
COUNT IL POSSESSION OF STOLEN PROPERTY, a violatIOn of NRS 205,275, a mISdemeanor, in the manner
following, to wit:
14
That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of
Washoe, State of Nevada, did willfully and unlawfully possess or withhold stolen goods haVing a value less than
Two Hundred Fifty Dollars ($250,00), to wit: an iPhone, at or near 1 North Center Street, Reno, Washoe County,
Nevada, such property being owned by CORY GOBLE, for his own gain or to prevent the true owner from again
15
16
possessing said property, knowing that the property was obtained by means of larceny or under such
circumstances as should have caused a reasonable man to know that such goods were so obtained.
11
18
19
20
POLK v. STATE, 749 S,W 2d 813 (1988): "As prevIOusly stated, the State must plead and prove that the
property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S.'
Cc 574, Must allege the good were received from someone other than the defendant:
Gaddis, 424 U.S, 544, Allen, 96 NE 2d 446, Polk, 749 SW 2d 813.
21
Gaddis, 424 U,S, 544, 96 SD, 1023,47 LEd,2d 222 (1976): " A person convicted of
22
23
violating 18 U.S,c. ~ 2113(a), (b), and (d) cannot also be convicted of receiving or
24
possessing the robbery proceeds in violation of 2113(c), Heflin, supra, 358 VB" at 419-
2S
420,79 S,Ct 45L Pp. 547-541("
26
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been
stolen by a person other than plaintiff in error, a .. ,The next assignment of error is that the
213
- 9/29-
State failed to prove beyond all reasonable doubt that the automobile in question was
stolcn by some person other than plaintiff inerror. To sustain a conviction of

receiving stolen property the proofmust show
ell that the proncrty has. in
fact. been
stolen by a person other than the one charz:ed with Tcceivinz: it; (2) that the one
6
charged with receiving it has actually received the property stolen or aided in concealing
it; (3) that the receiver knew the property was stolen at the time he received it and (4) that
he received the property for his own gain or to prevent the owner from possessing it.
(People v. Piszczek,404 III. 465.) Proof of these essential elements constituting the crime
lO
of receiving stolen property may be made by circumstantial evidence. People v. Ferris,

11
12
13
385 III. 186." PEOPLE v. ALLEN. 407 III. 596 (1950).96 N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974).316 N,E,2d 519: " It is
jurisdictional that if a criminal conviction is to be upheld,
[21 Ill. App,3d 980 1
16
18
the indictment must charge a crime (People v. Edge,406 III, 490, 494-495 (1950); People
19
v, Harris, 394111. 325, 327 (1946)), and must contain the nature and elements of the
20
otTcnse in order that the defendant may fully prepare a defense and be afforded the
21
constitutionally intended protection against double jeopardy, (People v. Gritlin,36 1l1.2d
22
430,432-433 (1967),) [n the instant case, the indictment, drawn upon the conclusional
24
premise that the property was stolen, fails to allege that it was stolen by a person other
25
than the one charged with receiving such property and, by this omission, creates the
26
presumption lhat lhe possessor stole the property himscl f. Since one person cannot be
both the thief and the receiver of stolen property nor receive stolen property from himself,
2f3
- 10129-
..
....
the fact that the property received was stolen by another was an (;sscntia\ element to be
alleged and proved. (People v. Ensor, 310111. 483,484-485 (1923): People v. Dalke, 336
,\
111. 446, 448-449 (1929): People v. Harris, 394 III. 325,329-330 (1946): People v.
Devore, 402 Ill. 339,341-342 (1949): People v. Malone,! IlI.App.3d 860, 863-864
(1971 ).) Lacking this element, the indictment failed
(0
charge the offense of receiving
stolen property under section \ 6- \ (d). A conviction under an indictment which does not
charge an offense is void. People v. Edge,406111. 490 (1950).
The judgment is,
the~efore,
reversed ....
10
I fcel that the majority has misconstrued the efficacy of section 16-1 (d) in arriving at a
11
12
conclusion not urged by the defendant. The omission of the words "stolen by another" in
the indictment does not crcale the presumption that defendant had himself stolen the
14
15
property from the owner. The use of the words "*

property
* * knowingly obtain control of stolen
* * under such circumstances thaI would reasonahly induce him to believe that
the property was stolen *" (emphasis added) in the indictment clearly implies that
17
18
when defendant ohtained control of the property in question (in any manner whatsoever),
19
the property had already been stolen by another. That is the plain and ordinary meaning
20
of the indictment.
21
I believe the majority may be confusing what can and cannot be reasonably implied from
22
evidence introduced at trial with what may be implied from the clear phrasing of the
indictment. At trial it is not
[ 2 \ Ill. App.3d 98 \ ]enough for the prosecution to merely show that the property in
26
2I
question was stolen property and that the defendant was in possession of that property in
order to prove the offense of thelt under \ 6-1 (d) (the former offense of receiving stolen
28
-
11/29-
property). (People v. Baxa (1972),50 1I1.2d 111,277 N.E.2d 876.) The defendant's
unexplained possession of stolen property soon after a theft is evidence that the dcfendant
.1
stoic the property himsel f but is not evidcnce of defendant's receiving stolen property
knowing it to have been stolen. (See Pcople v. Malone (1971), 11I1.App.3d 860, 275
N.E.2d 136, and the cases cited therein.) However, the phraseology of the indictment
herein permits a reader of the indictment to find, even after only a eursory rcading, the
necessary elements of the offense, i.e., that the property was already stolen by another
when the defendant received it.
10
While it may he true that the addition of the words "stolen by another" would make the
11
12
j
indictment more explicit, the addition of these words would only be grammatically
redundant and mere surplusage legally.
The indictment, therefore, was sufficient to charge the detendant with an offense under
15
16-I(d)(1).
16
After a thorough examination of the record, I do not believe that the evidence produced at
17
18
19
20
21
trial was sufficient to tind the defendant guilty beyond a reasonable doubt. For this reason
I, too, would reverse the defendant's conviction."

Appellant correctly argues that the standard of proving value, for conviction, is the
same in "receiving" cases as in "larceny" and "then" cases. He erroneously urges that the
22
slate failed to meet that standard under our holding in Cleveland v. Slate, 85 Nev. 635,
24
461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is
25
the fair market value of the property at the time and place it was stolen if there be such a
26
standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK
7.7
COUNTY 504 P.1d 695 (1972).
28
-
12I:~9-
:'
SHEPP v. STATE, 4841',2d 563 (1971): "Count 3 charged Shepp with having received
'i
property stolen by him during the commission of the burglary charged in Count 2. Since
6
a thief cannot receive from himself the fruits of his lafl:eny, the jury must be
instructed that it could convict of either burglary or receiving. I 484 P.2d 5651 but
not of hotb. People v. Taylor. 4 Cal.App.2d 214. 40 P.2d 870 (Cal. 1935); People y.
Morales. 263 Cal.Ann.2d 211. 69 Cal.Rntr. 553 (1968); Milanovich y. United States.
10
365 U.S. 551.81 S.Ct. 728. 5 L.Ed.2d 773 (1961); Thomas v. United States. 418 F.2d
11
12
567 (5 Cir.1969); Bakerv. United State.~. 357 F.2d II (5 Cir.1966l. Such an

instruction was requested but the court declined to give it. This was error, and later
14
is
acknowledged by the court to be such when it set aside the receiving conviction and
ordered a new trial on that charge. The appellate issue is whether that manner of handling
16
the error etTectively cured it. The error was not cured by the setting aside of the receiving
17
18
conviction since there is no way of knowing whether a properly instructed jury would
1 'J
have found the defendant guilty of burglary, Count 2, or receiving, Count 3. Milanovich
20
v. United States, supra. Both convictions should have been set aside and a new trial
21
ordered"
22
23
24
State v. Pansey, 61 Nev. 333,128 P.2d 464 (1942):". Receiving Stolen Goods. Criminal
intent is an essential clement orthe crime or receiving stolen goods .. 17. Criminal Law.
26
In nrosecution for receiving stolen goods. where instruction given by court followed
language of statute with reference to accused's intention to nrevent the [61 Nev. 330.
- 13129-
UPDA TE MOTION FOR NEW TRfAL AND MOTION TO ARREST JUDGMENT
Page 3361 owner from again possessing property, defendant was not entitled 10
instruction which told jury that goods must have been received with fraudulent
intent of depriving owner of the immediate possession thereof. Compo Laws, sec.
10335."
BERNIER V. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court
ofNevad: "At the conclusion of a preliminary examination, l-lenny Bernier was ordered
8
9
to stand trial tor possession of stolen property, a violation ofNRS 205.275.1 Bernier then
petitioned for a writ of habeas corpus contending the evidence adduced by the
10
prosecution was insufficient to establish prohahle cause that she had committed the
11
12
charged offense. The district court considered and denied her petition and Bernier here
reasserts the same contention.
14
15
Bernier docs not deny having possessed the property; rather, she argues the proof did not
show that she knew the property was stolen and that such knowledge cannot be inferred
16
from mere possession.

17
18
We agree that mere possession is insufficient to establish the requisite knowledge ... "
"Under Nevada law, Lane could not be convicted of both robbery and receiving
19
'20
21
stolen property.
This court reversed a conviction for possessing stolen property on the
ground that the legislature did not intend to compound the punishment for larceny or
27.
robbery by permilling a conviction for receipt or possession of the stolen property against
;>3
the person who took the property.

40-41 (1986); Lane
28
State, 110 Nev. 1156,881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206,94 P. 218 (1908): It is long standing authority that for a
2(;
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V.
Point V. State, 102 Nev. 143, 146-48,717 P.2d 38,
charge
of possession of stolen property to stand, there must be a showing of all the elements. and
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that if eYen one clemcnt is missing, the "harge cannot be maintained. Stale v. Pray, 30 Nev.
2
206. 94 P. 218 (1908). Possession of stolcn property does not in itself prove guilt of the offense.
Staab v. State. 90 Nev. 347, 526 P.2d 338. 341 (1974). Instcad. the burden of proof of all three
clcments rests with the
attorney charged with "summary criminal contempt" one reported decision ever, In Re
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Kunstler. 606 NYS 2d 607.
10
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Can't join in same proceeding
it
disbarment and contempt proceeding: Dickerson v. State
179 SW 324.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary
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criminal contempt" Order, even though, given the incarceration was served, it is a tinally
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appealable order, see Gilman 275 V. Comm 474, 657 SE 2d 474.
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Bifurcate disciplinary matters:
[n
re Parep (Nev. 1941) III P.2d 533.
[n
re Kaemmer,
178 S W 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In
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Re Hines 482 A. 2 378. triem 929 P.2d 634 Smith 85 P. 524 [n re Finsh 27 A. 3d 401 In
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re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973(,07) Cohn, 151 SW 3d 477
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('04) In re Crandell. 754 NW 2501 In re Cobb, 838 NE 2d 1197 In RE Ginsber 690 NW
22
2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515
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joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
24
Whether Goble had "ownership" in iphone matter 920 P.2d 112

25
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Sheely 102 p.2d 96

Participation in larceny as precluding receiving stolen property charge, 29 air 5th 59
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(1995).
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1
4
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unused. tllllimdy evil:lilln warrant needs to be reissued, (ireen. 344 SE 21.1 507.
Woods 19 NYS 2d 6S3
Regan 425 NYS 2d 725
Iorio. 410 NYS 2d 195
Russell v Kalian. 414 A.2d 462: expired warrant I,,, eviction no good
Leese v Horne. 47 P.2d 316
Burhams, 89 P.3d 629
Between the fi,llowlIlg two timestamped recordings finally provided by City Attorney Skau (WCPD
Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths prior to
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the arrival of the peaCe to stay peaceful in Coughlin's reterences the then recent murder of Stephen Gale jusl
blocks away approximately two months prior to the 8/20/11 arrest. incident to the theli ofa purse, and Lelise
prefers to spend his tlllle chiming in, unprompted, on the regard, arrogantly enough. that he can assist the
court if it feels Coughlin is "draggin' his feet" incident to the inappropriat placement by Judge Sferrazza of
Lcslie as "stan by counsel" ""hich really amounted to no more than yet another coercive practice put in place
by Judge Sfermzza to further his stated goal of avenging the criticisms Coughlin levied upon him inCIdent to
Judge Sferrazza's incredibly questionable on-the-t1y pandering/remixing of his Order of 10/13/ II (if
Coughlin, as he. in fact did, deposit a "rent escrow" 01'$2.275. Sferrazza ruled and noticed in writing that
Coughlin would get a "Trial" on the unlawful detainer action ... until rich man's opposing counsel Casey
Baker, Esq, coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate. Your
Honor. .. whereupon Judge Sferrazza. You arc to his constituency by remixing is previous order regardless
of the extent to which Coughlin was not noticed thereto with respect to that which would be involved on the
October 25, 20 II trial thcy are and where only those aspects of a summary proceeding that in year to the
landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a
plenary unlawful derainer trial and the ability to bring counterclaims were matters Coughlin was precluded
from accessing by judge Sferrazza. lust Rosin is interesting approach to landlord tenant matters continued all
II
with respect to the manner in which service was affected
011
November 3 in violation the courthouse
sanctuary doctrine by Deputy Plamondon in the Renojustice court civil division filing office no less (and
that is rhe same bailiff Plamondon managed to take the tilings Coughlin submitted online November 15 out
of the criminal division tiling om,e of the Reno justice court where Robbin Baker it Mr. Coughlin let them
in her posllion well prior to the 5 PM closing of that filing office and with DVDs attached to those tilings
Coughlin swcars under penalty of perjury that Ms. Bakcr admitted this to him
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PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20,2011 11-2S-17 PM Source_1D = IS.mp3
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SECONDARY RADIO TRAFFIC Start_Time = Saturday. Augu't 20, 2011 11-36-19 PM Source_1D =
5.rnp3
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In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed
from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public defender
applying good nicely peers deciding that the night was doing too much to assist Coughlin in
defending himself and or otherwise zealously advocating on call Pat good night in Coughlin had a .
trial prep strategy session "hile Cough lin was in custody on July Friday. July 13 at approximately
430 man and you good night reiterating the extent to which he would be appearing on Coughlin's
to have to try the case at trial on July 16.2012 Monday morning at 9 AM and it was only upon
Coughlin arriving and heing brought to the court in custody seeded Jeremy Bosler was suddenly
lilling in tor Goodn ight with and indication Goodnight's December 19, 20 II file stamp discovery
requests served upon the stay and district attorney Zach young reads at page I therein; "REQUEST
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FOR DISCOVERY COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and
through his attorney of record, Joseph W. Goodnight Deputy Public Defender, and hereby
requests the following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. I. Inspect
and receive copies or photograph any written or recorded statements or confessions made by the
Defendant or any witness, or copies thereof: within the possession, custody or control of the State,
the existence of which is known or by the exercise of due diligence may become known to the
prosecutor. NRS I74.235( I )(a). This request includes any video and audio recordings.
including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch
l0l:s. written or recorded. generated in connection with this case." It is telling the extent to
which on the record at that July 16 trial date Washoe County public defender Jeremy Bosler
indicated that Jil11 Leslie would immediately be rounding you a replacement role pretty suddenly
disappearing Goodnight. And that Leslie would be prepared to try the case by Friday and that the
court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that
Jim Leslie would, by that Friday, have completed all the trial prep Jim Leslie would be doing on
this case by Friday, and that that would be the case whether or not that evinced any surt of
concern fur his client. ability to zealously advocate on his client behalf or willingness to do so. or
indication that Jil11 Leslie felt that the judges of the Reno Justice Court would hold him to a
standard of care at all tending to indicate that Mr. Leslie has any skin in this game whatsoever.
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Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation
of Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing
disregard for the rules of professional conduct an intentional manifestation of Leslie's desire to
secure a conviction the Washoe County District Attorney's Office and therein secure added boys
from local law enforcement District Attorney's Office and perhaps the Reno justice court itself.
Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the
Washoe County public defenders office in connection with February 27, 2012 clandestine status
conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever'
refuted whether they tlley have been sworn prior thereto or not an especially where Dogan's
coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the
confiscation without a search warrant or court order of any kind (or at least one ever served on
Coughlin in any manner) ofCuughlin smart phone and micro SD card incident Judy impermissible
suml11ary contempt finding by judge Nash Holmes just two hours after the clandestine status
conference between Dogan young on February 27, ~O 12 in RMC case I I TR 26800 for which
Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict
between that traffic citation trial in the Reno Muni court which stemmed from Coughlin's being
retaliated against vice RPO Sargent Tarter in connection with Coughlin telling Tarter one of (he
top 30 highest-paid city of Reno employees of and admission to raking bribes frol11 Richard Hill by
RPD officer Chris Calier Junior incident to Calier placing Coughlin in handcuffs pursuant to a
custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November
13, 20 I I. That crim inal trespass conviction has now become the subject of a Nevada Supreme
Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia
Lopez of the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord
client. and a summary eviction matter that judge Sferrazza presided over wherein judge Sferrazza
purportedly controlled the civil division of the Reno justice court to the extent that Coughlin's
notice of appeal on December 26 submitted for tiling December 26,20 II was not file stamped by
rhe civ il division staff of the Reno justice court. This impropriety is further problematic where
Coughlin had served upon the Reno justice court's custodian of records and she civil clerk Karen
Stancil (whom Richard Hill references in his January 12. 2012 letter her grievance against
Coughlin (0 the State Bar of Nevada (see Hill's January 14.2012 grievance against Coughlin to
the State Bar of Nevada, which ultimately became one of the three grievances depicted
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numerically in the caption of the SBN v_ Zachary Barker Coughlin SCR 105 Complaint tiled by
the Slate Bar stamped August 23, 2012 (in addition to the NG 12 - 0434 grievance by judge Nash
Holmes incident to the February 27, 2012 trial in II fR 26800 held in violation ofNRS 178.405
by way ofNRS 5,071 (RK and RMC under one roof, Judge Nash Holmcs admits to strategy
sessions to discredit Coughlill being held with other RMC judges including then Administrativ
Judge William Gardner, who refused to rccw;e himself from the criminal trespass matter incident
to the criminal complaint Signed by Richard Hill at Coughlin's tormer law office upon Coughlin
being subject to a custodial arrest by ollieer Chris Carter on November 13,2011, resulting in a
criminal trespass conviction of Coughlin in II CR 26405 where it RPD Sargent Marcia Lopez
ultimately had to admit on videotape to Coughlin that neither she nor Hillmeritless or her partner
officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial arrest on
that day in where Lopez also admits none of those individuals or anyone present that day identitled
themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace
about 5 feet high underneath the former home law office wherein Coughlin was found at a time
when Coughlin still had not receive back fi-om the Reno justice court the impermissible $2275 rent
escrow depositjuuge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's
admission that the Renoju,tice court judges held a meeting wherein they admitted that Coughlin
was correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice
court rule 44 that may support the secret quote house rules been fact in the civil division of the
Reno justice court wherein tenants were in summary eviction matters were subject to torced rent
escrow deposit in violation of justice court rules civil procedure 83 and that the Reno justice court
had neither published nor had approved by the Nevada Supreme Court any sort of corollary to
justice court rule Las Vegas rule 44 (JCRLV 44), Further that criminal trespass conviction and the
wrongful arrest connected thereto occurred even where the Washoe County Sheriffs office deputy'
Machen filed a false affidavit on November 7, 2011 alleging to have personally served Coughlin
with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact,
Conclusion of Law, and Order of Summary Eviction (which Casey 0_ Baker, Esq. lied about his
testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to
recuse himself despite Ihe fact that his sister judge Linda Gardner is listed as the grievant (and him
goes to Pat King's awkward assertions that the "Clerk of Court" sent bar counsel Patrick 0_ King,
Esq, Judge Linda Gardner's April 2009 order sanctioning Coughlin inCIdent to a divorce matter
where and he was representing a victim of domestic violence on behalf of our Washoe legal
services (a rather interesting approach by former prosecutor judge Linda Gardner in comparison to
the extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice
court incident to deputy district attorney Young's repeated malfeasance misconduct violations
stays pending competency or evaluations failure to turn over eXCUlpatory materials failure to
propound discovery failure to respond reasonable discovery requests demonstration a retaliatory
animus in conjunction with scattershot three, count them three prosecutions of Coughlin this year
for charges which young either amended to in advance implicating Supreme Court Rule (SCR)
111(6) (in 065630 young amended the criminal complaint from a misuse of911 charge to do a
charge more delcte1'ious to Coughlin's professional license as a lawyer and/or patent agent by
amending the charge nearly a year after the lanual,), 14, 2012 arrest in the matter to a charge that
young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort
to achieve a plea-bargain and resolve what is a messy case the city of Reno Police Department and
emergency dispatch services and again the Reno justice court incident to the eviction and
RJC20 12-000375 run the rental at which the domestic, iolenee resulted in Coughlin's calls to
emergency ;ervices or <j II stand located at 1422 E_ 9lh St. (therein implicating the three, count
lhem three extremely suspect rolling this year by judge Schroeder of the Reno justice court against
Coughlin in the extremely qUick like 40 min_ from tiling quiCk issuance of up temporary protection
order to Richard G Hill on January 12,2012 in connecl1on with Hill's fraudulent abuse of process
and false statements to police officers affectlOg the arrest custodial arrest of Coughlin on January
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UPDATE MOTION FOR NEW TRIAL AND MOT10N TO ARREST JUDGMENT
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12, 2012 will jaywalking (Hill lied to RPD orticcr HuilingsII'0I1h in alleging that Coughlin had
already lost his appeal of summary eviction matter in 1708 Barber which judge Sferrazza presided
and which was then on appeal beforcjudge Flanagan (whom subsequently had Coughlin with an
outrageous $42,000 attorney fee award against Pro per appellant Coughlin in the appeal of the
summary eviction order issued by Judge Sti:rrazza and 1708 on March 30, 2012 incident to and
motion for attorneys fees tiled by Casey D Baker of Hill's \1ffice on April 19. 2012 which just
happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay
required by NRS 178.405 and getting judge Elliot (whom "randomly" was assigned to Coughlin
appeal of the petty larceny conviction of a candy bar and some cough drops Irom Walmart in II
CR 22176 (the sole basi> for Coughlin's current temporary suspension of his law license incident
to bar counscl's SCR 111(6) Petition in 60838) stemming Ii'om an arrest on September 9, 2011 that
was violative of Nevada law where tribal police "flicers alTeeted a custodial arrest for a
misdemeanor (much less one not alleged to have occurred in their presence) in violation ofthc
express dictate against doing so found in NRS 171.1255 should especially where Walmarts sale
witness testifying at the pelly larceny trial. would be dentist Thomas Frontino. whom testified on
behalf of the 2nd SI. Wal-Mart at which Coughlin was subject to a custodial arrest for
misdemeanor petty larceny" a candy bar and some cough drops in connection with Coughlin's
selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some
cough drops while doing so ... Despite the fact that that Walmart alleges to have had absolutely no
video tootage supportive of i15 allegations even where its interior is absolutely dOlled with "pupil
style" will surveillance cameras and where French you admit that his supervisors had previously
indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning
sOllle of Wahnarts policies and where John Ellis of the W. 7th St., Walmart in any as yet unknown
loss prevention associate specifically and expressly threatening abuse of process against Coughlin
on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant store
managers and customer service managers many of whom have had that position tor over a decade
routinely daim do not remember the return policy or restated in a manner that depa(, substantially
from the policy which Walmart holds out to the public on its website Walmart.com and which on
that website specifically makes applicable to in-store purchases that return policy as stated at
Walmart.com no matter what the convenient for getting in misremembering ofWalmarts managers
may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with WalMart on September 9th. 20 II affected a citizen"s arrest of Coughlin on that date in connection
with the alleged petty larceny by Coughlin of a candy bar and some cough drops which
conveniently for the Reno Police Department just days after Coughlin filed a written complaint
detailing the police misconduct by Reno Police Department officer Grohl and Rossa incident to the
arrest of Coughlin the wrongful arrest of Coughlin on August 20, 2011 in 063341 ajustice court
criminal petty larceny and receiving stolen property charge against Coughlin (despite the fact that
the majority viewpoint throughout American jurisprudence that one cannot be charged with both
petty larceny and receiving stolen property of the same item particularly where the receiving of the
item is alleged to have been from oneself atler one had larceny is the item lending an inference that
Joe Sferrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as possible to
affect the leverage over Coughlin to mitigate the liability Reno justice COUlt may face in
connection with its numerous since is violating about law respecting the manner in which evictions
are carried out and or the misconduct of local law enforccment and prosecutors in carrying out
retaliatory arrest and prosecution of Coughlin where the judiciary in Washoe County is off
criticizes being overly influenced by the District Attorney's Omce. That Walmart petty larceny
conviction stemmed from a trial betore Reno Municipal Court judge Kenneth Howard (a 1981
graduate McGeorge ;,chool of law whom Coughlin's twice former Reno Municipal Court appointed
public defender Keith Loomis (not in the Wal-Mart case, as judge Kenneth Howard denied
Coughlin a court appointed defender there despite his exprc" failure to rllie that jail time was not a
possibility in his pretrial order and where mandatory authonly exists requiring that he then appoint
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Coug.hlinl:Ourt appointed counsel palticularly where Coug.hlin established his indigel1cy. Judge
Howard's malfeasance in connection with that conviction of Coughlin extends further the extent
that he carlyon in that November 30 trial on it in 20 II reviews Coughlin for causing the
November 14 trial setting. to have been continued only to in a 3 min. add-on at the conclusion of
the hearing which are trial "hich judge I loward down such a malter of public concern that he Five
city of Reno employees at the courthouse until nine o'clock at night to get it done that in fact judge
Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial
that was not Coughlin fault that all and where the Reno Municipal Court had previously granted a
continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin
stemming from Richard G Hill Esquire's criminal trespass complaint (connected to the summary
eviction matter over which judge Sferrazza presided) where the Reno Mun icipal Court freely
granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G
Hill'~ need to take a six-week vacation beginning carly November 20 II and it was that same sixweek vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice
court judge Sferrazza to denying Coughlin a hearing on his motion to contest personal property
lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to
contest personal property lien on November 17,2011 even where is extremely suspect that the
justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to
set the hearing on November 17 as Janice admitted when judge Sferrazza called her is of hi> own
witness at the December 20, 2012 hearing that was tinally set (as Richard Hill's e-mail wherein he
threatened Coughlin that he would be able to control the justice court in his desired to prevent such
a hearing been set until he returned from his six-week vacation in late December 20 II .... It
incident to that same hearing on Coughlin's Illation to contest personal property lien judge
Sferrazza ordered Karen Stancil and Joslyn John is of Ihc filing otTice of the Reno justice court to
tile in unsworn statements purporting to prove that Coughlin somehow failed to allow the justice
court to setting hearing on his motion to contcst personal property lien however that doesn't
explain the extent to which bailiITPlamondon was able to apparently without Coughlin's
perl11is;ion serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7,
20 II hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking
axis justice court filing oftice for something unrelated to bailiff Plamondon's desire to affect
service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends
with in law school and to this day Loomis himself in 1982 graduate McGeorge school law along
with wash County Dis!. Atty_ Richard Gammick, both of whom were one year ahead of Reno
justice court judge Clifton whom recently granted 2004 graduate McGeorge school of law deputy
district attorney Zach young in order taking away the ability to file by fax from Coughlin a
privilege Ihal j" accorded any other criminal defendants in the Reno justice court de5pite the fact
that that o,-der was granted at the November 27, 20 12 hearing at which Coughlin's then attorney
public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself
admitted that he had not received the motion young alleged who tiled on November 26, 2012
seeking such an order from judge Clifton barring Coughlin's ability to fax tile or send young it a
fax of any S0l1 appm-cl1lly or perhaps Tom despite the fact that Coughlin had merely comply with
judge Clition's request that he provide judge Clifton something supportive of Cough lin's
contention that Biray Dogan had utterly failed her by the advocacy zealous arc not of any sort
whatsoever incident to his quote representation of Cough lin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's
fonner client Pete Eastman, recently adml11ed to COllghlin both of the State Bar of Nevada
communicated he and his wife false assel1lOns respecting a non-existent order against Coughlin by
Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization
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ill creditors rights at www.llvbar.org)(former law practice partners with an individual from
Washoe Legal Services "hom Coughlin is suing in 60302, Karen Saba, Esq., formerly of Beesley
Peck, L fD and whom trashed Coughlin's work before him and in Nevada Bankruptcy Court at
Coughlin's November 14,2012 formal disciplinary hearing to which judge Beesley's testifying was
not noticed to Coughlin previous to the hearing and in violation of Supreme Court rule 109 a
violation made all the worse in light of the ttlct it bar counsel Pat King had known of any
involvement of judge Beesley in any matters relative to the ultimate Supreme Court rule 105
complaint against Coughlin for over six months at least and sO in no way can be said to just stuff 1
his last-minute supplcmentingjudge Beesley and milquetoast attempts to provide Coughlin S
supplemental deSignation of witness and summary of evidence and regard to both judge Beesley's
testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY at the
hearing (both of those gentlemen attended McGeorge school of law in 1977 a\(mg with Reno
Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions
disapproving of Coughlin's competency as an attorney at the hearing despite the fact that neither of
them could provide an)1hing in the way of speciticity with regard to "hat issues they would take
with any of the work they reviewed of Coughlin's or judge Beesley', case filings in judge before
judge Beesley's department in the NVB.) in early May 2012 in violation Supreme COUli Rule 121's
contidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin fOI'mal
disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen
RI 1larris Esquire whom admitted to misappropriating SO'ne $755,000 from his clients and using it
on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge
Beesley sees competency in Mr. Harris and could overlook the $755,000 for my client where it be
$14 worth of candy bars and cough drops from Coughlin and Coughlin's March 30, 2012 filing in
Cadle Co. v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on
March 15,2012 at 2:30 pm in representing Mr. Keller that was affected by the fraudulently
procUl'ed order for summary eviction in the Reno justice court RJC Rev20 I 1-000374 that morning
obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice court wherein the audio
record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to
hurriedly move the case summary eviction case against Coughlin through despite Judge Schroeder
admittedly having had a different order of hearing the cases planned for that morning docket and
despite the fact that the fax header on the summary eviction order that was hurriedly moved
through indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on
3/ lSI 12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into
Coughlin's rental sometime shortly after I PM tllat same day: 3/15/12, without announcing
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themselves as law enforcement and where they entered with their guns and/or pagers drawn in and
immediately placed Coughlin in handcuffs and told him he was detained in contrast to the typical
procedures carried out by the Sheriff's office incident to evictions in Washoe County. Incident to
that summary eviction (where the docket, at least, more review is necessary, indicates that Kern
and Western Nevada Managemelll's Sue King ,witched up their basis for an eviction all the sudden
in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for seeking an
eviction to one for non-payment of rent (seemingly in response to Coughlin Pre Hearing Brief
pointing out'the difficulties they would face under Glazer in pursuing a No Cause, particularly
against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where
the Park Terrace !fOA had expressly approved the arrangement with two individuals "hom were
arguably sublessors to C(lughlin). in the third grievance against Coughlin forming SCR 105
complaint for which a formal disciplinary hearing, the grievance tiled by Judge Dorothy Nash
Homes in NG 12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in
1977. Perhaps, the filing that Judge Beesley was referring to when he threw Coughlin under the
bus at Coughlin's 11114112 formal di>eiplinary hearing ("ith one of the three grievance numbers
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listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by .
60838 for the Wal-Mm1 candy bar conviction that resulted in the current now 5 month long
suspension of Coughlin's license to practice law in Nevada) is the matter wherein. on March 30th.
20 II Coughlin tiled Ihe following:
Filed: 3/30/2012. in NVB Adversary Proceeding Cadle Company v. Keller
10-05104
Entered: 3130/2012 Brief
Dodd Text: Brief in Opposition to Notice of Default and Praecipe/Intent to
take Default with Certiticate of Service Filed by ZAGl COUGHLIN on
bchalfofSAMANTHA L. HALL. ROBERT KELLER (Related
document(s)49 Notice of Entry of Default tiled by Plaintiff CADLE CO.)
(Attachments: # (I) Affidavit Affidavit of Counsel Coughlin for Keller in
Support of Opposition# (2) Exhibit Exhibit I Regarding WCSO Eviction
Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash
Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley
regarding excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to
RMC# (6) Exhibit 2 24 20 fax to nnc regarding deticiency in record on
appeal# (7) Exhibit II TR 26800 NOTICE OF APPEAL AND MOTIONS 3
7 12 WITH EXI-IlBIT I ATTACHED) (COUGHLIN, ZACH)
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In submitting that somewhat inflammatory 3/30/12 filing (which curiom,ly seemed to

immediately result in .Judge Nash Holmes entering an Order of the same date in II TR 26800
whereby ,he Order Coughlin's property released to him. though DDA Mary Kandaras dragged her
feet until April 7th, 2012 before tinally "allowing" the Washoe County Jail to release to Coughlin
the property that it alternately admitted to having released to the City of Reno Marshals on
2/28/12. denied having the miero sd card. denied the micro sd ever being booked into property,
alleged to have given Judge Sferrazza's former tribal court Bailiff and former Coughlin client Peter
Eastman on 2/29112 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys
so Eastman could arrange for Coughlin's dog Jackson Pawluck to be fed and cared for during
Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be
better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card
confi,cating without a warrantl5 day summary contempt jail sentence for testifying that an RPD
Sargent lied in connection with his testimony about the Richard G. Hill, Esq. retaliatory issuance
of three traffic citations outside Hill's law office, where RPD Sargent John Tarter told Coughlin to
leave aftcr Coughlin presented upon being relcased frolll jail incident to a three-day stay stemming
from Hill's line 2 Reno Police Department officers and managing caught to get Coughlin subject to
custodial trespassing arrest (detailed at length 111 6190 I) and Hill refusing to give Coughlin his
drivers license law accuser clients tiles and Coughlin reporting to Sargent John Tarter at that time
that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to
Coughlin in response to Coughlin qucrying him as he too was on Richard Hill's payroll that RPD
Officer Chris Calter, Jr admitted to Cough Iin: "Yes. Richard Hill pays me a lot of money so r
arresl who he says to arrest and I do what he says to do ... " and "here both officer Carter and
Sargem Marcia Lopez refused to undertake any diligent inquiry response to Coughlin's imploring
them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value oflhe 121
River rock propel1y for the month of November that was commiserate with the same $900 that
Coughlin was previously charged for the full use all occupancy of the premises. The lackluster
failure to query Hill with any diligence by both officer Carter and Sargent Lopez is reminiscent of
- 22129-
,
what Reno Municipal Court Cmlrt appointed ddcnder Keith Loon1is E,quire in 1982 graduate
McGeorge school of law told Coughlin at an April 10, 2012 trial date in that criminal trespass
mailer wherein Reno Municipal Court judge William Gardner refu>.cd to recuse himselffrom
hearing that case against Coughlin despite the fact that at Ihat lime he had tiled a grievance with
the State Bar of Nevada against Coughlin by way of the NG 12 - 0434 grievance that his fellow
RMC judge Dorothy Nash Holmes filed
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Judge Beesley formerly pal1nered with now Washoe Legal Services child advocacy
d,rector Karen Sabo. Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash
Ilohnes confiscating Coughlin's smart phone and micro sd card. and regular cell phone on 2/28112.
when. olltside any permissible interpretation of a search incident to arrest given Coughlin property'
had been booked into his personal property at the Washoe County jail on 2/27112 (upon Judge
Nash Holmes summarily sentencing Coughlin to 5 days in jail for contempt. despite citing to a non
summary civil contempt statute in NRS 22.010 and NRS 22.100, but characterizing her Order as
finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS
199.340, Nevada's criminal contempt statute. which is not summary in nature, and therefore
requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her
Marshal Joel Harley (and its not clear Harley even said what Holme's alleged he did in rendering
her "second bit at the apple" 01'3/12/12 in comparision to her 2/28112 Order Finding Defendant in
Contempt and Imposing Sanctions ... ln Nevada. a Summary Contempt Order under NRS 22.030
(which is civil in nature) for conduct not committed in the immediate presence of the Court (such
as the alleged conduct involving a restroom and disassembling a smalt phone or recording device
and hiding some component part thereof in the restroom that Judge Nash Holmes murkily. hazily.
and vaguely testilied to during Coughlin's 11/14112 formal disciplinary hearing, and which she
included in the Order she rendered in that traffic citation case stemming from Coughlin being told
to leave Hill's law omce upon appearing tlleir demanding his keys, wallets, driver's license, and
client's mes ,hortly after being released from a 3 day custodial arrest stay in jail incident to Hill's
criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011001708, the eviction matter presided over by Judge Sferrazza). Like the Order Judge Linda
Gardner claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v.
Vaxevanis FV 11-03383 (sec attached in Exhibit I). Judge Sferrazza attempted to characterize the
Order he entered on 12/21 I 12 following a very contentious six hour hearing on Coughlin's
November 17th. 20 I I tiled stamped Motion to Contest Personal Property Lien as an "Order
Resolving Tenant's Motion to Contest Personal Property Lien" despite Coughlin clearly indicating.
on the record at that hearing thaI he was certainly not "agreeing" to anything. nor was he waiving
his right to appeal any Order Judge Sfen'azza may enter or render incident to that Hearing".whieh
was conducted in an is coercive atmosphere wherein Richard Hill WaS permitted to joke along with
Renojustice court bailiffs radius in chief bailiff SexlOn as to the fact that he to quote would like to
stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court
bailiffs had either as bailiff arrested told Coughlin that he would put his foot of Coughlin's ass or
made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on
two different occa,ions the week of Thanksgiving 2011 that Coughlin indicated that the tiling
office andlor not attempt to tile documents so close to the 5 PM closing time of the filing office.
(see attached in Exhibit I).
76
and him him him him and him

2"7
In fact, in Hill's January 14th. 2012 grievance to the SBN, Hill
writes, inaccurately;
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"4. We represent Dr. Matthew Mcrliss, a physician from Chico. California.
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D... Mcriiss owns the property at 121 River Rock Street, Reno, Nevada.
Beginning in March 20 I O. the property was leased to Mr. Coughlin and his
then-girlfriend. The lease expired in February 20 II. The girlfriend left the
community in approximately May 20 \ \. Dr. \\krl;", contacted us ill
approximately August 20 II to assist in evicting Mr. Coughlin. Coughlin had
not paid rent or utilities ,ince May. He contended that there were habitability
issues with the propc.1y that justified his withholding rent."AII of his clahns
were decided adversely to his position at the eviction hearing. Justice of the
Peace Peter Sferazza ordered Coughlin evicted from the premises effective
November I, 20 \ I. On that date. the Washoe County Sheriffs Oepartment
l,erformed their normal eviction procedure: locks were changed and the
eviction notice was posted on the front door. We videotaped the home and
its contents at that time. Upon inspection over the next few uays, it became
apparent that "somebody" was breaking into the home on a regular basis. On
Sundav, November 13,20 II, Dr. Merliss came to town, and r met him at the
home ~n River Rock Street. As we walked through the home, it was obvious
lhat
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One, it is not true for Hill to wr,le "The lease expired in February 20 II." The Standard
Rental Agreement utilized by the parties provided that the Lease renewed upon its terms
automatically in accordance with the NRS 118A holdover tenant provision. Further, it is not
accurate for Hill to write "Coughlin had not paid rent or utilities since May." One, the landlord
assented to an arrangement with Coughlin's former co-tenant, Melissa Ulloa, whereby he agreed to
allow Ms. Ulloa to make installment payments to make up for the fact that she took Coughlin's
$450 contlibution to Ihe $900 for each of the months of May 20 I \ and June 20 II and only sent the
landlord Mer\iss $550 ror May 20\ I and nothing for June 2011. Coughlin provided Ms. Ulloa
with $450 for each of those months. and therefore, in combination with Dr. Merliss's assent to
Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge ofa variety to
which the two petty larceny charge, Coughlin faced shortly after Ms, Ulloa', secretly absconding with
Co~ghlin's rental comributions (whIch Coughlin was only made aware, and the concomitant rent due, upon
an Augu,t 11th, 2011 email from the landlord Merliss). Merli,s admitted to assenting to the repayment plan
with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Ilill
or Raker in their demands and eViction notice" in violation of NRCP II) admitted, under oath, that he had
expressly. m writmg, assented to an agreement with Coughlin for a rent deduction of$350 going forward in
exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weed," (see the attached
artiticlal turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper
for the other property Merliss owned next door and hi, quasi real estate broker property manager Darlene
Shal'Pe quickly grew unhappy with, givcn it was cutting in to the "$2,000" that Dr. Merliss eventually
claimed. under oath, at the 10125112 t!vlction "Trial" that he wound up paying Green Action Lawn Service to
"deal with the weeds" at Coughlin's former home law office. "Dealing with the weeds", to Green Action
Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law
oftice substantiallos&es $}5\ 'j)\'$f\\S t\me away from work and expenses associated with immediately
Illltigating the criminal conduct of green action lawn service where they not only tore up the artificial turf
IIlstaliation even [hough they knew it was there prior to submittlllg their bid for services to landlord Merliss,
)S
who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin
on or about May 24th 20 J I in exchange for Coughlin quote dealing with the weeds. Green action lawn
26
service sought close the artificial turf installation Coughlin put into place of his fomler law office tile week
prior to theIr learing It up and leaving industry when they were doing the weeds at the property Merliss owns
) 7
next-door at 252 Mill St.

Hill's grievance of 1114112 to the SBN goes on
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allege:
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- 24119-
UPDATE MarrON FOR NEW TRIAL AND MarrON TO ARREST JUDGMENT
,
"Someone had been in there since I had last been in several days before. Dr.
Merliss discovered that the basement door was barricaded (not locked) from the inside.
?
n,e Reno Police Department was summoned. They tried to coax "hoever was in the
basement out, \\'lthout succe~s. After Dr Merliss. had to kick the door down, it '\vas
discovered that Mr Coughlin had broken ill and was in thl! basement. He was arrested
and IS presently fadng criminal trespass cilarges in Reno Municipal COtirt. Sec case no
II CR 16405 21. lie is also facing a contempt motion in front of Judge Sfcrrazza in the
eviction case. Sterazza has stayed that matter pending the resolution of the criminal
trial. That was scheduled for January 10,1012, hut was continued at the reque,t of Mr.
Coughlm's new attorney.

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5. The eviction order IS now un appeal to the Second ludicial District Court
See case CVII-03628, pending in Department 7. As part of the eviction proccss, a lien
waS a"crted against the personal property that Coughlin left behind at the home. On
November 16,2011, Coughlin tiled a motion to contest the landlord's tien in the Reno
Ju~tice Court. The court tried to promptly set a hearing, but Coughlin refused to
cooperate in setting the matter, and the coun took it off calendar. Coughlin then
reiniriated [hat process and a hearing was held in Dcccmb~r, at which time the court
heard evidence of Coughlin's lack of cooperation in setting the November hearing. Vou
may also want to contact Reno .Iustice Court staff. and in particular. chief clerk
Karen Stancil, about Mr. Coughlin's abusive trearment of her and her statl After the
hearing. the court issued an Order granting Coughlin a tWa-day time window to remove
his personal property. The first day was Thursday, December 22,20 II. After Coughlin
was allowed into the home that first day, he sent out an e-mail to the effect that because
he had appealed Judge Sferazza's order, he was entitled to a stay of proceedings and
was to resume in the home. As a result, he did very little to remove any of his personal
property that day. On Friday, December 2], 20 I I, after he learned, again, that his stay
had been denied, Coughlin assembled a small crew and they were able to remove a
substantial amount of his personal property. (You need to understand that Mr. Coughlin
is a hoarder. We have the photos and videos if you would like to see them.) However,
Mr. Coughlin did not get all of his property out. For example, I counted 13 car seats
that he had somehow managed to get down into the basement.
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Having failed to remove all of his belongings, Mr. Coughlin then moved
before Judge Flanagan for a temporary restraining order to prevent the disposal of his
abandoned property in accordance with Judge Sferazza's order. Attached is Mr.
Coughlin's motion, my office's opposition, and Mr. Coughlin's reply. These
documents demonstrate Mr. Coughlin's complete and utter incompetence as an
attorney.
On January 11,2012, Judge Flanagan denied Mr. Coughlin's request for a
temporary restraining order. On January 12, 20 II. the contractor hired to clean the
house commenced work. Mr. Coughlin flagged the contractor down in traffic when he
(the contractor) was on his way to the dump with the abandoned property trom the
house. Coughlin called the police, \.\'ho arrived at the transfer station Coughlin was
falsely asserting that the contractor had tried to mn hill I over. He also told the police"
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The ECOMM recordings (at least what Skau decided to divulge, finally) can be
dc"ribed thusly:
PHONE C ALL Start_Time ~ Saturday, August 20, 20 I I I 1-2}-52 PM Source ID ~ 50
Cory Goble's fi"t 911 call from Austin Lichty's 775 378 6673 wav
PRIMARY RADIO TRAFFIC Start_Time ~ Saturday, August 20, 2011 11-24-19 PM
Source_ID ~ 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Stan_Time ~ Saturday, Augllst 20. 2011 I \-24-34 PM
Sourcc_ID 46 Rosa saYll1g 396 en route.wav
::3
- 15/29-
""!"'"
PRIMARY RADIO TRAFFIC Start_Time ~ Saturday, August 20, 2011 I \2506 PM
.1
Source_1D ~ lJ reporting party advised they are now at lirst and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday. August 20. 2011 112522 PM
Sourcc_1D = 11 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 20 II 112630 PM
Source_1D ~ 12 RPD Rosa saying charles 396 on the other end.way
PRIMARY RADIO TRAFFIC Start_Time = Satllrday, August 20, 1011 112634 PM
Source_ID
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,
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14 Ullllltdlible short statement sounds like gUilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 112725 PM

Source_ID .0 41 probably Durald. saying Reno C I 53 twenty three.way
PRIMARY RADIO TRAFFIC Start3imc = Saturday, August 20, 2011 112729 PM
Source_1D = 43 prohably a dispatcher saying c 153.way
PRIMARY RADIO TRAFFIC Start Time = Saturday, August 20, 2011 111811 PM
Source_ID = 17 Ouralde saying RCI1-;; C 153 I'll he out on him on the Center 51.
Brldge.wav
PRIMARY RADIO TRAFFIC Start_Time ~ Saturday, August 20, 2011 112817 PM
Source _ID ~ 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start Time ~ Sunday, August 21, 20 II 120840 AM
Source_ID = 17 Dispatcher indicati';g Reno CI53 wagon available for a male.wav
PRIMAR Y RADIO TRAFFIC Start_Time = Sunday, August 21,20 II 120851 AM
Source_ID = 26 someone other than Duralde sounds like make that a level b clear that
in about 5 minutes WaY
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 121951 AM
Source_ID = 42 prohably Ouralde saying Reno CI53 to main station break 151
unintelligible. wav
PRIMARY RADIO TRAFFIC Start_Time ~ Sunday, August 21, 2011 122102 AM
Source_ID ~ 28 odd by somebody cl53 scems to split in middle yet still one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 123803 AM
Source_lD ~ 22 Duraldc saying Reno cl53 rtfretuming.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday. August 21. 2011 123810 AM
Source_ID = 27 Duralde', wife Dispatch Jessica Duralde c 153 104 break union 9 to
reno.wav
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lH
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SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20,2011 1136.19

PM Source_lD = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday. August 20. 2011 1136.31
I'M SourceJD = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 1137.23
PM Source_ID ~ 14 man saying come and split til at up then female dispatcher saying
go ahead with that.wav
21
CONCLUSION
Please consider these additional materials and arguments respectfully
2G
submitted.
27
- 26/29-
,
j
AFFIRMATION Pursant to NRS 2398.030
The undersigned docs hereby aftirm that the preceding document does not contain the
3
DECLARATION
The assertions herein are made, pursuant to NRS 53.045 under penalty of perjury and
7
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based upon my first hand knowledge of these matlers, except to perhaps a very, very few
aspects of a a very few assertions which are made upon information and belief.
10
Dated this November 30th, 2012

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/s/ Z c
Zach
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- 27/29-
CERTIFICATE OF SERVICE:
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Pursuant to NRCI' 5(b), 1 do hereby certify that, on this date, I, Zach Coughlin r
deposited in the United Slates mail at Reno, Nevada, in a sealed envelope, postage
prepaid, a true and correct copy of the foregoing UPDATE MOTION FOR NEW TRIAL
AND MOTION TO ARREST JUDGMENT and or electronically served (via electronic
method of transmission previously given express permission to utilize by those with
requisite authority 10 provide iI, upon which Couglin reasonably rdied and or relics):
ZACHARY N, YOUNG, ESQ,

Washoe County DA Otlice
8
1',0. Box 30083
10
Reno. NV 89520
11
Phone Number: 775-328-3200
l2
Fax number: 775-325-6703

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Admit Date: 10/20/2004

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DATED THIS: Dated this Nov
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exhibit I: various relevant materials: 59 pages printed at 2 pages per sheet

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.....; "... 0
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t,;':~ ?)
EXHIBIT 1
,'--
2J12
~~-NORTHERN ~~::R OF NEVADA ~.",t;; ~'\R OF NEVADA

A DISCIPLINARY BOARD
Case No. NG12-0204, NG12-0435 and NG12-0434

ST
STATE BAR OF NEVADA,
nil'll: ..
COMPLAINT
Complainant.
vs.
ZACHARY B. COUGHLIN. ESQ.,
Bar No. 9473
II
R""""nd<onI.
PLEASE TAKE NOTICE that pursuant to Supreme Court Rule ("SCR") t05(2) a
VERIFIED RESPONSE OR ANSWER to thiS Complaint must be filed with the Office of Bar
Counsel, State Bar of Nevada, 9456 Double R Boulevard, Ste B. Reno, Nevada, 89521,
Jwfthin twenty
addressed
In
(20~
days of service of Ih,s Complaint
Procedure regarding service IS
SCR 109
Complainant, State Bar of Nevada rStale Bar"), by and through its Assistant Bar
)1
Zachery Coughlin rRespondenn, Bar number 9473, IS a member of the State Bar of
Counsel Patrick O. King, is informed and believes as follows.
I Nevada admitted
on March 25, 2005. Respondent's date of birth is September 27, 1976
j
, The address that Respondent has on file with the State Bar of Nevada. in accordance with
EXHIBIT 1
II
Rule of Professional Conduct ("RPC") 79(1 )(a) IS Post, Offi~ Box 3961, Reno NV 89505.
;1 Respondent
engaged to acts of misconduct warranting the Imposition of professional
:! dlsclphne
The State Bar alleges as follows
Multiple grievances were received by the Office of Bar Counsel between thfl"
l!penod of January 14 and March 15. 2012, concerning Responden!

I
Due to tile senOdS
!Iallegations of misconduct. grievance files were opened and an Investigation was initiated by
10 one of t-Jis pending criminal matters, Case No. RCR2012 065630. City of Reno v. Zachary
Coughlin.
Assistant Bar Counsel Patrick King.
and lack of respect for the court and opposing counsel.
Respondent was advised of the gnevances via U.S. mall, e-mail and by a brief
meeting with Mr. King at the State Bar Office in Reno
10,
Respondent did not cooperate with
11.
lesponsive and disparaging e~mails.
home he was renting effective November 1, 2011
The investigation of the grievances against Respondent shows a serious
! from
'had broken into the home and was barricaded In the basement. The Reno Police tried to
a War-Mart store with an approximate value of fourteen dollars ($14 00). On NO'Jembe,
Petit Larceny, a violation of RMC 8.10.040.
Respondent appealed the judgment of
i\l conviction. The judgment of conviction was affinned on appeal.

1
6.
coax whoever was In the basement to open the door. Dr. Merhss was forced to kick open the
On September 9, 2011, Respondent shoplifted a candy bar and cough drops
3D, 2011, Municipal Court Judge Kenneth R Howard found Respondent gUilty of Ihe offense
I of
After the locks were changed and the
j eViction notice was posted on the front door the owner, Dr Merliss, discovered that someone
'nattern of misconduct.
The circumstances leading to the above-mentioned arrest are as follows: at an
eviction hearing Justice of the Peace Peter Sferrazza ordered that Respondent vacate the
Respondent has not made a request to be placed on disabihty status, nor has
he acknowfedged that he may have mental infirmity, illness, or addiction.

4
Respondent was arrested on November 13, 2011 by Reno Police Departmenl
and charged wrth trespaSSing. a misdemeanor, for which he was later convicted
the investigation and rather than respond to the grie'ltaoces as requested, Respondent sent
3.
The document clearly shows Respondent's unprofessional. disruptive conduct.
I door where
I!
!!was living in the basement.
Respondent was arrested for criminal trespass and was
I
i subsequently convicted of that charge.
12
See Exhibit 1.
Dunng the tnal Respondent's conduct was so disruptive that Judge Howard
the Reno Police found Respondent. Respondent had broken into the home and
Respondent, representing himself as co-counsel, filed a 36~page motion to
dismiss on March 5, 2012.
The motion was denied by Judge William Gardner and was
. .Respondent in direct contempt of Court and sentenced him to serve three (3) days in
idetermlned to be without merit. The motion, on its face, demonstrates that Responder'lt lacks
II jail.
!competence to practice law.
II
Ii
See Exhibit 2,
7,
On August 20. 2011. Respondent was arrested on a second larceny charge for
II allegedly stealing
I;
"
a cell pt-Jone. Those charges are currently pending," Reno Justice Court.
Respondent was again arrested on JanlJary 13,2012, for allegedly abuSing 911
:;
~I emergency services. a gross misdemeanor.
;1
On February 21, 2012. Respondent filed a document entitled, Notice of
. Appearan.s;~... Fn.t!Y of Plea of Not GUilty WaIver of R1Qht 10 ArraIgnment Mohon to DIs['fJlU.
13. . Once Respondent was evicted, an order was obtained 10 remove his
: belongings from the home Respondent interfered with the contractor who was hired to
remove Respondent's personal belongings. The police were called and after talking with
Respondent they recommended that he find something else to do. Respondent refused to
follow their advice and was subsequently arrested by the Reno police .
14.
In the case of City of Reno vs. Zachary Barker Coughlin, Case No. 11 TR
2680021. a trial was held on a traffic citation issued to Respondent. The matter was called
at approximately 3'00 p.m. and concluded without a verdict at about 4'30 p m. after the court
held Respondent in criminal contempt of court for his behavior and activities committed in the
25.
Court executed an "Order After Trial," In case No. OV08-01168. In that case, Respondent
direct presence of the court during trial.

15.
represented the DefendantiCounter Claimant.
In a March 12. 2012 Order, MUnicipal Court Judge Dorothy Nash Homes found
Judge Holmes explained in her Order that after Respondent
The most troubling aspect of thiS case was Mr. Coughlir.'s rude, sarcastic and
disrespectful presentation at tnal; Mr. Coughlin's inability to understand a balance
sheet; his failure to conduct discovery and his lack of knowledge with regard to
the rules of evidence and t:"lal procedure. All of this was compounded With a
continuousty antagonistic presentation of the case that resulted In a shift from a
fairly simple divorce case to a contentious divorce trial lasting an excessive
amount of time.
served his ftve-day contempt of court sanction imposed by the court on February 27. 2012,
Respondent fax-filed to the court a 224-page document. Judge Holmes found that the
document contained rambling references to his personal fife and was incoherent.
16
In her Order Judge Gardner explained
Respondent's Inappropriate behavior in part as follows:
"dear and convincing evidence" that Mr. Cough"" committed numerous acts of attorney
misconduct. See Exhib;t 3.
On April 10, 2009, Oistnel Judge Linda Gardner of the Second Judicial District
27.
In her Order, Judge Homes found by clear and convincing evidence that
In light of the forgoing Respondent violated RPe 1.1 (Competence), RPe 1 2
Respondent violated Rule of Professional Conduct rRPe") 1.1 (Competence), RPe 1 3
(DIligence); RPC 3.1 (Meritorious Claims and Contentions); RPC 3.3 (Candor to the
(Diligence), RPC 3 1 (Meritorious Claims and Contentions), RPC 3.2 (Expedning Lnigation),
Tribunal); RPC 3.4 (Fairness to Opposing Party and Counsel); RPC 35 (Impartiality and
RPC 3 3(a) (Candor toward the Tribunal), RPC 34(e) (Fairness to Opposing Party and
Decorum of the Tribunal); RPC 4.1 (Truthfulness in Statements to Others); RPC 4.4
RPC 8.4 (c) (Engaging In Dishonesty, Fraud, Oeceit or Misrepresentation) and
II (Respect for the Rights of Third Persons); RPC SA (Relations with Opposing Counsel); RPC
4(d) Engage in conduct that

17.
:11"fOrma
IS
Prejudicial to the Administration of Justice).
Respondent filed Affidavits of Poverty In Support of his Motion to Proceed
Pauperis, wherein he fails
to disclose that he
IS
I
I
18
Oesplte a claim of poverty in the above mentioned affidavits, Respondent told
the Court thal his incarceration for contempt would adversely affeel his clients.
19
1;
WHEREFORE. Complainant prays as foflows:
That a hearing be held pursuant to Nevada Supreme Court Rule 105;
a licensed attorney and instead
!unde:f" Employment and Self-Employment he ldentiftes himself as a" Jack of All Trades".
118.1 (Disciplinary Matters); RPC 8.2 (Judicial and legal Officials), and RPC B 4 (Misconduct).
On March 22. 2012, Respondent appeared at the Reno Municipal Court
wearing (srnlley face) nanne\ paJamas Respondent became argumentative and Marshals
2.
That Respondent be assessed the costs of the dISCiplinary proceeding
11 pursuant to Supreme Court Rule 120(1), and
Hotmall Print Message
Etmt
3.
grievance and complaint against DDA Young and WCPD

Dogan, Leslie, and Bosler
That pursuant to Supreme Court Rule 102, such disciplinary action be taken by
the Northern Nevada Disciplinary Board against Respondent as may be deemed appropriate
TC,
., under the circumstances.
"
Respectfully submitted Ihls
Zach Coughlin (zachcoughlln@notmall.com)

Sat 9/08/12 1:50 AM
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,
,
(iQSC
complaints@nvbar.org; complaint@nvbar.org; davldc@nvbar,org; glennm@nvbarorg
1 attachment
1.:S
day of August, 2011.

STATE BAR OF NEVADA
DAVID A. CLARK, BAR COUNSEL
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Zach Coughlin, Esq.
PO Box 3961
Reno, NV 89505
By~D07~sistant Bar Counsel

Patrick 0 King;
Tel: 775 338 8118

Fax: 949 667 7402
Nevada Bar No, 5035

9456 Double R Blvd., Ste B
Reno, NV 89521
ZachCoughlln@hotmaJI.com
September 9th, 2012
I
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State Bar Of Nevada

complamt@nl/bar.org
complalntsq1nvbar .org
DavldC@nvbar.org
Dear gar
f~e
Coun~el,
IfiRI! 20NEW%2Dtemp/9"fo208%2:J 12%20grrevance"'o20agalnst"-'o20J,m'%20leslle%20!:o%20wmplalnts@nvbar.org.htmf12f312012 2 4W 29 AM]
Hatma,l Print Message
Hatmarl Print Message
(e) Nol subpoena a lawyer 10 a grand Jury or other cnmlnal proceeding to present eVidence about
Dear Bar Counsel,
a past or present client unless the prosecutor reasonably believes:
Please accept thl~ correspondence as a formal grievance against botn Washoe County Deputy District
Attorney Zach Young, Esq. and Washoe County Public Defender Biray Dogan, ESQ, for the reasons set
fortll herein, With the understanding that J plan to supplement this further In the near future,
Mr. Dogan, despite RPC sections devoted to diligence, competence, and communciatlons with clients,
you failed to copy me on (or even Inform me of) DDA Young's attempt to amend the complaint In
RCR2012-065630 to a misdemeanor that would require, If a conViction IS garnered, Bar Counsel to
file Petition seeking suspension of one's law license under SCR 111(6), given "obstructmg a public
officer" IS specifically delineated as a "serious offense" therein. I have, In the past 1n wntlng and
verbally, Indicated to Dogan and his supervisors Jim Leslie and Jeremy Bosler, that I demand to be
copied of every filing In any case for which they appear for me, Dogan made contradictory and
untruthful! statements to me with regard to whether he ever gave me a copy of my file in thiS
motter, At f;rst, Dogan mdicated I1C did himself, and that he was sure of that, then minutes later he
ted he was sure that he was there to witness JIm Leshe give me the one copy the WCPD ever
Ided me. WCPD staff has admItted to me that there was a package avaIlable for me to olck up,
_' er the date on whICh Dogan and Leslie allege they gave me my file, but that because I did not pick
'It up soon enough, It was Withdrawn from the front desk, Thereafter Dogan and Leslie have
maIntained the positIon that I was prOVIded that package, With varying, contradictory, evasive, and
vague statements (and In leslie's C(1se, testImony) as to just how and when that occurred.
fit
Additionally, Dogan and Leslie persISt In seekmg to combme hearings In thiS case and the two cases
JIm Leslie is attorney of record on (RCR2011-063341 and RCR2012-067980)witn the case Dogan IS
attorney of record on (RCR2012-06S630, and whICh Leslie atternately, when Its convenient to him,
malntams he IS allowed to chip In on, or, alternately, maintain that he has not a connection thereto
and thus ally misconduct 10 connection WIth that case may not proVide a baSIS for a conflict bemg
found In RCR201 1-06334 t), despite my express Indication that Dogan and Leslie must refrain from
dOing so.
Further, DDA Young is Violating RP( 3,8 and other ethical rules. In seeking to attain some leverage In
RCR,2012-065630 by amendmg the Complaint to a charge that falls wtlhin the purview of $CR 111(6)
("senous offense", etc), where the allegatIOns do not prOVide probable cause for such a charge, DDA
Young is Violating RPC 3,8, Further, DDA Young has a duty to divulge to the Court the conflict
inherent In his office's partnenng WIth an entity that I am sumg on a wrongful
dIscharge/discrimination/retaliation baSIS, Washoe Legal SerVICes, whIch IS partnenng With the WCDA
In an Early Case Resolution program that IS v!olatlve of the Sixth Amendment Right to Counsel.
__
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Rule 3.8. SJ)e(:iaf Responsibilities of a Prosecutor. The prosecutor In a Criminal case shall:
(a) Refrain from prosecuting a chargE' that the prosecutor knows IS not supported by probable
cause;
(b) Make reasonable efforts to assure that the accused has been ad'/lsed of the nght to, and the
procedure for obtaining, counsel and has been given reasonable opportunity to obtain counsel;
(C) Not seek to obtain from an unrEpresented accused a waiver of Important pretnal rights, such
as the- nght to a prellmmary hearing,
(d) Make tlmelv dlsclOSl!re to the defense of all evidence or mformatlon known to the prosetutor
t"at tends to negate the gUilt of the accused or mitigates the offense, and, In connection WIth
sentenCIng, disciO"ie to the defense and to the tnbural all unprivileged mitigating Information known
to the prosecutor, except when the prosecutor I~ relieved of thiS respon~lbllity by a protectlw, order of
t'le tribunal;
.,1(> JI'RI .... 20NEW%2Ctemp:g%20R%2.012.%2C1grn"vanceal,ZDagamst"'o20J,m%20Leshe%2:lta%20corTIplalnts@nvhar.orghtm[12/3f2012 2 40 29 AM)
(1) The mformation sought IS not protected from disclosure by any applicable pnvllege;
(2) The eVidence sought IS essential to the successful completion of an ongoing Investigation
or prosecution, and
(3) There IS no other feaSible alternative to obtain the Information;
(f) Except for statements that are necessary to Inform the publiC of the nature and extent of the
prosecutor's action and that serve a legitimate law enforcement purpose, refrain from making
extrajudicial comments that have a substantial likelihood of heightening public condemnation of the
accused and exerCise reasonable care to prevent mvestlgators, law enforcement personnel, employees
or other persons aSSisting or assoCIated With the prosecutor in a cnmmal case from makIng an
extrajudicial statement that the prosecutol would be prorllbited from making under Rule 3.6 or this
Rule.
DDA Young has contInually sought to deny Coughlin hiS right to a leglbmate pre-trial heari'1g In
RCR2012-{)65630, 1n fact, Young needs to answer to whether or not RMC Judge Na!:>h Holmes and he
(as well as Dogan or anyone with the WCPD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom In 11 TR 26800 and shortly thereafter found Coughlin In
"CrImInal contempt" In a traffic citation trial, seconds after Coughlin testified that RPD Sargent Carter
lied 111 hiS testimony related to the three traffic Citations he had Issued on Coughlin inCident to RIchard
HIli, Esq's refusal to return Coughlin hiS client's files or Coughlin's state Issued IdenttfcatlOn,
Add1tlonally, please add to thiS grievance, Reno City attorney Allison Ormaa<;, for her lack for Candor
to the Tribunal (RPC 3.3) In asserting that the word "retaliation" and the subject of retaliatIOn did not
appear in the pohce report for that November 15th, 2011 traffic citation when clearly, the report
reveals that is does, The SCR 117 Petition Coughlin now faces IS based in large part on Judge Nash
Holme's Order and subsequent gnevaf"\ce flied With the State Bar In connection With a Trial In 11 TR
26800 on February 27th, 2012, set for 1:30 pm, and DDA Young and Dogan allegedly met on
February 27th, 2012, at or around 1:00 pm, despite haVing noticed Coughlin that the Status
Conference set for that time In RCR2012~055630 had been vacated. Judge Nash Holmes JudiCial
Assltant could not locate Judge Nash Holmes for nearly 15 mlOutes on that date when the time tor
Tnal came around. WCPD Bosler and Dogan have refused to confnm or deny whether they had any
commUnications WIth Judge Nash Holmes or anyone connected With tile RMC on or around that date
regarding Coughlln's alleged "competency" Issues. Leslie has been extremely evasive In answering
such questions. Court's have a duty to suspend proCeedings If competency Issues are ralsed, across
departments, and arguably across the RJ( to the RMC, particularly jf Judge Nash Holmes was privy to
the "secret" Status Conference that was held on February 27th, 2012, depslte the RJC havmg vacated
!t and Dogan haVIng communicated as much to CoughlIn after Coughlin pOinted out the scheduling
conflict With 11 TR 26800. I am formally requesting Bar Counsel to inllJate an Inquiry Into w!lether
Judge Nash Holmes waS Privy to the Order for Competency Evaluation orderd on Febluary 27th, 2012
in RCR2012-065630, and 1f so, whether she Violated any RPC's by continuing to hold tI-Je Tnal in 11
TR 26800, espeCially In hght of her subsequent gnevanc1/Complamt WIth the SBN and Orders In that
matter.
DDA Young violated RP( 3.8 In seekmg to have Coughlin returned to custody In September 5th, 2012.
Thc~e was absolutely no baSIS for Young seeking to do so at that time other than to disadvantage
Coughlin, ego triP, and Impermlssllby coerce Coughlin out of purSUing any CIVil remedies that he may
have available given the police and prosecutorial misconduct that Coughlin has sys~cmatlcally been
subJected to m the last year,
On tnat '1ote, the July 3rd, 2012 arrest In RMC 12 CR 12420 for "distrublng the peace", no "proof or
Insurance" and "failure to secure a load on a truck" led to Coughlin spending 21 day,; 10 Jail after the
RPD, In conjunction with Reno City Attorney J11t Drake advocated fo~ R~.!JC Judge Gardner to raise the
$1,415 bondable bad to 53,000 cash only, on a "public c;aferty and welfale bas!!>" desp'te tf"Je only
file JJ/RI/ .. 20NEW%2OternpI9%Z08%2012%2()grlevance01020ag<lInst''1<I.2()J"'t1%20leslle%20t0%20compl~lnts 'illnv'oar org.htm[ 12/3120 12 2 40'29 AM]
Hotmall Print Me=ge
pet missrlbe rationale for bail under Nevada law being to Insure the defendant's appearance at trial.
Please .;Iccept thiS as a grievance against John Kadlic and Jill Drake, Esq. for violating RPC's, mdudlng
RPC 3.8. It IS telling that the disturbing the peace charge and proof of Insurance charge were dropped
on September 4th, 2012, but not before a Reno City Attorney (the S(gnature IS dleg(ble) sought to
Violate Soldal v. Cook County and Wheeler v. Coss some more by adding a trespass complaint against
Coughlin, whom had, at the tlrlle of the arrest, two vahd leases at the property in question. If a Reno
City attorney filed a trespass charge, It 15 a Violation of the RPC, and I Wish for thiS to be COr'jstruedas
a gnevance and for further investigation to be undertaken. Certainly, Keith LoomiS gnevance of
August 28th, 2012 looks more supportable
Rule 3.3. Candor Toward the Tribunal.
(a) A lawyer shall not knowtngly.

(1) Make a false statement of fact or law to a trrbunal or fall to cor"ect a false statement of
terral fact or law previously made to the tribunal by the lav,ryer,
(2) Fad to disclose to the tnbunal legal authonty In the controlhllg JUrisdiction known to the
,aviY.r tQ 3e dlrecUy adver~ to the position of tile ellent and not dIsclosed by opposing counsel; or
(3) Offer eVidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a
Witness c;:!lIed by the lawyer, has offered maten",1 eVidence and the lawyer comes to know of Its
falsity, the lawyer shall take reasonable remedial measures, Including, If necessary, disclosure to the
tnbunal. A lawyer may refuse to offer eVidence, other than the testimony of a defendant In a crimmal
matter, that the lawyer reasonablv believes IS false.
(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person
intends to engage, IS enga~:llng or has engaged in cnmlnal or fraudulent conduct related to the
proceedrng sGhall take reasonable remedial measurE'S, mcluding, if necessary, disclosure to the
tnb(Jnal.
(c) The duties stated In paragraphs (a) and (b) continue to the conduslOn of the procecdmg, and
apply even If compliance requires d'sclosure of Information otherWise protected by Rule 1.6.
Cd) In an ex par'.:e proceeding, a lawyer shall mform the tnbunal of all mdtenal facts known to the
lawyer that Will enable the tnbuna! to make an mformed deCision, ..... hether 0, not the facts are
adverse.
DDA Young Violated RPC 3.3 when, at t~lalln RCR2011-063341 on August 29th. 2012 he asserted to
RJC Judge Sferrazza that Layton v State preSnted mandatory bmding authority In Nevada preventing
Judge Sferrazza from excerClsing any dlscretlhon With regard to whether Coughlin could appear as hiS
own co-counsel. Certainly, Wheby and other cases prove otherWise. Yet, DDA Young was Insistent
a'ld clear In hiS stctements that there was "mandatory. bmdmq authonty" preventIng any excerctse of
such dlscretton by the court to po'rmlt a co-counsel arrangement.
Young has continually sought to deny Coughlm hiS ng!lt to a legltjma~e pre-trial hearing In
2012-065630, m fact, youl1g needs to answer to wi':ether or not RMC Judge Nash Holmes and he
_:. well a'S Dogan or anyone ,.'Ith the WCPD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom rn 11 TR 26800 and shortly thereafter found Coughlin In
'cpmlnal contelT'pt" In a traffic otattor. tnal, seconds after Coughhll testIfied that RPD Sargent Carter
hed in hiS testimony related to the three traffic citations he had Issued on Coughlin Incident to Richard
HIli, Esq's refusal to return Coughlin hiS client's files or Coughhn's state Issued ldentifcatlon.
AddItIonally, please add to thiS g~le"ance, Reno City attorney Alltson Ormas5, for her lack fa Candor to
the Tribunal In asserting that the word "retaliation" and the subject of retaliation did not appear In the
police report for that November 15th, 2011 traffIC Citation when d'arly, the report r>veals that IS
does.
4f
-,
Hotm~iI
Print Message
Rule 3.4. Fairness to Opposing Party and Counsel. A lawyer shall not
(a) Unlawfully obstruct another party's access to eVidence or unlawfully alter, d('stroy or conceal a
document or other matenal having potenaa! eVidentiary value. A lawyer shall not counselor assIst
another person to do any such act;
(b) FalSify eVIdence, counselor assist a witness to testify falsely, or offer an IIlducement to a
witness that IS prohibited by law;
(c) KnOWingly disobey an obligation under the rules of a tribunal except for an open refusal based
on an assertion that no valid obligation eXIsts;
(d) In pretrial procedure, make a fnvolous discovery request or fall to make reasonably diligert
effort to comply WIth a legally proper discovery request by an oppoSing party;
(e) 1n t(lal, allude to any matter that the lawyer does not reasonably belJeve JS relevant or that
Will not be supported by admissible eVidence, assert personal knowledge of facts In Issue except when
testifying as a witness, or state a personal opimon as to the )ustness of a cause, the credibility of a
Witness, the culpability of a CIvil litigant or the guilt or innocence of an accused; or
(f) Request a person other than a chent to refrain from voluntanly givmg relevant Inforrnatlon to
another party unless:
(1) The person is a relative or an employee or other ager1t of a client; and
(2) The lawyer reasonably believes that the person's Interests Will not be adversely affected
by refraining from giVing such information,
DDA Young, on July 16th, 2012, Violated RPC 3.4 when he made the statement to the Court In
RCR2011 063341, at Trial, that Coughhn caused the continuance that was necessitated that day by
Joe Goodnight, Esq, (WCPD) sudden removal from the case, Coughlin pOinted out that even he had
not been given any rationale for GoodnIght's sudden removal from a MOl'1day Tnal when Goodmght
had met with Caughlin for trral prep the Fnday before, tending to IndIcate tnat either Young was privy
to rnforTl"atlon from the WCPD that Coughlin was not pnvy to, or Young was making arguments not
based m fact or law or In line With RPD 3.4(e). DDA Young then sought to backtrack, making mincing
statements about hoW he "assumed" thiS or that and how he had not actualy had Impenlllssilbe
communlCat!ons WIth WCPD Bosler (who was flIhng In for Goodmght). RJC Judge Sferrazza
rebuked DOA Young, pornttng ou~ that he should not 'assume' anything.
H
DDA Young continues to impermiSSibly seek to leverage another obstructrng/reslsMg/maki!lg a "false'

statement to a publiC officer Charge In RCR2012-067980, despIte hiS haVing been prOVided
excuplatory Videos and despite a lack of probable cause to support the complamt, the Information
pled thereIn being deficient as well. Additionally, Coughlin's June 26th and July 3rd, 2012 emalls (see
below) make clear that the RPD. Reno Justice (ourt, Was.hoe County Sheriff, et al were made aware
weUln advance of the defiCIenCies tn the 5 day unlawful detatner nonce drafted and served by lew
Taite!, Esq's apparent business partners, Nevada Court Services, who are comml~mg the unauthOrized
practice of law in their "evICtion consulting selvices" (please see mv recent grievance In that regard).
An attornev who imbates, causes to be IllIhated, or threatens to IOJtrate a crlmmal prosecution for the
purpose of mfluencing a CIVIl matter IS Violating the rules of ethiCS, Set:' f\-lodel Code of Prof'l
ResponSibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or ThreatenIng to
Initiate, Criminal Prosecution as Ground for DlSClpl!j1lng Counsel, 42 A.l.R.4th 1000 (2006). DDA
Young and the WCDA may be Violating the follOWing: Att()me~ \ 1t'I.Hcd ),1,l[.:,,,,,,n.ll (<lnd\l('1 [uk,
rrolJlh!lmg ~'~onJuel PKJudlcl<11 fa Ih~ .-!dmllll-.lnlll(lJl
"I' IU--IICC
Jlld pl"illbIUllg J
~l'[I.I) tt' \.,bt31l1 an ad~<lntage- III

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file !flRIf ...20NEW"Iu20temp/9%208%2J 12%20grlevance"I'20agaonst"JQ20Jlm%20L~slle%2atO'lo20compI3IntS{f'nvb.:ir .org.htm[ 12/3/2012 2 40 29 AM]
HotrTlC'1I1 PTiot
Hotrr>i311 Print Message
be sanctlOl"ed, or even disbarred, for coerCing any person connected to the case, for making false
statements of matenal fact or law. or for frivolous behavl1Jr before the immigration courts. A Plaintiff
that has been harassed, Intlmldated or treated in a bad faith manner by a Defendant has two
recourses: Rule 11(b)(1) and Rule 11(b)(2). However, malicIous prosecution actions are necessary to
deter persons from procunng the arrest of another maliciously and Without probable cause. Hunt v.
Lawson, 2008 Wl 4691052 (Ky. 2008), as corrected, (Oct. 24, 2008). ~erlet v. Rizzo, 64 Cal. App. 4th
53,75 Cal. Rptr. 2d 83 (1st OISt. 199B).
M~ge
Compensatory Damages TopIC Summary Correlation Table References 117. JnJury to reputation
West's Key Number Digest West's Key Number DIgest, MahClous Prosecution k67 Compensatory
damages In a maliCiOUS prosecution action may include harm to the plaintiff's reputation caused by the
underlYing action,[FNl] Including the damage to one's reputatIon from the maliCIOUS Institution of
administrative proceedlOgs.(FN2} Thus, the plaIntiff in an action for malicious prosecution may recover
damages for injUry to hiS or her reputabon,[FN3] Including Injury resultmg from the publicatIon of
reports of the proceedings.[ FN4] CautIOn: Although a maliCiOUS prosecution IS. at common law,
assumed to be harmful to an indiVidual's reputation, it is nonetheless necessary to make an objective
showmg of an individual's reputation before the malicious prosecution versus the damaged condition
of hiS or her reputation afterwards to support an award of damages for iOJUry to reputatjon.[FN5] The
plaintiffs own testImony that he or she lost respect due to the maliCIOUS prosecution is not enough,
Without other objecbve evidence, to SUPPOlt such an award,[FN61 EVidence of a plaintiff's prior arrests
is properly admitted In a mahaous prosecution action If that evidence bears directly on the queshon of
whether or not the plaintiff's arrest In fact damaged hIS or her reputation. In view of hIS or her
prev10us arrests.[FN7] However, It has also been held that a tnal court does not err In excluding such
eVidence, because It has no relevancy to the Issue of compensatory damages.[FN8] (FNl1 Bhalla v.
Debek, 287 Conn. 397, 948 A.2d 1009 (2008); Sikora v. Gibbs, 132 OhIO App. 3d 770, 726 N.E.2d
540, 111 A.loR.5th 685 (lath Dlst. Franklin County 1999); Wecht v. PG PUb. Co., 725 A.2d 788 (Pa .
Super. Ct. 1999). [FN2} MelVIn v. Pence, 130 F.2d 423, 143 A.L.R. 149 (App. D.C. 1942). [FN3}
Browning v. Ray, 1968 OK 52.440 p.2d 721 (Okla. 1968). [FN41 Grimes v. Greenblatt, 47 Colo. 495,
107 P. 1111 (1910). As to proof of publicity glVn to prosecution, see 119. [FNS) Rodick v. aty of
Schenectady, 856 F. Supp. IDS (N.D. N.Y. 1994) (applYing New York law). [FN6J Rodick v. City of
Schenectady, 856 F. SuPp. lOS (N.D. N.Y. 1994) (applYing New York lilw). [FN7J Delchamps, Ine. v.
Bryant, 738 So. 2d 824 (Ala. 1999). [FN8] Szare]ko v. Amerllng Volkswagen, Inc., 55 A.D.2d 801, 390
N.Y.S.2d 266 (3d Dep" 1976).
WCPD Jim leslie has violated RP( 1.2 in RCR2011-063341 in attempting to withdraw from Crlmtnal
defendant Coughlin one of the few Inviolable rights a cnmlnal defendant has. leslie has refused to
attempt to procure authentication or foundation for the admission of excuplatory videos of the arrest
of August 20th, 2011 In that case from any of the witnesses In the case. Rather, leslie has malntamed
that he will only put on such videos (whether as eVIdence or to refresh a wItness recollection, and or
for Impeachment purposes) If Coughlin himself takes the stand and prOVIdes authentlcatton and
undatl0n for the videos, thereby exposing Coughlin to a waiver of hiS nght to decide whether or nat
testl~, af'ld opening the scope of cross examinatIon !mpermisslbly. Fu~her, leslie has refused to do
. - or prOVIde any legal research to determme the permiSSIbility of only utlhzlng portlons of any such
video eVidence. That IS to say, Leslie Insists that the Videos must be submitted In toto, even portions
that damage Coughlin's case. Leslie has a duty of dIligence and competence, and hiS blase refusal to
provide any legal citation for hiS contention that Coughlin's defense may not Include picking an
choosrng which portions of such Videos to utilize In Trial IS Violative of those duties, In addition to
violating RPC 1.2's dictate that a "lawyer shall abide by a chents deCISion concerning the obJecbves of
reoresentation and, as reqUired Rule 1.4. shall consult WIth the client as to the means by whICh they
are to be pursued" and that "the lawyer shall abide by the client's deCiSIon, after consultatIon With the
lawY,:r, a: to a pleil to be ent~rcd, whether to waive JUry tnClI im1Lll:'tgth~~,gnLwij(
~ tifY. ....
..
Sincerely,
Rule 1.2. scope of Representation and Allocation of Authority Between Client and Lawyer.
(a) Subject to paragraphs (c) and (d), a lawyer shall abIde by a client's deCiSion concern-Ing the
objectives of representation and, as required Rule 1.4, shall consult With the client as to the means by
whIch they are to be pursued. A la ....'Yer may take such action an behalf of the dent as IS impIJedly
authorized to carry out the representatIOf1. A lawyer shall abide by a client's deciSIon whether to settle
a matter. In a Criminal case, the lawyer shaJl abide by the client's deCiSion, after consultation WIth the
la'.wer, as to a plea to be entered, whether to waive JUry tnal and \'\r'hetl,er the client will testify.
(b) A lawyer's representation of a client, includeng representation by appoentment, does not
constitute an endorsement of the client's political, economIC. social or moral views or actiVities .
(c) A 12 ....f).'er may hmlt the scope of the representation If the limitatIon IS reasonable under the
mstances and the client gives informed consent.
'';.'r (d) A lawyer shall not counsel a chent to engage, or assist a client, In conduct that the lawyer
knows is cnmrnal or fraudulent, but a lawyer may diSCUSS the legal consequences of any proposed
course of conduct with a chent and may counselor assist a client to make a good faith effort to
determine tile validity. scope, meaning or application of the law.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin(rohotmarl.com
Fl;lther, thIS grievance seeks to ha'le an Investigation undertaken to deterunme whether the
Circumstances detailed en the June 7th, 2012 email by Coughlin to davldc@nvbar.org, and the WCOA,
wherem a tattery via a ht cigarette projected at Coughlin at close range by Cory Goble was the
subject of a ;Jrant of Immunity by the WCDA, desolte the extent to which such conduct IS II1e9al and
reasonable calculated to dissuade Coughlin from testlYHlg In RCR2011-063341. Further iOqUiry IS
requested as to the permiSSIbIlity of WCPD Jim Leslie refUSing to even bnng up the subject on cross
examinatIon of Gohle, ZClrate or Duralde In that matter,
file f I '11: 11 ... :1.0NEW%2otemp'9%208%2012%2()grle\'a"'(!",:!:l1;ga,,.,~t%20J'm~o20L('SI'~%1Oto%20complalm@n"biI, .or-g.htm{ 12/3/1t112 2 40 29
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MEiSi'l~
P~",nt.
CiD<:.e
wcso Deputy Machem's "personally served" Affidavit of

11/1/2011
;,qr;" Zach Coughlin (zachcoughlln@hotmail.com)
s~,,:, Mon 2/06/12 2:57 AM
r" Istuchell@washoecounty.usi mkandaras@da.washoecounty.us; nvrenopd@coplogic.comj
rsilva@washoecounty.us; kadIICJ@reno.gov; fourthestate@gmail.com;
jamesandreboles@msn.com
_,""ILcw,-,,:e,eCQvr ty,'c, 'CUr e Jr 0,"lii....,astv:OCQ,""",""S

Dear IA Supervisor Stuchell and DDA Kandaras.
( realize you \vil1likely not read all of this. The main thing is I am respectfully
rcqllc~ting that you confiml with Deputy Machem that he d1d, 111 fact. "personally
serve" the Summary E\ ictioll Order on me at 121 River Rock St . Reno R9501 on
November 1.2011 at 4:30 pm, in connection with perfonnlllg the lockout. It is my
positlOn that I was not "personally served" and I am trying to figure out whether Deputy
Machcm is lying or Vi. hether the phrase "personally served" means something other than
what I believe it means, etc., etc I appreciate your attention to this.
I am "riting to inquire about and complaJ11 w1th regard to an Affidavit of Service filed
by or for \VCSO Deputy Machem with respect to the senace of a Order Granting
mary Eviction again!-.t me (m my law office ",here non-payment of rent wa~ not
CU, no less In violation of NRS 40.253 and whcre a 52,275 rent escrow deposIt was
oi'stcd upon me 111 violatlOn of 40.253(6), especially where a stay of eviction was not
granted evcn whlle thc RJC beld on to most all my money ... ).
My issue with the WCSO is thal Machem's Aftida\ 11 of Service indicates that he
"personally sened" me, which kmd of reminds me of all that robo-sIgning and MERS
fraud I come across In my day job (and do you \",onder how many attorneys in thc
foreclosure dcfense game I am 111 constant contact wIth who arc watchmg and ""itness
the potential RICO nolations this writing mcntlOns"), wh1ch includes being a
foreclosure defense attorney So \",111ch is. 1t"? [)1l~ Macbem "personally serve" me the
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Sumn1ary Eviction Order? RIchard G. Hill. Esq. hkes to ~rgue that I was "served" in
compliancc with all time related rules because it was done in the "usual custom and
practice of the \VCSO. What. exactly. is the "usual custom and practice of the WCSO'?
I hear a lot about thls "within 24 hours!! stuff. So. I go hunting for some black letter
law to support what those at the RJe and in the clueless community at large (which
often mcludes Nevada Legal Servlces and \\lashoc Legal SerVICC1-., the pcople you guys
had such trouble actually serving in the lawsuits I filed, Wh1Ch may have actually hclpcd
improved legal services in this community. if they were 110t disl111sscd due to
insufficiency of service of process. even where the IFP reqUIred the WCSO to served
the defendants .... ). Anyway. back to the "within 24 hours" phraseology: 'I
This whole business about "The court may thereupon issue an order directing thc sheTlCf
or constable oCthe count} to remove the tenant \\1Ih1O 24 hours after receipt oCthe
order ... " is inapplicable to this situation, where an Order Granting Summary EV1ction
was signed by October 27th , 2011. That language 1S only found in situations
inapplicable to the current one. NRS 40."53(3)(h)(2), and NRS 40."53(5)(a) arc the
only sections ofNRS 40 where this "withm 24 hour,," language occurs. anu those
situations only apply where, in:
40.253(3)(b)(2): -< 3. A notice served pursuant to subsection lor 2 m\l~t: .. (b) Advise
the tenant; .... (2) That iflhe court detennines that the tenant i1-. guilty of an unlmvfu(
detamer, the court may issue a sllmmary order for removal of the tenant or an order
providing for the nonadmittallcC of the tenant, directmg the sheriff or constable of the
county to remove the tenant within 24 hours after receipt of the order"
and,
(a) The landlord or the
40.253(5)(a): "5. Upon noncompliance with the notice:
landlord's agent may apply by affidavit of complaint for CVIctlOn to the Justicc court of
the township in which the dwclhng, apartment, mobile home or commercIal premIses
are located or to the district COlIrt of the coullty in WlllCh the dwellmg, apartment,
mobile home or commercial premises arc located, whichever has jurisdIction over the
matter. The court may thereupon issue an order directing the sheriff or constable oCthe
county to remove the tenant within 24 hours after receipt of tile order." The way these
~ummary eviction proceedings are being calTied out In Reno JUSt1CC Court presently
shocks the conscience and violates Nevada law. There i!-. not baMs for effectuating a
lockout the way V\,TCSO'S Deputy Machem did in this case. The above two scctions
containmg the "Within 24 hours of receipt" language arc H1,apphcahlc. as tbose situations
dD not invoke the present circumstances. where the Tenant did file an Affidavit and did
contest this matter to a degree not often seen. To requirc Ne\ ada'!'. tcnant1-. to get lip and
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get out "wIthin 24 hours" of "rcCClpt of the order" (what ~ocs that even mean? The lISC
oftcnns like "rendition". "rendered", "notice ofentr)''', "pronounced", is absent here,
and this "receipt of the order"' language is something rarely found elsewhere in Nevada
law-see attached DMV statutory citations, and in employment law litigations \\ here one
must file a Complaint within 90 days of"reccipt" of a Right To Sue Letter, a situation
which follows NRCP 5(b). and NRCP 6(0) in imputing receipt of such a leller. when
actual receipt is not shown, by applying a "constmctlvc noticc" standard that relics
upon the days for mailing extension of time for Items served in the mailing, etc) In
Abraham \ .. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009). the
record did not reflect when the plaintiff received hIS right-to-sue letter. The letter was
.,ued on November 24, 2006. The cuurt calculated that the 90-day penod commenced
~~ovember 30, 2006, based on three days for mailing after excluding Saturdays and
Slmdays. In order to bnng a claim under either Title VII or the ADA. a plaintIff must
exhaust admInistrative remedies and sue within 90 days of receipt ofa right to sue
lettcr See 42 U.S.C ~ 2000e-5(1)(1). See Baldwin County Welcome Center v. Brown.
466 U.S. 147. I4~ n. L 104 S.Ct. 1723, 80 L.Ed.2d 196 (l9R4)(granting plamtiff an
additional thn:c day!o. for mailing pur!o.uant to Rule 6).
Further, despIte what the inaccurate handouts of Nevada Legal Services may say about
this "24 hours" and the applicability ufthe JCRCP to cases like these, NRS 40.400
Rules of practice, holds thai ;"The provisions of:NRS, Nevada Rules of Civil
Procedure and Nevada Rules of Appellate Procedure relatIve to civil actions. appeals
and ne\.\ trials, so far as they are not incon:-.istcnt with the proVIsions of NRS 40.220 to
40420. inclusive, apply to the proceedings mentioned in those sectIons. As such NRCP
6(a),(c) applies to the Order of Sum maT) Eviction that we SO Ucputy Machern alleged,
under penalty ofpcIjury, that he "personally sen-cd" upon me on November l, 2011.
That is a he by Mr. Machem. unless "personally served" IS defined in a rather
~rsonal way and or Machcl11 and I have totally difTcrcllt understanding of the
~lition of "personally sen:cd", which may be the case. Or, perhaps the Sheriffs
Office is busy and doesn't w3nt to \\ all around to "personally serve" every tenant it
wishe~ to evict. Fine. then Just use the "mail it and allow three days" rule in NRCP
6(e). the landlord's might not hke it. but they can usc that fru~tratlOn as an incentive not
to Jump to litigating every di~agrcemcnt about habitability that a tenant brings to them.
You may nol rcaliLe ho\', ridiculous some landlord's get. In my case, I alTered to fix
basic thll1gs that clearly Implicated the habitability mles m NRS 118A.290 and the
Californian neurosurgeon. Bc\crly Ifill High School graduate landlord balked and
complained then hired and attorney tour days II1to a di~rute ... at which point the nJlcs
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against contacting rcpresen~ed parties prevented much in the way of real settlement
diSCUSSIOn, particularly where opposing counsel has contmuously demonstrated a
complete indifference to pursuing settlement (why would he at the rate~ he bills hours
at?) I just don't think the Shenffs Office needs to sully its image or damage the
citizen tenants of Washoe County in the name of pleasing people like Dr. Matt Mcrliss
or Richard G. Hill, Esq.
I AM REQUESTING, IN WRITING, THAT BOTH OF YOUR OFFICES
INVESTIGATE THIS AND PROVIDE A SWORN AFFIDAVIT FROM MR.
MACHEM THAT ADMITS THAT I WAS NOT PERSONALL Y PRESENT WHEN
HE SERVeD THE ORDER FOR SUMMARY EVICTION IN RJC RfeV2011-001708
ON 1111112 AT 4:30 PM (ACCORDING TO HIS AFFIDAVIT OF SERVICE). YOU
NEVER KNOW, I MIGHT HAVE IRREFUTABLE PROOF THAT 1 WAS
SOMEWHERE ELSE AT THAT TIME, SO. BE CAREFUL There Simply IS not
anythmg specific in Nevada law addressmg how such Summary EVictIOn Orders arc to
be served and carried out. The sections dealing with
NRS 40.253 Unlawful detainer. Supplemental remedy of summary eVICtion and
exclusion of len ant for default in payment of rent ...
6. Upon the filing by the tenant of the affidaVIt pcnnitted in subsection 3,
regardless of the infonnatiOIl contained in the affidavit and the tiling by the landlord of
the affidavit pcmlitted by !;ubscction 5, the Justice court or the district court shall hold a
hearing. after service of notice of the hearing upon the parties, to determine the
truthfulness and sufficiency of any affidavit or notice provided for in this section....lf.the.
court detennjnes that there is no legal defense as to the alleged unlawful detainer and
the tenant is gllllty oran uulay.rul detainer the CQurt may Issue a summar:)' order: for
remo"al of the tenant or an order P[Q\ idiog for the nonadmlttam:e: of the tenant. ...
7. The tenant may. upon payment ofthl' appropnate fces relatmg 10 the filing and
service of a motion, file a motion with the court, on a fonn provided by the c1crk of the
court, to dispute the amount of the cost,.\o, if any, clanncd by the landlord pursuant to
NRS II8A.460 or 11 RC230 for the inventory. moving and storage of per"onal property
left on the premIses. The motIon must be filed within 20 days after the !o.ummary order
for remuval of the tenant or the abandonment of the prembes by the tenant or withm 20
days after:
(al The tenant has vacated or been removed from the premises: and
(b) A COP) of those charges has been requested by or proVIded to the tenant.
E whichever is later.
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8. lIpan the filing of a motion pursuant to subsection 7. the court shall schedule
hearing on the motion The hearing mllst be held within 10 days after the filing
of the motion The court shall affix the date of the hearing to the motion and order
a copy served upon the landlord hy the sheriff constable or other process server.
At the hearing. the court may:

(a) Detetmine the costs. If any. claimed by the landlord pursuant to NRS 11 RA.460
or 1 IRe .230 and any accumulating daily custs; and
(b) On.Jcr the release ufthe tenant's property upon the payment of the charges
detcnnined to be due Of ifno charges arc determined to be due II
,A.<;o want to know why NRS 40.253(8) \\'as not followed with respect to my
.;,ember 17th. 2011 filIng ofa rvtotton to Contest Personal Property Lien. Why didn't
the WCSO serve notice. as required by NRS 40.253(R) upon the landlord's attorney
Richard Hill? Why didn't I get a hearing within the 10 days called called for by that
section (to get back my client':, files no less)., hut rather, 1 had to wait a full 33 days to
get a hearing, and service of notice of the hearing was not effectuated, as reqUired by
NRS 40.235(R). by the WCSO. Why"
Please provide an mdication. in writing. of the names and ca.;;e numbers for the last 20
mcidences when the \VCSO has served notice of a hearing set pur~uant to NRS
40.253(S). What's that" The WCSO ha, NEVER sc,,'cd such notIce'! Yet thc WCSO
i ... !ht:TC with bells on (or Machem IS) to he in Ailidavib of Service to lock out the
citizen tenants of Washoe County lmpenmssilby early vis a vis NRCP 5(b)(2) and
~RCP 6(e)? \\lhy 15 that? Is it a conspiracy" Does money talk? When J was arrested
for rrcspac;;sing on November 12th. 2011 by RPD Officer Chris Carter and Sargent
Lopez. Carter admitted to me that "RIchard Hill pays hun a lot of money and therefore
. rrests v. hom Richard Hill says tu and does \\hat Richard Hill say~ to do .... " Both
~-o
er and Sargent LOpCL refused to mvc.;;tigate, despite prompting. ""hethcr Richard
ifl has sent the tenant/arrestee a biB or demand letter an bill for the full rental value of
the property. 5900 per month. under some mterpretation of the "reasonable storage,
moving, and Illventorymg expenses" collectable by a landlord under a personal property
Itnc sct forth in NRS 118A.460 (one could also interpret such a bill as Hill's
withdrawing or eradicating the Order of Summary Eviction it:,elf. wInch was not
"personally scn cd" by the \\'a<;hoc County Sheriff (despite what their Affida"it of
Service says . .I wasn't even there at the t1lnc they changed the locks .. and so the
Sutnmary EvictlOn Order \\ as not properly scrved under NRCP 6. and despite the Reno
Justice Court impermissibly converting S2:\00 of my money undcr a "rent escrow"
Messa~
Order its required l comply with in order to htigate habitabtllty Issues 111 a summary
eviction proceeding under NRS 40.253, dcspite NRS 40.253(6)'s express dicate against
such an Order (unless, pursuant to JCRCP R3. a justice court gets such a mle. like
Justice Court Rule of Las Vegas (JCRLV) Rule 44. published and approved by the
Nevada Supreme Court. which the RJC has not. rather, the RJC applIes all these
inSIdious secret "house rules" (like forcing tenants to deliver themselves to the filtng
office to submit to personal service notice of a summary eviction hearing withm. like.
12 hours of the Tenant filing a Tenant's Answer or Affidavit in response to an eviction
Noti.ce, rather than the service requirements of such notice following NRCP 6 (days for
mailing. etc .. etc., in other words, III the RJC everything is sped lip imperissllby to help
landlord's out, and the NY. S. Ct rulmg in Glazier and Lippi~ clearly contemplate
pcrsonalliabihty against the Court and or Judges themselves for so domg) .... A Qui Tam
action or something a la Mausert'1:! in Solano County, I believe. in CalifornIa, would be
very mtercsting ... Still haven't heard anything from the Reno PD about the vanous
complaints I ha\'c filed \vith them 111 wnting related to the wrongful arrests. excessive
force and other misconduct committed agall1st me. though they did arrest me tbe other
day for calling 91 linci..ient to some domestic \iolence for whieh I was granted to
Extended Protection Order'!) against my fonner housemates .... old Sargent Sigfree
ordered that arrest. as he did two days prior when he ordered a custodial arrest of me for
"jaywalking".
Funny thing, I never heard anythmg hack from the RPD ahout cnmplamts like the
following one:
From:NvRenoPdrgcopiogic.eom
Sent' Wed 9107111 10:51 PM
To. zachcoughlin~~hotmail.com
'**'00 NOT RESPOND TO THIS E-MAIL
",
file Ii fRl/t
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AM]
W c're sorry the following problem"" as found during reviey.

of your submittcd report TIl 005956:
THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS
REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR
AND IT WILL BE ADDRESSED.
Thank you.
Officer IVOZN IAK.
file If/Rill O!o20a%20NEWOj,20temp!2~fo205%2012%20EMAJL %20TO%20KANDARAS.htm[12f3/20t2 2 40'30 AJIII]
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Reno Police Department

What is mteresting there IS that at least I was provided the name of an officer. a
"\,\'ozniak" (though 1 have been unable to confirm the existence of
slIch an RPD Officer.
or whether" THIS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT
HOWEVER THIS REPORT WAS PRINTED AND PASSED ON TO THE
OFFICER'S SUPERVISOR A:-<D IT WILL BE
ADDRESSED."
\,\-'hat is more strange is that I submitted several online police reports to the Reno PO (a
~rle of which asserted complaints against various Reno PD officers. or asked why
W'P Officer Carter. whom admitted taking bribe:, from Richard G. HilL Esq. at the
afmy custodial arrest for trespassing (the one \\here Richard Hill :-.igned a
Criminal Complaint for tre~pass. then Officer Carter and Sargent Lopez refu:-.cd to
follow up on my imploring them to ask Hill whether he has recently sent me a bill for
the "full rental \'alue" of the property. the same amount that had been charged for the
"usc and enjoyment" of the premises. $900. in comparision to what NRS 118A.460 may
deem "reasonable storage" expenses for which a lIen is a\ ail able to a landlord. though
NRS IIXA.S20 has outlawed rent distraint ... upon tenant's personal
property .. Regardless. between lanuary R - 12th. 2012. Jnd \\as arrested t\\icc by the
Reno PD shortly after subnlltting these wntten complaints to the Reno PD.
Hille
Actually. upon being relea~e from jail 011 Noyemher 15th. 2011. incident to the
custodial trespass arre:o.t. I went to Richard HIlI's otlice to get my wallet and dri\'er's
license. He refused to provide it to me until late ~o\'ember 22nd. 20 I I. Hill called the
Reno PD on the 15th (or maybe I did because he was \\ithholdlllg my ~tatc Issued rD.
~ne [ "",ould need to rent a room. drive my (.;3r. and my wallet, which i~ kind of
~tI in sllch situations .,.). Any\"ays. Sargent Tarter of the Reno PD showed up, he
\\~l1t 111side HIli's office with Hill for qUIte some tunc and the result was Tarter telling
me to leaye. I did. but while dnvlng down St. Laurence towards S. Virgmia (Hill's
office loS at 652 Forrest S1. 89503 and would have required tul11ing down the wrong \vay
of a one way street. Forrest. to go back to HIli's Office (so dearly 1 was not headed to
Hill's office) Sargent Tarter began tailing me. then he pulled me over. then he gave me
a ticket. in retaliation if you ask me for reporting RPD Officer Carter admittIng that he
takes bribes from HIli to Sargent Tarter mmutes earlier. Vh. well, any\\ays. another
Sargent calls me later that night. taking the "good cop" role. But upon mfonning him of
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what RPO Officer Carter told me a~out HIli paymg him money to arrest people during
the 11112/11 trespassmg arrest, that Sargent immedIately informed me that, despite this
being the first he heard of that. he was sure that was not happening .. .I gue~~ RPD
Officer Carter b trying to explain away his comments about Richard Hill paying him
money to arrest people by dismissmg them as sarcasm, a joke, said in jest,
whatever.. .. but I donlt see how that situation (a lIcense attorney gettIng arrested for a
crime, a cOllviction for which would result III that attorney bemg reql11red (0 repurt Said
conviction to the State Bar of Nevada under SCR 111, etc" and possibly resulting in a
suspension of that attorneyls license to practice law. or worse .. ) is all that jocular ofa
situation. Combine that with the too quick to dismiss my reports of brihery by Richard
Hill to officer Carter to the RPD Sargent who called me on 11/15; II regarding the
retaliation by Sargent Tarter that I complained of. and I don't think it i!-. all that
unreasonable for anyone to take RPD Officer Carter at hiS word regarding Richard G.
Hill, Esq. paying h1ln money to arrcst whom Hill says to arrcst. Add to that Sargent
Sigfree ordering my arrest for jaY""alking (by a trainee RP[) Officer) on January 12th.
2011 (custodIal arrest. bail of$160 emptied my bank account out. or pretty close to It)
while 1 \\'35 peacefully filming from a public spot Richard G I hll. Esq'~ contractor Phil
Hm\ ard. whom had submitted bills In courts records and fillllgs under the lien for
"reasonable storage moving and inventorying" found in NRS II RA.460. even where old
Phil used my own plywood at the property to board up the back porch (curiously
leaving the screws holding up the plywood exposed to exterior of the property where
anyone could easily unscrew them. and also leaving 111 a windmv umt ac secured only
by ducttape in a window facing a side\\alk by the LakeMill Lodge ... \vhlch resulted in
$8.000 at least afmy personal property being burglarized from my former home law
office on Dccmeber 12th. 201 I while Hill was assel1ing a lien on all my personal
property found therein (and my client's files. which arguably arc not even my property,
but rather, the client's property). Hill \vent on to place 'What he believe"! to be my social
security number III C01llt records, 011 purpose. despIte his Signing an Allirmation
pursuant to NRS 2398.030 that that was not the case (attaching a two page report to the
RPD a~ an Exhibit) Then Hill and his contractor Phil Howard both cot11ITIltted perjury
when the si!,'TIed Declarations atte:-.ting that I had climbed on the contractors truck or
ever touched Hill. Hill lies constantly. whether under penalty of perjury or nO\\.:-.o I
don't have time to rebut every little lie he makes (he makes me out to comes across a:, a
Yosemite Sam cancature of a human being in his filings when he dcscnbcs mc ... ).
Further. "hy am I arrested for trespassing and not those from NC\'ada Court Services
where they went behind c1o:,ed gate the the backyard of my home la\\, office and hanged
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on wmdov. extremely loudly tor 40, nllllUtcs at a time 3 times a day. one guy ringing the
doorbell. one guy moving around all other sides of the property banging on the
windows. peering In closed blinds. and affecting a phony "color of law" tone.
reselnblance. and verbal commuTII(:ations. misleadingly announcing that they were
"Court Services. come out now~". wearing their pretend Sheriff outfits. big eqUIpment
saddled belts (including fireanns, I behc\e, and radios). etc. ,etc.
L1t.i.p~~_,;. ~. .'.. I,,:.:'0... ~'LQ\ Ll'.lb. .~... .I.:..\..\ilL~:.i1.\..dL~ . --:J Q l_~2..q2l.lJXL
Add to that that Nevada Court Services Jeff Chandler drives hy in his Monster Tmck
baring hh. personalized "NeS" license plate while I am in the RPD squad car,
..AIdcutTed. outside my fanner law office at 121 River Rock. at the time of the 1/12/12
.!walking arrc~t and the appearances arc troubling. Nm\, add to that that Le\\. Taitcl,
Esq . \\'3S my court appOInted public defender in the Reno MUnicipal Court in the
trespass case~ and that Judge Gardner had refused to provide me the names of
prospective appointed defense counsel (I wanted to run a conflicts check) at my
arraignment (where Marshal Mentzel barked at me in a threatening tone. lIsing.
menacing language), whereupon Taitel was appointed as my defense attomey and filed
a notice of appearance. and received my confidential file. pc sheet. arrest reports, ssn.
ctc ..... only its turns out that Taitcl shares and office and a receptionist wnh Nevada
Court Services and they list him and IllS picture on their website as "associated with"
their Process Server corporation. despIte the prohibitlon lawyers face against fcc
sharing \\ ith non-Ia\\)'ers . Then. Taitel somchow manages to get out of dcfcnd1l1g my
case \.\'ithout filing a Motion to \Vithdraw as Counsel. despite that being required by the
Reno Municipal Court Rule 3(8):
RMCR Rule 3(8): Authorization to Represent iB): An attorney desiring to withdraw
from a case shall file a motion ""iih the couT1 and serve the City Attorney with the
~e . The court may mle on the motion or set a hcanm!.
~~: perhaps m05t trouhling of alliS thc ImpLicatIOn that the Reno CIty Attorney's
Office, which defends actiont. against the City of Reno Police Department and its
Officers. has a vested interest in discrediting me in ad\ance of the wrongful arrest
la\\ suit that the Reno City Attorney's office knew was Imminent at the time of all of the
above incidents, relating to the follo""ing August 20th. 20 II \. . rongful arrest by RPD
OITicc.:r's Duralde am.I Ro:,a. !1l'P . }\\'=-\~ ... )'\nltub':,~\)I>\".{l(,hc,'\ ......~P. R~. L~4Ut:hl,' So.
that's what attempting to coerce a suspect's consent to an impermissible search sounds
like? Add to that that the trespassing: case is before Judge Gardner, \vhom most
recently was employed with the Reno City Attorney's Office
file Ii fRIll G"'20<l%20NfW"'~2Dtemp!2%206%20 l2 20EMAiL %20TD...o20KAND.IIRAS.htm[12/3!2012 2 'U]O AM]
OutIllOk Pnnt Message
And. you know what is funny? Officer Del VecchIO cuffed me and placed me in hiS
squad car last summer after he terrified me and another gentleman who had bicycles.
He veered across the road and screeched his squad car to a halt, jumped out. and dId
some other stuff. then demanded my name and ID ... and the lawyer in me didn't like that
that much, and he didn't like me not wanting to give it to him . ThiS occurred right 111
front of my home law office in the summer of2011. He eutTed me and told me 1 was
gomg to jail for something about 3 light on the fron[ of my bicycle (the one NV Energy
ltkely stole when the shut otT my power. unnoticed. on Octobcr 4, 201 I) despite my
bIke actually hav1I1g such a light .... but then Del Vecchio':., partner did him a solid and
talked some sense 1I1to him. and I humbled it up for Del VecchIO and \\C both let it go.
and I didn't go to jatl.. .. Until Del Vecchio was present supervismg ~omc Officer's
traimng at the scene of my custodial (9 hour) jaywalkmg arrest) on 1/12/12. Blit Del
Vecchio. I guess either didn't want to or wasn't able to talk some sense into Sargent
Sigfree ..... and then Sargent Slg!'ree Ithe spelling is likely off) had me arrested and
charged with a gros~ mIsdemeanor. "Misuse of 911" ju~t two days later. on January
14th, 2011 when I called 911 to report that my roommates were laughing menacingly
when I asked them why my dog was missmg (I had also been cha~ed up to my room
numerous times since moving in with these people. sometbmg I had to do because so
much of my money had been taken up with bailor lost earnings due to all thcse
wrongful arrests and abllse of processes menttoned above ... also these housernates had
chascd me with a ten inch butcher knife, two of my tires were slashed, 1 was locked out
all night on New Years Even when these changed the locks at around l111dmght, had my
furnnure thro~:n in the street, property stolen. coffee thrown on me. de~troying my
smart phone In the process, etc., ctc ..... And despite the housemate having an outstanding
arrest warrant, and animal abuse bcmg listed amongst the clements of domestic
violence, Sargent Sigfrce told mc he was 3rrcst1l1g me because I "keep putting yourself
in these situations". like. where I am a victim. and that he was "trying to help yOll". he
said with a smirk and a laugh to his fellow RPD Officers, whom then proceeded to lI~e
excessive force against me. I guess he was helping me by !)addling me with a gross
misdemeanor with a $1,500 bail, especially where its bcen arranged for Court Services.
or prc-Tnal Services to foreycr deny me an OR. despite my meeting the factors for ..:;uch
set forth In statute (30 year resident. entire Immediatc family lives here. licensed to
practice law III Nevada. etc., etc) . ..I guess 11 should not be too much of a surpriSC to me
that Reno City Attorney Pam Rohcns failed to address the perjury of all three of her
witne~ses or that her fellow Reno Cay Attorney Chri~torher Hazlett-Steyclls lied to me
file IIIRI/1%20a%20NEW%2otemp/2%206%2012%20EMl\Jl%20TO%20KANDARAS.htm[12/3/20l2 2 40 30 AM]
CM\ook Pont
~ge
about \\hcthcT or not the Reno City Attomcy's Office even had any documentation
rclat~d to my arrest or \",,'hethcr it would in the month before my arraigl1In~nt, despite
that fact that subsequent productions of discovery tend to indicate that the Reno City
Attorney's Office did have those matenals at the time. I could be wrong about some of
this .. But that would requirc and awful lot of coincidences.
Washoe County Sherifrs Office

911 Parr 8hd., Rno. NV 895\2.
..
Mugshot Profile
aM.!.:ltfLlfl, ZACt1AIt,.
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Sincerely.
1kI.w.1"1I II'
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.~L ROLLINGSWOP"l'H RPD
POLICE CETIC'EF
On J::I'lIMry , <' "e12 at approl(l,"ately :SJ 1 ~lr9 I (W ce."! LE::::r-!

In '~f~renc' to ol po~<;rb!~ flgh: ~hal /'lad JJst occurrro
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WITNESS 1: HILL,RICHARD
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Olf:c(" HOt UNGSWORTH WM, ~trp.ndy 01\ ~ne ~J:le.ak.ll1g With the 1~'Jfll .... ed ri1'I'~ Wf'
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He 'S ,in ..tlOUlt:y n:,prcsent,nglhe pCQperty O'Wner o~ 121 RWef Rock:31 COVGHUN_ 7ach",,!/, W~~ a h.
."'I1CI
ICf',arnt of tt'le propl"lly W>10 I'",a tJoeoell e",'c1ef1 January 1 t'011 Hii' oki'l'S loun:1 aVlnq n";),fr b..:s':'emell 01 (h~
re.,ldellC'_' on No... elTlber ;3 ?011 HB wa,; dltcslL'{! for tre--..p,1!;.S>f"'9 011 !hJt i1!=1tf' HTll <1,',1 C~)l},"HL;"'" :lave tx:-e0'"\
,rwr.>I~f'd ,n l('g<11 p'oceed,"1S PVf\'" 5Inr.~ On the ualQ' O' January I~ ;;>0:( (;(lIIGI-IUN ~,:' ...vd ~Ilhc 121 f~.v.'
T?e<:k <'Ir:ldraso;. ;;uld bega'"l hara;:'S'119 the ct)ntrar.tcr ~<S ell'lplo,r+:.'Cs ....I'orr. ..... "1; f'!"lHWlnll r:ro~;('I~y <'Onl lile
losldct1cc COlJGI-1UN beci!lr:le up~('! as some Of the nru~rty hF.-1'lg l~mO\l!Xl, was lett I" tt-e reSIOE''lCe by t-If"'l
COUGI-'I iN WiK ~cr~am,!'JQ ond <n1erfenng w':th tt'e c~trdClor Md emplo'r-ees D'le to me {':1'i.1IJrbancf'
~()UG,'fU~~ W9S c:-ea:,ng HILI ra'lpd j:'<..'lICC
HILL ~!)1l'n f~fll"'" reslcenc.p
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m1rr'1~l;>t..:.jy tp~rn"'t:! that no flgh! hem occ.:urred ~nd ~ W1I'i );1",;::), ,I ... erbal a1tO::"CilllCfl OHIC('r HO\IINf",:-;o/vnq rtl
was Spi:"::J~'NJ wlll1 !"f' f~,.:)!~'('lg p:!r!v Hill ~'r:t",.11(1 !-if> <;!~tf.'f1 kJ '1'.:' and n a s:a!cr.cnl
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LAW ENFORCEMENT PERSONNEL 2, ;TRAVIS LOOK RPD
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-LAW ENFORCEMENT PERSONNEL l' WESLEY LEEDY RPD

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WITNESS 2: STEWART.PHIL
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$OCnu. SI!!COP.ITY NUMBEfl
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ORIC
'12-808
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OnR).TCR L'ICElfSE
lNOtvtDQJU.
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12-808
Arrest Report
POLICE
Nt:.'IMlil
\'\'1"'0 ':In 3C-nE' I SP(l~? wll~ ST~:""4R r P"',I I-Ie 'S 1"'" c.)rf.r;v-Inr """':
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RENO
--
I River
the1r work true/( aN drove It !o m@ W;Jste Managemef't Ifansfer statKJIl IlIt CQmmerclal
F'J:;..... .and Sutto SI Re'flQ NV V./t'I'lc at tTlalioCatlon, they were f1;:.gge<l cown by an ang:y COuGHLIN who st<lt~
They h;td \'lIS property ;JM he needed 10 re-claim 'l: Me WitS f,1rnlr>g the C"Itlrf' 1n\'elactIOfi STEWARi ~Mn cal\wl
FOft 1"O\.tct: lISE OftLV'
RENO POUC,- OEPARTMENT

STATEMENT
0Sf.~ _
1_;'" -
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'~!N ;'Q_~ l.?_'~!....
H!LL al'1c\ ;!'Is-ked
If COUGHLIN todd -mneve his p1'opertv COUGHt \"1 w;:lS df'nTM Whtle on S(;1l!('Jt!, RCf'O PO W3"S
(hspa1ch(>d 111 ref-fflef;to!'! Ie t~ atterG.."I:'Dn SG, BR..... DSHA.W Wi!" -Dr. s-::cne aN:! <td ....'St.'<1 <'4jl parties
V'J"-11e on S~ a\ ttJ{!- trans.fer sla;,ol\ Officers detcfn1rrW lroe al'creaTl@ to be ,,1,,11 and IJfovldoo 1'1'olmatIIYl on
l~ ,.,,,,,ue I!' each pa.'i'J The r.ppor1I"q party, COU{1H~ IN, also proveti to be ul~cooccrat"J~ thmllchoUl ofk.e-r
\nt~facl'on
Whlle I >Nil";' on 5,-~ne COUGHLIN .va,,; ",:lmlTll.>Iy conhmtat,onal wrth Hlll ~nd STEWA.RT '-It> ccn:lnued 10 !MI'I
e ')fllcP' and RP Inter;K:hofl ("tf"Ci'-f HOLUNOSWORH-\ aQY1s{.>O )"I-ll of hI!'. Op\IO"lS IT?O '1:c) <1m! ~\!I~d
.', ,'U3 ..... , IN tt~1 fl Was. pmb<lbly ~ll~1 1m 'Wll to avo;d ;'(In,III::.1 ant~ "llnybe leave the' .... 'Ela
V,(t.J'......
r:Ll then feN tho! property <Jnd CCUGH'--.IN CO("ltr'ueQ 10 stay J11 the vICinity of the P",!l":>erty aM t:fM \Ml,le
'IU'i\$ -w91\<,""l ~fO\J'l(! ('<e H'Stdfo:oce 1-.0 wQI .... Od mto a~ al::>nq the 'T:1"clc of RIVer RQc!o: $1 SiJt!lNat<s
wC'(" pfOVI~ nn both ~'r.!t"5- n! '"'!('- ~tl"f'e't
.
CCIJGI-IUN
Dlle to COUGHI 'N',; comlnl)ed rrm;w;llc;:!IO>'1 WIth poJla'!. ~a!lo" ot t.alfS fQ( SeN!ce an" h;'; prOJ-1AAslty 1'0
C'Jro.tlt'l advef~ ~h.1NtC'!" EI!t~r bel"'!g (1cM~ bV otftUY'.> eft the ~, oj .Jaru.l'y 12. 2Ot2 C:O\Jc;Hl,tN d1d nor
..te
q~!H'I~V 'Of
C;t<!tIDf'
C:CUGH\ IN was pl"'...,c,a IJnd"!f arT~t ~Qf w;lb. .-.g In tf'e roadlNay <1nd IT.,.,50C.-ted iu we Ja~ W\ttY.oui Irlo1",nt
!-I~ver, he wa::. el<1rerT'ely confrommlonal i1 n d arqUl'fle!'tabvc !rrcvgl'\out tM ;)rfesl process
While attefT1p~1ng to 'iJ<'1n ldel'llrfylng InlormatlOfi from COUGHUN d:lf'~ the a!fC!st process, he frequent1y ~
,Vgu"lt'nta"lv-e and refused to prOVIne some Inform~!,on A portlQl1 of tnlS convef51l'!tltlf1 WHlS recorded with rrry
d'!;,'l<'1' f pcordl?f ThiS; .;aud'o recor-dlrlg W~5 bUrm"d Ito a CD a"'ld bc>ol(~ 'nte QPD ev!<1pr'!':f'!
\o\'h~ an 5CP.t'le
.....,'1
N]
we a!s.o tearl'led fro'"
to Pf"vr.j.,.
CO~~
,:;T~WART
tt'-3t he wld hi'> E!fI'lP'OYeE'$ had "1f"l~ ttlt! .werst and W(.uld be
(J'IN> ."Ifr1 ~tJ RPO
No
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Th,," TPO was obtamed by HILl.
,n'::-"rr:,lltan
A fl..(l.rSre":> Ii 1\ 1Jt.lf 'A$S .:/7
N.I k......" Frf.'!; J:(I'V~W"J
:. q~/'!.>5.''n~_IJ...~._d''4(I.i''-?X.
SG 1 StFRf- \v.;rs on scene
COUGHLIN w,,~ Mrved a WO by O"":cer lOOI( wtule on ClJ<;tody ~t

aga-Inst adverse parly COUGHtr,..,.
2',4- ~ ... ~~.fi"'- ""~ a,>.~"" ., r;,r ~?tJ?"

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OlSSl!t4INArtO:It Rf'!:TRICTLO TO au~NAlJUSll<.-" AGUfUUIJHl'
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Tel 775
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Fax Q49 667 7402
6 26 12 warning to WCSo rpd. etc. Reno eviction noticed for Sparks
lachCoughllll(q'hott'l1ail com
Justice Court
Dear Spark" Ju~tlce Court.
:1 7#8Ch Coughlin (,>'acheIJtlg:hlln(~1 hOlmatl com)
:-:~,.;
\\ed 7/~':-'1:!4(l<)P\t
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k<ldhClrll, reno gO\: 7young(a da \\ d~hoe-count~ .us. mkalldara,~(a du wilshocc(lu11ly Il~. haz1ett-
.,
~tc\'en~~"'-~'TC'110
I called and reee'\Vcd penmSSlOll III tile IIlIS by fax .. l.tm mdigent and rcque~r " fcc w.mer. and f:Hltng Ihal. an
opportUlllty !U cure any filing fcc (kficlency
gO\'
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From . ....achcou~hhll(li,.,hntmal1 com

Tn ~hcrlff\\cb'-,iwa~hoe..:ounly us: btllchdl(,! washlll',olmty tIS. btancll(l!'w,\\hoc(\lunly liS:
chansen(u- \,a~hoenl\lmy U~. mJmCrrl~1 rcno gnv
Sublect -Reno C\ Jctton non(ed for Spark~ JustJCC Court
Date. Tut.'. 26 Jun 2012 07.58 36 ~OiOO
"
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D<:aJ
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J matt,'1
I ~ptlke \\ll\t ,\ Rcnu Poh..:c Department WillI Identtlk'd tllm,\elfa~ 5mgcnt Miller lu\t \\cek and he mdll',lled thl.!
\\'C50 planrlt!'d 10 mille cfft!'ctuale all CVl(:!lon on tIm datc. hlnl' 26. 2012 A r hdh!\C Ih,1I \Hluld hc: rlcmaturc a:.
Nc\ada Landlord T cmUlt la\\ prm Ide!> for filiIlg a Tenanl':. Ans\\cr or Affid;l\ 11 b~ Il(l.m afler thc fifth lull da~
fJulhclal da~s) and rnda~;, In Sparks Ju;,th:e Court arc 1101 futl lim ~ tnlhal ;.cn"c. alltllt'garllle;,~. Spar\.." JU;.tICt!'
Coun. I hdll'H'. J\ not th .. appropnatc lanm] \\h~rc.:l~ hcre. thc sllll~ I~ Inemcd In Rl.'1Hl/\\',lrd I-nap")
FJ'I( lJ-IlJ flfo7 '40.:!

.laL:hCollghlm!(1 hOlmail..:tllll
Court
Glvcn ~parks ]USI!Ct: (oun JS open 5 day!> a \\eck (c1ol>c~ at nooll on Fnda~! and Ro:nn JI\;.llCC Coun ha~ 4
jlldlclal da}!> a wed. the dcadhne for filing a special appcarance (to eOn!l'st Jlln . . dlltmnl ami ur u 1 ena]J!'!> "\nq\er
of Allidavlt IS dllTkult to mea~IlTl;
~Q505
7'75.1~R ~J
Ju~tlee
Am [llll~!J.ken 1Il \.'ICWlll~ thl:> m"n~r to he oUhide the lun~dkllO\l of the Spmk, IU~IICt' COllrt, ,md ralher.
to he h'llldled ill RC\ll! lustlce COUrI"
31)f>(
Rcno :'\ ,.
Jumce Court. WCSO, RPD alld Rt'1111
I have received (though not personally ~en'cd) whal appeaf\ to be an ('\ 1(11011 ntlll,'(' (5 da) Iln Ia"" rut d('l,lIner"]
for r('ntal~ ]o..:aJeJ :\1 loSO Sky ~1olln1a1ll On\'c. Reno, X<J5.:!J.lml tit(' llO!ICe mdl(,l!":~ Ibat I mll~1 Iilc a T('nalll'"
An:;\\cr wIth thl' Sparb JIJ~tice Coul1
Z.lCh Coughlin
ro sox
Spar\..~
....a..:hc.lugllllnra hlllmdil Cilln
Smcl'rel~.
~;:IO"cnl<,! ..... a"hocCtlUnl~ U~
Suhl..:'~1 Heno oL:\.-IClj(111110Iu:'cd lor Sp:Hk\ JustICe (lun

Dale Tilt!. 26Jun ':!Ol~nl) 10 1.J~n7nn
ZJch Cou!!hlm
PO BOX J%I
Reno \;\" !!9:<,05
tel 77~ )JM MIll'
ra ....)"q (,(,7 7401
Dcar CIvil SureI' I\or lIan!;cn

1_.lch ("coughhn
PO BOX 391> I
R.!n(l. , \ klf50;
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Outlook Pro'"
n""L)L)k p"", \.1~"3g"
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subpoena duces tecum for any written notice or any other sort of notice
Civil Division
:,\ 1
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fl30 Greenbrae Orne

Sparks, Ncvada S9";31
(775)3:;17(,03 Ph('Ile
j775)35::! }004 rax
Cl\ 11 D..:panmcm StlpCf\ l">Of
Chris Ilan~cJ1
i(i;~
,y,'ll'\~~;!'_.l'I':'_l.,
'IVI!.\ Dl\I:-'lon ofSpark.~ IU:o.tlcc Court l;-. mdde up (lfthrc<:: nl,qm fUm.llon;..
,.
11 Comphullb fOf damages 111 eXCCS::' of ~5000 or If a Sllli 111\ oh c;. a hreach of cOlltract. pumtl\c damages. an
3ltlon to ohWIIl po,<,~cs"lnn of property. J 'Hit\. of resllhltl{lll. or ('lher hhc aCllnn.<.. \cg:alcolIl\;',d I!!- !!-tlgges.ted for
1\
Ihese Iypes 11f 'Ktlons

[, ictioD'i
An aClllr procc~,<.
legally dl~posscs;"lng a person of land nr rClllal property
or
Zach C(lu~hlin (za;::hcoul-lhlm(ghotmall.com)

Muo LO 19112 2'56 A~
Itlhhals(i:1 wa~hoeeounty us; 19ra~((! \\ ilsho~cOllm~ us.
bd('lgan(~t\\ <l;,ho~county
liS
thai your office purport~ to have provided me for the August 6th, 2012 "combo hearing" m rcr2012065630 and rcr20 I 2~06 79RO you had no problem fax1l1 me o;omethign slIl11lar on or around August
23rd. so. 11 ~hould be no problem producmg any purported written notice (aLong \\ ith an attestatIOn
that such \'<as. actually ~ent to me "1'<1 any 111edium at all. \\ bieh ,,"ould be cuntrary to M5 Gray's
prevIOus IIldlCilIICJnS)
A
Sincerely,
A
this is a supboena for my Nov 14th. 2012 heanng III SAN v Coughlin
0434 ..please compty or be preparcO to e:<..phl1n yourself at the heanng
T1g12~0205. ng12~04J5
and
Sm.n Ciaim1i
'\n aCllIln filed in order to obtain a mon~tal!' Judgment A ('[ann:. mU~1 not exceed $5000. A ,<.mall claim:. aetlOll
llla~ he likd \.\-Ith Ihe SparJ...~ JlI:.lIC": Court IfOIlC of the follo\\l11g ~rphe~ to the defendant
I. They re~lde \\rthln the boundan('~ orthe "park,,> Tov.m.hlp.

2. They arc cmpluycu wtlhmlhc houm]drlc,<, of the Sp.nk:. TU\\l1:.hlr .\IId,or,
J_ They do hu~me~;. \\lIltm the bOlmd,mc!> ll{tlll: Sp,lrh T(mn;.hlp
Zach Coughhn
1471 E 91h SI
Reno. '\;\. 895 12
Tel and
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Q.\9 1:>(,7
'40~
ZachCough hn(ivholtnall colli
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o. ~f\\~f 11' " ,:(1::'- 0:11] :",:1<\ "\IL ",,~OH '". :0\ rol
'\c;' .)n \ '\ I!" ,,~I)rl Till'; :(,' '\ If' "~fJ'" '\ "[l-\It \S run, I::' ~ :'111: :: .. (, ;: -\'11
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f.:.1
I \II\IL" ,,~OT('I' "~(Jnor; \ ... o,~o-\ '\1~',,~OLl SLiI ",c()RI C,AIUlI'\{.' .. c('I.Io:'\'"\ ,~Oso.~IW ,,::111 "",:'M.~5h ;Il" ,::Ilf\{,~')~(' 1\\"" I:: l 2111: c 40 'c \ \11
Hotmall Pnnt Message
Hotma.l F'r'nt Message
Ck!se
Pnpt
WLS Let Taitel, conflict, professional misconduct, criminal

misconduct
of La\\." 41 A.. L.R.4th ..161 (1985),
An 3ttorne~ "ho initiates, causes to be mitiateel. or threatens to initiate
""; Zach Coughlin (zachcoughlm@hotmail.com)

~"
"Disdplina~ Action Agains.t Att6Tne-) fOT Aidinj;!; or As~i .. tin~ Anotht"r PeNon in t:nauthorb:ed Praetict"
Fn 8(24(12 11.31 AM
iii
criminal prosecution forthe
purpo~(' of influencing a d"il maher is "iolating the rllll'S of !'thies. S~e Mod('l Cnd(' of Prof'1
complal nts1pnvbar.org; complaint@lnvbar.org

Responsibllit) DR 7-105 (1983). Sell' also (;re2o~' (;. Sarno. Annotation, Iniliating, or Thrcateninj;!; to
Dei.lf B,Jr (oum...:1.
Iniliatt".. Criminal ProslE'Cution
llU!d like tll file :.J fortnal gl 1'::\ ,lnL(: ,1g::l1n~t Lc\\ '{ '\ttel. \\'(l~hoc Lq;a! S.::n ICC'>, .10": G::!1"!I1, anJ
" "ada L,1Ult SCr.I(;(;' In (',11ltlCltlon "nil the ITl:-tr!..:n, .;;e:t torth bckm <llld In\; C~lSC a~am,t WLS 1'<;
(;11 :lPPC<l! hefore: the )\'ChHb Supn. . mc Coun I!gln now, wIth (Jatin In,)\ mg tI~ dl~1l11S; m~ appeal
hd ....... J Upnll j l:Jt!III\. . t~l lime'" fik <111 OP(';11l11g Kn,"r l'au ... .::d hy IllI:\l' t,\ (1 lbuJukl11lv procurrcu
,Ill ;.:,,1'" :-oet::" S (I C"l.... 60302
f1!:
liS
Ground for Di5:iplininl!: Counsel. 42 A.. L.R.4th iOon (2(106) .. Additionally.
a practitioner may be sanctioned, or eYen disbarred. for eoercing an) per!>on conn('ctcd to the cas(', for
making fah(' ~tatemenh of material fact or la,l'. or for fri\'olou~ h('ha"ior before the immiJ!ration court~ ..
A l')amtiff that has been hara!o~d. intimidated or Ir('ated in
bad faith manner h)' a O('r('ndant lUI .. tuo
recourses: Rule I i(b)(l) and Rule 11 (b}(2),
Ab(l. pl(;a~c add We-PO .hm Lt':.-.lIe to the c{lmplamt a::-. he ha~ continually rdu:.-..:u {(l gather the
alldlo cd fl(lm \(d,ltl Kr.:b'<; Pwtl'dlOn Ord..:r cxh'lb!On h..:anng 111 tht.' luly -'I'd, 21112 arrl',,1 malll'!"
R<. R ~012~(J()-;"}:O:(I. in atidlth)ll t(\ 1~lIll1lg li1 gather the: July 10th. 21)12 aud!l) hom the TII~lln RCR
:?JJ I :!J)t'i13-t I [0 dCiennlnt~ \\ hcther the .\ugUq 291h. ~O I ~ court Jatl.' 1<, .I l\(',mng on pre-trw I
ll1()tJon~ nr. 111 j.xt.:I Tn,d. In addHwn In lht: ~llh('r lTIl"l'I\1HhK. t Lc~llt' hd:-o tl11TIl!llttcd in m~
rl'prl',,'..:ndtllm ,md add Biray Dogan. I\ll(lm .. Jj,l!1g \\ IIh Le"he dPP;I!~lllly ,L<"\l'lted Tll the RJl Ih,1\ 1
fikd rn ~hO\\ t(l a h-:-,lnng III RCR201,2.n65'O on Augu~t 22th, ~012, Jt:~PJtc \\'CPD :-.li11fLll1d<l
Jdmlltmg Ihdt ~h . . . (lid nO! mall out thl.' notice of till' hcann~ to me a!' h(."1 oHicc had mark..:d
my PO BO.\. ~q61 Reno R9503 addrc<;s, 3S "nl1 longel good" .1Ild. 3cl'mdlngl:.. failed to mad the
not1('c. 11nl:- to ~W\l~ DOg311 as,<.,en [hat l~ \';a" maJ!ed. and jlHwide a fa, of Ihe: ]"urpollcd 110llce.
hanng LhL' Inltt .. !1~ "L(," aL The' hot\orn, \\11Icl1 Llmh (inl;' ctlnllnm:-d I\a~ an rmh . . aLlOn Ihm she:
rn:'I'31t'd the ktt-::r. Dog<ttl h.'J~ n:fll'ied tl) appn:.t' the Court ofhJ~ t:rror :lm1 undw.' the prt:ludl . . 1!' [()
me: l;mHlght hy making I1h" appcur to bl' neg!Jgl'nt and ab,>('m~c rurthcL Dogan 3\",1 l\:~lil' cm"tt111nc
~r' tp cnmbll1' lK'f1llg, n; ,h"o 'h", "''', k, ,n; llllprnn""hk 0''''''
) :-tllel \\ 01i..s for WLS n,)\\ Tallc!\ p::l11n\?r~ at ;"'c' ::td::t (llUll :"('1\ ICC\ UP{)r, m/I)lltlatton ~!ld
hr:hl'L rceclltl) had me anr:"tl.'d or l.'l1lltnhulcd therelo (thtou~h J.t \\1<1.\'" pCljll!l.'d atTid;]\1I 01
pcl .... on,11 ,et \ Ice. :lttempteu brc.1kmg, dlld (,l1krmg and altl'mpt cd II e:-ora,'> <Inti ,t":-;lU!t ,md '\( 'S', amI
JdTChallulc!":-. ull<llltlHlnzcd PldcL!C(." o! kll\ "lit.! otller al.'tl\!Ilc~J on bulh JUIH. . 2Stl! lOl2 anti lui\'
3rd . 201~
Gra~
From: zachcougl"lfin@hotmall.com
To: Jgann@llpsonneilson,com
Subject: WLS Let TaIte!, con4!ct, profeSSional misconduct, criminal misconduct
Oate: fn, 24 Aug 2012 11:24 39 .. 0700
llelillent h~!lllg Spark'> III~Tlct.. COlirt. ~I;-, the aprIOprl,Ltt:' f(lrlllll to tilt:' <l Tt:'!1.!l1t\ Alh\\er lhO:11
\;C';" r('l'('ned a Lnl'k(lLH Ordcr th1ln Reno ru~tlr.:l' ("()uli. d':;"Pllc Ill,! :nl\allLC llO!l;:C ~(I b01h lll<..'
I
"69 a..1.r. 4th 41B"
file II'R\i.
! \\::tnt ,I \Hlttcn r\.!'~pnnse from you and \\'LS explalflIng IhlS \{l mc and \I!WI Stt'P~ h<tH' be<"l1l3kcn
to 3111dlOrah: thh ml:'-'C()lHlul.'1 Oh . T:l1td abo undcrtook ttl he m} U1111i .Ippptnled puhIH.: dd~J1(ler
ill R:-"'fC ca"e II cr 1(,405 fl1f" IlH.'h r leceil C'd a cnmlml rrc'~r"'~ C\ln~'I('tl,111 (Ill Jun\? ! Xrh 20 I ~
dnd '\C::" <.TLrmn'llly tn::.-.p",>:-..:d ,md ,1\~(lUlkd tn;! on 11\\mC1UlI\ Or..:Cd;"lon:- thxough 1i1J.:' <.'\\cllon llhltlet
RJC RC12011-001708 from \\hlch lhal CntnllUlllrcspa~!> COI1\!l'tWIl '>rnlll~" I nltl'l wllhd!r.;w (1{11ll
the ca<,e without followlIlg R1'l!lC Rld(>~ fegardlllg fihgn <1 \\"llttelllllO(J'1l1 C\.phlltllllg the Il':J.'>Ol1l11g
rOI ~~cklng.lll OldcI grantmg \\l1hdra\\al
I \\U" sllIng :"JC';; ::11111(' tllnc r.~]\~'ll\)O" ,Jilin)'
!~rl\:'''L'll1dLlon III tlltl! mal1~r.. \\hdc LOkI shan:d and oflir..:e, :.-.t..l!{ /.:r, lIumht.'l \\Itll :\C~ and \\<l~
i1:.IeJ 011 :'\"CS\ \\("I1:-lIc tis. thl!'lr "St~lff .l.ttomey" and "a\:.ocHlted \\ !tit" ~CS T,llll!! 1<; !lOW !,,,n or
the ECR ptogrtl!l1 run b~ WL~, III :'-'Olll(' colln..:ctlOn 1\ Jlh the we DA f.Uld Ih\.!' \\ C'SO tlrrl'~!c-d me
on July 3rd. lOll with 'C~ 1111l1\\,. ;\CS pmporttng to ('TIlllllldlly trl'''r,'''~ 1111.: fil)lll and ~"lHlr..:
Ap,HtmCn1 Comrlex wllcrCI!1 I ~tt!1 had (\'0 'allJ Ic:l<,cs, <"mel \\hcrc Ihe ,ItlC ('\ Ictl(11l11!dCI wa~
fraudulently procurcd b:. tho~e ('omnllttlng the lImlllllwrl.lcd pra<.'llCC' of 1,1\\ (R \\ lay !ted abllut
~nt:ttlng per'>onaJ \~rVICC on m: on .Il1lW 14th. 20J2 <tll.l th ... :; u<t) unl,1I1 I'lll dCld!Ih..'! !l,,!tlt.' \1;1,
"n{'~ti~{'n('l'.
inattention. or
prof~~irmal
incnmpetenc(' of altorne~ in criminal defeme"
gi'll'1si;%2Clllm%}Ol~le%2:0and%20VlCPO%208lo2024%2012%209%205%2012%20and o'o209%20Bo,,2012.htrn[12/3/2012
2: 4033 AM]
RJC \\'lSO, RPO ,m(l.~palb JII"UC':; CUll It IC'gat~ItJ1!! lhc~(: ]1I1hdll'W11IClI dckch ,1I)d JUl' plt\CC~,
dl.'tlclcnclc.:'
fite /fiRI! ...gam5t%20Jlm%20LesI'E%20and%20WCPD%208%2024%2012%209%20S%2O! 2%20,lnd/209'o20f!0/~2a 12 .htm[ 12/3/2012 1 40 BAM)
Hotmall Prim: Message
>-1otmall Pnnt Message
~ llh:..:rcl:-.'
Zach Coughltn
PO BOX 3961
Reno, NV 89505
. . . 775 338 8118
t-ax 949 667 7402

ZachCoughlin(Q""hotmatl.com
August 2rth, 2012 grievance against Jim Leslie, WCPD

Zach Coughlin (zachcoughlln@hotmait.com)
wed 9/05/12 12.11 PM
davldcc.q::nvbar.org r D<ltnckk'1i: nvbar .org; complalnt@nvba~ .org; complalnts@nvbar.org
Dl2'ar Bar Counsel.
Pka!:>i.? fi (e Ihl:-.
<h [] gTlC\
ance
l)r
ltllTInl! complamt.
The \,,"crn has refused many rCOlscmabk r~ll',-\;':Sb 1 ha'\c m"d~ ~(\ far Addt\lonaHy, t
hehcvc tl1crc i::. a hn..,,<., for 111ming for <l dl::'111Is<;;al m rcr20( 1-063341 given \-1r
Ciohle's failure to sho\\' up at \he: last TriJI Date III thi . . matter \11. l.e:-.((c r.:ontinues
to rcfuse pre:sen e the
I ... .sue'i
for Llppe[]L
I llat
I am that the WCPD l1as II.:'f"uscd 10 respond 111 wl'JtlJ1g to my inqulfles regtlrdll1g any
F ebnlary- 27th. 2012 COll1lllUlllcatJl)1l \\ ah the Reno ~1l1n\Clpal C \)uJ1 or Judge "'Jash
~Inlllle'" " ... Al!-.o. f1lca..,c rc~rond to Ill) inquirie:-. \\'ith re~pect to \\ hl.':thcr: Oll or
anyC\lle" nit ~Olll office' (includrng Hiray Dogan) e\'er c(lmmullicated with anyone
,'.-ah (he Reno iVluniClpal Court nncludmg Judge Na:-.h 11olmes. c.'pecial1y on february
2 "7th. 2012 at or around 1:OOpm. dc~pl{c the fact that your (henL me, \\ as noticed that
tilL" Statll~ Confercnr.:c pre\ lou .... l)' :">chedulcd for that time \\'J~ vacall..'d ... and dt:"pltL" the
hlL't tltat (\11 thtlt \'ery date Y{lHr aS~OL'mtc Blr<lY Dogtlll "nd moved fnr a . . CCOll\.'
cnmpctcllL': C\ JIU.ltIClll (11 dcrl..'d of me. 3ppan':l1tl) :.Inn meetlng \\ ilb DDA Young and
filE
ii RII .. Q<lIn<;t%lOJlmoIo2OLes!reOI.20ando';'20WCP[)ooLC8%2024%2012%209'o20S~'o2012lo20"nd%209%lDB%2012.htm[12/]/2012
,;lIlothcr person or two ... and neIther you nor an~ one with yom nl1kc !lll~ re~ponckd to
my inqU1rie~ in that regard. \ 1~ a Vb. \yhL'th..:r Judge t\'ash I (oll11c:-, (whom could not he
found by her 1-taff III L:ourt at that time, which \',:a~ the- tlOle ~dl~dulc for the traffi(.; trial
\n \1 TR 26800 on 2;27 11. al \vhic:h 1 \va~ found 11l cr1minal contemp1 and :-.enlcnced
to 5 da) ~ 111 jaIl. and fur" hi(.;h I have had lu report that COll\'\ctLon 10 the Slate Bar of
Nevada and the L'SPTO)' 1I0\\' is It that Mr. Dogan could gel an Order signed
reql1lnng me to have a Distnct C0U11 competency hC<1nng. yet I \vCl~ permitted to stam.1
trial in RMC ( I TR 26~OO? 1'...1r. Lcsh..:: has continually jumped in on case..; assIgned to
Joe Goodlllgbt or BIray Dogan and indicated to me thm his ~lIrcn 1~()r) capaclI)'
allows him to do ";0. He has arp:ucd to the Court that my heha\,l(lr 111 thc . . c \ anou~
C:l~e:-. prcduded a succe~ . . f111 Faretta crl11va~. then arf!ucs hi . . behavwr for a (<'I1I1ICL
anai)sls IS 11l11itcd tojust rcr2-II-0633441. 111a115 1l(lljU5t. 1\"01,... , ILmY[lne \\,Ith thl.!
R!\1C. particularly Judge r-.:ash Holme~ or 'lllyone 111 cnn1llllllllcatlon with Her HOllor.
was present at or <l.\\"are of the import of the Fehmary ~7th. 2fl 12 clandestine St<1tus
Conference between DDA Young and D~puty Public Defclldel 81ray Oogan, 1\\ ou[d
like to kno\', about It...
On numerous occa~ions noW I ha\c Icqllc~tcd. \crhally ant! in wntmg, for the WCPrJ
tu prll\ Ide me \, hatl.!ver pan of my file 1Jl RCR 11 ~065630 lhat I am penniltcd to hini:
ivlr Dogan. just recently made tnCUllSISknt l-otlltell1l:nb to mc regarding whcthn I \\, a:-:
('\"1.;'[" proyjdcd such materials. III the Wl PD lohb). 111 person. Mr. O\}gun at fir<;t
indIcated he was sure he hi1l1sclfplo\'!ded me those material:-.. thell ~r.:(lffcd ,n the ideil
ofpro\"lding them again. ifby chance Ilh"!\l'r anually recci\'cd Ihem Theil. MI
Dugan ~hol11y thereafter clumged hl~ aL'Count. and im.i~teJ .11111 Le~lie prond\!d me
tho~c matcriab. in person lW Ic'is . "
Please note, 1 fih.'d a gricvance ag:.lin!'>t \'ir Lc::.lie on August 24th. 2012. and Mr.
LeslIe has had c0I11111Unic<1tiOIl today \\ IIh the State Bar ur l\Lvada IIldicatmg the Bar
1::-. unaware of that. at lca~t to S0111L CA.h:nt.
2 40 33 AM)
~llInrldlllt
01 gn:.'I\dllCC reJd.
III
p,u1
'Subjc(.;t \\'1 S Let Taite!. conflict.

X 2~'12
lach
T0
profe"~lUl1al mi~l'ondtlct.
l'Ilminal Il1hci.mduCI
("~lughhn
cornplaintt-!~
nvhar.org. complmn1((i,m bar.org
Frnm l..old\ C0u~Min {J.Kh\:1l\\~hlln.0l)\'\m;1l\ IT'm)

"'(,Il! l-n" 24rL:~ II '\ .\\1
T0
C()mr\:llm"~i,n\ 1;:\1 nl~:. ~'()mrltllnt'~1l\ har 0lg
Dr:,lf Bar ('oun".:!, l(ll11ltleu mde\<lIlt ll1alt'rI,ill, Abo. pk-;t~e ,ldJ \\'('PO ~1l.~
~t <I~ he 11<1" l'(lnlmualh refu!.cd III g,l1h<:1 tho:: aU(llll cd 11(1111 \[dan h . r.:b':. PI(lI':dIOll Olda
(';\.TC'll"Jnn hL'drlll!! III the July 3rJ. 211 J 2 <Jnl'..,t ll1;l1tcr RC R .2(1I.i0(1'9S(). III ;\(khtl('11 to f:lIlmg: fC'
file /IIRI/ ...galnst%20)lm%20leslle%20and%20W(PD%208%2014%2QI2%209%20S%2012'o20and%209%20!l%2012 htm(12/3!2012 2 40')] AM]
Hotmilll Prmt Message
Hotma.1 Print Message
gath~~r 111-' 1\11)' 1nth. ~(l12 :1\Idl(\ fmm the 'I nal in RCR 201 ~"n(IJ3-l1 1('1 dct.::nmn(' v.hcth("!' the
August 29th, 2012 c()ut1 dat,:: !s a hei1fl1\& on prC'"lfI<ilm(>tlOm. or. III fact. a Tita! in addllWll 10 the
nthc!" rnl"'c(llHlu<:t t e"\It: ha." committed 111 Ill} l..:pre:>'l'llJ!wIl. and add BIray Dogan, whom, .llnng
\\Ilh L(>~h(> apr.lrently [I<;:-,c-rtcd h) Ihe Role thai I flied \(1 ~hfl\\' 10 a heanng ill RCR~OI2"()ns(1.30 rm
AugU:,l 22.~h. 201~. 1.1':'>111\1;' \\'CPD ~h\IT Lind:.! lJray adlllltlmg: 11wt :-oh..: duJ not mml out th.: n(ltH.:~'
of the he~tr1[lg: to me a~ her (1ITic(: had marl-cd my PO UO.\. 3qfJ! RCllo 8')503 addrc:-05 as "no longel
g00d" :1\1d. acC("rdl1lg.1~. t:111cd to mati the n('ltle.:, only to 11a\'(' Dogan a:,:~en that I:': "a~ madeJ. and
rTl'\ Id<.' a fa, of tile pUl1mrted notIce, banng the Initial, "l(i" at tlte bottom, \\hlCh Lindn (ira)
CllnllnTIcd \"0,'1:>' an mJ1Caltnll Ih:l1 "he- prcp<trcd the Icth.'r Dogan ha' n:ru~cd!O ,1Pplt;"1.' the Court (If
hi, ~rror .md undue tile preJU(ilce to me bwught oy makmg me appe<lT t(1 be negligent ami arN!ntee
FU11h:.:r, Oog:m ,md L!.!,,\tc n.mttnue to Iry to comhme hcann~>- In th!.!.'>\? Ihrc..:: ca~e:. t(> an
tmpcltTll::;;.;tblc c\tcnt
ZachCoughlln@hotmall.com
September 9th, 2012
State Bar of Nevada

complamt@nvbar.org
complamts@nvbar.org
DaVldC@nvbar.org
Reno, NV 89505
Tel 775 33B 8118
Dear Bar Counsel,
Fax 949 667 7402

ZachCoughlin@l"totmail.com
Dear Bar COLinsel,
grievance and complaint against DDA Young and WCPD

Dogan, Leslie, and Bosler
.'
"~
Zach Coughlin
(zachcoughllrv~hotmad.com)
Sdt 9/08(12 1:50 Ar4

complaint5@rwbaLorg; comp\alnt~fI\'ba~ org, davloc@nvbar.org; glennm@nvbar org
1 attachment
,,:r' ,) K[".
", :', ~', J,', ' " .c "i,
'( :: d~.":'- 0'
l?
Zach Coughlin, Esq.

PO Box 3961
Reno, NV 89505
Please accept thiS correspondence as a formal grievance against both Washoe County Deputy District
Attorney Zach Young, Esq. and Washoe County PublIC Defender BIray Dogan, Esq. for the reasons set
forth herem, With the understandmg trat ( plan to supplement this further In the near future,
Mr. Dogan, despite RPC sections devoted to diligence, competence, and communClations Wlt'1 cllI~nt5,
you failed to copy me on (or even Inform me of) DDA Young's attempt to amend the complajnt in
RCR2012-06S630 to a misdemeanor that would require, if a conViction is garnered, Bar Counsel to
file Petition seeking suspenSion of one's ldw license under SCR 111(6), given "obstructmg a publiC
officer" IS speCIfically delineated as a "serious offense" therein. I have, In the past m wrttmg and
verbally, Indicated to Dogan and IllS supervIsors Jim LesJte and Jeremy Bosler, that I demand to be
COPied of every flhng 11"1 any case for whICh they appear for me. Dogan made contradictory and
untruthful! statements to me With regard to whether he ever gave me a copy of my file 'In thiS
matter. At first, Dogan mdlcated he did himself, and that he was sure of that, then minutes later he
stated he was sure that he was there to wltlleSS JIm Leshe gIVe me the one copy the WCPD ever
prOVided me. WCPD staff has admitted to me that there was a package available for me to pick up,
after the date on which Dogan and Leslie allege they gave me my file. but that because I did not pICk
It up soon enough, It was Withdrawn from the front desk. Thereafter Dogan and Leslie have
m;::untamed the posItion that I was prOVided that package, With vary1Og, contradictory, evaSiVe, Clnd
vague statements (anci 10 Leslie's case, testimony) as to just how and when that occurred.
Tel. 775 338 8118

Fax: 949 667 7402
file
,I'
Rtf .. gil'Mst%20]'m%20les.h:!%20ilr.d%2:JWCP')%2uSQ,o:!;l)24~'"2012%209%20Sn,,2012'J.20and'h,209%208%2012 htn<[12/1/2012 2 40 33 Ar-1]
Additionally, Dogan and Leslie persist In seeking to combme heanng.:;
10
thIS case and
~he h\o
cases
file f f IRII ... g~lnst%20Jlmn-020lesl'eo.'20and%20WCPD%208%2024"'o2012%209%20SOlo2012%20,md"'o209%208%20 12.ht"'[ 12/3120 12 2 40 33 AM]
Hatmall Pnnt MeSSilge
Hotmall Prmt MessaQe
Jim Leslie IS attorney of record on (RCR2011-063341 and RCR2012-067980)wlth the case Dogan IS
attorney of record on (RCR2012-065630, and which Leslie atternately, when Its convenient to him,
maintains he IS allowed to chip In on, or, alternately, mamtam that he has not a connection thereto
and thus any misconduct In connection with that case may not provide a baSIS for a conflict being
found In RCR2011-063341), despite my express indICation that Dogan and Leshe must refrain from
doing so.
Further, DDA Young is violating RPC 3.8 and other ethical rules. In seeking to attain some leverage In
RCR1012-065630 by amending the Complamt to a charge that falls wtihin the purview of SCR 111(6)
("serious offen.:;e", etc), where the allegations do not proVide probable cause for such a charge, DDA
Young IS Violating RPC 3,8, Further, DDA young has a duty to divulge to the Court the confltct
ini1erimt III his office's partnering with an entity tllat 1 am sUing on a wrongrul
dlscharge/discrimlnatlon/retallabon baSIS, Washoe Legal Services, whICh IS partnenng With the WCDA
in al1 Early Case ResolutIon program that IS Violative of the Sixth Amendment Right to Counsel.
~, '-';I~""''''''''''~r''')'1'
.6~_." __ ,_,,,, ","_,,_;~~",-
C"
Holme's Order and subsequent grievance ftled With the State Bar in connection WIth a Trial in 11 TR
26800 on February 27th, 2012, set for 1:30 pm, and DDA Young and Dogan allegedly m~t on
February 27th, 2012, at or around 1:00 pm, despite havrng noticed Coughlin that the Status
Conference set for that tIme in RCR2012-0656:l0 had been vacated, Judge Nash Holmes JudiCial
Assltant could not locate Judge Nash Holmes for nearly 45 minutes on that date when the time for
Tnal came around. WCPD Bosler and Dogan have refused to (onfrim or deny whether they had any
communICatIOns With Judge Nash Holmes or anyone connected With the RMC on or around that date
regarding Coughlin's alleged "competency" Issues, Leslie has been extremely evasive in answenng
such questions, Court's have a duty to suspend proceedings if competency Issues are raised, across
departments, and arguably across the RJC to the RMC, particularly If Judge Nash Holmes was privy to
the "secret" Status Conference that was held on February 27th, 2012, depslte the RJC haVing vacated
It and Dogan haVing commUfllcated as much to Coughlin after Coughlin pOinted out the scheduling
conflict With 11 TR 26800, I am formally requesting Bar Counsel to Initiate all inquiry 'Into whether
Judge Nash Holmes was pnvy to the Order for Competency Evaluatron orderd on February 27th, 2012
in RCR2012-065630, and If so, whether she violated any RPC's by continUing to hold the Trial In 11
TR 26800, espeCIally 10 light of her subsequent grievance/Complaint With the SBN and Ordels to that
matter,
,",-04')'
f._
Rule 3.8. Special Responsibilities of a Prosecutor. The prosecutor in a CrIminal case shaH
(a) Refrain from pro~ecutlng a charge that the prosecutor knows IS not supported by probable
cause;
(b) Mak.e reac;onanle efforts to assure that the accused has been advised of the right to, and the
procedure for obtaining, counsel and has been given reasonable opportunity to obtain coun5el;
(c) Not seek to obtain from an unrepresented accused a waiver of Important pretrial rights, such
as the right to a preliminary heanrrg,
(d) Make t.lmely disclosure to the defense of all evidence or information known to the prosecutor
tf-Jat tends to negate the gUilt of the accused or mitigates the offense, and, In connection With
sentenCing, disclose to the defense and to the tribunal all unpnvlleged mitigating Information known
to the prosecutor, except 'Nhen the prosecutor IS relieved of thiS responSIbility by a protective ord~r of
t'1e tnbunal;
(e) Not subpoena a lawyer In a grand Jury or other Criminal proceeding to present eVidence about
a past or present client unless the proser..:utor ro?a50nably belreves:
(1) The information sought 15 not protected from disclosure by any applicable priVilege;
(2) The eVidence sougllt IS essential to the successful completion of an ongoing Investigation
or prosecution; and
(3) There IS no other feaSible alternative to obtain the Infonnatton;
(r:\ Except for statements that are necessary to Inform the Dubhc of the nature and extent of the
prosecutor's action and that serve a leg'ltJmate law enforcement purpose, refrain from making
traJUdlClal comments that have a substantial likelihood of heightening public condemnation of the
used and exerCise reasonable care to prevent Hlvest!gators, law enforcement personnel, employees
", ther persons a<;slst1ng or aSSOCiated With the prosecutor In a cromlnal case from mal(lng an
extrajudiCial statemen~ that the pr05ecutor would tle prohibited from making under Rule 3.6 or thiS
Rule.
fli:
DDA Young has contlnuCllly sought to deny Coughlin his right to a legitimate pre-trial hearing In
RCR2012-065630, In fact, Young needs to answer to whether or not RfvlC Judge Nash Holmes and he
(as well as Doga'1 or anyone With the W(PD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom In 11 TR 26800 and shortly thereafter found Coughhn "In
'Criminal CJntempt" In a traffIC o':atlofl tnal, seconds after Coughlin testified that RPD Sargerlt Carter
lIed In hiS testimony related to the three traffic Citations he had ISSUed on Coughlin inCident ~o RIChard
Hili, Esq's ~efusal to return Coughlin hIS chent's files or Coughlin'S state Issued IdentlfcatlOn.
Additionally, Dlease add to thiS grievance, Reno CIty attorney Allison Ormaas, for her lack for Candor
to Ul Tribunal (RPC 3,3) In asc;ertlng ~hat the word "retaliation" and the subject of retaliation did not
appear rn the pollee report for that November 15th, 2011 tra"fic citatIOn when clearly, the rCiJort
reveals that IS does, The SCR 117 Petition Coughlin now faces IS based in large part on Judge ~~ash
file' .' I RI/. ,galnst""'20JlmQ/~20Leslle%20and%20',VCPeo',20R"o2024%20UW"2:J9%205"!o2012.,>20and nm209%20B%2012 htm[12,'Jj2012 :2 40 33 AM]
DDA young Violated RPC 3,8 In seeking to have Coughlin returned to custody In September 5th, 2012.
There was absolutely no basis for Young seekmg to do so at that time other than to d!sadvantage
Coughhn, ego triP, and Impermlssllby coerce Coughlin out of pursuing any Civil remedl!:> that he may
have available given the police and prosecutorlal misconduct that Coughlin has systematically been
subJected to In the last year.
On that note, the July 3rd, 2012 arrest In RMC 12 CR 12420 for "dlstrubing tt'le peace", no "proof of
Insurance" and "failure to secure a load on a truck" led to Coughlin spending 21 days In Jail after the
RPD, U1 conjunction With Reno City Attorney Jill Drake advocated for RMC Judge Gardner to raise the
51,415 bondable ball to $3,000 cash only, on a "pubhe saferty and welfare baSIS" despite t'le only
perITIlss!1be rationale for ball under Nevada law being to Insure the defendant's appearance at tnal.
Please accept th'ls as a gnevance against John Kadhc and Jill Drake, Esq. for Violating RP(,s, Including
RPC 3,8, It IS telling that the disturbing the peace charge and proof of Insurance charge were dropped
on September 4th, 2012, but not before a Reno Oty Attorney (the sIgnature IS Illegible) sought to
Violate Soldal v, Cook County and Wheeler v. Coss some more by adding a trespass complaint against
Coughlin, whom had, at the tIme of the arrest, t ..... o vahd leases at the property in question, If a Reno
CIty attorney filed a trespass charge, It IS a Violation of the RPC, and I WISI'] for thiS to be construedas
a grievance and for further Investlgatron to be undertaken. Certainly, Keith Loom's grievance of
August 28th, 2012 looks more supportable
Rule 3.3. Candor Toward the Tribuna',

(a) A lawyer shall not knOWingly:
(1) Make a false statement of fact or law to a tnbunal or fS11 to correct a false statement of
material fact or law preViously made to the tribuna! by the lawyer;
(2) Fal! to disclose to the tnbunal legal authOrity In the conti oiling JUrisdiction known to the
lawyer to be directly adverse to the pOSition of the dent and not disclosed by opposing counsel, or
(3) Offer eVidence that the lawyer knows to be false, If a lawyer, the lawyer's client, or a
witness called by the lawyer, has offered material eVidence and the lawyer comes to know of Its
fal5'ty, the lawyer shall take reasonable remedial measures, Includ'flg, If nccesSllry, disclosure to the
tribunal. A lawyer may refuse to offer eVidence, other than the testlf'llony of a defendant In a crifTlinal
matter, that the lawyer reasonably believes 15 false
(b) A lawyer who represents a Client In an adJudicative proceedmg and who knows that a person
mtends to engage, IS engaging or has engaged In Criminal or fraudulent conduct related to the
file ///RIJ .. galnst%10)lm"'o20Les!le%20and%20WCPD"':.206%2014%1012%209%205%2012":o20and%2090!o208%2012 htm[12/3/2012 2. 40 33 AM]
Hotmml ?rlnt Message
Hotmall Prmt Message
proceedtng sGhali take reasonable remedial measures, mdudl'lg, If necessary. disclosure to the
tribunal.
(c) The duties stated In paragraphs (a) and (b) continue to the conclusion of the proceeding, and
apply even If compliance reqUires disclosure of Information otherwise protected by Rule 1.6.
(d) In an ex parte proceeding, a lawyer shall inform the tnbunal of all matenal facts known to the
lawyer that will enable the trtbunal to make an Informed deCision, whether or not the facts are
adverse.
not been given any rationale for GoodnIght's sudden removal from a Monday Tnal when Goodnight
had met With Caughlin for trial prep the Friday before, tending to mdlcate tha~ etther Young was privy
to information from the WCPD that Coughlin was not privy to, or Young was making arguments not
based in fact or law or in hne with RPD 3.4(e) DDA Young then sought to backtrack, making minCing
statements about how he "assumed" thiS or that and how he had not actualy had Impermlssllbe
communications with WCPD Bosler (who was filling in for Goodnight). RJC Judge Sferrazza
rebuked aDA Young, pomtmg out that he should not "assume" anything.
DDA young Violated RPC 3.3 when. at trial tn RCR201l~063341 on August 29th, 2012 he asserted to
RJC Judge Sferrazza that Layton v State presented mandatory blndtng authOrity In Nevada preventing
Judge Sferrazza from excemSlng any discretition with regard to whether Coughlin could appear as hiS
own co-counsel. Certainly, Wheby and ather cases prove otherwise. Yet, DDA Young was inSistent
and clear In his statements that there wa5 "mandatory, binding authOrity" preventing any excerCise of
such discretion by the court to permIt a co~counsel arrangement.
DDA Young continues to Impermissibly seek to leverage anotller obstructlngjre5istlng/maklflg a "false"

statement to a public officer charge In RCR2012~067980, despite hiS havmg been prOVided
excuplatory videos and despIte a lack of probable cause to support the complarnt, the information
pled therein being deficient as well. AddItionally, Coughhn's June 26th and July 3rd, 2012 emalls (see
below) make clear that the RPD, Reno Justice Court, Washoe County Sheriff, et al were made aware
well in advance of the defiCienCIes In the 5 day unlawful detainer notICe drafted and served by Lew
Taitel, Esq's apparent business partners, Nevada Court SerVices, who are committing the unauthOrIZed
practice of law In their "eviction consulting services" (please see my recent gnevance in that regard).
An attorney who inItiates, causes to be Initiated, or threatens to Initiate a Criminal prosecution for the
purpose of influenong a ClVlt matter IS Violating the rules of ethICS. See Model Code of Prof'l
Responsibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or Threatening to
Initiate, Cnmlnal ProsecutIon as Ground for DlsClplrnmg Counsel, 42 A.L RAth 1000 (2006). ODA
Yaung and the WCDA may be vlolatrng the follOWing' i\tt(lml.:~ \ r"LIl~'j! pl(lk~"I,'n;l1 c"nduc! rule"
l1r011lhlllllg ((lnJucl rrI.:J1IJII.:I.11 In th..: :Hlmllll ...mHlOll
Young has continually sought to deny Coughlin his right to a legitimate pre-trial heartng In
2012~065630, In fact, Young needs to answer to whether or not RMC Judge Nash Holmes and he
,. s well as Dogan or anyone With the WCPD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom In 11 TR 26800 and shortly thereafter found Coughlin in
"crtmlnal contempt" In a traffic (ltatlon tnal, seconds after Coughltn testified that RPD Sargent Carter
lied In hiS testimony related to the three traffic Citations he had tssued 0'1 Coughltn incident to Richard
H!II, Esq', refusal to retlJm Coughlin hiS client's files or Coughlm's sttte tssued Identlfcation.
AdditIonally, please add to thiS grievance, Reno City attorney Allison Ormass, for her lack fa Candor to
the Tribunal I" asserting that the word "retaliation" and the subJect of retaliatIOn did not appear In the
police report for tl1at November 15th, 2011 traffic citation whell clearly. the report reveals tl.at is
does.
of 1\'~11C;; dllrl
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Rule 3.3 (formerly Supreme Court Rule 172) IS the same
rl<)hd'lIll1t:
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ABA Model Rule 3.3.
Rule 3.4. Fairness to Opposing party and Counsel. A lawyer shall not:
(a) U'ltawfully obstruct another party's access to eVidence or unlawfully after, destroy or conceal a
document or other material haVing potent!al eVidentIary value. A lawyer shall not counselor assist
another person to do any such act;
(b) FalSify evidence. counselor assist a witness to testify falsely, or offer an Inducemen'. to a
witness that IS prohibIted by laIN;
(c) KnOWingly dIsobey an oblrgabon under the rules of a tnbunol except for an open refusal based
on an assertIon that no valid obligation eXIsts;
(d) In pretrial procedure, make a frivolous dIscovery request or fall to mak.e reasonably dIlIgent
rt to comply WIth a legally proper discovery request by an opposmg party,
'" (e) In tnal, allUde to any matter that the lawyer does not reasonably believe is relevant or that
Will not be supported by admlss,ble eVIdence, assert personal knowledge of facts In issue except when
t~stlfYlng as a Witness, or state a ~rsonal opinIon as to the Justness of a cause, the credlbtllty of a
wltn5S, the culpabIlity of a (Iv:! litigant or the gUllt or mnocence of an accused; or
(f) Request a per<ion othel than a client to refralTl from voluntarily giving relevant mformation to
another party unless'
(1) The person IS a re!atlve or an employee or other agent of a chent; and
(2) The lawyer reasonably believes that the person's Interests Will not be adversely affected
by refraining from glvmg such InformatIon.
DDA Young. on July 16th, 2012, Violated RPC 3.4 when he maoe the statement to the Court In
RCR2011 ~063341, at Trial, that Coughlin caused the continuance that was necessitated that day by
Joe Goodnight. Esq. (VlePD) sudden removal from the case. Caughlin pOlilted out that even he had
flte / / R I!..gcllnst%20lrm%20Le5t'f''olOand%2~""fCPD%20fl%202ol0'~20 12"'0209%205 01.,20 12%20and"'.209""208%2012.htm[ 12/3/2012 2' 40 33 AM)
S .J.(d. g). 1.'51\. I{ ~ loll ':-;- 2'::'::' In r<: I{ohllhlln. J(, SO 3d 1)(,2 tLa 20trl'o Additionally, a practItioner may
be sanctioned, or even disbarred, for coercmg any person connected to the case, for Mal(tng false
statements of matenal fact or law, or for frivolous behaVIor before the immigration courts. A Plarntlff
that has been harassed, Intimidated or treated In a bad faith manner by a Defendant ha5 two
recourses Rule U(b)(l) and Rule 11(b)(2). However, maltclous prosecutIOn actions are necessary to
deter persons from procuring the arrest of another maliCiously and Without probable cause. Hunt v.
lawson, 2008 WL 4691052 (Ky. 200B), as corrected, (Oct. 24, 2008). Merlet v Rizzo, 64 CaL App. 4th
53, 75 Cal. Rptr. 2d 83 (1st Dlst. 1998).
WCPD JIm Leslie has violated RPC 1.2 In RCR2011~063341In attemptmg to Withdraw from CruTItnal
defendant Coughhn one of the few InViolable nghts a Criminal defendant ras. Leslte has refused to
attempt to procure authentication or foundation for the admiSSion of excuplatory VIdeos of the arrest
of August 20th, 20U,n that case f,am any of the witnesses In the case. Rather, Leslie has mamtall1ed
that he Will only put on such Videos (whether as eVIdence or to refresh a witness recollection, and or
for Impeachment purposes) If Coughlin himself takes the stand and proVIdes authentication and
foundation for the videos, thereby expostng Coughlin to a w;;:lIver of hiS right to deode whether Or nat
to testify, and opening the scope of cross examination Impermissibly. Further, Leslie has refused to do
or proVIde any legal research to determIne the permlsslbtllty of only ut\lrz.lng portions of any such
VIdeo eVidence. That 15 to say, Leslie InSists that the vld'os must be submitted in toto, even portions
that damage Cougillin's case. Leslie has a duty of diligence and competence, and hiS blase refusal to
provide any legal citatIOn for hIS contention that Cougl1lin'5 defense may not Include pICking an
cllooslng whICh portions of such Videos to utlhze In Tnalls Violative of those duttes, In addlbon to
Violating RPC 1.2'5 dictate that a "lawyer shall abide by a client's deci'ilon co'lcernlng the objectives of
representation and, as requlred Rule 1.4, shall consult With the dent as to the means by which trey
file:IIIRI/ . . galnst%20Jlm%20Leshe%20and%2(1wCPO~'j208~"2024'o20 12%209%20S%2012%20and%209%20El"lo20 12 htm( 12/3/20 12 2 40 33 AM}
Hotm 1II Pnllt Message
are to b pursued" and that "tile lawyer shall abide hy the client's deciSion, after col15ultatfon with the
lawyer, as to a plea to be entered, whether to waive JUry trial a.!J.d~Aethm....th~i.eIll..win
Hotma,l Pnllt Mes5age
N.y.s.2d 266 (3d Dep't 1976),
t6ti[Y: .
Smcerely,
Rule 1.2. Scope of Representation and Allocation of Authority Between Client and Lawyer.
(a) Subject to paragraphs (cJ and (d), a la~-vyer shall abide by a cliellt's deoslon concerning the
objectives of representation and, as reqUired Rule 1.4, shall consult with the client as to the means by
which they are to be pursued. A lawyer may take such action on behalf of the client as IS Impliedly
authonzed to carry out the representation. A lawyer shall abide by a client's deciSion whether to settle
a matter. In a criminal case, the lawyer shall abide by the client's deCISion, after consultation with the
lawyer, as to a plea to be entered, whether to waive JUry trial and whether the client Will testify.
(b) A la...vyer's representation of adient, Induding representation by apPOintment, does flot
stitute an endorsement of the client's pohtlcal, economIc, social or moral views or activities .
j
(c) A lawyer may limIt the SCoce of the representation If the limitatIOn IS reasonable under the
~" cumstances and the client gives Informed consent.
Cd) A lawyw shall not counsel a client to engage, or assist a chent, In conduct that the lav/yer
knows is cnmlnal or fraudulent, but a lawyer may diSCUSS the legal consequences of any proposed
course of conduct with a client and may counselor assist a chent to make a good faith effort to
deterrrllne the vahd:ty, scope. m~anjng or applICation of the law.
Zach Coughlin
PO BOX 3961
Re'lO, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmall.com
Further, thiS gnevance seeks to have an Investigation undertaken to dctenmm whether the
circumstances detailed In the June 7th, 2012 ema11 by Cougo,lln to davldc@nvbar.org,and the WCDA,
wherein a battery via a lit Cigarette projected at Coughlin at dose range by Cory Goble was the
subject of a grant of ImmunIty by the WCDA, despite the extent to which such conduct is Illegal and
reasonable calculated to dissuade Coughlin from te5tiYlng In RCR2011063341. Further InqUiry IS
requested as to the pennlsslblhty of WCPD Jim Leslie refUSing to even bnng up the subject on cross
examination of Goble. Zarate or Duralce In that matter
Compensatory Damages TOPIC Summary Correlation Table References 117. InjUry to reputation
west's Key Number Digest West's Key Number Digest, MaliCiOuS Prosecution 1<.67 compensatory
damages In a maliCIOUS prosecution action may Include harm to the plamtlff's reputatIon caused by the
underlying action,[FNl] Including the damage to one's reputation from the malicious instltut:)i1 of
admInistrative proceedtngs.[FN2] n,us. the plaintiff III an actIon for malicious prosecution may recover
damages for inJury to hiS or her reputatlOn,[FN3J Including inJury resulting from the publication of
reports of the proceedlngs.[ FN4] Caution: Although a maliCIOUS prosecution IS, at common law,
umed to be harmful to an mdivldual's reputatIon, 1t IS nonetheless necessary to make an objective
Wing of an IndlV!dual's reputation before the malloous prosecution versus the damaged (Ondltlon
" lis or her reputation afterwards to support an award of damages far InJury to reputatlOn.[FN5] The
plaintiffs own testimony that he O~ she lost respect due to tile mahc'ous prosecution IS not enough,
\vlthout other objective eVidence, ~o 5Upport such an award.[FN6 J Evidence of a plamtlffs pnor arrests
IS properly admitted m a maliCiOUS prosecutIOn action If that eVidence bears directly on the question of
whether or not tpe plalnt!ff's arrest 1'1 fact damaged hiS or her reputation, in view of hiS or her
prevIOus arrests.[FN7J However, It has also been held that a trial court does not err In excluding such
eVIdence. because It has no relevancy to the Issue of compensatory damages.[FN8J [FNIJ Enatla v.
Debek, 287 CO"1n. 397, 948 A.2d 1009 (2008); SIkora v G'bb,>, 132 OhiO App. 3d 770. 726 N.E.2d
540, 111 ALR.5th 685 (10th D:st. Frank:hn County 1999); Wecht v PG Pub. Co., 725 A.2d 788 (Pa.
Super. ct. 1999). [FN2J MelVin v. Pence, 130 F.2d 423, 143 A.LR. 149 (App. D.C. 1942). [FN3]
BroWning v. Ray. 1968 OK 52, 440 P.2d 721 (Okla. 1968). [FN4J Grimes v. Greenblatt, 47 Cofo. 495,
107 P. 1111 (1910). As to ;Jroof of publiCity given to prosecution, SE'e 119. [FN5] RodfCk II City of
Schenectady, 856 F. Supp. lOS (N.D. N.Y. 1994) (applyng New York law). [FN6J Rodick v. City of
Schenectady. 856 F. Supp. 105 (N.D. N.Y. 1994) (applY1ng New York law). [FN7] Dlchamp<;. Ire. v.
Bryant, 738 So. 2c 824 (Ala. 1999). [FN8] Szare]ko v. Amerling Volks'Nagen, [nc., 55 A.D,2d 801, 390
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January q, 2012
w,.,w""b.v.,,'X
J.Jear Mr, Coughlin

The Office of Bar Counsel has rcccwed the enclosed correspondence from Richard G,
f hl1. Esq" ",hlch alleges professIOnal misconduct on your part A~ ~uch, a gnevance fi!e has
hccn opened
VI:\ EMAIL O:-.lLYp.ltnl.kJ.. Q.:.!1~~I_.~)J_~

Patnl'k Kmg, E:oq
:\s:.t:.tant Bar Counsel
SI<llt'l!nr of ~('\'ada
945" Double R, Blvd,
Renn,
rlea.-.c respond In '" ntlng 10 this sne\'ancc withm ten (10) days from the date of this letter
and kindJ), dirKt your R"Iponse to the Stale Oar's Reno office Your response should address
each allegatIOn contamed within \1T Hill's grievance and. \\henCYCT poSSIble, all appHtablc
dvcumentatlon in support 01 )our re5pon~e should be mcludell
If you intend to supplement :>,our response, please indIcate an expected date of receipt fOT
the same in ~our response If you ha .... e any qucsllom, please do not hcsitute 10 contact me
Sincerely,
7~-;:'o,l:~
Patricl.. U Kmg.
Assistant Bar Counsel
POK-1p
Enclosure
~c\'ada
H9:J21
Re:
Zachary B. Coughlin. F.sq_

Ne"'ada Oar No, 9473
Mr King
You and r ha\'e prc\ lously dls('usseu ~tr, Coughlm, :\Ir, Cou~hlin, due to
his mental in!'>tahilit), lack ()fintc~rity, and complete incompctenn', l'unstltutcs a danAcr
to the public If he IS .lilllwcd to continue to prUdU"l'!aW Thl~ 1~'Iter is \\ritit'n to
(h~l"hJ.r~e my and 1Il~ ilSSOU.Jtc'!> rcportlllg obliAOItlons under RI'C 8 '3. I'It>aSt'rOnsltiE'f
t hI:' follOWing
Ni'~"/J{' t' r.~!'!'ill, ('\'10-0/341 Altn'~ugh not am""!1,~ ~Ir C(lughlin's
most significnnt dhi! al "IUI.ltlons. It prt'sellts a good microeo ... m of hi!'> dl'rt>iletlOns Mr
Gt':O!'>111 has a cllt'nt of our offin', }ft' defrauded till' plaintiff, a!'> IS hl~ nJflriU'i t'/I('rondl in
dC'llmg 1\;111 I'omen Appro)tllllatt'l~ one ,ear ,If:er JlIdgmcnt was t'ntt'red ,Iml till' [il~e
(,{Hlcimicd, Mr, CUlI)1,hhn mtcf]l.'ch,d hUTI:.df in the ra~l' on twh:M of (;t'1>1>I!l, tt:lI1)!. to
L'olk'Ct on ,I S,IIWIIOIl ,n'ard a~;tinM OppO!'o1llg t'Oun,d It turns out th ... t bt'l':\U1>l' he h.Jd
tilt.'d bankruptcy, t:e!'>!'>1fi no longt'r own~ thl:- claim If~oll Illok at tht, filt', VOl! Will !'>t'e
that Cou}!hlin appeared ,md tilt'11 filed ,\ hiDIIIC "P,ll I!.II \\itllllnll,.II' ([\It.'tum'nt on
Dt'Cl'mhcf 1:1, ::01 L
letter to Patrick King, E:.q.
Lt"tter to Patrick Kin~, Esq.

January 14, 2012
Pa~t'2
January 14, :.1012
Page3
Subsequent to that tmlt', Coughlin ha~ bet-It ghoshniting docum~nts that

purport to he {rom Ct'"sin, indh Iduany, and e-fihng tht'm for Gessin. Ht;> is llslng [hI:'
"/'.>/" (or Ge.'.>In''''' MF;n,llure The!)t' are dearly not documents th<tt are sl~ned or
prt'pared by Mr. <Jessin, ,lnd the fact that '.>omebody(Coughhn) e-files them confirms he
IS ghostwritin~ without the reqUired disclosure. In addition, it appt'nrs that Coughlin
11<15 facilitated the lilinl/. of" hal ma~ be a fraudulent bankruptcy on ht'h'llf of Gessin.
COll~hlin's lack of~tt'I1C"'IS o:iemonstrated In the Cessm edSt' hv thl;" fact th",t he
do('s not u1l\!erslal~;t:l'ffc(:1 on the ownership ofGcssm's potcntiJ.l claims from
Ge!>sln havln~ fikd a hatlkntpt<.~, (i c., tllt> danm now bclon~ tu tht b<Jnkrupt(y tr\l~t('(',
not Ge"SIn.)
As with ,111 of the mailers referenced befow, I strongly suggest that you
contact the Second ,JudiCial Distnel Court and get ("-filing alL~SS to the cases mentioned
.. 0 you can look at the documents yourself. Glade Hall, Esq" IS oppos1Og counsel in Ihat
case and mar be of help 10 )ou.
2. I am informed .md heht'v(' thai :\fr COllghhn was recently convicted of a
theft crIme in Reno ~funiclpal Court. I am further infurmed th.lt the mattcr arises out elf
~hopliftlllg at Walm.m That ca~t> I~ presently on appeal to the tlistrlct court In case
number CRII-2064. ~Ir Coughlin I~ representing himself.
3 !\Ir COll~hhn IS prt'~entl}' facm~ cnmmal (,hart:;es rcgardlllg the theft or
.an IPod. Thatl~ pendlllg in Reno .Justice Court as case numbi!r RCR201l-0tJ1341 r
IHIVe revw"ed tht fdt. ),tr. Coughlin got into some sort of ar~ull\enl with hIS publiC
defendt'r. As a re:-'1111, tit" W.IJt> referred Qut for a competenn ell,llu,\lIOn
4. We represent Dr ~fatthew :-'Ierhss. a ph)!liclan frum ChICO, Cahfornia

Dr. ~1er1lss owns the propl?rty at 121 Rlvf'r ROl'k Street, Reno, ~f'v.lda. Beglllnlng III
:>.larch 2mo, the pmpt'rty was le:lsed to ~Ir Coughlin and hiS then-~Irlfnend. The leas{
e,plrl'd III Febru.lT) 201 t The girlfriend left tht, commumt... trl approximately :\tay ~Ol,
Dr. :'\.lerh~s l"(Jllt;IUf'd Il~ III approxImately Augnst 2011to aSSI,t in C\lctlng, ~Ir
('OURhllll. Coughlin had flul pai{1 r~nt or uhlitleJt> :-l11ee :'t1ay_ He lontcmied Ih.11 there
..... ere h.abltabllity IS,',lll."'" wllh thc properly that Ju ... lifiell hl~ wilhhol(hng rent. :\11 at hb
ll<1I11IS were deCided aJller..ely to his posIllon at the eVictIOn ht;'arlilg . .Justice of the
P,-",IC{' Peter SferaLZa ordered Coughhn t'\ I('ted from tht' premises effl:'ctill:' Nm't'mrn.r I,
;'::011. On !hilt dOlif'. Ihe Wa~hoe County Sheriff~ Department performed their normal
cvlcllon procedure hwks "'ere changed and Ihe e~lct1on nUII('e \\<1 ... posted on the front
door We \'ldcotaped the homc and It~ t:onlents at that time. U(l()Il lII~pecti{Jn over the
n:o.t fe ..... davs, it bee,l1l1e,lpparent th,lt ""omebod~" .... a~ breaking into the hmne un a
re~lliar hOI"''''
On Sundar, ~"')\ember n, 20U, Dr :'ler1t~s came to town, and IlIIet hilll
\s..,..e \\,dkcti Ihrollfo1;h the h()r!ll~, It .... lIS ob\IOUS that
,!llhe homcon Rncr RULkStrcct
~ol11eone had heen 111 there slnee I had last been in sev('rdl day~ before. Dr. :>.rer1ts~
discovered that the ha~elllent door 'vas harnC<lded (not locked) from the IIlsaie The
Reno Police Dep.lrlm('nt was summorwd The}' tned to coax whoever w.as in the
basement out, without success. After Dr il-lerliss had to kick the door lIm,n, it \\.IS
discovered that I\lr. CoughlIn had broken in and Wa& Ii~-ing in the b<lsement He wa~
arre'ited and IS presently facmg cnmtnal trespa.;,.;, charge" 1Il R('lIo !\JlInlclpal Court. Se
cast" no, 11 CR 26405 21, He IS dlso facing a contempt motion In front of .}udp;t" SferdlZa
In the e\iction case ~~ Sft'razza has .. tayed that matter pt'IHling the rt' .. olutlon of the
criminal trial. That '-\\as scheduled for ,ranuary 10, 2()12, hut \\,tl, continued al the
request of :\fr Coughhn\ new d!torney.
5 nle e\'jctlon order is now on apPt'al to the Second .ludillal DI~trict

Court, See case C\'uo3628, pending ill Department 7. As part ()fthe eVictIOn process,
a lien v.as as!:oerted agaill~t the personal property that Coughhn It'ft behind at the home.
On November 16,2011, Coughlin filed a motion to contest the landlord'~ lien tn the Reno
Ju!>hce Court. The court tried to promptly !:oet a he'lring, but Coughlin refU:!>t'd to
cooperate in settIng the matter. and the court took It off calend.lr Coughlin then reinitiated that prol'e!:>s and a hearing WdS held in DecemhN, at which tlml' the court h('ard
e\ idenceofCoughhn's lack of cooperatlQn in setting the November hearing You may
,11~o w.Int to contact Rt'no Justice Court !:otaff, and 10 particular, chief clerk Karen Stolndl,
about Mr. Coughlin's ahuslve treatment of her and her staff After the hearin~, the court
issued an Ordl;"r granting Coughlin a two-day timt' \\lndow to remove hIS personal
property. The first day wa!:o Thuri:oda~, December 22. 2011 After Coughlin wa.;, allowed
into the home that first da), he &ent out an email to the effert that because he had
appealed Judge Sferalt;}'S order. he was entltletl to a stay of proc!c'edmgs and was limn!!
to resume h~lIIg in the home. A!> a rl"suit, he did 'cry little 10 remove any of his per~onal
property that day On Friday, December 23, 2011, after he Ilamed. agalll, thdl hi';' ~tay
had been denied, Coughlin assembled a ..malllTew and they wefe able to remov(' a
substamial amount of hi .. pcn.onal propert)'. (You need to tlnder~tand that :>'fr.
Coughlin is a hoarder. We have the photos and video~ if you would like to see tht'm )
Ho~ever, Mr, Coughlin did not get all ofhts propert~ DUe For E"xampie, I counted 13 car
seats that he h,.d somehow managed to get down Intn the basement
fla\ III,\!; faIled to rcmO\-e all afltl'" belongings, :\fr. CouRhhn then II1(J\ed
heforf' Judge Flanagan for.1 t('mporaT)' re .. trainmg order to pn'vent the dl ... pO~,11 of hiS
.1bandoned proper!) in accordance \\Ith Judge SferaZZJ\ order Attach~d I... :'tfL
CoughllO'S motion, m) office's OppositIOn, and :'tlr Cou~hlll1'~ reply. Thl'sf:' documents
demomtrate ML Coughlin'::. complete and lIUer lllcompt'teIlCt' ill, an attonlL'~
On .}anuM}' I:, 21H2, Judge FI.\n,lg.1II denied !olr. Cou)!;hlins request (or.1
rC"'training order On .I,lOuary 12, 2011, th(' (ontral'tor hlrtd to clean the
house commenced work :>'fr, Cou~hlin t1'I.~!!;("(1 the contrartflT down 11l tr,lflic when he
(th!:' contractor) was on hiS .... a}- to lhe dump WIth the ab,Hldollt'd propclty tmm the
h')l11(', Cou~hhn c.tlled the puilce, who ,Irru'cd .It the tr!lflsfer !ot,lIlOn Coughlm \\'a~
Libel} ,Issertlng th,lt the contractor h,1l1 tn",d to rlln hUll O\f."r He ,\1:-.0 told thl:' police
telllpordr~
Letter tn Patrick Kmg, Fsq.

.hmuilry 14, :W12
Page 4
Letter to I'atrick Kinf" b4l,.

January 14, 2012
Page 5
that the contractor had stolen his p01>SeSSlOns After I presented the court orders to the
police, the contmctor v.a~ all()wpd tn proceed :\t their instructIon, I ha\'e nov. had a TPO
issued agiunsl Coughllll hy Reno Justice Court.
9 Coughlin has also tried tn file a case aF,Hmst me, my associate. my dienl,
'lOd utherl>. ilJdud1T1~ the Reno .fu.!Jtlce Courl. It is al!lulu he found on the \\eh.!Jltt'
.fudge Stcinhcimer h:l:o rulcd that he did not comply with ;.lRCP 8.
liuw4;"ver, hef()re the contractor could get back to the Ri\er RUl-k house,
t}H're. He had his video camera and was walk11l~ up and down the stn'et
scream11l!?, and yelllng""',e pohce, at the contractor, dnd at me, when I arrived. Mr.
COtlg,hlin endt~ lip beU1F, ,Irrt'st('d .lod taken to Jail. 1 he puhct' Informed me that
becauM' of tht, numm-r ami t)'pt:"'3 of con tach the~ hine had nllh him. he I~ no longer
ellgihle for citations in tht, (,vent of infr.lctlflns
w. Cou~hhn's beh,l\lor W,l.S unusual to ... tnrl, and has become more anti
more biZllrl't' dUrln~ tht, timl.!' W{' h.we bt'l.!'n dealin~ WIth tllm. Ht' Sl'rn'~ p,lpers he dot'S
not file. and files pi'lper!i.c dnes not sCr\'e. He col1!:olstcntly ~ign~ C('rtlfkah'~ of .!Jcr\icc
that ht' h,ls maIled to \1$, bul we h..t\e ~ rl'CeiH!d aO"1hmg from him hy rn':l1l th' ha~
postcd, ideas of the c,ictioll SCI\ ICC attempts and part~ of thc In.)1 Oil Y()uTube,
indudmgsnme reconilnp,s he st!crdly tn:ulc In court WIth hi:; cellphmw
Endost"d you Will find a copy of a supplemental dorumE"nt filed by :-'1r.

Coughlin (111 ,),111 ll<!ry LJ. :,!0I2, .and .!Jcnt In m) ... taff.lnd I hycmaLl from Coughhn that
mormng. PIE'llse notc that the <ltturne), deM~nation on the first page mdlcates that It b
htoin~ filed byColIghlin a:. appellant Y'.)11 "III note that the Capllon h from a different
t'ase_ HIS IIndenr in v.fllch case Mf. Cou,;hhn lOtended to file Ihis document, althoup.h,
because of Ihe l'.ISC !lumber .lnd the caption, It .lppear.!J to h,l\(, ultimately been routed to
tht" Carp('IHier l-a~e (C\'08-0l7oq) and not the t'\ irtion appeal ca~e(CVI1-o3628) (arn
tnl(1 that l'()ullselln th(' ("ptll)nt'd ('ase mll) ,\I"n be 111 the process offilinp..1 bar
('ompl::unt (\~,llnsl CUll~hlin.
11 Anotherexamplp of his iOcornpetence IS that h(! does not ulldt'rst,\I1li

what order~ are, :md are ll!'t, .11)Pf'alable. He does not tlt1<I(,!~t<lnd th,lt filing a notIce of
Hppt'al di\'C!,t::. the lov.l'rcourt of Jl1rl~diltllm.
Cou~hlin ",a~
h. \Vhen the house was scl'ured after Couv,hhn's arrest. we found a crack
pille ami ,I hat; of .... hat apreMed to lw m.lriJlhtna ThE' contractor also reported fimling a
ho~ of pIII~ ali(I a \ idl ()f :"OIl1t' ';;ort \\'e untiE'rstand Cou~hlin has un:-,ucl't'~sfl1lly tried
th., l";'Iv.~('r~ CIITll't'rlw{1 (or [.n, ~t'r:. pro~r.lm, ami th,lt Ill' h.h ,I hl"tory of l'oLlb~t,mce
probl(,t1h
I am confident that onCl' you look into this matter,
an
fl. Mr Cnughhn has a hahit of Initiatln):: cases and a.!Jkmg til pron~ed in
tu,'r1\a P<1II/~I'/S He bds (lone so III l'a~f''' a~ainst me, mv office, m\ chent, and '\',l~h(Je
Le);::l.1 Services \'OU \\df (Ind !!wm I(you run a search forCoughlm lon theSt'com!
Judiciall1htnd Court ,~",hSIIt: The courts that h,I't' reVIewed the duculllents ha\e
g~'llcr'llly tll'IIIt,tt hi~ rt'qm':.t:'> Wh:lt l~ of note I" th.11 hi:- rt;!pre~entatlllll~ in tht'
.tppl!cattons to proceed Injorn/(! pU{q1l'rl~ are Hll'on:'>islent ' .. ilh .md rontro:try to the
I cprt.'::'C!lt.ltions that ht h.I'> madt' to JUd~l' Flanagan m the C'Untl'xt of :.t,t'kmg a
tC1llpora\'~ l't'-.lrainmK unit'\' On Iht' one hand, he wlb the Court ht' b hroke and ha:'> Jl(J
rl opert" ,md ,>11 tht, otht'r hand, ht, I'" Idling Ihl' emlrt that h(, h,b a ~rt'at deal of
\,II;'.1ole propert~ at Ihl:' hOll1e Ih,ltlleed;. to be protected. ThiS dcmon:.trall's ,I I!:nlSS
Idek I,t rand,)r \\llh Iht' tribunal:. With "hirh b., d('<lb
will a~r('t' that :>'1r.
Slfllt'reh',
IS/
RIchard <1 Hill

RGH:kn
Enclosures.
7 "1f. CO\l~hlin has fil(t\ two lav.;'Ulls a~ain:.t his former employer.
'\o'dshO!:' I.t>~al Sen ices. He has sued
of the board of dirt'ctors and the man.l)!;pmenlllf
the eomrl,ln) Bolh C,l:.es h.1Ve non ht"t'n (ltsmissf'd Bolh ca::.es demonstr,lte hIS 1,ll'k of
cornpdent'c. I s\1AAe~: ~ou (Unl,let ,J\)~eph G.lnn, Esq, III L.l!, \CF..l!" .1:' ht;! \',lSCOlIllSe\
for the dt'ft'llllants in th.l! ('.lSt' You ma' \~',U\tto wnt.lrt P,l\11 EIc..tno. F~'Iq , the dlreclor
of \\a:.hoe Lc~.11 St'P'll't'~
\'011
COll~hlin should nol he practiCing law. He IS a danger 10 the cOIl1.ITlUnity.
-Cou~hlin .\mended Emer~ncy Motion for Restrainin~ Order

-:\tt'rlb::. OPPoMtlon to Molion for TRO
-Coughlin Rt'pl) to OppositIon to Mollon for TRO
-Supplemental Reply 10 Opposition d'lte!l III.]! 12
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I
2
3
4
5
10
11
Plaintiff,
Case No. ALL CASES
vs.
Dept. No. ALL DEPARTMENTS
12
ZACHARY COUGHLIN,
13
Defendant.
________________________1
14
15
ORDER
16
Pursuant to Justice Court Rules of Civil Procedure Rule 84(b)(1) as Chief
17
Justice of the Reno Justice Court J am responsible for the administration of court rules and
18
regulations.
19
20
Pursuant to Rule 84(b)(5), the Chief Judge oversees all administrative and
clerical work and functions of the court.
21
Pursuant to Rule See) of the Justice Court Rules of Civil Procedure, a court may
22
by local rule permit papers to be filed, signed or verified by electronic means that are consistent
23
with technical standards, if any, that the Iudicial Conference of the United States establishes.
24
Currently, Reno Justice Court has not adopted a rule permitting papers to be filed
25
electronically.
26
Justice Court Rules of Reno Township Rule 10(0 provides that the clerk must
not accept for filing any pleading or documents which do not comply with this rule, but for
good cause shown, the Court may pennit the filing of noncomplying pleadings and documents.
Henceforth,
5
IT IS HEREBY ORDERED that the Defendant, Zachary Coughlin, shall not be
6
pennitted to file any further documents in any and all departments of Reno Justice Court by
electronic means including, but not limited to, fax or email. In the event he violates this Order,
he will be in contempt of court and subject to twenty-five (25) days imprisonment for each
2
3
5
6
7
8
WRI TOWNSEND, Secretary to

10
11
12
13
Name:
Address to which
mailed/delivered:
14
November 28, 2012

15
16
Zach Young, Esq.

P. O. Box 30083
Reno, NY 89520
17
18
19
Name:
Address to which
mailed/delivered:
20
21
22
23
24
25
26
November 28, 2012
Zachary Coughlin
1741 East N'mth Street

Reno, NY 89512
and deposit in U.S. mail
FI I
\=ID
.
.,
l,,. ...
STATE OF NEVADA
..
COUNTY OF WASHOE
2012 DEC -1+ AH 1: 32
-----------~/
_____
. . . . : :~: : '_!O::.....:..fW..:..::....::"---'-H-'---.:.'--.!.,ft.!...C~y--"E:..:::....::S"----_ _ _, being first duly sworn, deposes and
says: That affiant is, and was on the day when he served the within Order, a citizen of the United
States, over 21 years of age, and not a party to, nor interested in, the within action; that the
affiant received the Order on the
(i!b
1\
day of _____u=-=e::;:...C--'-'--____, 20
I ~, and
/7
~A~C;:.!.~.:.!:.'4.e=-Lr_.J.oC..J,OL'U~r;;'.LHl..1L!e...L..1A/l.L./_ _ _ _--'
personally served the same upon _~?:=-'
on the
the said
eh
day of
!J c_
ZAC&1('/ CouVU ~o./
, 20
,by delivering to
, personally, at
.../../----=:SJ=(,{.L77-I'-'---'>:=!..LlIE>f.I'A""--"''-Cl....--'.5oL.LZ_:__, _ _ _ _---Ltft.!.!=W,.!!..!,lJ~_ _"State of
_---<..eAJtB-..JL.<VM""='-'A'----_ _ _, a copy of the Order.

...
Sign~of Person Mllki ervice

this___ day of ______________.20 _ _
Notary Public in and for said County and State.

My Commission expires: _______________
\'
I'
"
"
'; ~
DA # 432068
:'nll Otl~
RPD RP11-016399
,-,.
') -'
U .... ,J
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEV~~ l5~~.~~.~:~iHf
* * *

RCR 2011-063341
Plaintiff,
v.
6
7
(,:1
-j
DEPT: R02
;;-N j
Def~.
. AMNPEp
CRIMINAL COMPLAINT
10
11
verifies and declares upon information and belief and under penalty
12
of perjury, that ZACHARY BARKER COUGHLIN, the defendant above-named,
13

COUNT I.
14
15
PETIT LARCENY, a violation of Washoe County Code
53.160 and 125.050, a misdemeanor, in the manner following, to wit:
16
17
2011, at Reno Township, within the County of Washoe, State of Nevada,
18
did willfully and unlawfully steal, take, and carry away the personal
19
property of another, to wit:
20
Hundred Fifty Dollars ($250.00), said personal property being the
21
property of and owned by CORY GOBLE, at or near 10 North Virginia
22
Street, Reno, Washoe County, Nevada, with the intent to permanently
23
deprive the owner thereof.
24
///
25
///
26
///
an iPhone of a value of less than Two
I'
COUNT II.
POSSESSION OF STOLEN PROPERTY, a violation of
NRS 205.275, a misdemeanor,
in the manner following, to wit:
2011, at Reno Township, within the county of Washoe, State of Nevada,
did willfully and unlawfully possess or withhold stolen goods having
a value less than Two Hundred Fifty Dollars ($250.00), to wit:
iPhone, at or near 1 North Center Street, Reno, Washoe County,
Nevada, such property being owned by CORY GOBLE, for his own gain or
to prevent the true owner from again possessing said property,
an
10
knowing that the property was obtained by means of larceny or under
11
such circumstances as should have caused a reasonable man to know
12
that such goods were so obtained.
13
14
DATED this
!
15
16
17
18
19
20
21
22
23
25
PCN RPDll12566C
Custody: X
Bailed:
Warrant:
26
08234320688
24

District Attorney: YOUNG
Defense Attorney:
Bail CD\~)(e I~C
Restitution:
NJ
2
(~
. 'II
Pursuant to NRS 174.234, the following are the names and
chief.

OFFICER RON DOSA
CORY GOBLE, 5020 Las Brisas Boulevard, Reno, Nevada

7
NATHANIEL K. ZARATE, 830 E. Plumb Lane, Reno, Nevada

8
NRS 174.234 also requires the defendant, at least five
10
judicial days prior to the trial date, to file and serve upon the
11
12
13
14
of the witness.
15
16
17
18
19
20
RICHARD A. GAMMICK
District Attorney
21
22
23
24
25
26
By
~Z7A~CC~~~Y~.~~------------------
Deputy
Attorney
>
(I
\1.
DA # 432068
RPD RP11-016399
2011 ,"JG 2'f r,;! 9: 0 I

1
2

RCR 2011-
Plaintiff,
063 341
~/
6
7
/
/,/
/~~CHARY
/g
v.
DEPT:
BARKER COUGHLIN,
CRIMINAL COMPLAINT
Defendant.
10
11
verifies and declares upon information and belief and under penalty
12
of perjury, that ZACHARY BARKER COUGHLIN, the defendant above-named,
13
14
15
PETIT LARCENY, a violation of Washoe County Code 53.160 and

125.050, a misdemeanor, in the manner following, to wit:
16
17
2011, at Reno Township, within the County of Washoe, State of Nevada,
18
did willfully and unlawfully steal, take, and carry away the personal
19
property of another, to wit:
20
Hundred Fifty Dollars ($250.00), said personal property being the
21
III
22
III
23
III
24
III
25
III
26
II/
an iPhone of a value of less than Two
(J
1
property of and owned by CORY GOBLE, Washoe County, Nevada, with the
intent to permanently deprive the
DATED this
~4. \V\ day
of
~~~~~~_____ '
2011
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
25
PCN RPDl112566C
custody: X
Bailed:
warrant:
26
08234320688
24

District Attorney: YOUNG
Defen~~ At~orn~:
Bail I!> 'A\yl:->

Restitution:
NJ
. I
(I
(J
Pursuant to NRS 174.234, the following are the names and
chief.

OFFICER RON DOSA
CORY GOBLE, 5020 Las Brisas Boulevard, Reno, Nevada

7
NATHANIEL K. ZARATE, 830 E. Plumb Lane, Reno, Nevada

8
NRS 174.234 also requires the defendant, at least five
10
judicial days prior to the trial date, to file and serve upon the
11
12
13
14
of the witness.
15
16
17
18
19
20
RICHARD A. GAMMICK
District Attorney
21
22
23
24
By
/III
~ZA~C~H-I~~~~----------------
Depu)t.y
j
25
26
rict Attorney
(~
ARREST REPORT AND
/1- /6399
~ECLARATION OF PROBABLE CAUS~
.
51,' -Pft
ORIGINAL
RPD 111256fC
R'S<=(5'1 tZ f
CASEI
b-f-
PIIOTO" _____
MI 9: 21
~,----
II-/( Jr?
R-----
ARRESTEE'S (Last. Forst, Middle)
NAME
COUCflU~ hAUlAAY
RESIDENCE (SIreet. City,
te, Zip)
ADDRESS
ARREST
DATEO~(lo1t1
TlME1').J6.
LOCATION
I AI ce.-vJl!A. 71'
/0 A/
"IRS/ORD #
20~~}.O
"IOC
BAIL
LOCATION
WARRANT # & DATE
~500-
OCJ])7
1IIAGIA/I"J,.
CHARGE
C/I",I-Vt:J
rr
F=Felony, G=Gross Misd, M=Misd FGM
I. ~
..v' Y
2
3
4
5
6
7
;',
II! QV!fAL/J{{ :///020 1{
I'tJ
The unclelsigned,
, a police officer, of gEM")
hereby
:SecIares under penalty of pet'jury. thalihe aIJove.-named defendant has been arrested on probable cause and is sUIJie<:f: to delention for the above~listed offense(s). Either
~ or """" inIoonation and belief lhis officer learned !he following facts and cirrumstances whICh support the arresl and delenlion:
~J
RElS TO _ _ _ _ _--1t;;:.'-.J.T_'(!....'--,,-<_ _ _ _ _ _ _ _ _ _ _ _ _ DATE

DISSEMINATION is RESTRICTED TO CRIMINAL JUSTICE AGENCIES ONLY,
'BY~
SECCNDARY DISSEMINATION TO NON-G IMINA~ AGENCIEf'IS PROHIBITED,
'HEREFORE. Declarant requesfs that a finding be mada by a magistrate that probable cause exists to hold said person lor preliminary hearing (if charge is a
Iony or gross misdemeanor) or lor trial (n charge is a misdemeanor).
Ige
OVIEWED
R PROBABLE CAUSE (PC)
: FOUND
of
PC NOT FOUND
DECLARAtfl
DATE'-"-J,--~-,-TIME
5, I (P
MA~t~TRAn:
" . .
{"
DECLARATION SUPPLEMENT
I,.age: . 2 OF 2
CAS~:# 11-16399
On !\ug~st 20, 20 II at approximately 2327 hours on the Center St Bridge. at I N Center St, I contacted
defendant Zachary COUGHLIN. on a report of a larceny of a cellular phone. COUGHI,IN makhed the
description relayed to me by dispatch and he was also pointed out by bystanders to be the suspect in the
larceny when I arrived at that location.
I !irs\ asked COUGI IUN if he had the victim's phone. COUGHLIN stated that he had the right to not
answer my question. As COUGHLIN was wearing baggy clothing, which can conceal a weapon
according to my training and experience, I pat searched him for weapons and felt an object resembling a
cellular phone in each of his Iront shorts pockets.
Nex\ I spoke to the victim, Cory GOBLE who stated that he has an Apple Iphone that he had bought a
couple of years ago for $300. GOBLE had set his phone down on a concrete wall in the plaza at ION
Virginia St, and was skateboarding approximately 15 feet away from it. GOBLE's Iriend, Nathaniel
ZARATE, then informed him that COUGHLIN had just walked by and taken GOBLE's phone.
GOBLE stated that they confronted COUGHLIN, asked him for the phone back, but COUGHLIN stated
that he did not have the phone. GOBLE then called his phone number from a friend's celluar phone and
saw the screen of his phone light up in COUGHLIN's left front shorts pocket. GOBLE stated that they
didn't hear the ringer on the phone because the phone was set to vibrate only.
I next spoke with ZARATE who confirmed that he had observed COUGHLIN take GOBLE's phone frolTI
where GOBLE had set it down, and then observed COUGHLIN put it in his left front shorts pockel.
I obtained GOBLE's cellular phone number and called the number from another phone. I heard a vibrating
noise coming from COUGHLIN's left front pocket and louched the outside of his shorts where I had
previously felt the phone. I then stopped calling GOBLE's phone from the separate phone and the phone
in COUGHLIN's pocket, that had been vibrating, stopped.
I then placed COUGHLIN under arrest fill' Grand Larceny, as he had taken lhe property of another person
valued above $250.
I retrieved the phone from COUGIILlN's pocket and GOBLE was able to further verify his ownership of
the phone based on the password for the phone and calls that had been made in the previous hours.
COUGHLIN was then transported to the Washoe County Jail and booked without further incident.
WHEREFORE, Declarant requests that a linding be made by a magistrate that probable cause exists to hold said person for
prelim mary hearing (!fcharge IS a felony or gross misdemeanor) or for a trial (if charge is a misdemeanor),
REVIEWED FOR PROBABLE CAUSE (PC).
I'C FOUND
PC NOT FOUN))
DATE: _ _ __
DEFENDANT ORDERED RELEASED. DATE:
DECI.ARANT~.
.MAGISTRA TE
PAGE
._-------_._-_.
OF
.MACiISTRA 1'1,
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Location: Reno Criminal
Judicial Officer: Sferrazza, Peter
Filed on: 08/24/2011
State Of Nevada vs. Zachary Barker Coughlin
CASF
Agency Number: RPll-016399 (RPD)

DIstrict Attorney Number: 432068
Probable Cause Number: RPDll12566C
I'\T())~ 'IXI JOi"i
Date
Deg
0812412011
M
RPD - Reno Police Department
Offense
I.
PETIT LARCENY
Arrest: 0812412011
2.
POSSESSION OF STOLEN
PROPERTY
Arrest: 08124/20 I I
08/24/2011
Case Type: Misdemeanor
Case Status: 09/0712012 Active

Case Flags: Sealed Transcript
RPD - Reno Police Department
Related Cases
RCRZ012-065630 (Same DefendantlRespondent)
RCRZ012-067980 (Same Defendant/Respondent)
Statistical Closures
05/07/2012
Transferred (before/during trial)
Bonds
Cash Bail with Notice #63376
11116/2011 8:53:40 Posted
AM
Counts: 1,2
Own Reeog;uzanee
Counts: 1.2
#62023
$465.00
$.00
C.\SI~
Current Case Assignment

Case Number
ASSU;;\".\IE'oIT
RCRZOII-063341
Reno Criminal
08/24/2011
Sferrazza, Peter
Court
Date Assigned
Judicial Officer
PAR I \' I\,FOR~I-\TJOJ\'
Lead Attorneys
Plaintiff
The State of Nevoda
Young, Zach
775-328-3200 x351O(W)
Defenda.t
Coughlin. Zachary Barker
Public Defender
Retamed
775-337-4800(W)
\'1,;'\ r~ & ORDERS 01- THE CO{IHT
08/22/2011
WPublic Defender Appointed
08/24/2011
Case Filed
08124/2011
Formal Charges
CT. J. PETIT LARCENY, a violation ofWCC 53160 and 125.050 AMENDED CT.Il.
POSSESSION OF STOLEN PROPERTY, a violation ofNRS 205.275
PAGE 1 OF 9
Printed on 1210512012 at 10:29 AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011063341
08/2412011
08/25/2011
Plea (Judicial Officer: Sferrazza, Peter)

1. PETIT LARCENY
Not Guilty
!i'J Arraignment (10:00 AM) (Judicial Officer: Sferrazza, Peter)
08/25/2011
Bail Set
Own Recognizance: Bail Conditions Set by the Honorable Jack Schroeder
08/25/2011
Bail Set
465.00 Bond or Cash Bail: Bail Conditions Set by the Honorable Jack Schroeder
0812512011
09/08/2011
QJ Own Recognizance Release

Pre-Trial Conference (8:30 AM) (Judicial Officer: Clifton, David)
09/08/2011
!i'J Order for Competency Evaluation Pursuant to NRS 178.415
1010512011
!i'J Motion Filed

Emergency Ex Parte Motion for Sanctions Pursuant to NRCP 11, and Other Rebef
10110/2011
6J Letter Sent
Correspondence submitted on an Ex Parte basis
10/1212011
Motion Hearing (10:00 AM) (Judicial Officer: Sferrazza, Peter)
10113/2011
CANCELED Motion Hearing (iO:OO AM) (Judidal Officer: Lynch, Palrid.)

Vacated
10113/2011
1011812011
CANCELED Motion Hearing (11:00 AM) (Judicial Officer: Sferrazza, Peter)

Vacated
WInformation Filed
General Appearance by Named Defendants
10/26/2011
Motion Hearing (10:00 AM) (judicial Officer: Sferrazza, Peter)
11/14/2011
Bail Set
465.00 Bond or Cash Bai/- Bail Conditions Set by the Honorable Peter J. Sferrazza
11/14/2011
QJ Own Recognizance Revoked

Per Judge Sferrazza
11/28/2011
PreTrial Conference (8:30 AM) (Judicial Officer: Sferrazza, Peter)
11/30/2011
!il Request for Audio CD Filed
12/19/2011
!iJ Request Filed

Request for Discovery
0211312012
!i'J Motion to Suppress FIled [Mail Service]
02/15/2012
QJ Authorization to Represent Filed
REl'io CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
0211512012
J Motion Filed
Motion to Allow Late Filing Pre~Trial Notice
02115/2012
fiJ Motion Filed

Pre~Trial Motion
02117/2012
[) Notice of Appearance Filed

and Supplement to Motion to Accept Pre Trial Motions Where Untimely
0212112012
fiJ Motion Filed

Motion to Strike Fuga/ive Document
02/21/2012
fiJ Motion Filed

Motion to Continue Trial
02/21/2012
fiJ Motion Filed

Motion to Appoint Co Counsel
02123/2012
WNotice of Witnesses Filed
02/23/2012
fiJ Opposition to Motion to Suppress Filed
02/27/2012
WOpposition to Motion to Continue Filed

Trial Date and Motion to Appoint Co-Counsel
02/29/2012
05103/2012
Misdemeanor Trial (8:30 AM) (Judicial Officer: Sferrazza, Peter)
WResponse
Reply to State's Opposition to Motion to Suppress
05103/2012
05/0712012
QJ Request for Submission Filed

Parties Present: Plaintif!
The Slate of Nevada
Public Defender
Young, Zach
Defendant
0510712012
Goodmght, Joe
Deputy Districl Attorney
fiJ Mental Health Court (Judicial Officer: Sferrazza, Peter)

Defense requested to be transferred to Mental Health Court. State did not oppose as long as
the Defendant entered a plea to Ihe charges. The Cour/finds that the Deftndant does not in/act
have to enter a plea. State requested that if/he Court decides to transfer this case to Mental
Health Court, prior to that happening, witnessfees be paid in the amount 0/$75.00. Defense
opposed stating Defondant has no means ofpaying witness fees It is ordered that the
Defendant is to pay $75.00 witness foes by May 7, 2013. Upon/urther order althe Court, this
case is transferred to the jurisdiction of District Court Mental Health Court without a plea.
05107/2012
QJ Case Transferred to Another Court
0511 6/2012
fiJ Request for Audio CD FIled

requested by Joseph W. Goodnight. Deputy Public Defender.
05/30/2012
fiJ Rerrand from Second Judicial District Court FIled

PAGEl OF 9
Printed on 1210512012 at 10:29 AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Order Returning Case from Specialty Court to Original Department
07116/2012

Parties Present: Plaintiff
The State of Nevada
Deputy Dlstrict Attorney
07/1612012
Young. Zach
Defendant
Public Defender
Coughltn, Zachary Barker

Bosler, Jeremy T.
Hearing Result (Judicial Officer: Sferrazza, Peter)

Defense moves for continuance; Public Defender Jeremy Bosler indIcated that a new Deputy
Public Defender shall be appomted to take over the case. State Agrees. Trial shall be set on
August 29, 2012, all motions shall be decided at that date.
08/06/2012
Ii1 Request for Audio CD Flied
0810912012
WMotion FIled
to Proceed in Forma Pauperis
08109/2012
Motion Denied
to Proceed in Forma Pauperis
08/0912012
Notice
The Honorable Peter J. Sferrazza will hear Motion to Suppress at the arne set for Trial.
08/27/2012

The State of Nevada
08/27/2012
Young, Zach
Defendant
Public Defender
Coughlin, Zachary Barker

Leslte, James Briand
Iii Amended Criminal Complaint Filed

Stricken
08/27/2012
Hearing Result
The State moved to strike Second Amended Criminal Complaint.
08/27/2012
Motion Granted
to strike Second Amended Criminal Complaint.
08/27/2012
Hearing Result
The State read offered plea negotiations mto the record at which time the Defendant accepted
the offered plea. The State filed Amended Crimmal Complaints. Hearmg proceeded. At
conclusion a/the hearing, the Court will not accept Defendant's plea. The State moved to
Strike Amended CrIminal Complaint. GRANTED. Trwl remains set August 29,2012, at 9:00
A.M.
08/29/2012

ZACHARY CaUGHLTN CASE
0812912012
Continued to 08/2912012 - MSC Reset/Continuance - The State ofNevada:
Defendant
Public Defender
08/29/2012
The State of Nevada

Young. Zach

Leslie. James Briand
9J Request for Audio CD Filed

Requested by Jim Leshe, Deputy Public Defender.
08/29/2012
PAGE40F9
Printed on 12/05/2012 at /0:29 AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Defendant addressed maHon to appoint co-counsel. Defendant's Counsel addressed motion to
appoint co-counsel. The Stale opposes motion to appoint co-counsel. Motion DENIED. If
Defendant so chooses the Court will conduct a Faretta Canvass. Defendant moved for selfrepresentation. The Court canvassed the Defendant regarding the Faretta inquiry. The State
objects to Defendant's motIon to represent himself on the grounds that it is untimely and that
this is for the purpose of delay and not In good faith. Defendant's counsel addressed motion/or
self-representation. Motion DENIED. The State's motion to Strike all Documents that were
flied solely by the Defendant IS hereby GRANTED. The Defendant previously flied Motion to
Suppress. Motion Hearing proceeded. The State opposes Defendant's Motion to Suppress.
Defendant's motion to Suppress GRANTED to the extent ofthe "pat down search". Trial
proceeded. WItnesses held to subpoenas.
0812912012
WMotion FIled
Pre-Trial Briel Motion for Summary Judgment
0813012012
WRequest for Audio CD Filed

requested by Zachary Coughlin
0910512012
0910512012
0910512012
Misdemeanor Trial (10:00 AM)

Parties Present: Plamtiff
Defendant
Public Defender
Witness
11.. State of Nevada

Young, Zach
Leslie, James Briand
Duralde, Nicholas

Trial proceeded. Pursuant to the Order of the Court, Audio Proceedings may be given to
Defendant at no cost Defense moves for a competency evaluation. Motion GRANTED.
Defendant is ordered to obtain a Competency Evaluation. Trial continued to October 15, 2012
at 9:00 A.M. Special Setfor Judge Sferrazza.

Request for audio CD al public expense from Defendant granted by Judge !iferrazza.
0910712012
WOrder Filed
Order for Competency Evaluation Pursuant to NRS 178.415 filed
0911212012

Requested by Zachary Coughlin.
09117/2012

requested by James Leslie, Deputy Public Defender
09117/2012
WRequest for AudIO CD filed

requested by James Leslie, Deputy Public Defender
1010212012
,.Ij Evaluation Completed

Competency EvaluatIOn
10122/2012
1012212012
Motion Hearing (10:00 AM) (Judicial Officer:

Competency/Motion Hearing
Public Defender
Defendant
Sferrazza, Peter)
The State of Nevada
Leslie, Jim
Young, Zach

Defendant has been found competent. Defendant has indicated that he would /tke to represent
PAGE 5 OF 9
Printed on 1210512012 at 10:29 AM
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2011-063341
himself Defendant Farelta Canvassed. Defendant's moHon to represent him,elofis
GRANTED The Court also appointes Public Defender Jim Leslie as standby counsel. Motion
by Defendant to have transcript prepared at public expense. Motion DENIED. Trial confirmed
set for November 19. 2012. at 8'30 AM.
10/23/2012
iii Request for Audio CD Filed

requested by Undo Gray from the Public Defender'S Office
10/3012012
10130/2012
11107/2012
{i] Authorization to Represent Filed

Request for Audio CD Filed
requested by Defendant
6J Motion Filed
Motion To Quash Sllbpoena Duces Tecum.
11107/2012
ru Response
Response To Subpoena Duces Tecums
]]10712012
iii Motion Filed

Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding
Issuance of Subpoenas
11108/2012

Motion to shorten time
Parties Present: Witness
IlI08/2012
SlulU, Creigton
iii Order Piled

Ex Parte Emergency Order Pendmg Hearing
11108/2012
HeaTIng Result (judicial Officer: Sferrazza, Peter)

Ex-Parte Emergency Order Pending Hearing to be filed by the Reno City Attorneis office.
Hearing set for November 13, 2012. at 9:00 A.M.
11108/2012

Reno CIty Attorney's Office to prepare Ex Parte Emergency Order and serve Defendant and
the Public Defender's Office. Hearing set for November 13. 2012. at 9:00 A.M.
11/08/2012
WNotice
Affidavit ofServIce
]]113/2012
Motion Hearing (9:00 AM) (Judic,al Officer: Sferrazza, Peter)

II II 312012
Continued to 1111312012 - MSC Reset/Continuance - Coughlin. Zachary
Barker
Parties Present: Defendant
Witness
Skau, Creigton
11/13/2012
HeaTIng Result (Judicial Officer. Sferrazza, Peter)

City ofReno City Attorney present, Crelg Skau representing a number of City of Reno
Employees, which are listed m Mr. Skau's motions or pleadings. Pursuant to the Courl's order,
Mr Coughlin shall provide to the Court the subpoenas proofof witness fees paid, Mr.
Coughlin had served with anginal proofof service with no more than a one page document for
each subpoena as to why the person was subpoenaed; Why it lS necessary for the person that
was supboenaed to be present for trial and why the subpoenaed testimony or documents are
relevant. Defendant shall provide the the original subpoenas and the supporting documents by
Thursday, November 15, 2012 by 11:00 A.M. The Court will make a decision as to whether the
persons who have been subpoenaed, shall be ordered to be present for this case. The City of
Reno is ordered to allow Mr. Coughlin to pick up the City of Reno Police Report and City of
PAGE 6 OF 9
Printed on 12/05/2012 at 10'29AM
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2011-063341
Reno E-COMM malenats regarding case RMC 2011-063341 without paying the cost of
$108.00. Mr. Skau indicates he WIll ensure this will happen, ifMr. Coughlin makes an
appointment to appear at the City Attorney's Office at a specific date or time. Defendant shall
file all original affidavits or declarations or certificates ofservice wllh the Court, if Mr.
Coughlin wants the subpoenas to be honored. The subpoenas served by mail must be properly
issued and served TEN (10) days In advance and must be reve/ant to this case. No new
subpoenas are to be lssued unless the Court reviews them prior to service, must be relevant to
case and witness Jees paid unless proof is provided that the Court ordered the subpoenas can
be served without a wllness fee.
11114/2012
Q.) Motton Filed

Motion To Quash Subpoenas
1111 5/2012
iii Motion Filed

Motion for Mistrail and Memorandum of Law
11115/2012
iii Motion Filed

Submission of Materials Related to Return a/Service a/Subpoena and Motion for Order for
Austm Llchtis Address from DMV
11/16/2012
iii Order Filed

Order Denying Motions For Mistrial And Continuance.
11116/2012
11119/2012
iii Order Filed

THIS CASE RCR2011-063341 is a SPECIAL SET FOR JUDGE SFERRAZZA CONTINUED
TRIAL FOR COUGHLIN
101/512012
Continued to 11/1912012 - Pre-Trial Reset/Continuance - The State of
Nevada; Coughlin, Zachary Barker
The State of Nevada
Defendant
1111912012
11119/2012
Young, Zach
Hearing Result (JudiCIal Officer: Sferrazza, Peter)

Defendant will be allowed the audio recordingfor this hearmg at no cost. Court orders
payment ofa wItness fee t~ Colton Goble at a later time. Defense moved for continuance due
to missing witnesses State opposed DENIED. Case continued to November 20, 2012.
iii Motion F,ied

Motion for Mistrial and or Continuance
11/2012012

Parlles Present: Plaintiff
The State afNevada

Young, Zach
Defendant
Public Defender
Leslie, James Briand
1112012012
Hearing Result (Judicial Officer: Clifton, DavId)

Jim Leslie of the Public Defenders Office has been released as Co-couYlsel and lS no longer
required to attend any further hearings regarding this case.
11120/2012
Disposition (Judicial Officer: Sferrazza, Peter)

L PETIT LARCENY
Found Guilty
2. POSSESSION OF STOLEN PROPERTY
Found Guilty
11/20/2012
Sentence (Judicial Officer: Sferrazza, Peter)
PAGE70F9
Printed on 1210512012 at /O29AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011063341
I. PETIT LARCENY
SUSPENDED
Sentence to Confinement
Agency: Washoe County Jail
Term: 180 Days
CTS: 7 Days
Comment: not to exceed ONE (I) to TWO (2) years.
1112012012
Amended Sentence (Judicial Officer: Sferrazza, Peter)

1. PETIT LARCENY
IMPOSED
Condition - Adult:
l. Department of Alternative Sentencing, SupervisIon for 1-2 years. All supervision
fees are WAIVED. 11120/2012, Active 11120/2014
2. Abstain from Drugs and Alcohol, 1112012012, Closed 1112012012
3. No Further V101ations, 1112012012, Closed 1112012012
4. Proof of Evaluation and to Follow Evaluation Recommendations, To obtain a
Mental Health Evaluation and provide proof to the Court. 11/20/2012, Active
1212012012
5. Other, Defendant is to take all prescribed medications. 11120/2012, Closed
11120/2012
11120/2012
WOrder to Attend Filed
1112012012
WRequest for AudIO CD Filed
11/2112012
WMisdemeanor Judgment FIled
11126/2012

requested by Zachary) Coughlin
1112612012

requested by CreIg Skau, Esq., Reno City Attorney's Office
11126/2012
WMotion Filed
unreadable
1112612012
WMotion Filed
Emergency Ex Parte Motion/or Extension a/Time to File Motion/or New Trwl; Motion/or
MIStrIal; Motion to Strt'ke; Motion for Arrest of Judgment

11127/2012
WMotIon Filed
Emergency Ex Parte Motion/or Extension ofTlme to File Motionfor New Trial; Motion/or
Mistrial; Motion to Strike; Motion for Arrest ofJudgment
1113012012
Request for Audio CD Filed

requested by James LeslIe, Deputy Public Defender
DATI'
Defendant Coughlin, Zachary Barker

Total Charges
Total Payments and CredIts
Balance Due as of 1215120n
75.00
0.00
75.00
Defendant Coughlin, Zachary Barker

Bond Balance as of 121512012
465.00
PAGE80F9
Printed on 12105/2012 at 10:29AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
PAGE90F9
Prmted on 1210512012 at 10:29 AM

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Code 3700

IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

ZACHARY BARKER COUGHLIN, .

Dept. No., 'II)

In the Justice Court of Reno Township, County of Washoe

Case No.: RCR 2011-063341

Notice Of Appeal; Designation of Record; Request For Transcripts

Pre-Trial Brief: Motion For Summary Judgment

30. Order For Competency Evaluation Pursuant To NRS 178.415

Defendant's Exhibit "5"

Dated this December 5, 2012.

Deputy Court Clerk

With Document Code:

IN THE JUSTICE COUR r OF RENO TOWNSHIP

STATE OF NEV ADA:

) CASE NO: RCR2011-063341

\that nrs 4.14(a) only applies to civil cases.

I\PPEALS TO DISTRICT COURT

*113091---(NRS A 1995, 1536)

11911 Cr. i'mc.

663; RL 7513; NCL 11310J----{NRS A 1967,

NRS 189.060 Grounds for dismissal of appeal; enforcement of judgment.

(b) For failure to appear in the district court when required.

IPart 1911 Cr. Prac.

*666; RL 7516; NCL *11313]

(Added to NRS by 1965,376; A 1985.57,972)

3. That the fact'i stated do not

deciding upon this matter.

AFFIRMATION AND DECLARATION

DATED this 28th of August, 2012:

Zachary N. Young, Esq,

Jim LcIsie, Esq.

DA TED this 28th of August 201-'2:

Zach C ghlin, Esq./<'

- 4/4 NnTJr~j:;' {)V

'-' m6{..& !Ker e ..

APPLICATION FOR APPOINTMENT

... --+- - -----

PRETRiAL SERVICES OFFICER

GRANTED. The Court

Washoe County Pretrial Services

-- ---------- ---- -------------- -I

-----_._--------- ---- ----Age

Counts Court Bail Amt/Type

RENO POLICE DEPT

121 RIVER ROCK ST.

lime at Current Addross

Defcndant Justicc Identifier Codes/Criminal History

Incident No. L000144bb

Determination of Indigency Report

Client: COIJGHL IN, ZACHARY BARKER

RENO JUSTICE COURT

121 RIVER ROCK ST. RENO, NV 89501

Occupation and Employer:

IN THE JUSTICE COURT OF RENO TOWNSHIP BY-~~,--L

COUNTY OF WASHOE, STATE OF NEVADA

THE STATE OF NEVADA,

ZtlCtfMLy BM1LEpe Co~~2 it!.

ORDER FOR COMPETENCY EVALUATION PURSUANT TO NRS 178.415

cause appearing therefor,

Developmental Services of the

Department of Health and Human

If the Defendant is not of sufficient mentality

666; RL 7516; NCL 11313]