12 5 12 065630 Refiled From 11 27 12 With New Addition To Ex 1opposition To Motion To Amend, or Alternatively, Motion For Reconsideration of

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11C14C19, the matte) i- cu))entl> -et *o) a !)ial on Decem'e) 11th, at &hich time no &itne--e- &ill 'e
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4)o(o-ed Com(laint,
Vi)a>
St)om'e)g
()e-ent. D !he State no& -ee@- to amend the cha)ge to a mi-demeano) o**en-e o* Re-i-ting, Dela>ing,
o) 2'-t)ucting a 4u'lic 2**ice) in +iolation o* NRS 199.8%A;9 *o) the im(e)mi--i'le (u)(o-e o*
le+e)aing SCR 111A$9. !he Com(laint a- amended doe-nDt e+en 'eging to -tate *act- that -u((o)t the
element- )eEui)ed, and i- +iolati+e o* R4C ;.8. S
... ,R71<EN! , cou)t ma>, in it- di-c)etion, allo& *o) an amendment to a cha)ging document
u(on ()o(e) motion ()o+ided doing -o i- not o+e)l> ()eFudicial to the de*endnat, 'ut it i- he)e, and the
-tateD- (u()o-e in -o amending i- im()o(e).. +. State, 11 Ne+. 159, 1$ A%%59. NRS 17;.%95 A19
()o+ide-: B!he cou)t ma> (e)mit an indictment o) in*o)mation to 'e amended at an> time 'e*o)e
+e)dict o) *inding i* no additional o) di** e)ent o**en-e i- cha)ged and i* -u'-tantial )ight- o* the
de*endant a)e not ()eFudiced.B .n the in-tant matte), the State -ee@- to amend the cha)ge to a
mi-demeano), the)e'> )e-ol+ing the ca-e at the 0u-tice Cou)t le+el. !he ()o(o-ed cha)ge e--entiall>
allege- the -ame mi-conduct a- &a- alleged in the o)iginal cha)ge. !he State doe- thi- in the inte)e-t-
o* Fu-tice, and -uch i- (e)mi--i'le 'a-ed on the StateD- +e-ted di-c)etion in cha)ging ca-e-. See +.
State, 15 Ne+. 1, $ A%%99 Aac@no&ledging that Ba ()o-ecuto) ha- ')oad di-c)etion i) cha)ging a
de*endantB and that B-o long a- the ()o-ecuto) ha- ()o'a'le cau-e to 'elie+e that the accu-ed
committed an o**en-e de*ined '> -tatute, the deci-ion &hethe) o) not to ()o-ecute, and &hat cha)ge to
*ile o) ')ing 'e*o)e a g)and Fu)>, gene)all> )e-t- enti)el> in hi- di-c)etionB9.
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OPPOSITION TO MOTION TO AMEND, OR ALTERNATIVELY, MOTION FOR RECONSIDERATION OF
ORDER GRANTING STATE'S !LY 31ST, 2012 MOTION TO AMEND
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-uch an amendment doe- not ()eFudice the De*endant, a- unde) the ()o(o-ed amended cha)ge, he
&ould 'e -u'Fect onl> to c)iminal (uni-hment o* a mi-demeano) )athe) than the ha)-he) (otential
-entence o* the o)iginal cha)ge, &hich i- a g)o-- mi-demeano). "inall>, thi- ()o(o-ed amendment i-
timel> and 'eing made &ell in ad+ance o* t)ial :in *act, the onl> hea)ing cu))entl> -et in thi- matte) i-
a hea)ing &ithout &itne--e-.
.... C2NC81S.2N !he State he)e'> )e-(ect*ull> )eEue-t- that thi- Cou)t den> it <otion *o) 8ea+e
o* Cou)t to ,mend Com(laint, -o that thi- matte) ca ()oceed to t)ial a- a mi-demeano).
,"".R<,!.2N 41RS1,N! !2 NRS ;9?.%;%
AFFIRMATION AND DECLARATION
. decla)e, (u)-uant to NRS 5.%45, unde) (enalt> o* (e)Fu)> unde) the la&- o* the State o*
Ne+ada that the *o)egoing i- t)ue and co))ect and that thi- document doe- not contain an> -ocial
-ecu)it> num'e)-, (u)-uant to NRS ;9?.%;%, an a**i)mation to that e**ect thi- he)e'> i-.
D,!ED thi- 7!/, 2" No+em'e), %1
GC-C Zach Coughlin
Zach Coughlin
DE"END,N!
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4R22" 2" SERV.CE
2N thi- date, . cau-ed a co(> o* the *o)egoing document - to 'e -e)+ed u(on the *ollo&ing '>
-ending to thei) )egi-te)ed email add)e-- and *a# num'e) a- *ound on &&&.n+'a).o)g, hand deli+e)>
to d)o(-lot o) *)ont de-@, and '> (lacing a t)ue and co))ect co(> o* the *o)egoing document in the
1.S. mail add)e--ed to:
Zacha)> N. 5oung, E-E.
3a-hoe Count> D,
1 South Sie))a 4.2. ?o# ;%%8;
Reno , NV 895%
4hone Num'e): 775:;8:;%% "a# num'e): 775:;5:$7%;
Email: H>oungIda.&a-hoecount>.u-
?i)a> Dogan, E-E.
3a-hoe Count> 4u'lic De*ende)D- 2**ice
4.2. ?o# ;%%8; Reno , NV 895%9
4hone Num'e): 775:;;7:48$8 "a# num'e): 775:;;7:485$
Email: 'doganI&a-hoecount>.u-
0ERE<5 !. ?2S8ER, E-E.
?a) No. 495
2ne Cali*o)nia ,+e
Reno, NV 895%9
A7759 ;;7:48%%
,tto)ne> *o) De*endant
D,!ED thi- 7th o* No+em'e), %1
GGGGGGGGGGGGGGG
Zach Coughlin
DE"END,N!
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.NDEJ !2 EJ/.?.!S
E#hi'it 1: +a)io-u mate)ial-
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CODE 2<)60 2Ql2FEB 21 PH I: 31
I THEJUSTICECOLIRTOF RENO roWNSHIP
INAND FOR TilECOUNTY OF WASHOE, STATE01' NEVADA
THESTATEOFNEVADA,
Plaintiff,
vs.
Case No.'(/...C'((. 1L OC:::>':J(;30
15. ):Y)
0. _1-
Dclcndant.
____________________1
ORDERFOR [VALUATIONS
Uponmotionofwunsd lor Dcfendwl! herein nnd good causeappearing thcrcl,m;,
IT IS HEREBY ORDERED that the Ddcnd'Ult beexamined by two psychiatrists,
two psychologists, orone psychiatristand one psychologist from Lake's Crossing fo rthe purpose
ufdetermining whetherthe Defeodant has the presentabihtyto:
I . Understand the natureofthe criminal chargesagainsthun;
2. Untkrst,md the nature and purposeofthecoun pruceeull1gs; or
3. Aid and assist hiscuunscl In thedefense"ith areasonabledegreeofratillnal
understailliing.
I;
/,/
1
, "

, , -
1 IT IS FURTHER ORDERED Ih"t th" is lu bdurc
2 Hunorabk E//,?'It uf Ihe SI!cond JuJlcial Dislrict Court. Dcpartmcnt \ 11\
...1'\
J 121Il!12 30 at hour of < '.5ZJ for a competcncy
1
cvaluation
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DATED \
.20 / ,;)"
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JUST ICE OF 'I'll EACE
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02127.2012
02t2sn012
0)022012
0]/15/2012
0]n9/2012
OSnJ/ 2012
0713 112012
OSlO9 2012
08/ 09 2012
0&09 2012
08/ 21 2012
081 21 / 2012
0827.2012
0827,2012
0827(20[2
08/ 2712012
CASE S MMARY
CASE NO. RCRl012-065630
1500 00 Hond or Cash Ball Ball Condlllond &1 by lhe lIonoruble Scali Peurson
^1aD:aIut} hlaIu5Conference (I ]0 PM) (1Bd1C18 '1!Ccf bf00Cf.18CX|
L3Scf8hSclfcd I0 Ph0Icf L0uU
10 D C lflmOl1 PS)CII
5ufClyHond oSIcd
Uohd LXuDCf8Icd
CANCELED M:lldlIOJ bIIuSConference (I ;30 I'M) (Jullkial OrCtr: L) nch, "atrlcl.)
V(ealt
9 KCmDd lfom bcCoDd 1ud1018l 1lSIfICIL0BH Ilcd
Mallon 1!cd
MOl/Oil /or l.eal' o/ Courl lO Anamd ComplUlf// fled
9 KcqucSI of.Vud1OLL:lcd
r Iollon Filed
/0 '>rud I Forma Pal/puIS
Mallon Denied
to />rofed / Formu PUlI/rlS
rlotion IIlrln(I'30PM) (1udlcialOmcer bl0,clcl|
06I 121012 Continued 10 0 7116011 - MSC NeSeflCOnilnuunC' nlf Slate ol\e
l,
Cough/III, Zachar Barker
0 7//61011 Conllnued 10 08062 011-MSC ReSefCOrlllnuunc(' The Slate o/.\Ivada
Coughlin, Zochar)
' 8(1f/er
0861 1011 Can/li/led 10 081111011 MSC ResetlCanlllll/allCe Th, State o/ Nel'ada,
COl/ghlin, Zodlry 80rkfr
"OrllfS PrtSf'n/ P/allltif
!
Th! SIO/' 0/ Nemda
Public lk/emier Dog(/I, Hlfuy
Deputy Dlstricl Allarnf' YOIlllg,7, ,,eh
/)f/tlliam lOllRMlII, Zachar /arker
Hc8fmg KcSu!I l1ud10t3'!!Ccf` bcH8. clcf_
/Jo/endU/1/ /alled 10 appear, lk/ensl requests thal lhlS case bl COrll/fIIled Ulld sel >\llh hiS
IlIIsdemtolior Reno Jusllce Courl Cast set/or August )9,201) al 8 JOA M Sale opposes as
Ihls I AIr Cuugh/Ill's second "me/adlllg ID appear I/ense'
s mOilOn IS CRANTED MSC IS
set/or AI/gusl19, ]011 at 9 OA AI
^uI\un Il(arln (830 AM) {1ud1C18!'l!1Ccf bC 8. clcf|
PUrle S Present PIQlllllf 1t StOlt 0/ "elmia
lut' D,st"ct Alloe Young. Mch
De/endanl COUgh/III, /.chuf OorAer
PubliC De/endfr udl!e, Jumes O"ulld
Pmthdcd Lflmm8!LumQ8Ihl 1lcd {1u0lCI8'ICcf b clct
Stru:Aen
cM:hg KcSuI 1ud1018!'l10cf bCN ,l'clCI|
Thf Statf mow'd 10 smi Secold Amell ifd Cm7/lIIol Camploml
Mallon LI8Dlcd {1ud1018!'ICcf: bcH,cIcf_
/Q )"k( SeC(}d Amel/ded Crullnul Complaml
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J J# ABGUEN
A. The Trial Should Not Be Cont inued as t he Defendant Has Failed t o
Est ablish Good Cause
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THESTATEOFNEVADA,
Plaintiff,
vs.
Case No.'(/...C'((. 1L OC:::>':J(;30
15. ):Y)
0. _1-
Dclcndant.
____________________1
understailliing.
I;
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1
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, , -
...1'\
1
cvaluation
5
DATED \
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Document Code:
Zach Coughlin,Esq.
NV Bar No: 9473
4!! E. 9th "t. #!
$eno, NV %9&!
'ele: 77&(33%(%%
)a*: 949(++7(74,!
-ttorne. /or 0ro "e -ttorne. 1itigant
23"'4CE C53$' $EN5 '56N"740
6-"75E C53N'8, NEV-D-
0-$9 'E$$-CE '56N75:E" -""N
; 6E"'E$N NEV-D- :-N-<:EN',
4NC., <a.le -gnes 9ern, Esq. and <a.le -.
9ern. 1td.; 1-ND15$D 5$ D318
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1andlord,
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'enant.
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C-"E N5:
DE0'. N5:
?23D<E ")E$$-ZZ- 4ND4C-'ED the.
6531D N5' -CCE0' '74" C-"E )5$
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JURY TRIAL DEMANDED
'EN-N'@" -N"6E$ -ND 'EN-N'@"
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N5'4CE '5 B34'; :5'45N )5$
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'EN-N'@" -N"6E$ -ND 'EN-N'@" -))4D-V4'ADEC1-$-'45N '5 3, D-8 N5'4CE '5
B34'; :5'45N )5$ "-NC'45N" -ND -''5$NE8@" )EE"
054N'" -ND -3'75$4'4E"
'enantADe/endant, Zach Coughlin, Esq., hereC. /iles an -nsDer, or alternati=el., an
-mended 'enant@s -nsDer to the 3, da. N5'4CE '5 B34' -ND -N8 "3B"EB3EN' & D-8
N5'4CE '5 B34' 3N1-6)31 DE'-4NE$ N5'4CE,
'enant /urther mo=es /or sanctions against landlord, Eursuant to N$" 7.,%&, /or the attorne.s@ /ees
tenant has needlessl.
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'enant@s -nsDer and -//ida=itADeclaration to 3, Da. No Cause E=iction, 'enant@s Counterclaim
note: this was file stamped
2/27/12 by the RJC in
RJC REV2012-000374
disposed of by RJC Judge
Schroeder, on 3/15/12 on a default
basis where Coughlin was 8 minutes
late to the stacked docket hearing
coughlin, pursuant to wcso police was cuffed
and evicted at gunpoint
3 hours later.
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incurred due to 0arF 'errace and E' -1@s recFless uses o/ this court@s Erocesses. 0arF 'errace has not
comElied Dith the requirements o/ the rules o/ ci=il Erocedure the. seeFs to in=oFe. 7is
motion is /atall. /laDed and in/irm as a matter o/ laD.
'his oEEosition and motion is Cased on the Eoints and authorities CeloD, the
aCo=e(re/erenced statute and rules o/ ci=il Erocedure, and all EaEers and Eleadings on /ile
herein.
NRS 40.310 Issue of fact to be tried b !ur if "ro"er de#a$d #ade. %&e$e'er a$ issue of fact
is "rese$ted b t&e "(eadi$)s* it s&a(( be tried b a !ur* if "ro"er de#a$d is #ade "ursua$t to
t&e Ne'ada Ru(es of +i'i( ,rocedure or t&e Justice +ourt Ru(es of +i'i( ,rocedure.
C5:E" N56, the undersigned 'enant and states:
. 4 am the tenant o/ a rental united located at 4!! E. 9th "t. #!, $eno %9&!.
!. m. rent is not suCsidiGed C. EuClic housing authorit. or other go=ernmental agenc..
<laGier =. 2ustice Court o/ "mith Valle. 'E., Ne=. %+4, %99 0.!d ,& ?Ne=. 2ul !7, 99&>:
H"ummar. e=iction statute alloDing landlord to aEEl. to Iustice@s court /or e=iction
order Cased on de/ault in Ea.ment o/ rent did not aEEl. to unlaD/ul detainer action
against tenant Dho ne=er Eaid an. rent nor Das required to Ea. an. and, thus,
summar. e=iction order Das outside Iurisdiction o/ Iustice@s court. N.$.". 4,.!&3..5n
:arch , 993, $ichard )ulstone, Eresident o/ )ulstone, ser=ed <laGier Dith a thirt.(
da. notice to quit the EroEert.. <laGier /ailed to =acate the Eremises,and on -Eril !,
993, )ulstone ser=ed <laGier Dith a /i=e(da. notice. 'his notice e*Eressl.
threatened an action in Iustice@s court /or e=iction, Eursuant to N$" 4,.!&3,)N the
summar. e=iction statute. )N. N$" 4,.!&3 alloDs a landlord to aEEl. to the Iustice@s
court /or an e=iction order Cased on de/ault in Ea.ment o/ rent. 4/ the tenant can
shoD, C. a//ida=it, a legal de/ense to the alleged unlaD/ul detainer, /urther
Eroceedings must Ce conducted Eursuant to the more /ormal e=iction Erocedures in
N$" 4,.!9, to 4,.4!,. 4/, on the other hand, the tenant /ails to shoD a legal de/ense
to the alleged unlaD/ul detainer, then the Iustice@s court ma. issue a summar. order
/or remo=al o/ the tenant. 'he Iustice@s court held a hearing Eursuant to the Ero=isions
o/ N$" 4,.!&3 and ordered that <laGier =acate the EroEert. Dithin thirt. da.s.
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<laGier then /iled a Eetition /or a Drit o/ certiorari Ce/ore the district court, alleging
that the Iustice@s court e*ceeded its Iurisdiction under the Jsummar.K e=iction
Ero=isions o/ the statute C., inter alia, inquiring into matters Ce.ond the truth/ulness
and su//icienc. o/ the a//ida=its, and /ailing to dismiss the Jsummar.K e=iction
Eroceeding once a legal de/ense had Ceen raised. 'he district court held a hearing on
the Drit Eetition and denied the Eetition. 5n aEEeal to this court, <laGier argues that,
Eursuant to N$" 4,.!&3, once he raised the legal de/ense that he Das a li/e tenant
under the grant o/ a li/e estate, the Iustice@s court Das oCligated to dismiss the
Jsummar.K Eroceeding and to require that the landlord Erosecute his unlaD/ul
detainer action under the JElenar.K e=iction Eroceedings Ero=ided /or in N$" 4,.!9,
to 4,.4!,. LL,+ -lthough <laGier@s argument is logicall. sound, it is simEl.
irrele=ant. 4t is clear that, desEite all the Eroceedings CeloD and the arguments o/ the
Earties Ce/ore this court, N$" 4,.!&3 does not aEEl. to this case. 'he statute is
aEElicaCle JDhen the tenant o/ an. dDelling M N Dith Eeriodic rent reser=ed C. the
month or an. shorter Eeriod, is in de/ault in Ea.ment o/ the rent.K ?EmEhasis L%++
added.> -ll Earties to this action concede that <laGier ne=er Eaid an. rent, nor Das he
required to Ea. an.. 4t ma. Ce that )ulstone is entitled to ha=e <laGier remo=ed /rom
the EroEert., Cut not Eursuant to N$" 4,.!&3. 'here Das no case or contro=ers.
Ce/ore the Iustice@s court Cased on N$" 4,.!&3, and accordingl., the Iustice@s court
e*ceeded its Iurisdiction C. issuing the summar. e=iction order. -ccordingl., De
re=erse the Iudgment o/ the district court and remand to the district court Dith
directions to grant the Drit. )urther, De order that the e=iction order entered C. the
Iustice@s court Ce =acated. Ne=.,99&. <laGier =. 2ustice Court o/ "mith Valle. 'E.
Ne=. %+4, %99 0.!d ,&, "ee, also, Ne=.,99+. 1iEEis =. 0eters ! Ne=. ,,%,
9! 0.!d !4%H
N$" 4,.!&3 3nlaD/ul detainer: "uEElemental remed. o/ summar. e=iction and e*clusion o/ tenant
/or de/ault in Ea.ment o/ rent. . E*ceEt as otherDise Ero=ided in suCsection ,, in addition to the
remed. Ero=ided in N$" 4,.!&! and 4,.!9, to 4,.4!,, inclusi=e, Dhen the tenant o/ an. dDelling,
aEartment, moCile home, recreational =ehicle or commercial Eremises Dith Eeriodic rent reser=ed C.
the month or an. shorter Eeriod is in de/ault in Ea.ment o/ the rent, the landlord or the landlordOs
agent, unless otherDise agreed in Driting, ma. ser=e or ha=e ser=ed a notice in Driting, requiring in
the alternati=e the Ea.ment o/ the rent or the surrender o/ the Eremises: ?a> -t or Ce/ore noon o/ the
/i/th /ull da. /olloDing the da. o/ ser=ice; or ?C> 4/ the landlord chooses not to Eroceed in the manner
set /orth in EaragraEh ?a> and the rent is reser=ed C. a Eeriod o/ DeeF or less and the tenanc. has
not continued /or more than 4& da.s, at or Ce/ore noon o/ the /ourth /ull da. /olloDing the da. o/
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ser=ice. P -s used in this suCsection, Jda. o/ ser=iceK means the da. the landlord or the landlordOs
agent Eersonall. deli=ers the notice to the tenant. 4/ Eersonal ser=ice Das not so deli=ered, the Jda. o/
ser=iceK means the da. the notice is deli=ered, a/ter Eosting and mailing Eursuant to suCsection !, to
the sheri// or constaCle /or ser=ice i/ the request /or ser=ice is made Ce/ore noon. 4/ the request /or
ser=ice C. the sheri// or constaCle is made a/ter noon, the Jda. o/ ser=iceK shall Ce deemed to Ce the
da. ne*t /olloDing the da. that the request is made /or ser=ice C. the sheri// or constaCle. !. -
landlord or the landlordOs agent Dho ser=es a notice to a tenant Eursuant to EaragraEh ?C> o/
suCsection shall attemEt to deli=er the notice in Eerson in the manner set /orth in EaragraEh ?a> o/
suCsection o/ N$" 4,.!%,. 4/ the notice cannot Ce deli=ered in Eerson, the landlord or the landlordOs
agent: ?a> "hall Eost a coE. o/ the notice in a consEicuous Elace on the Eremises and mail the notice
C. o=ernight mail; and ?C> -/ter the notice has Ceen Eosted and mailed, ma. deli=er the notice to the
sheri// or constaCle /or ser=ice in the manner set /orth in suCsection o/ N$" 4,.!%,. 'he sheri// or
constaCle shall not acceEt the notice /or ser=ice unless it is accomEanied C. Dritten e=idence, signed
C. the tenant Dhen the tenant tooF Eossession o/ the Eremises, that the landlord or the landlordOs
agent in/ormed the tenant o/ the Ero=isions o/ this section Dhich set /orth the laD/ul Erocedures /or
e=iction /rom a short(term tenanc.. 3Eon acceEtance, the sheri// or constaCle shall ser=e the notice
Dithin 4% hours a/ter the request /or ser=ice Das made C. the landlord or the landlordOs agent. 3. -
notice ser=ed Eursuant to suCsection or ! must: ?a> 4denti/. the court that has Iurisdiction o=er the
matter; and ?C> -d=ise the tenant: ?> 5/ the tenantOs right to contest the matter C. /iling, Dithin the
time sEeci/ied in suCsection /or the Ea.ment o/ the rent or surrender o/ the Eremises, an a//ida=it
Dith the court that has Iurisdiction o=er the matter stating that the tenant has tendered Ea.ment or is
not in de/ault in the Ea.ment o/ the rent; ?!> 'hat i/ the court determines that the tenant is guilt. o/ an
unlaD/ul detainer, the court ma. issue a summar. order /or remo=al o/ the tenant or an order
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Ero=iding /or the nonadmittance o/ the tenant, directing the sheri// or constaCle o/ the count. to
remo=e the tenant Dithin !4 hours a/ter receiEt o/ the order; and ?3> 'hat, Eursuant to N$" %-.39,,
a tenant ma. seeF relie/ i/ a landlord unlaD/ull. remo=es the tenant /rom the Eremises or e*cludes the
tenant C. ClocFing or attemEting to ClocF the tenantOs entr. uEon the Eremises or Dill/ull. interruEts
or causes or Eermits the interruEtion o/ an essential ser=ice required C. the rental agreement or
chaEter %- o/ N$". 4. 4/ the tenant /iles such an a//ida=it at or Ce/ore the time stated in the notice,
the landlord or the landlordOs agent, a/ter receiEt o/ a /ile(stamEed coE. o/ the a//ida=it Dhich Das
/iled, shall not Ero=ide /or the nonadmittance o/ the tenant to the Eremises C. locFing or otherDise. &.
3Eon noncomEliance Dith the notice: ?a> 'he landlord or the landlordOs agent ma. aEEl. C. a//ida=it
o/ comElaint /or e=iction to the Iustice court o/ the toDnshiE in Dhich the dDelling, aEartment,
moCile home or commercial Eremises are located or to the district court o/ the count. in Dhich the
dDelling, aEartment, moCile home or commercial Eremises are located, Dhiche=er has Iurisdiction
o=er the matter. 'he court ma. thereuEon issue an order directing the sheri// or constaCle o/ the
count. to remo=e the tenant Dithin !4 hours a/ter receiEt o/ the order. 'he a//ida=it must state or
contain: ?> 'he date the tenanc. commenced. ?!> 'he amount o/ Eeriodic rent reser=ed. ?3> 'he
amounts o/ an. cleaning, securit. or rent deEosits Eaid in ad=ance, in e*cess o/ the /irst monthOs rent,
C. the tenant. ?4> 'he date the rental Ea.ments Cecame delinquent. ?&> 'he length o/ time the tenant
has remained in Eossession Dithout Ea.ing rent. ?+> 'he amount o/ rent claimed due and delinquent.
?7> - statement that the Dritten notice Das ser=ed on the tenant in accordance Dith N$" 4,.!%,. ?%>
- coE. o/ the Dritten notice ser=ed on the tenant. ?9> - coE. o/ the signed Dritten rental agreement,
i/ an.. ?C> E*ceEt Dhen the tenant has timel. /iled the a//ida=it descriCed in suCsection 3 and a /ile(
stamEed coE. o/ it has Ceen recei=ed C. the landlord or the landlordOs agent, and e*ceEt Dhen the
landlord is ErohiCited Eursuant to N$" %-.4%,, the landlord or the landlordOs agent ma., in a
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EeaceaCle manner, Ero=ide /or the nonadmittance o/ the tenant to the Eremises C. locFing or
otherDise. +. 3Eon the /iling C. the tenant o/ the a//ida=it Eermitted in suCsection 3, regardless o/ the
in/ormation contained in the a//ida=it, and the /iling C. the landlord o/ the a//ida=it Eermitted C.
suCsection &, the Iustice court or the district court shall hold a hearing, a/ter ser=ice o/ notice o/ the
hearing uEon the Earties, to determine the truth/ulness and su//icienc. o/ an. a//ida=it or notice
Ero=ided/or in this section. 4/ the court determines that there is no legal de/ense as to the alleged
unlaD/ul detainer and the tenant is guilt. o/ an unlaD/ul detainer, the court ma. issue a summar.
order /or remo=al o/ the tenant or an order Ero=iding /or the nonadmittance o/ the tenant. 4/ the court
determines that there is a legal de/ense as to the alleged unlaD/ul detainer, the court shall re/use to
grant either Eart. an. relie/, and, e*ceEt as otherDise Ero=ided in this suCsection, shall require that
an. /urther Eroceedings Ce conducted Eursuant to N$" 4,.!9, to 4,.4!,, inclusi=e. 'he issuance o/ a
summar. order /or remo=al o/ the tenant does not Ereclude an action C. the tenant /or an. damages
or other relie/ to Dhich the tenant ma. Ce entitled. 4/ the alleged unlaD/ul detainer Das Cased uEon
suCsection & o/ N$" 4,.!&4, the re/usal C. the court to grant relie/ does not Ereclude the landlord
therea/ter /rom Eursuing an action /or unlaD/ul detainer in accordance Dith N$" 4,.!&. 7. 'he
tenant ma., uEon Ea.ment o/ the aEEroEriate /ees relating to the /iling and ser=ice o/ a motion, /ile a
motion Dith the court, on a /orm Ero=ided C. the clerF o/ the court, to disEute the amount o/ the
costs, i/ an., claimed C. the landlord Eursuant to N$" %-.4+, or %C.!3, /or the in=entor.,
mo=ing and storage o/ Eersonal EroEert. le/t on the Eremises. 'he motion must Ce /iled Dithin !,
da.s a/ter the summar. order /or remo=al o/ the tenant or the aCandonment o/ the Eremises C. the
tenant, or Dithin !, da.s a/ter: ?a> 'he tenant has =acated or Ceen remo=ed /rom the Eremises; and
?C> - coE. o/ those charges has Ceen requested C. or Ero=ided to the tenant, P Dhiche=er is later. %.
3Eon the /iling o/ a motion Eursuant to suCsection 7, the court shall schedule a hearing on the
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motion. 'he hearing must Ce held Dithin , da.s a/ter the /iling o/ the motion. 'he court shall a//i*
the date o/ the hearing to the motion and order a coE. ser=ed uEon the landlord C. the sheri//,
constaCle or other Erocess ser=er. -t the hearing, the court ma.: ?a> Determine the costs, i/ an.,
claimed C. the landlord Eursuant to N$" %-.4+, or %C.!3, and an. accumulating dail. costs;
and ?C> 5rder the release o/ the tenantOs EroEert. uEon the Ea.ment o/ the charges determined to Ce
due or i/ no charges are determined to Ce due. 9. - landlord shall not re/use to acceEt rent /rom a
tenant that is suCmitted a/ter the landlord or the landlordOs agent has ser=ed or had ser=ed a notice
Eursuant to suCsection i/ the re/usal is Cased on the /act that the tenant has not Eaid collection /ees,
attorne.Os /ees or other costs other than rent, a reasonaCle charge /or late Ea.ments o/ rent or
dishonored checFs, or a securit.. -s used in this suCsection, Jsecurit.K has the meaning ascriCed to it
in N$" %-.!4,. ,. 'his section does not aEEl. to the tenant o/ a moCile home lot in a moCile
home EarF or to the tenant o/ a recreational =ehicle lot in an area o/ a moCile home EarF in this "tate
other than an area designated as a recreational =ehicle lot Eursuant to the Ero=isions o/ suCsection +
o/ N$" 4,.!&. N$" 4,.!%, "er=ice o/ notices to quit; Eroo/ required Ce/ore issuance o/ order to
remo=e. . E*ceEt as otherDise Ero=ided in N$" 4,.!&3, the notices required C. N$" 4,.!& to
4,.!+,, inclusi=e, ma. Ce ser=ed: ?a> B. deli=ering a coE. to the tenant Eersonall., in the Eresence o/
a Ditness; ?C> 4/ the tenant is aCsent /rom the tenantOs Elace o/ residence or /rom the tenantOs usual
Elace o/ Cusiness, C. lea=ing a coE. Dith a Eerson o/ suitaCle age and discretion at either Elace and
mailing a coE. to the tenant at the tenantOs Elace o/ residence or Elace o/ Cusiness; or ?c> 4/ the Elace
o/ residence or Cusiness cannot Ce ascertained, or a Eerson o/ suitaCle age or discretion cannot Ce
/ound there, C. Eosting a coE. in a consEicuous Elace on the leased EroEert., deli=ering a coE. to a
Eerson there residing, i/ the Eerson can Ce /ound, and mailing a coE. to the tenant at the Elace Dhere
the leased EroEert. is situated. !. "er=ice uEon a suCtenant ma. Ce made in the same manner as
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Ero=ided in suCsection . 3. Be/ore an order to remo=e a tenant is issued Eursuant to suCsection & o/
N$" 4,.!&3, a landlord shall /ile Dith the court a Eroo/ o/ ser=ice o/ an. notice required C. that
section. Be/ore a Eerson ma. Ce remo=ed as ErescriCed in N$" 4,.!9, to 4,.4!,, inclusi=e, a
landlord shall /ile Dith the court Eroo/ o/ ser=ice o/ an. notice required Eursuant to N$" 4,.!&&.
E*ceEt as otherDise Ero=ided in suCsection 4, this Eroo/ must consist o/: ?a> - statement, signed C.
the tenant and a Ditness, acFnoDledging that the tenant recei=ed the notice on a sEeci/ied date; ?C> -
certi/icate o/ mailing issued C. the 3nited "tates 0ostal "er=ice; or ?c> 'he endorsement o/ a sheri//,
constaCle or other Erocess ser=er stating the time and manner o/ ser=ice. 4. 4/ ser=ice o/ the notice
Das not deli=ered in Eerson to a tenant Dhose rent is reser=ed C. a Eeriod o/ DeeF or less and the
tenanc. has not continued /or more than 4& da.s, Eroo/ o/ ser=ice must include: ?a> - certi/icate o/
mailing issued C. the 3nited "tates 0ostal "er=ice or C. a Eri=ate Eostal ser=ice to the landlord or the
landlordOs agent; or ?C> 'he endorsement o/ a sheri// or constaCle stating the: ?> 'ime and date the
request /or ser=ice Das made C. the landlord or the landlordOs agent; ?!> 'ime, date and manner o/
the ser=ice; and ?3> )ees Eaid /or the ser=ice. N$" %-.,, J1andlordK de/ined. J1andlordK means
a Eerson Dho Ero=ides a dDelling unit /or occuEanc. C. another Eursuant to a rental agreement. N$"
%-.!, J5DnerK de/ined. J5DnerK means one or more Eersons, Iointl. or se=erall., in Dhom is
=ested: . -ll or Eart o/ the legal title to EroEert., e*ceEt a trustee under a deed o/ trust Dho is not in
Eossession o/ the EroEert.; or !. -ll or Eart o/ the Cene/icial oDnershiE, and a right to Eresent use and
enIo.ment o/ the Eremises. N$" %-.&, J$entK de/ined. J$entK means all Eeriodic Ea.ments to
Ce made to the landlord /or occuEanc. o/ a dDelling unit, including, Dithout limitation, all reasonaCle
and actual late /ees set /orth in the rental agreement. ?-dded to N$" C. 977, 33; - 999, 9%4>.
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'his action is Crought to address )ederal )air 7ousing or Ne=ada laDs ErohiCiting discrimination. 4
am Ceing discriminated against Cased on imEermissilCe characteristics. )urther, m. lease has not
e*Eired or terminated .et. N$" %-.+, J$ental agreementK de/ined. J$ental agreementK means
an. oral or Dritten agreement /or the use and occuEanc. o/ a dDelling unit or Eremises. ?-dded to
N$" C. 977, 33>
N$" %-.&, $etaliator. conduct C. landlord against tenant ErohiCited; remedies; e*ceEtions. .
E*ceEt as otherDise Ero=ided in suCsection 3, the landlord ma. not, in retaliation, terminate a
tenanc., re/use to reneD a tenanc., increase rent or decrease essential items or ser=ices required C.
the rental agreement or this chaEter, or Cring or threaten to Cring an action /or Eossession i/: ?a> 'he
tenant has comElained in good /aith o/ a =iolation o/ a Cuilding, housing or health code aEElicaCle to
the Eremises and a//ecting health or sa/et. to a go=ernmental agenc. charged Dith the resEonsiCilit.
/or the en/orcement o/ that code; ?C> 'he tenant has comElained in good /aith to the landlord or a laD
en/orcement agenc. o/ a =iolation o/ this chaEter or o/ a sEeci/ic statute that imEoses a criminal
Eenalt.; ?c> 'he tenant has organiGed or Cecome a memCer o/ a tenantOs union or similar
organiGation; ?d> - citation has Ceen issued resulting /rom a comElaint descriCed in EaragraEh ?a>; ?e>
'he tenant has instituted or de/ended against a Iudicial or administrati=e Eroceeding or arCitration in
Dhich the tenant raised an issue o/ comEliance Dith the requirements o/ this chaEter resEecting the
haCitaCilit. o/ dDelling units; ?/> 'he tenant has /ailed or re/used to gi=e Dritten consent to a
regulation adoEted C. the landlord, a/ter the tenant enters into the rental agreement, Dhich requires
the landlord to Dait until the aEEroEriate time has elaEsed Ce/ore it is en/orceaCle against the tenant;
or ?g> 'he tenant has comElained in good /aith to the landlord, a go=ernment agenc., an attorne., a
/air housing agenc. or an. other aEEroEriate Cod. o/ a =iolation o/ N$" %.,, to %.!,,
inclusi=e, or the )air 7ousing -ct o/ 9+%, 4! 3.".C. QQ 3+, et seq., or has otherDise e*ercised
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rights Dhich are guaranteed or Erotected under those laDs. !. 4/ the landlord =iolates an. Ero=ision o/
suCsection , the tenant is entitled to the remedies Ero=ided in N$" %-.39, and has a de/ense in
an. retaliator. action C. the landlord /or Eossession. 3. - landlord Dho acts under the circumstances
descriCed in suCsection does not =iolate that suCsection i/: ?a> 'he =iolation o/ the aEElicaCle
Cuilding, housing or health code o/ Dhich the tenant comElained Das caused Erimaril. C. the lacF o/
reasonaCle care C. the tenant, a memCer o/ his or her household or other Eerson on the Eremises Dith
his or her consent; ?C> 'he tenanc. is terminated Dith cause; ?c> - citation has Ceen issued and
comEliance Dith the aEElicaCle Cuilding, housing or health code requires alteration, remodeling or
demolition and cannot Ce accomElished unless the tenantOs dDelling unit is =acant; or ?d> 'he
increase in rent aEElies in a uni/orm manner to all tenants. P 'he maintenance o/ an action under this
suCsection does not Ere=ent the tenant /rom seeFing damages or inIuncti=e relie/ /or the landlordOs
/ailure to comEl. Dith the rental agreement or maintain the dDelling unit in a haCitaCle condition as
required C. this chaEter. N$" %-.3%, )ailure o/ landlord to suEEl. essential items or ser=ices. .
4/ the landlord is required C. the rental agreement or this chaEter to suEEl. heat, air(conditioning,
running Dater, hot Dater, electricit., gas, a /unctioning door locF or another essential item or ser=ice
and the landlord Dill/ull. or negligentl. /ails to do so, causing the Eremises to Cecome un/it /or
haCitation, the tenant shall gi=e Dritten notice to the landlord sEeci/.ing the Creach. 4/ the landlord
does not adequatel. remed. the Creach, or use his or her Cest e//orts to remed. the Creach Dithin 4%
hours, e*ceEt a "aturda., "unda. or legal holida., a/ter it is recei=ed C. the landlord, the tenant ma.,
in addition to an. other remed.: ?a> 0rocure reasonaCle amounts o/ such essential items or ser=ices
during the landlordOs noncomEliance and deduct their actual and reasonaCle cost /rom the rent; ?C>
$eco=er actual damages, including damages Cased uEon the lacF o/ use o/ the Eremises or the
diminution o/ the /air rental =alue o/ the dDelling unit; ?c> 6ithhold an. rent that Cecomes due
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during the landlordOs noncomEliance Dithout incurring late /ees, charges /or notice or an. other
charge or /ee authoriGed C. this chaEter or the rental agreement, until the landlord has attemEted in
good /aith to restore the essential items or ser=ices; or ?d> 0rocure other housing Dhich is comEaraCle
during the landlordOs noncomEliance, and the rent /or the original Eremises /ull. aCates during this
Eeriod. 'he tenant ma. reco=er the actual and reasonaCle cost o/ that other housing Dhich is in e*cess
o/ the amount o/ rent Dhich is aCated. !. 4/ the tenant Eroceeds under this section, the tenant ma. not
Eroceed under N$" %-.3&, and %-.3+, as to that Creach. 3. 'he rights o/ the tenant under this
section do not arise until the tenant has gi=en Dritten notice as required C. suCsection , e*ceEt that
the tenant ma., Dithout ha=ing gi=en that notice: ?a> $eco=er damages as authoriGed under EaragraEh
?C> o/ suCsection i/ the landlord: ?> -dmits to the court that the landlord had FnoDledge o/ the lacF
o/ such essential items or ser=ices; or ?!> 7as recei=ed Dritten notice o/ the uninhaCitaCle condition
caused C. such a lacF /rom a go=ernmental agenc. authoriGed to insEect /or =iolations o/ Cuilding,
housing or health codes. ?C> 6ithhold rent under EaragraEh ?c> o/ suCsection i/ the landlord: ?>
7as recei=ed Dritten notice o/ the condition constituting the Creach /rom a go=ernmental agenc.
authoriGed to insEect /or =iolations o/ Cuilding, housing or health codes; and ?!> )ails to remed. or
attemEt in good /aith to remed. the Creach Dithin the time ErescriCed in the Dritten notice o/ that
condition /rom the go=ernmental agenc.. 4. 'he rights o/ the tenant under EaragraEh ?c> o/ suCsection
do not arise unless the tenant is current in the Ea.ment o/ rent at the time o/ gi=ing Dritten notice
Eursuant to suCsection . &. 4/ such a condition Das caused C. the deliCerate or negligent act or
omission o/ the tenant, a memCer o/ his or her household or other Eerson on the Eremises Dith his or
her consent, the tenant has no rights under this section. ?-dded to N$" C. 977, 339; - 9%&, 4+;
9%7, 34; 999, !3,; !,,7, !%+; !,, !37> N$" %-.39, 3nlaD/ul remo=al or e*clusion o/
tenant or Dill/ul interruEtion o/ essential items or ser=ices; Erocedure /or e*Eedited relie/. . 4/ the
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landlord unlaD/ull. remo=es the tenant /rom the Eremises or e*cludes the tenant C. ClocFing or
attemEting to ClocF the tenantOs entr. uEon the Eremises, Dill/ull. interruEts or causes or Eermits the
interruEtion o/ an. essential item or ser=ice required C. the rental agreement or this chaEter or
otherDise reco=ers Eossession o/ the dDelling unit in =iolation o/ N$" %-.4%,, the tenant ma.
reco=er immediate Eossession Eursuant to suCsection 4, Eroceed under N$" %-.3%, or terminate
the rental agreement and, in addition to an. other remed., reco=er the tenantOs actual damages,
recei=e an amount not greater than R!,&,, to Ce /i*ed C. the court, or Coth. !. 4n determining the
amount, i/ an., to Ce aDarded under suCsection , the court shall consider: ?a> 6hether the landlord
acted in good /aith; ?C> 'he course o/ conduct CetDeen the landlord and the tenant; and ?c> 'he
degree o/ harm to the tenant caused C. the landlordOs conduct. 3. 4/ the rental agreement is terminated
Eursuant to suCsection , the landlord shall return all EreEaid rent and securit. reco=eraCle under this
chaEter. 4. E*ceEt as otherDise Ero=ided in suCsection &, the tenant ma. reco=er immediate
Eossession o/ the Eremises /rom the landlord C. /iling a =eri/ied comElaint /or e*Eedited relie/ /or the
unlaD/ul remo=al or e*clusion o/ the tenant /rom the Eremises, the Dill/ul interruEtion o/ an.
essential item or ser=ice or the reco=er. o/ Eossession o/ the dDelling unit in =iolation o/ N$"
%-.4%,. &. - =eri/ied comElaint /or e*Eedited relie/: ?a> :ust Ce /iled Dith the court Dithin &
Iudicial da.s a/ter the date o/ the unlaD/ul act C. the landlord, and the =eri/ied comElaint must Ce
dismissed i/ it is not timel. /iled. 4/ the =eri/ied comElaint /or e*Eedited relie/ is dismissed Eursuant
to this EaragraEh, the tenant retains the right to Eursue all other a=ailaCle remedies against the
landlord. ?C> :a. not Ce /iled Dith the court i/ an action /or summar. e=iction or unlaD/ul detainer is
alread. Eending CetDeen the landlord and tenant, Cut the tenant ma. seeF similar relie/ Ce/ore the
Iudge Eresiding o=er the Eending action. +. 'he court shall conduct a hearing on the =eri/ied
comElaint /or e*Eedited relie/ not later than 3 Iudicial da.s a/ter the /iling o/ the =eri/ied comElaint
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/or e*Eedited relie/. Be/ore or at the scheduled hearing, the tenant must Ero=ide Eroo/ that the
landlord has Ceen EroEerl. ser=ed Dith a coE. o/ the =eri/ied comElaint /or e*Eedited relie/. 3Eon the
hearing, i/ it is determined that the landlord has =iolated an. o/ the Ero=isions o/ suCsection , the
court ma.: N$" %-.!9, 7aCitaCilit. o/ dDelling unit. . 'he landlord shall at all times during the
tenanc. maintain the dDelling unit in a haCitaCle condition. - dDelling unit is not haCitaCle i/ it
=iolates Ero=isions o/ housing or health codes concerning the health, sa/et., sanitation or /itness /or
haCitation o/ the dDelling unit or i/ it suCstantiall. lacFs: ?a> E//ecti=e DaterEroo/ing and Deather
Erotection o/ the roo/ and e*terior Dalls, including DindoDs and doors. ?C> 0lumCing /acilities Dhich
con/ormed to aEElicaCle laD Dhen installed and Dhich are maintained in good DorFing order. ?c> -
Dater suEEl. aEEro=ed under aEElicaCle laD, Dhich is: ?> 3nder the control o/ the tenant or landlord
and is caEaCle o/ Eroducing hot and cold running Dater; ?!> )urnished to aEEroEriate /i*tures; and ?3>
Connected to a seDage disEosal s.stem aEEro=ed under aEElicaCle laD and maintained
in good DorFing order to the e*tent that the s.stem can Ce controlled C. the landlord. ?d> -dequate
heating /acilities Dhich con/ormed to aEElicaCle laD Dhen installed and are maintained in good
DorFing order. ?e> Electrical lighting, outlets, Diring and electrical equiEment Dhich con/ormed to
aEElicaCle laD Dhen installed and are maintained in good DorFing order. ?/> -n adequate numCer o/
aEEroEriate receEtacles /or garCage and ruCCish in clean condition and good reEair at the
commencement o/ the tenanc.. 'he landlord shall arrange /or the remo=al o/ garCage and ruCCish
/rom the Eremises unless the Earties C. Dritten agreement Ero=ide otherDise. ?g> Building, grounds,
aEEurtenances and all other areas under the landlordOs control at the time o/ the commencement o/
the tenanc. in e=er. Eart clean, sanitar. and reasonaCl. /ree /rom all accumulations o/ deCris, /ilth,
ruCCish, garCage, rodents, insects and =ermin. ?h> )loors, Dalls, ceilings, stairDa.s and railings
maintained in good reEair. ?i> Ventilating, air(conditioning and other /acilities and aEEliances,
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including ele=ators, maintained in good reEair i/ suEElied or required to Ce suEElied C. the landlord.
!. 'he landlord and tenant ma. agree that the tenant is to Eer/orm sEeci/ied reEairs, maintenance
tasFs and minor remodeling onl. i/: ?a> 'he agreement o/ the Earties is entered into in good /aith; and
?C> 'he agreement does not diminish the oCligations o/ the landlord to other tenants in the Eremises.
3. -n agreement Eursuant to suCsection ! is not entered into in good /aith i/ the landlord has a dut.
under suCsection to Eer/orm the sEeci/ied reEairs, maintenance tasFs or minor remodeling and the
tenant enters into the agreement Cecause the landlord or his or her agent has re/used to Eer/orm them.
?a> 5rder the landlord to restore to the tenant the Eremises or essential items or ser=ices, or Coth; ?C>
-Dard damages Eursuant to suCsection ; and ?c> EnIoin the landlord /rom =iolating the Ero=isions o/
suCsection and, i/ the circumstances so Darrant, hold the landlord in contemEt o/ court. 7. 'he
Ea.ment o/ all costs and o//icial /ees must Ce de/erred /or an. tenant Dho /iles a =eri/ied comElaint
/or e*Eedited relie/. -/ter an. hearing and not later than /inal disEosition o/ the /iling or order, the
court shall assess the costs and /ees against the Eart. that does not Ere=ail, e*ceEt that the court ma.
reduce them or Dai=e them, as Iustice ma. require.
N$" %-.7, J'enantK de/ined. J'enantK means a Eerson entitled under a rental agreement to
occuE. a dDelling unit to the e*clusion o/ others. N$" %-.!,, $ental agreements: "igning;
coEies; required Ero=isions; disEutaCle EresumEtions; use o/ noncon/orming agreement unlaD/ul. .
-n. Dritten agreement /or the use and occuEanc. o/ a dDelling unit or Eremises must Ce signed C.
the landlord or his or her agent and the tenant or his or her agent. !. 'he landlord shall Ero=ide one
coE. o/ an. Dritten agreement descriCed in suCsection to the tenant /ree o/ cost at the time the
agreement is e*ecuted and, uEon request o/ the tenant, Ero=ide additional coEies o/ an. such
agreement to the tenant Dithin a reasonaCle time. 'he landlord ma. charge a reasonaCle /ee /or
Ero=iding the additional coEies. 3. -n. Dritten rental agreement must contain, Cut is not limited to,
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Ero=isions relating to the /olloDing suCIects: ?a> Duration o/ the agreement. ?C> -mount o/ rent and
the manner and time o/ its Ea.ment. ?c> 5ccuEanc. C. children or Eets. ?d> "er=ices included Dith the
dDelling rental. ?e> )ees Dhich are required and the EurEoses /or Dhich the. are required. ?/>
DeEosits Dhich are required and the conditions /or their re/und. ?g> Charges Dhich ma. Ce required
/or late or Eartial Ea.ment o/ rent or /or return o/ an. dishonored checF. ?h> 4nsEection rights o/ the
landlord. ?i> - listing o/ Eersons or numCers o/ Eersons Dho are to occuE. the dDelling. ?I>
$esEecti=e resEonsiCilities o/ the landlord and the tenant as to the Ea.ment o/ utilit. charges. ?F> -
signed record o/ the in=entor. and condition o/ the Eremises under the e*clusi=e custod. and control
o/ the tenant. ?l> - summar. o/ the Ero=isions o/ N$" !,!.47,. ?m> 4n/ormation regarding the
Erocedure Eursuant to Dhich a tenant ma. reEort to the aEEroEriate authorities: ?> - nuisance. ?!> -
=iolation o/ a Cuilding, sa/et. or health code or regulation. ?n> 4n/ormation regarding the right o/ the
tenant to engage in the disEla. o/ the /lag o/ the 3nited "tates, as set /orth in N$" %-.3!&. 4. 'he
aCsence o/ a Dritten agreement raises a disEutaCle EresumEtion that: ?a> 'here are no restrictions on
occuEanc. C. children or Eets. ?C> :aintenance and Daste remo=al ser=ices are Ero=ided Dithout
charge to the tenant. ?c> No charges /or Eartial or late Ea.ments o/ rent or /or dishonored checFs are
Eaid C. the tenant. ?d> 5ther than normal Dear, the Eremises Dill Ce returned in the same condition as
Dhen the tenanc. Cegan. &. 4t is unlaD/ul /or a landlord or an. Eerson authoriGed to enter into a rental
agreement on his or her Cehal/ to use an. Dritten agreement Dhich does not con/orm to the
Ero=isions o/ this section, and an. Ero=ision in an agreement Dhich contra=enes the Ero=isions o/ this
section is =oid. ?-dded to N$" C. 977, 333; - !,,, 3&!; !,,3, !9+%; !,,7, !%!> N$"
%-.!, $ental agreements: 0a.ment o/ rent; term o/ tenanc.. . $ent is Ea.aCle Dithout demand
or notice at the time and Elace agreed uEon C. the Earties. !. 3nless the rental agreement estaClishes a
de/inite term, the tenanc. is /rom DeeF to DeeF in the case o/ a tenant Dho Ea.s DeeFl. rent and in
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all other cases the tenanc. is /rom month to month. 3. 4n the aCsence o/ an agreement, either Dritten
or oral: ?a> $ent is Ea.aCle at the Ceginning o/ the tenanc.; and ?C> $ent /or the use and occuEanc. o/
a dDelling is the /air rental =alue /or the use and occuEanc.. -t .our e=iction hearing, tell the Iudge
.our side o/ the stor.. 8our IoC
is to con=ince the Iudge that .ou ha=e a legal de/ense to the e=iction. 'he Ne=ada "uEreme Court
has determined that Jlegal de/enseK is Dhen .ou ha=e a Jgenuine issue o/ material /act.K -n=ui, 11C
=. <.1. Dragon, 11C, +3 0.3d 4,& ?!,,7> N$" 4,.!& 3nlaD/ul detainer: 0ossession o/
EroEert. leased /or inde/inite time a/ter notice to quit; older Eerson or Eerson Dith a disaCilit. entitled
to e*tension o/ Eeriod o/ Eossession uEon request. N$" 4,.!& 3nlaD/ul detainer: 0ossession o/
to e*tension o/ Eeriod o/ Eossession uEon request. . - tenant o/ real EroEert., a recreational =ehicle
or a moCile home /or a term less than li/e is guilt. o/ an unlaD/ul detainer Dhen ha=ing leased: ?a>
$eal EroEert., e*ceEt as otherDise Ero=ided in this section, or a moCile home /or an inde/inite time,
Dith monthl. or other Eeriodic rent reser=ed, the tenant continues in Eossession thereo/, in Eerson or
C. suCtenant, Dithout the landlordOs consent a/ter the e*Eiration o/ a notice o/: ?> )or tenancies /rom
DeeF to DeeF, at least 7 da.s; ?!> E*ceEt as otherDise Ero=ided in suCsection !, /or all other Eeriodic
tenancies, at least 3, da.s; or ?3> )or tenancies at Dill, at least & da.s. ?C> - dDelling unit suCIect to
the Ero=isions o/ chaEter %- o/ N$", the tenant continues in Eossession, in Eerson or C. suCtenant,
Dithout the landlordOs consent a/ter e*Eiration o/: ?> 'he term o/ the rental agreement or its
termination and, e*ceEt as otherDise Ero=ided in suCEaragraEh ?!>, the e*Eiration o/ a notice o/: ?4>
-t least 7 da.s /or tenancies /rom DeeF to DeeF; and ?44> E*ceEt as otherDise Ero=ided in suCsection
!, at least 3, da.s /or all other Eeriodic tenancies; or ?!> - notice o/ at least & da.s Dhere the tenant
has /ailed to Eer/orm the tenantOs Casic or contractual oCligations under chaEter %- o/ N$". ?c> -
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moCile home lot suCIect to the Ero=isions o/ chaEter %B o/ N$", or a lot /or a recreational =ehicle
in an area o/ a moCile home EarF other than an area designated as a recreational =ehicle lot Eursuant
to the Ero=isions o/ suCsection + o/ N$" 4,.!&, the tenant continues in Eossession, in Eerson or C.
suCtenant, Dithout the landlordOs consent: ?> -/ter notice has Ceen gi=en Eursuant to N$" %B.&,
%B.7, or %B.9, and the Eeriod o/ the notice has e*Eired; or ?!> 4/ the Eerson is not a natural
Eerson and has recei=ed three notices /or nonEa.ment o/ rent Dithin a !(month Eeriod, immediatel.
uEon /ailure to Ea. timel. rent. ?d> - recreational =ehicle lot, the tenant continues in Eossession, in
Eerson or C. suCtenant, Dithout the landlordOs consent, a/ter the e*Eiration o/ a notice o/ at least &
da.s. !. E*ceEt as otherDise Ero=ided in this section, i/ a tenant Dith a Eeriodic tenanc. Eursuant to
EaragraEh ?a> or ?C> o/ suCsection , other than a tenanc. /rom DeeF to DeeF, is +, .ears o/ age or
older or has a Eh.sical or mental disaCilit., the tenant ma. request to Ce alloDed to continue in
Eossession /or an additional 3, da.s Ce.ond the time sEeci/ied in suCsection C. suCmitting a
Dritten request /or an e*tended Eeriod and Ero=iding Eroo/ o/ the tenantOs age or disaCilit.. -
landlord ma. not Ce required to alloD a tenant to continue in Eossession i/ a shorter notice is Ero=ided
Eursuant to suCEaragraEh ?!> o/ EaragraEh ?C> o/ suCsection . 3. -n. notice Ero=ided Eursuant to
EaragraEh ?a> or ?C> o/ suCsection must include a statement ad=ising the tenant o/ the Ero=isions o/
suCsection !. 4. 4/ a landlord reIects a request to alloD a tenant to continue in Eossession /or an
additional 3, da.s Eursuant to suCsection !, the tenant ma. Eetition the court /or an order to continue
in Eossession /or the additional 3, da.s. 4/ the tenant suCmits Eroo/ to the court that the tenant is
entitled to request such an e*tension, the court ma. grant the Eetition and enter an order alloDing the
tenant to continue in Eossession /or the additional 3, da.s. 4/ the court denies the Eetition, the tenant
must Ce alloDed to continue in Eossession /or & calendar da.s /olloDing the date o/ entr. o/ the order
den.ing the Eetition. N$" 4,.4,, $ules o/ Eractice. 'he Ero=isions o/ N$", Ne=ada $ules o/ Ci=il
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0rocedure and Ne=ada $ules o/ -EEellate 0rocedure relati=e to ci=il actions, aEEeals and neD trials,
so /ar as the. are not inconsistent Dith the Ero=isions o/ N$" 4,.!!, to 4,.4!,, inclusi=e, aEEl. to
the Eroceedings mentioned in those sections. N$" 4,.34, -dIournments. 'he court or Iustice o/ the
Eeace ma. /or good cause shoDn adIourn the trial o/ an. cause under N$" 4,.!!, to 4,.4!,,
inclusi=e, not e*ceeding & da.s; and Dhen the de/endant, or the de/endantOs agent or attorne., shall
maFe oath that the de/endant cannot sa/el. Eroceed to trial /or Dant o/ some material Ditness, naming
that Ditness, stating the e=idence that the de/endant e*Eects to oCtain, shoDing that the de/endant has
used due diligence to oCtain such Ditness and Celie=es that i/ an adIournment Ce alloDed the
de/endant Dill Ce aCle to Erocure the attendance o/ such Ditness, or the DitnessOs deEosition, in time
to Eroduce the same uEon the trial, in Dhich case, i/ such Eerson or Eersons Dill gi=e Cond, Dith one
or more su//icient sureties, conditioned to Ea. the comElainant /or all rent that ma. accrue during the
Eending o/ such suit, and all costs and damages consequent uEon such adIournment, the court or
Iustice o/ the Eeace shall adIourn the cause /or such reasonaCle time as ma. aEEear necessar., not
e*ceeding 3, da.s. N$" 4,.3&, 'rial not to Ce adIourned Dhen comElainant admits e=idence in
a//ida=it Dould Ce gi=en. 4/ the comElainant admit that the e=idence stated in the a//ida=it mentioned
in N$" 4,.34, Dould Ce gi=en C. such Ditness, and agree that it Ce considered as actuall. gi=en on
the trial, or o//ered and o=erruled as imEroEer, the trial shall not Ce adIourned.
'he landlord is tr.ing to e=ict me /or m. e*ercising m. rights as /olloDs: comElaining o/ haCitaCilit.
issues and =iolations o/ criminal laDs and retaliation.
4 ha=e a lease Dhich has not e*Eired and the landlord has not gi=en me notice that the.Ashe is
terminating m. lease. :. lease alloDs me to use the Eremises /or a h.Crid EurEose o/ a home laD
o//ice, ie a commercial lease, as such the No Cause t.Ee o/ e=iction is not a=ailaCle here, esEeciall.
Dhere, as her, m. lease has not terminated C. its terms as o/ .et.
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4 ha=e not recei=ed a notice /rom the landlord telling me to lea=e the Eremises. the. can talF aCout
Dhat the. told H2ohn DoeH to do, Cut...-itFen requires the. change an. H2ohn DoeH notices to re/lect
m. actual name one the. Dere aEErised o/ it. 'he Dere as earl. as 2anuar. &th, !, according to
"ue 9ing, .et the. /ailed to ser=e aEEroEriate notice.. 4/ 4 ha=e e=er oDed the landlord an. rent, 4
ha=e Eaid it all or ha=e Eaid it Dithin the time required C. laD.
-ssociation@s negligence =is a =is 1aura and Chris@s negligent andintentional torts committed against
me, Dhich ha=e resulted in thousands o/ dollars o/ damages. 0lease coE. me on an. and all
corresEondence =ia /a* or email as the landlords and or their argents ha=e Ceen or areDithholding m.
mail or otherDise inter/erring Dith m. acces to it, and the. ha=e also done Dith resEect to the
essential ser=ice o/ electricit... -ssociation@s negligence =is a =is 1aura and Chris@s negligent
andintentional torts committed against me, Dhich ha=e resulted in thousands o/ dollars o/ damages.
0lease coE. me on an. and all corresEondence =ia /a* or email as the landlords and or their argents
ha=e Ceen or areDithholding m. mail or otherDise inter/erring Dith m. acces to it, and the. ha=e also
d 6ritten comElaint to 0'75-@a emElo.ees or agents, causing 0'75- to retaliate against Coughlin
Das Ero=ide on 2anuar. %, !,! in tDo seEarate Dritings, Dhich alleged: H0ursuant to N$" %- and
N$" 4,, 4 am hereC. comElaining in Driting o/ .ours and 1aura 7arrison@s =iolation o/ the /olloDing
criminal laDs: - /elon. con=iction /or malicious destruction o/ Eri=ate EroEert. under N$" !,+.3,
and 93.&& must Ce C4V41 14-B414'8 )5$ 15"" 5$ D-:-<E '5 0$50E$'8 N$" !,&.9%,
Determination o/ =alue o/ loss /rom crime; notice to =ictim; order o/ restitution deemed Iudgment to
collect damages. C7-0'E$ !,+ ( :-14C453" :4"C74E) N$" !,+.,,& J<ra//itiK de/ined. N$"
!,+.,, Destruction or damage o/ EroEert. C. unlaD/ul assemCl.. N$" !,+.,& Destruction or
damage o/ croEs, gardens, trees or shruCs. N$" !,+.,4, Entering EroEert. Dith intention to damage
or destro. EroEert.. N$" !,+.!& Damage o/ EroEert. used /or EurEose o/ religion, /or Curial or
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memorialiGing o/ dead, /or education, as transEortation /acilit., as EuClic transEortation =ehicle or as
communit. center; damage o/ Eersonal EroEert. contained therein; Eenalties; restitution. N$"
!,+.4, Nuisance in Cuilding; tresEass uEon grounds; disturCing assemCl.. N$" !,+.&, 9illing,
maiming, dis/iguring or Eoisoning animal o/ another Eerson; Filling estra. or li=estocF. N$" !,+.+,
1eading or dri=ing horse aDa. Dithout authorit.. N$" !,+.!,, 0osting o/ Cills, signs or Eosters
unlaD/ul. N$" !,+.!!, $emo=al, alteration or destruction o/ monuments or landmarFs designating
Coundaries. N$" !,+.!+, )raudulent and malicious destruction o/ Dritings. N$" !,+.!7, De/acing
Eroclamations and notices. N$" !,+.!%, 'amEering Dith EaEers. N$" !,+.!9, 5Eening or
EuClishing sealed letter or telegram. N$" !,+.3,, )alse signals endangering cars, =essels or motors.
N$" !,+.3, 4nIur. to other EroEert.. N$" !,+.3!, 3nlaD/ul remo=al o/ Eetri/ied Dood /rom
Eosted or designated sites; duties o/ certain o//icers. N$" !,+.33, 0lacing gra//iti on or otherDise
de/acing EroEert.: )ines and Eenalties; Earent or guardian resEonsiCle /or /ines and Eenalties i/
Eerson =iolating section is under age o/ % .ears; susEension o/ dri=erOs license. N$" !,+.33&
Carr.ing gra//iti imElement at certain locations Dith intent to =andaliGe, Elace gra//iti on or de/ace
EroEert.. N$" !,+.34, <ra//iti $eDard )und created; administrati=e assessment to Ce imEosed /or
certain =iolations; use o/ mone. in )und. N$" !,+.34& 0erson or entit. to Ce Eaid i/ restitution is
ordered /or =iolation o/ N$" !,+.!& or !,+.33,. Zach Coughlin, Esq.H 'he second Driting: H'his is
additional Dritten notice Eursuant to N$" %- and N$" 4, comElaining o/ and requesting reEairs
and reimCursement /or the /olloDing: no cg/i outlet near sinF in uEstairs Cathroom. .ou CroFe the
door to m. room and the locF and /ailed to Ero=ide a Fe. laura harrison slashed tDo o/ m. tires,
necessitating R&, in reEairs. 8ou threD hot co//ee on me and ruined m. htc <! smartEhone, a R4,,
Ehone .ou ha=e Creached are deal Dith resEect to m. Ceing alloDed to Ce neD carEet o=er the =er.
dirt. carEet doDnstairs. 8ou ha=e reEeatedl. used /orce and threat o/ /orce to Ere=ent me /rom
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accessing the Dashing machine doDnstairs /or doing laundr. and Ere=ented m. use o/ the Fitchen
8ou admitted to changing the deadColts on the /ront and CacF door@s on NeD 8ears da. at !:3, am,
locFing me outside on a night Dith /reeGing temEeratures, necessitating an e*Eense o/ R+, /or
alternate lodging that night. )urther, .ou and 1aura 7arrison ha=e unlaD/ull. interruEted an essential
ser=ice, m. electricit., reEeatedl.. N$" %-.39,. 0lease cure these issues or 4 intend to deduct them
/rom an. /uture rent. 4 am comElaining o/ .ours and 1aura 7arrison@s =iolations o/ criminal laD
statutes :. dog had cheDing gum stucF in its hair in se=eral Elaces, in a manner that suggests it Das
EurEose/ull. done. 4 Dill remind .ou that aCuse to animals is included in the 0rotection 5rder
"tatutes. )urther, .ou and :s. 7arrison are in =iolation o/ /ederal laD in Ere=enting m. access to the
mailCo* included in our agreement, as it Das agreed that 4 Dould Ce a//orded the oEEortunit. to
recei=e mail at the 4!! E. 9th "'. #! -ddress and use o/ the mailCo*. "incerel., Zach Coughlin,
Esq.H
0otential counterclaims in a residential e=iction action =ar. /rom Iurisdiction to Iurisdiction. "ee, e.g.,
5hio $e=. Code -nn. Q 9!3.,+. "ome states restrict the counterclaims that a tenant ma. assert in a
summar. e=iction Eroceeding. 4oDa Code -nn. Q +4%.9; :d. Code -nn., $eal 0roE. Q %(4,!.4 ?d>.
4/ a EroEert. oDner used illegal sel/(helE to remo=e a tenant Erior to or during the course o/ an
e=iction action, the tenant ma. ha=e counterclaims /or illegal e=iction, tresEass, or harassment. 'he
tenants Ere=ailed on such a claim in Villeneu=e =. Beane, %! Vt. &7&, !,,7 V' 7&, 933 -.!d 39
?!,,7>, Dhere the tenant /amil. struggled to Ea. their rent and Eurchase heating oil a/ter the /ather@s
serious inIur. in an industrial accident le/t him unaCle to DorF. DesEite the /act that the tenants oDed
CacF rent and the EroEert. oDner had Ceen /orced to Eurchase heating oil to FeeE the /urnace running,
the EroEert. oDner agreed to Eermit the tenants to remain in the residence /or an additional month
a/ter e*Eiration o/ the lease i/ the. Eaid the rent /or that additional month. 'he tenants Eaid the rent
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/or the additional month, Cut Dhile the tenants Dere aDa. at DorF and school one da., the landlord
Cegan remo=ing their Eersonal EroEert. /rom the residence. 6hen one o/ the tenants returned home
/rom DorF une*Eectedl., he had the Eolice remo=e the EroEert. oDner /rom the residence and the
tenants mo=ed their EroEert. CacF into the residence. During the course o/ the e=iction action /iled C.
the EroEert. oDner, the tenants Eaid rent into court until the. =acated the residence. 7oDe=er, the
EroEert. oDner engaged in a camEaign o/ harassment against the tenants Dhile the e=iction action
Das Eending, including ha=ing their utilities shut o// and Eosting signs on the EroEert. oDner@s
neighCoring Eremises stating that the tenants Dould not Ea. rent and Dould not =acate the residence.
Based on these actions, the tenants asserted a counterclaim /or harassment, illegal e=iction, and
tresEass. 'he aEEellate court uEheld the trial court@s aDard o/ R,,,,, in comEensator. damages and
R!,,,, in Euniti=e damages against the EroEert. oDner Cecause the EroEert. oDner@s conduct Das
outrageous and a =iolation o/ the tenants@ right to legal Erocess. Villeneu=e =. Beane, %! Vt. &7&,
!,,7 V' 7&, 933 -.!d 39 ?!,,7>. 5ne common counterclaim is Creach o/ the Darrant. o/
haCitaCilit.. Domen 7olding Co. =. -rano=ich, N.8.3d 7, 7+9 N.8.".!d 7%&, %,! N.E.!d 3&
?!,,3> ?tenant asserted a counterclaim /or Creach o/ the Darrant. o/ haCitaCilit. in the landlord@s
e=iction action>; 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +& ?!,,&> ?tenant asserted a
counterclaim /or Creach o/ the Darrant. o/ haCitaCilit. in the landlord@s e=iction action>. 4n certain
cases, a Creach o/ the Darrant. o/ haCitaCilit. ma. alloD reinstatement o/ the tenanc. e=en i/ the
EroEert. oDner alread. oCtained an e=iction order. )or instance, a :assachusetts Ero=ision Eermits a
tenant to Dithhold rent due to conditions in the residence that materiall. imEair or endanger the
tenant@s sa/et., health, or Dell(Ceing. 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +&
?!,,&> ?interEreting :ass. <en. 1aDs -nn. ch. !39, Q %->. 4/ a :assachusetts court renders Iudgment
in /a=or o/ the EroEert. oDner Cased on the nonEa.ment o/ rent, the tenant ma. reinstate the tenanc.
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C. Ea.ing the amount o/ the Iudgment into court Dithin one DeeF. 2aClonsFi =. Case., +4 :ass. -EE.
Ct. 744, %3& N.E.!d +& ?!,,&> ?interEreting :ass. <en. 1aDs -nn. ch. !39, Q %->. 7oDe=er, such
relie/ is not a=ailaCle unless the tenant Ero=es that the EroEert. oDner had Erior notice o/ the
conditions endangering the tenant@s sa/et., health, or Dell(Ceing. 2aClonsFi =. Case., +4 :ass. -EE.
Ct. 744, %3& N.E.!d +& ?!,,&> ?den.ing a tenant@s motion /or reinstatement o/ her tenanc. Cecause
she /ailed to noti/. the landlord o/ the conditions allegedl. endangering her health, sa/et., or Dell(
Ceing Erior to Dithholding rent>. )ailure to a//ord the EroEert. oDner the requisite notice Erior to
Dithholding rent Erecludes the tenant /rom asserting the Creach o/ Darrant. o/ haCitaCilit. as a
de/ense to an e=iction Eroceeding. 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +& ?!,,&>
?a//irming Iudgment in /a=or o/ the landlord /or Eossession and CacF rent>.Because a tenant@s claim o/
retaliator. e=iction is t.Eicall. asserted as an equitaCle de/ense, the usual remed. /or its success/ul
assertion is dismissal o/ the landlord@s action /or Eossession o/ the Eremises.M7!N 7oDe=er, in some
cases the tenant ma. Ce entitled to damages.M 73N 'his ma. include reco=er. o/ a rent aCatement /or a
Eeriod o/ uninhaCitaCilit.,M74N comEensator. damages,M7&N damages /or emotional distress caused C.
the retaliator. e=iction,M 7+N and attorne.@s /ees.M77N :ost courts ha=e held that Euniti=e damages are
not reco=eraCle on a claim o/ retaliator. e=iction,M7%N although a /eD courts ha=e aDarded Euniti=e
damages in some instances.M79N 4t is the tenant@s Curden to Ero=e damages. )or e*amEle, in 0aullin =.
"utton,M%,N a Ne=ada court /ound that the onl. e=idence o/ damages consisted o/ testimon. C. the
tenant that, /olloDing her e=iction, she Eurchased a condominium /or R!&,,,, doDn and R,&&!
mortgage Ea.ment ?Elus R3& association /ee> Eer month. 'he court held that as a matter o/ laD,
damages /or retaliator. e=iction do not include all or Eart o/ the Eurchase Erice o/ a neD home C. the
/ormer tenant. )urther, although the tenant@s ansDers to interrogatories indicated that she did incur
e*Eenses in mo=ing, she did not introduce an. e=idence at trial concerning the amount o/ these
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e*Eenses. Because she /ailed to carr. the Curden to Ero=e her damages, the court =acated a
comEensator. damage aDard o/ R!,,,,. 'he court also re=ersed an R%,,,,, aDard o/ Euniti=e
damages Cecause, said the court, Euniti=e damages are not authoriGed Dithout a =alid aDard o/
comEensator. damages. 'he court /urther determined that Dhile Ne= $e= "tat Q %-.&, clearl.
ErohiCited the non(reneDal o/ a month(to(month tenanc. /or a retaliator. EurEose, the statute Das
silent as to Dhether Euniti=e damages Dere reco=eraCle /or a retaliator. e=iction. 4n <oFe. =.
Bessette,M%N a landlord@s action /or unEaid rent allegedl. due Dhen the tenant =acated the Eremises,
the de/endant tenants counterclaimed /or damages Cased on retaliator. e=iction and the landlord@s
Creach o/ an imElied Darrant. o/ haCitaCilit.. 'he Earties had entered into an oral lease agreement /or
rental o/ a moCile home starting in "eEtemCer 9%& at a monthl. rent o/ R4,,. 'he tenants Eaid /or
electric ser=ice to the moCile home, Cut the landlord Eaid /or the electricit. /or a nearC. Carn, in
Dhich the tenants Dere alloDed to store their /reeGer. 'he trial court /ound that during the tenanc. a
=ariet. o/ EroClems de=eloEed, including Dater leaFage into the home through the roo/ ?Dhich Das
reEaired C. the tenants>, EoDer /ailures due to a /ault. trans/ormer, and a /urnace CreaFdoDn. :ore
serious Das a CreaF in the seDer line, Dhich caused unhealth. /luids to collect underneath the moCile
home and a /oul odor to Eer=ade the Eremises. DesEite numerous comElaints to the landlord to reEair
the seDer line CreaF, the EroClem remained unresol=ed /rom )eCruar. to 2une 9%+, and the tenants
stoEEed Ea.ing rent as o/ 2une , 9%+. 'he court /ound that /inal reEair to the seEtic s.stem came on
2une 7, 9%+, onl. a/ter the tenants EromEted a =isit /rom the toDn health o//icer. 5n 2une +, 9%+,
Erior to the reEair, the landlord ga=e the tenants notice to quit, e//ecti=e -ugust , 9%+. 'he trial
court /ound that a/ter the tenants stoEEed Ea.ing rent, the landlord locFed the Carn Dhere the /reeGer
Das located and shut o// the EoDer, causing the loss o/ R3,, Dorth o/ /ood. 'he tenants =acated the
Eremises on 5ctoCer 3, 9%+, aEEro*imatel. one month a/ter the landlord had sold the moCile home.
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M)N7%N "ee, /or e*amEle, 0ohlman =. :etroEolitan 'railer 0arF, 4nc., !+ N.2. "uEer. 4, 3! -.!d
%%% ?Ch. Di=. 973> ?holding that state statute did not authoriGe reco=er. o/ Euniti=e damages /or
retaliator. e=iction>; 0aullin =. "utton, ,! Ne=. 4!, 7!4 0.!d 749 ?9%+> ?holding that state statute
did not authoriGe reco=er. o/ Euniti=e damages /or retaliator. e=iction>. M)N79N "ee, /or e*amEle,
-DeeFa =. Bonds, !, Cal. -EE. 3d !7%, 97 Cal. $Etr. +&, ?st Dist. 97> ?holding that Euniti=e
damages are reco=eraCle in a retaliator. e=iction action e=en i/ the actual damages are nominal>. "ee
also Del Code -nn tit. !&, Q &&+?d> ?alloDing a success/ul tenant to reco=er three months@ rent or
treCle damages, Dhiche=er is greater, Elus attorne.@s /ees>. M)N%,N 0aullin =. "utton, ,! Ne=. 4!,
7!4 0.!d 749 ?9%+>. M)N%N <oFe. =. Bessette, &4 Vt. &+,, &%, -.!d 4%%, !3 -.1.$.&th %%7
?99,>. M)N%!N 0ursuant to 9 Vt. "tat. -nn. Q 44+&. "ection !3 )ootnotes: M)N%3N )or a general
discussion on the use o/ interrogatories, see Disco=er.S6ritten 4nterrogatories, 4 -m. 2ur. 'rials .
)or interrogatories to disco=er Casic /acts in tort actions, see Danner, 0attern Disco=er.: 'ort -ctions
?!d ed.>. )or checFlists and discussion o/ the use o/ e*Eert Ditnesses, see Danner, E*Eert 6itness
ChecFlists. $egarding deEositions, see 0attern DeEosition ChecFlists ?!d ed.>. 5n state court Eractice
Dith resEect to interrogatories, see Disco=er.S6ritten 4nterrogatories, 4 -m. 2ur. 'rials . 5n
Dritten interrogatories in /ederal district court, see )ederal $ules o/ Ci=il 0rocedure $ules !+, 33; see
also )ederal 0rocedure, 1. Ed. QQ !+:!9, et seq.. 4& -:23$ 05) 3d 37&
'he landlord@s ComElaint /ails to state /acts Dhich Dould alloD himAher to e=ict me, /urther 9ing and
6estern Ne=ada :anagement and "hiela 1ester ha=e admitted the. recei=ed nothing Eursuant to
their arrangement Dith -llaCacF and )oreshee, as such the Ne=ada "uEreme Court holding in <laGier
maFes inaEElicaCle a summar. e=iction Eroceeding. )urther, Dhere, as here, m. lease alloDs me to
use the Eremises /or a home laD o//ice, and the non(Ea.ment o/ rent has not Ceen alleged, N$"
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4,.!&3 maFes inaEElicaCle a summar. e=iction Erocedure under those circumstances, rather, a
Elenar. Erocedure is required. $egardless, a EroEer Iur. trial demand is hereC. made.
'here is EerhaEs another Eerson against Dhom this action should Ce Crought, namel. Erin -llaCacF
and 1aure )orshee.
4 ha=e not Ceen EroEerl. named in the notices. $ather, the Notice EurEortedl. Eosed on 2anuar.
,th, !,! onl. names a H2ohn DoeH desEite m. numerous Dritings to 6estern Ne=ada Dherein m.
name Das madse clear. 'he -itFen case maFes clear that the Erocedural and notice requirements o/
summar. e=iction matters must Ce stricl. adhered to, as such this H2ohn DoeH notice is ine//ecti=e.
4 ha=e other de/enses as /olloDs: retaliation, discrimination, lacF o/ allegation o/ nonEa.ment o/ rent,
75- admitted tenants Dere not oCligated to Ea. rent, as such, under <laGier, summar. e=iction
Erocedures una=ailaCle. 4:05$'-N': 4n some cases, the Court has the EoDer to gi=e .ou time to
/ind a neD Elace to li=e e=en i/ .ou do not ha=e an. o/ the listed de/enses. 4/ .ou Dish the Court to
determine Dhether .ou are entitled to it, Elease checF CeloD:
4 ha=e Ero=ided Dritten request to landlord /or an e*tension o/ 3, da.s in light o/ m. disaCilit..
4 am Driting to request the 3, da.s e*tension Cased uEon disaCilit.. 4 am in=oFing m. 740-- and other Eri=ac. rights
Dith resEect to di=ulging an.thign /urther aCout m. disaCilit..
C53N'E$C1-4:
4/ .ou Celie=e that .ou are entitled to a return o/ Eart o/ .our rent Ea.ment or other damages /rom the
landlord, comElete the statement CeloD: 4 here C. counterclaim in e*cess o/ R,,,,, in damages. 4
/eel that 4 am entitled to this amount /or the /olloDing reasons: damages to m.sel/, m. clients, and
m. Eractice in light o/ landlord@s and landlord@s agents actions. 1aura and Chris Ceing the
-ssociations emElo.ees and there/ore .ou gu.s or them Danted to settle Dith
me on account o/ a resEondeat suEerior theor. o/ liaCilit. maFing .our
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e*Eosure signi/icant enough to Iusti/. doing so. -ssociation@s negligence =is a =is 1aura and Chris@s negligent
andintentional torts committed against me, Dhich ha=e resulted in thousands o/ dollars o/ damages. 0lease coE. me on
an. and all corresEondence =ia /a* or
email as the landlords and or their argents ha=e Ceen or areDithholding m. mail or otherDise inter/erring Dith m. acces
to it, and the. ha=e also done Dith resEect to the essential ser=ice o/ electricit..
,-INTS AND AUT.-RITIES
)-C'"
N$" %-.&, $etaliator. conduct C. landlord against tenant ErohiCited; remedies; e*ceEtions.
. E*ceEt as otherDise Ero=ided in suCsection 3, the landlord ma. not, in retaliation, terminate a
tenanc., re/use to reneD a tenanc., increase rent or decrease essential ser=ices required C. the rental
agreement or this chaEter, or Cring or threaten to Cring an action /or Eossession i/:
?a> 'he tenant has comElained in good /aith o/ a =iolation o/ a Cuilding, housing or health code
aEElicaCle to the Eremises and a//ecting health or sa/et. to a go=ernmental agenc. charged Dith the
resEonsiCilit. /or the en/orcement o/ that code;
?C> 'he tenant has comElained in good /aith to the landlord or a laD en/orcement agenc. o/ a
=iolation o/ this chaEter or o/ a sEeci/ic statute that imEoses a criminal Eenalt.;
?c> 'he tenant has organiGed or Cecome a memCer o/ a tenantOs union or similar organiGation;
?d> - citation has Ceen issued resulting /rom a comElaint descriCed in EaragraEh ?a>;
?e> 'he tenant has instituted or de/ended against a Iudicial or administrati=e Eroceeding or
arCitration in Dhich the tenant raised an issue o/ comEliance Dith the requirements o/ this chaEter
resEecting the haCitaCilit. o/ dDelling units;
?/> 'he tenant has /ailed or re/used to gi=e Dritten consent to a regulation adoEted C. the landlord,
a/ter the tenant enters into the rental agreement, Dhich requires the landlord to Dait until the
aEEroEriate time has elaEsed Ce/ore it is en/orceaCle against the tenant; or
?g> 'he tenant has comElained in good /aith to the landlord, a go=ernment agenc., an attorne., a
rights Dhich are guaranteed or Erotected under those laDs.
!. 4/ the landlord =iolates an. Ero=ision o/ suCsection , the tenant is entitled to the remedies
Ero=ided in N$" %-.39, and has a de/ense in an. retaliator. action C. the landlord /or Eossession.
3. - landlord Dho acts under the circumstances descriCed in suCsection does not =iolate that
suCsection i/:
?a> 'he =iolation o/ the aEElicaCle Cuilding, housing or health code o/ Dhich the tenant
comElained Das caused Erimaril. C. the lacF o/ reasonaCle care C. the tenant, a memCer o/ his or her
household or other Eerson on the Eremises Dith his or her consent;
?C> 'he tenanc. is terminated Dith cause;
?c> - citation has Ceen issued and comEliance Dith the aEElicaCle Cuilding, housing or health
code requires alteration, remodeling or demolition and cannot Ce accomElished unless the tenantOs
dDelling unit is =acant; or
?d> 'he increase in rent aEElies in a uni/orm manner to all tenants.
'he maintenance o/ an action under this suCsection does not Ere=ent the tenant /rom seeFing damages
or inIuncti=e relie/ /or the landlordOs /ailure to comEl. Dith the rental agreement or maintain the
dDelling unit in a haCitaCle condition as required C. this chaEter.
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1ost Ero/its, lost goods, such as /ood, and the Cene/its o/ lost ser=ices, such as ad=ertising, are
e*amEles o/ losses that ma. constitute Hactual damagesH /or illegal e=iction. 4 :.$.".-. Q +,4?!>
?->. Degenhardt =. EDe 1td. 0artnershiE, !, :E !3, 3 -.3d 79, ?:e. !,>. Being an attorne. is
hard enough Dithout dealing Dith all o/ 0arF 'errace@s mal/easance. 0erhaEs i/ E' -1 e=er gathers
uE the gumEtion to hang out his oDn shingle the. Dill more /ull. aEEreciate that.
ANALYSIS
'enant@s reco=er. o/ damages /or emotional distress under 3ni/orm $esidential 1andlord and 'enant
-ct, + -.1.$.4th &!%; $ight o/ landlord legall. entitled to Eossession to disEossess tenant Dithout
legal Erocess, + -.1.$.3d 77; $eco=er. C. tenant o/ damages /or Eh.sical inIur. or mental anguish
occasioned C. Drong/ul e=iction, 7 -.1.$.!d 93+; & -m. 2ur. 0roo/ o/ )acts 3d 37&, 'enant@s $ights
and $emedies -gainst $etaliator. E=iction C. 1andlord. 99 -m. 2ur. 'rials !%9, $etaliator. E=iction
Claims.
E=idence suEEorted /inding that landlord@s e=iction o/ tenant Das retaliator. /or her comElaints
concerning Eersistent ElumCing EroClems and condition o/ common areas. N.$.".
%-.&,. 0aullin =. "utton, 9%+, 7!4 0.!d 749, ,! Ne=. 4!.
B. Da. o/ analog. to Je=iction millsK /or landlords, consider J)or e*amEle, aCuse o/ CanFruEtc.
Eroceedings C. renters Cecame so DidesEread in the Central District o/ Cali/ornia that JMiNn 99, 2.
Cli//ord 6allace, Chie/ 2udge o/ the Ninth Circuit Court o/ -EEeals, estaClished an -d 7oc
Committee on 3nlaD/ul Detainer and BanFruEtc. :ills to looF into EossiCle solutions to the Eractice
o/ aCusi=e /ilings to Ere=ent e=iction.K 2udge <eraldine :und, 3Edated $eEort o/ 3nlaD/ul Detainer
'asF )orce ?99!>. 'he committee /ound that CanFruEtc. JmillsK are a suCstantial cause o/ the
aCuse: 'he. churn out large numCers o/ Eetitions ?Dhich result in an automatic sta., /orestalling
e=iction>, Cut Eursue no /urther action. Estimates suggest that in the Central District alone, some
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!,,,,, to 4,,,,, such Eetitions are /iled e=er. .ear /or the sole EurEose o/ dela.ing the deCtor@s
e=iction. "ee id. at 7. -s those /amiliar Dith CanFruEtc. Eractice are onl. too Eain/ull. aDare, this
t.Ee o/ strategic maniEulation isn@t limited to renters@ Eetitions. "ee generall. :arc. 2.9. 'i//an.,
Crime and BanFruEtc., !4 BanFr.Ct.Dec. ?C$$>, at - ?"eEt. !, 993>.K
Awarding Attorney's Fees to Pro Se Litigants Under Rule 11, 2une, 997, 9& :ich. 1. $e=. !3,%,
2erem. D. "Eector. E' -1 cites no authorit. on this or an. other issue that li=es an.Dhere Ce.ond
/orm motion, temElate time, turn and Curn Eractice o/ laD. 6hile E' -1 did manage to cite the
"eller@s case, the. quotes no language /rom it and seemingl. maFes not attemEt to anal.Ge its ruling.
the. should ha=e. "ellers sEeaFs to aDards o/ attorne.@s /ees to Ere=ailing Earties in ci=il actions. 4t
does not EurEort to sEeaF to attorne.@s /ees aDards stemming /rom $ule =iolation, a situation
Dhere the granting o/ attorne.@s /ees to an attorne. Ero se litigant is /ar more acceEted throughout
-merican IurisErudence. "imEl. Eut, the "eller@s case is inaEElicaCle and E' -1 should stoE citing
cases Dhere the. clearl. has a =er. shalloD grasE o/ Dhat the. sEeaF to.
'o Dit:
Jstates that ha=e considered Dhether an attorne. EroEer Eerson litigant ma. Ce
aDarded attorne. /ees are di=ided, Dith a slight maIorit. Eermitting such /ees.
Decisions aEEro=ing /ee aDards to attorne. EroEer Eerson litigants generall. do so
on the Casis that an attorne. is Eaid /or rendering legal ser=ices, and i/ the. renders
such ser=ices on his oDn Cehal/, it results in as much Eecuniar. loss to him as i/
the. Eaid another attorne. to render the same ser=ices. "o, i/ a losing Eart. must
Ea. attorne. /ees an.Da., it should maFe no di//erence Dhether the /ees are to Ce
Eaid to an attorne. reEresenting himsel/ or another attorne. emElo.ed C. him. 4n
short, Ha laD.er@s time and ad=ice are his stocF in trade.H...6e interEret N$" +9.,3,
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to require that all EroEer Eerson litigants, Dhether attorne. or non(attorne., Ce
oCligated to Ea. attorne. /ees as a Ererequisite /or an aDard o/ Ere=ailing Eart.
attorne. /ees. 'his interEretation gi=es e//ect to the 1egislature@s clear intent that the
Ere=ailing Eart. in Iustice@s court Ce reimCursed C. the losing Eart. /or out(o/(
EocFet costs incurred to Erosecute the suit. 'o interEret the statute otherDise Dould
require us to rede/ine Dhat is meant C. an attorne. /ee, Dhich is commonl.
understood to Ce the sum Eaid or charged /or legal ser=ices. Because :attheDs
reEresented himsel/ and did not Ea. or incur an. oCligation to Ea. attorne. /ees, the
Iustice@s court e*ceeded its Iurisdiction C. aDarding such /ees. 6e there/ore grant,
in Eart, the Eetition /or a Drit o/ certiorari.K "ellers =. )ourth 2udicial Dist. Ct., 9
Ne=. !&+, 7 0 .3d 49& ?!,,3>.
N$" +9.,3, J0re=ailing Eart. alloDed attorne.@s /ee to Ce ta*ed as costs in Iustice court. 'he
Ere=ailing Eart. in an. ci=il action at laD in the Iustice courts o/ this "tate shall recei=e, in addition to
the costs o/ court as noD alloDed C. laD, a reasonaCle attorne. /ee. 'he attorne. /ee shall Ce /i*ed C.
the Iustice and ta*ed as costs against the losing Eart..K "o, E' -1@s Cig contriCution to the legal
research required to rule on this case is to cite "eller@s, Dhich does not sEeaF to Dhether a Ero se
attorne. can recei=e attorne.@s /ees Eursuant to a $ule sanction. 'he statute in=ol=ed does not
aEEl. here, either, Dhere a $ule "anction motion is in Ela.. )urther, e=en i/ it did aEEl., Dhich it
doesn@t, Coughlin did KEa. or incur an. oCligation to Ea. attorne. /eesK as the. has stated in the )act
section that the. Eaid to and incurred such an oCligation to himsel/. 6here :attheDs ma. ha=e not
Ceen e*act enough in his Eleadings, Coughlin has Ceen.
Coughlin has actuall., reasonaCl. and necessaril. incurred R&,,,, in the EreEaration o/ the Eleadings
the. has Eut /orth so /ar in this matter, and in dealing Dith E' -1@s regrettaCle, declasse conduct in
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this matter. E' -1 should Ce sanctioned in that amount, Elus an. /ees incurred in dra/ting a reEl. in
suEEort o/ this motion, and EreEaring /or and attending an. hearing. )urther, Coughlin hereC.
requests a hearing reElete Dith A JURY ?- $4<7' <3-$-N'EE B8 '7E 3N4'ED "'-'E"
"30$E:E C53$' EVEN 4N "3::-$8 EV4C'45N :-''E$", -N '7E$E 4" N5 15N<E$
2C$C0 ,+, "5 4 <E' -N -00E-1 '55T> on this matter to a=oid e=iction. 'here are e=identiar.
issues such as the amount o/ rent deductions agreed to, the amount o/ damages done C. 0arF
'errace@s landscaEing creD, thin sFulled tenant issues, etc.

67E$E)5$E, tenant, Zach Coughlin, Era.s that this Court rule that a summar. e=iction Eroceeding
is una=ailaCle to landlord here and aDard in e*cess o/ R,,,,, damages to 'enantACounterclaimant.
Dec(aratio$ #ade u$der "e$a(t of "er!ur/
I Dec(are* "ursua$t to NRS 03.040 t&at t&e fore)oi$) is true a$d correct a$d #ade u$der
"e$at( of "er!ur
A11IRMATI-N ,ursua$t to NRS 2334.030
'he undersigned does hereC. a//irm that the Ereceding document does not contain
the social securit. numCer o/ an. Eerson.
Dated this: )eCruar. !7th, !,!
UAsA Zach Coughlin
Zach Coughlin
'enantACounterclaimant
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,R--1 -1 SER5I+E
4, Zach Coughlin, declare:
5n )eCruar. !7th, !,!, 4, :r. Zach Coughlin ser=ed the /oregoing 'enant@s -nsDer and
-//ida=itADeclaration to 3, Da. No Cause E=iction, 'enant@s Counterclaim C. Elacing a true and
correct coE. hereo/ in the usEs mail, emailing, maFing all reasonaCle attemEts at Eersonall. ser=ing,
and /a*ing true coE. thereo/ to:
0arF 'errace 'oDnhomes 75-
cAo <a.le -gnes 9ern, Esq. and <a.le -. 9ern. 1td.
&4! 9ietGFe 1ane "uite !,,
$eno , NV %9&
'el: 77&(3!4(&93,
)a*: 77&(3!4(+73
ga.leFernVFernltd.com
0arF 'errace 'oDnhomes -ssn
cAo 6estern Ne=ada :anagement, 4nc.
$esidential, Commercial W -ssociation :anagement
"ue 9ing
0residentABroFerA"uEer=ising C:
%,4 :ill "treet, $eno, NV %9&,!
0h: 77&(!%4(4434
)a*: 77&(!%4(44+&
sueVDesternn=.com
DDD.Desternn=.com
in/oVDesternn=.com
$eno 2ustice Court, Ci=il Di=ision
". "ierra "t.
$eno, NV %9&,
Ci=il Di=ision )a*
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(((((((((((((((((((((((((((((
Zach Coughlin, 'enant
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Outlook Print Message

file:///R|/...ail%20to%20zach%20young%20regarding%20newly%20discovered%20ecomm%20recordings%20063341.htm[11/20/2012 8:14:36 AM]
Close Print
City Attorney Skau, updated discovery in iPhone case,
dispatch recordings, don't seem to reveal basis for "a
possible fight" assertions in office testimony and
prosecutors's filings and argument
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/14/12 2:09 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com
(skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org
(patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
(cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com
(consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us);
kadlicj@reno.gov (kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov);
schornsby@nvdetr.org (schornsby@nvdetr.org); jleslie@washoecounty.us
(jleslie@washoecounty.us); jgoodnight@washoecounty.us (jgoodnight@washoecounty.us);
jbosler@washoecounty.us (jbosler@washoecounty.us)
Dear DDA Young and Bar Counsel and Panel Members,
The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what
started all this off (by "all this" I mean the 46 days in jail, the 10 different trips to jail,
the five to six different evictions, all summary, the competency evaluations, and all the
associated grievances. This arrest and prosecution have largely been based on and the
office and prosecutor have cited to, their contention that the information from ECOMM
or dispatch told the RPD Officers (and the arresting Officer Nick Duralde is married to
a dispatcher working that night and perhaps whose voice is on these files, finally given
to me only today, by Reno City Attorney's Office Creighton Skau, after he secured my
attendance at a hearing that I do not believe was noticed in a legal since by sending me
an email saying J udge Sferrazza authorized service of the notice of the hearing by
email...which J udge Sferrazza denies (in fairness to Mr. Skau...its possible the J udge
did say that...Mr. Young could maybe shed some light on that, as apparently their was a
sort of group meeting with he, the Reno City Attorney and the WCPD on or about
November 8th, 2012 in rCR2012-063342, that I was not noticed on and, of course did
not attend).
Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch
reported a "possible fight" and how that somehow justified the rash approach taken by
Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand Larceny (7
days in jail, the eviction notice in the Richard Hills summary eviction from my former
home law office was served during the interim in RJ C Rev2011-001708) for a three
year old iphone that the alleged owner, Cory Goble, testified was worth about $80 at
the time....(and the overcharging of a felony enabled Officer Duralde to conduct a
search incident to arrest for a misdemeanor not committed in his presence, after 7
pm...which Nevada law prohibits, particularly where, as here, there was no citizen's
arrest (Coughlin himself called 911 and there is a video of the time prior to arrest
where Coughlin is heard imploring the skater youths to stay peaceful and wait for law
enforcement to arrive so a civil resolution of the dispute could be garnered).
I am writing now and providing this new production of ECOMM/911 dispatch
recordings that would seem to be the State's last hope of proving that the Officers were
told of, by dispatch, "a possible fight" and therein provide some factual basis for that
which Officer Duralde and DDA Young have testified to, and filed pleadings in that
matter arguing that reports of "a possible fight" justified the subsequent terry stop
weapons check pat down, and search incident to arrest (remember, Officer Duralde
announced 20 seconds into arriving on scene that he was going to arrest Coughlin and
do a search of Coughlin's pockets prior to conducting any of the pretexutal
"investigation" that he later testified to...its just that Officer Duralde did not realize he
was being recorded when he said that....no matter how he "remixed" things in his
Supplementary Declaration (filed within 48 hours of arrest) or his Narrative (by all
indications, the Narrative was only filed some three months after the arrest and
apparently after the RPD and City Attorneys Office became aware that the video of the
arrest was publicly available).
I have listened closely to these dispatch recordings and hear nothing about "a possible
fight". Does that make the Officer's Testimony perjury and DDA Young's conduct
misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the SBN's
Office on Double R. Blvd. I ask that you attend and explain these matters as this arrest
is pled in Bar Counsel Kings SCR 105 Complaint.
Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to
subpoena the dispatch recordings until October 3, 2012 (despite the Trial occuring on
May 7th, 2012 (in violation of NRS 178.405, no less), and again on J uly 16th,
2012....and, again on August 29th, and September 5th, 2012....and then please explain
why you feigned inability to personally serve subpoenas as a basis for failing to get
Nicole Watson (easily found and or served via a certified mailing under NRS 174.345,
at the addresses your investigator refused to turn over to me until November 2012 upon
a court order (you guys are supposed to help defend the accused, not the County or
local law enforcement against their potential civil liability for ego driven foolish
arrests) as a student at McQueen High School along with Lucy Byington, both
percipient witnesses, and where Watson was captured on tape admitting to the "man
with a six-pack" holding the phone aloft and offering it up, and announcing, very
loudly, that he woud "throw it in the river" if it was not immediately claimed (therein
presenting yet another claim of right defense and further vitiating the legitimacy of
DDA Young's retaliatory, deficiently pled, amending of the Complaint on December
5th, 2012 to included "possessing or receiving stolen property from another".
I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City
Attorney's gained an advantage and prejudiced my ability to defend in both NG12-
0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I will
note that at least J oe Goodnight gathered the three 911 calls.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 66 files to share with you on SkyDrive. To view them, click the links below.
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
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IN THE SUPREME COURT OF THE STATE OF NEVADA
IN RE: REINSTATEMENT OF ROBERT
S. BECKETT, ES ., BAR NO. 3383.
No. 57763
ORDER GRANTING PETITION FOR REINSTATE
This is a petition for reinstatement pursuant to SCR 111(10)
fled by attorney Robert S. Beckett. On December 30, 2010, this court
temporarily suspended Beckett fom the practice of law and referred him
to the disciplinary board based on his plea of no contest to a charge of
obstructing a public ofcer. Our order was premised on the fact that
Beckett's offense constituted a "serious" crime under SCR 111(6), for
which temporary suspension and referral to the appropriate disciplinary
board are mandatory under SCR 111(7) and (8).1
Beckett contends that he should be reinstated to the practice
of law during the pendency of his disciplinary proceedings because the
criminal case underlying our December 30, 2010, order has been dismissed
with prejudice.2 Beckett acknowledges that, even if he is reinstated, our
lAlthough not mentioned in the petition, on January 8, 2010,
we also referred Beckett to the disciplinary board based on his plea of no
contest to one count of misdemeanor wet reckless driving in California.
We declined to impose a temporary suspension at that time.
2Alternatively, Beckett requests that the court set aside his
temporary suspension pursuant to SCR 111(7). We conclude that Beckett
has failed to demonstrate good cause to set aside our order of temporary
suspension under SCR 111(7).
II -C9965
SncvCunt
OF
NEADA
order of reinstatement would not terminate the pending disciplinary
proceedings.3
SCR 111(10) gives us discretion to reinstate an attorney whose
underlying conviction has been reversed. The petition is accompanied by a
certified copy of a February 2, 2011, order from the Pahrump Township
Justice Court dismissing Case No. 10CR01587 with prejudice. In light of
the fact that the charge underlyng our order of temporary suspension has
been dismissed with prejudice, and our previous determination that
Beckett's California misdemeanor conviction did not warrant imposition of
a temporary suspension, we conclude that there is no longer a basis for
Beckett being temporarily suspended pending the outcome of his
disciplinary proceedings. We therefore grant the petition. Attorney
Robert S. Beckett, Bar No. 3383, is hereby reinstated to the practice of law
pending the outcome of his disciplinary proceedings.
It is so ORDERED.
J.
Saitta
J.

J.
Parraguirre
3SCR 111(10) that "reinstatement will not terminate
proceeding pending u,,"U attorney, the of
by hearing on the basis of the
"
2
SurmwCn
NEI ADA
cc: David A. Clark, Bar Counsel
Jeffrey R. Albregts, Chair, Southern Nevada Disciplinary Board
Kimberly K. Farmer, Executive Director, State Bar of Nevada
Michael J. War hola, LLC
Perry Thompson, Admissions Offce, United States Supreme Court
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THESTATEOFNEVADA,
Plaintiff,
vs.
Case No.'(/...C'((. 1L OC:::>':J(;30
15. ):Y)
0. _1-
Dclcndant.
____________________1
understailliing.
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2 2
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02127.2012
02t2sn012
0)022012
0]/15/2012
0]n9/2012
OSnJ/ 2012
0713 112012
OSlO9 2012
08/ 09 2012
0&09 2012
08/ 21 2012
081 21 / 2012
0827.2012
0827,2012
0827(20[2
08/ 2712012
CASE S MMARY
CASE NO. RCRl012-065630
1500 00 Hond or Cash Ball Ball Condlllond &1 by lhe lIonoruble Scali Peurson
^1aD:aIut} hlaIu5Conference (I ]0 PM) (1Bd1C18 '1!Ccf bf00Cf.18CX|
L3Scf8hSclfcd I0 Ph0Icf L0uU
10 D C lflmOl1 PS)CII
5ufClyHond oSIcd
Uohd LXuDCf8Icd
CANCELED M:lldlIOJ bIIuSConference (I ;30 I'M) (Jullkial OrCtr: L) nch, "atrlcl.)
V(ealt
9 KCmDd lfom bcCoDd 1ud1018l 1lSIfICIL0BH Ilcd
Mallon 1!cd
MOl/Oil /or l.eal' o/ Courl lO Anamd ComplUlf// fled
9 KcqucSI of.Vud1OLL:lcd
r Iollon Filed
/0 '>rud I Forma Pal/puIS
Mallon Denied
to />rofed / Formu PUlI/rlS
rlotion IIlrln(I'30PM) (1udlcialOmcer bl0,clcl|
06I 121012 Continued 10 0 7116011 - MSC NeSeflCOnilnuunC' nlf Slate ol\e
l,
Cough/III, Zachar Barker
0 7//61011 Conllnued 10 08062 011-MSC ReSefCOrlllnuunc(' The Slate o/.\Ivada
Coughlin, Zochar)
' 8(1f/er
0861 1011 Can/li/led 10 081111011 MSC ResetlCanlllll/allCe Th, State o/ Nel'ada,
COl/ghlin, Zodlry 80rkfr
"OrllfS PrtSf'n/ P/allltif
!
Th! SIO/' 0/ Nemda
Public lk/emier Dog(/I, Hlfuy
Deputy Dlstricl Allarnf' YOIlllg,7, ,,eh
/)f/tlliam lOllRMlII, Zachar /arker
Hc8fmg KcSu!I l1ud10t3'!!Ccf` bcH8. clcf_
/Jo/endU/1/ /alled 10 appear, lk/ensl requests thal lhlS case bl COrll/fIIled Ulld sel >\llh hiS
IlIIsdemtolior Reno Jusllce Courl Cast set/or August )9,201) al 8 JOA M Sale opposes as
Ihls I AIr Cuugh/Ill's second "me/adlllg ID appear I/ense'
s mOilOn IS CRANTED MSC IS
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PUrle S Present PIQlllllf 1t StOlt 0/ "elmia
lut' D,st"ct Alloe Young. Mch
De/endanl COUgh/III, /.chuf OorAer
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Stru:Aen
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Thf Statf mow'd 10 smi Secold Amell ifd Cm7/lIIol Camploml
Mallon LI8Dlcd {1ud1018!'ICcf: bcH,cIcf_
/Q )"k( SeC(}d Amel/ded Crullnul Complaml
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THESTATEOFNEVADA,
Plaintiff,
vs.
Case No.'(/...C'((. 1L OC:::>':J(;30
15. ):Y)
0. _1-
Dclcndant.
____________________1
understailliing.
I;
/,/
1
, "

, , -
...1'\
1
cvaluation
5
DATED \
.20 / ,;)"
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Document Code:
Zach Coughlin,Esq.
NV Bar No: 9473
4!! E. 9th "t. #!
$eno, NV %9&!
'ele: 77&(33%(%%
)a*: 949(++7(74,!
-ttorne. /or 0ro "e -ttorne. 1itigant
23"'4CE C53$' $EN5 '56N"740
6-"75E C53N'8, NEV-D-
0-$9 'E$$-CE '56N75:E" -""N
; 6E"'E$N NEV-D- :-N-<:EN',
4NC., <a.le -gnes 9ern, Esq. and <a.le -.
9ern. 1td.; 1-ND15$D 5$ D318
-3'75$4ZED -<EN';
1andlord,
=s.
Z-C7-$8 B-$9E$ C53<714N;
'enant.
>
>
>
>
>
>
>
>
>
>
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>
C-"E N5:
DE0'. N5:
?23D<E ")E$$-ZZ- 4ND4C-'ED the.
6531D N5' -CCE0' '74" C-"E )5$
74" C-1END-$ 5$ 5'7E$64"E 7E-$
-N8'74N< 4N $E1-'45N '5 4'>
JURY TRIAL DEMANDED
'EN-N'@" -N"6E$ -ND 'EN-N'@"
-))4D-V4'ADEC1-$-'45N '5 3, D-8
N5'4CE '5 B34'; :5'45N )5$
"-NC'45N" -ND -''5$NE8@" )EE"
'EN-N'@" -N"6E$ -ND 'EN-N'@" -))4D-V4'ADEC1-$-'45N '5 3, D-8 N5'4CE '5
B34'; :5'45N )5$ "-NC'45N" -ND -''5$NE8@" )EE"
054N'" -ND -3'75$4'4E"
'enantADe/endant, Zach Coughlin, Esq., hereC. /iles an -nsDer, or alternati=el., an
-mended 'enant@s -nsDer to the 3, da. N5'4CE '5 B34' -ND -N8 "3B"EB3EN' & D-8
N5'4CE '5 B34' 3N1-6)31 DE'-4NE$ N5'4CE,
'enant /urther mo=es /or sanctions against landlord, Eursuant to N$" 7.,%&, /or the attorne.s@ /ees
tenant has needlessl.
( (
note: this was file stamped
2/27/12 by the RJC in
RJC REV2012-000374
disposed of by RJC Judge
Schroeder, on 3/15/12 on a default
basis where Coughlin was 8 minutes
late to the stacked docket hearing
coughlin, pursuant to wcso police was cuffed
and evicted at gunpoint
3 hours later.
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incurred due to 0arF 'errace and E' -1@s recFless uses o/ this court@s Erocesses. 0arF 'errace has not
comElied Dith the requirements o/ the rules o/ ci=il Erocedure the. seeFs to in=oFe. 7is
motion is /atall. /laDed and in/irm as a matter o/ laD.
'his oEEosition and motion is Cased on the Eoints and authorities CeloD, the
aCo=e(re/erenced statute and rules o/ ci=il Erocedure, and all EaEers and Eleadings on /ile
herein.
NRS 40.310 Issue of fact to be tried b !ur if "ro"er de#a$d #ade. %&e$e'er a$ issue of fact
is "rese$ted b t&e "(eadi$)s* it s&a(( be tried b a !ur* if "ro"er de#a$d is #ade "ursua$t to
t&e Ne'ada Ru(es of +i'i( ,rocedure or t&e Justice +ourt Ru(es of +i'i( ,rocedure.
C5:E" N56, the undersigned 'enant and states:
. 4 am the tenant o/ a rental united located at 4!! E. 9th "t. #!, $eno %9&!.
!. m. rent is not suCsidiGed C. EuClic housing authorit. or other go=ernmental agenc..
<laGier =. 2ustice Court o/ "mith Valle. 'E., Ne=. %+4, %99 0.!d ,& ?Ne=. 2ul !7, 99&>:
H"ummar. e=iction statute alloDing landlord to aEEl. to Iustice@s court /or e=iction
order Cased on de/ault in Ea.ment o/ rent did not aEEl. to unlaD/ul detainer action
against tenant Dho ne=er Eaid an. rent nor Das required to Ea. an. and, thus,
summar. e=iction order Das outside Iurisdiction o/ Iustice@s court. N.$.". 4,.!&3..5n
:arch , 993, $ichard )ulstone, Eresident o/ )ulstone, ser=ed <laGier Dith a thirt.(
da. notice to quit the EroEert.. <laGier /ailed to =acate the Eremises,and on -Eril !,
993, )ulstone ser=ed <laGier Dith a /i=e(da. notice. 'his notice e*Eressl.
threatened an action in Iustice@s court /or e=iction, Eursuant to N$" 4,.!&3,)N the
summar. e=iction statute. )N. N$" 4,.!&3 alloDs a landlord to aEEl. to the Iustice@s
court /or an e=iction order Cased on de/ault in Ea.ment o/ rent. 4/ the tenant can
shoD, C. a//ida=it, a legal de/ense to the alleged unlaD/ul detainer, /urther
Eroceedings must Ce conducted Eursuant to the more /ormal e=iction Erocedures in
N$" 4,.!9, to 4,.4!,. 4/, on the other hand, the tenant /ails to shoD a legal de/ense
to the alleged unlaD/ul detainer, then the Iustice@s court ma. issue a summar. order
/or remo=al o/ the tenant. 'he Iustice@s court held a hearing Eursuant to the Ero=isions
o/ N$" 4,.!&3 and ordered that <laGier =acate the EroEert. Dithin thirt. da.s.
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<laGier then /iled a Eetition /or a Drit o/ certiorari Ce/ore the district court, alleging
that the Iustice@s court e*ceeded its Iurisdiction under the Jsummar.K e=iction
Ero=isions o/ the statute C., inter alia, inquiring into matters Ce.ond the truth/ulness
and su//icienc. o/ the a//ida=its, and /ailing to dismiss the Jsummar.K e=iction
Eroceeding once a legal de/ense had Ceen raised. 'he district court held a hearing on
the Drit Eetition and denied the Eetition. 5n aEEeal to this court, <laGier argues that,
Eursuant to N$" 4,.!&3, once he raised the legal de/ense that he Das a li/e tenant
under the grant o/ a li/e estate, the Iustice@s court Das oCligated to dismiss the
Jsummar.K Eroceeding and to require that the landlord Erosecute his unlaD/ul
detainer action under the JElenar.K e=iction Eroceedings Ero=ided /or in N$" 4,.!9,
to 4,.4!,. LL,+ -lthough <laGier@s argument is logicall. sound, it is simEl.
irrele=ant. 4t is clear that, desEite all the Eroceedings CeloD and the arguments o/ the
Earties Ce/ore this court, N$" 4,.!&3 does not aEEl. to this case. 'he statute is
aEElicaCle JDhen the tenant o/ an. dDelling M N Dith Eeriodic rent reser=ed C. the
month or an. shorter Eeriod, is in de/ault in Ea.ment o/ the rent.K ?EmEhasis L%++
added.> -ll Earties to this action concede that <laGier ne=er Eaid an. rent, nor Das he
required to Ea. an.. 4t ma. Ce that )ulstone is entitled to ha=e <laGier remo=ed /rom
the EroEert., Cut not Eursuant to N$" 4,.!&3. 'here Das no case or contro=ers.
Ce/ore the Iustice@s court Cased on N$" 4,.!&3, and accordingl., the Iustice@s court
e*ceeded its Iurisdiction C. issuing the summar. e=iction order. -ccordingl., De
re=erse the Iudgment o/ the district court and remand to the district court Dith
directions to grant the Drit. )urther, De order that the e=iction order entered C. the
Iustice@s court Ce =acated. Ne=.,99&. <laGier =. 2ustice Court o/ "mith Valle. 'E.
Ne=. %+4, %99 0.!d ,&, "ee, also, Ne=.,99+. 1iEEis =. 0eters ! Ne=. ,,%,
9! 0.!d !4%H
N$" 4,.!&3 3nlaD/ul detainer: "uEElemental remed. o/ summar. e=iction and e*clusion o/ tenant
/or de/ault in Ea.ment o/ rent. . E*ceEt as otherDise Ero=ided in suCsection ,, in addition to the
remed. Ero=ided in N$" 4,.!&! and 4,.!9, to 4,.4!,, inclusi=e, Dhen the tenant o/ an. dDelling,
aEartment, moCile home, recreational =ehicle or commercial Eremises Dith Eeriodic rent reser=ed C.
the month or an. shorter Eeriod is in de/ault in Ea.ment o/ the rent, the landlord or the landlordOs
agent, unless otherDise agreed in Driting, ma. ser=e or ha=e ser=ed a notice in Driting, requiring in
the alternati=e the Ea.ment o/ the rent or the surrender o/ the Eremises: ?a> -t or Ce/ore noon o/ the
/i/th /ull da. /olloDing the da. o/ ser=ice; or ?C> 4/ the landlord chooses not to Eroceed in the manner
set /orth in EaragraEh ?a> and the rent is reser=ed C. a Eeriod o/ DeeF or less and the tenanc. has
not continued /or more than 4& da.s, at or Ce/ore noon o/ the /ourth /ull da. /olloDing the da. o/
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ser=ice. P -s used in this suCsection, Jda. o/ ser=iceK means the da. the landlord or the landlordOs
agent Eersonall. deli=ers the notice to the tenant. 4/ Eersonal ser=ice Das not so deli=ered, the Jda. o/
ser=iceK means the da. the notice is deli=ered, a/ter Eosting and mailing Eursuant to suCsection !, to
the sheri// or constaCle /or ser=ice i/ the request /or ser=ice is made Ce/ore noon. 4/ the request /or
ser=ice C. the sheri// or constaCle is made a/ter noon, the Jda. o/ ser=iceK shall Ce deemed to Ce the
da. ne*t /olloDing the da. that the request is made /or ser=ice C. the sheri// or constaCle. !. -
landlord or the landlordOs agent Dho ser=es a notice to a tenant Eursuant to EaragraEh ?C> o/
suCsection shall attemEt to deli=er the notice in Eerson in the manner set /orth in EaragraEh ?a> o/
suCsection o/ N$" 4,.!%,. 4/ the notice cannot Ce deli=ered in Eerson, the landlord or the landlordOs
agent: ?a> "hall Eost a coE. o/ the notice in a consEicuous Elace on the Eremises and mail the notice
C. o=ernight mail; and ?C> -/ter the notice has Ceen Eosted and mailed, ma. deli=er the notice to the
sheri// or constaCle /or ser=ice in the manner set /orth in suCsection o/ N$" 4,.!%,. 'he sheri// or
constaCle shall not acceEt the notice /or ser=ice unless it is accomEanied C. Dritten e=idence, signed
C. the tenant Dhen the tenant tooF Eossession o/ the Eremises, that the landlord or the landlordOs
agent in/ormed the tenant o/ the Ero=isions o/ this section Dhich set /orth the laD/ul Erocedures /or
e=iction /rom a short(term tenanc.. 3Eon acceEtance, the sheri// or constaCle shall ser=e the notice
Dithin 4% hours a/ter the request /or ser=ice Das made C. the landlord or the landlordOs agent. 3. -
notice ser=ed Eursuant to suCsection or ! must: ?a> 4denti/. the court that has Iurisdiction o=er the
matter; and ?C> -d=ise the tenant: ?> 5/ the tenantOs right to contest the matter C. /iling, Dithin the
time sEeci/ied in suCsection /or the Ea.ment o/ the rent or surrender o/ the Eremises, an a//ida=it
Dith the court that has Iurisdiction o=er the matter stating that the tenant has tendered Ea.ment or is
not in de/ault in the Ea.ment o/ the rent; ?!> 'hat i/ the court determines that the tenant is guilt. o/ an
unlaD/ul detainer, the court ma. issue a summar. order /or remo=al o/ the tenant or an order
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Ero=iding /or the nonadmittance o/ the tenant, directing the sheri// or constaCle o/ the count. to
remo=e the tenant Dithin !4 hours a/ter receiEt o/ the order; and ?3> 'hat, Eursuant to N$" %-.39,,
a tenant ma. seeF relie/ i/ a landlord unlaD/ull. remo=es the tenant /rom the Eremises or e*cludes the
tenant C. ClocFing or attemEting to ClocF the tenantOs entr. uEon the Eremises or Dill/ull. interruEts
or causes or Eermits the interruEtion o/ an essential ser=ice required C. the rental agreement or
chaEter %- o/ N$". 4. 4/ the tenant /iles such an a//ida=it at or Ce/ore the time stated in the notice,
the landlord or the landlordOs agent, a/ter receiEt o/ a /ile(stamEed coE. o/ the a//ida=it Dhich Das
/iled, shall not Ero=ide /or the nonadmittance o/ the tenant to the Eremises C. locFing or otherDise. &.
3Eon noncomEliance Dith the notice: ?a> 'he landlord or the landlordOs agent ma. aEEl. C. a//ida=it
o/ comElaint /or e=iction to the Iustice court o/ the toDnshiE in Dhich the dDelling, aEartment,
moCile home or commercial Eremises are located or to the district court o/ the count. in Dhich the
dDelling, aEartment, moCile home or commercial Eremises are located, Dhiche=er has Iurisdiction
o=er the matter. 'he court ma. thereuEon issue an order directing the sheri// or constaCle o/ the
count. to remo=e the tenant Dithin !4 hours a/ter receiEt o/ the order. 'he a//ida=it must state or
contain: ?> 'he date the tenanc. commenced. ?!> 'he amount o/ Eeriodic rent reser=ed. ?3> 'he
amounts o/ an. cleaning, securit. or rent deEosits Eaid in ad=ance, in e*cess o/ the /irst monthOs rent,
C. the tenant. ?4> 'he date the rental Ea.ments Cecame delinquent. ?&> 'he length o/ time the tenant
has remained in Eossession Dithout Ea.ing rent. ?+> 'he amount o/ rent claimed due and delinquent.
?7> - statement that the Dritten notice Das ser=ed on the tenant in accordance Dith N$" 4,.!%,. ?%>
- coE. o/ the Dritten notice ser=ed on the tenant. ?9> - coE. o/ the signed Dritten rental agreement,
i/ an.. ?C> E*ceEt Dhen the tenant has timel. /iled the a//ida=it descriCed in suCsection 3 and a /ile(
stamEed coE. o/ it has Ceen recei=ed C. the landlord or the landlordOs agent, and e*ceEt Dhen the
landlord is ErohiCited Eursuant to N$" %-.4%,, the landlord or the landlordOs agent ma., in a
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EeaceaCle manner, Ero=ide /or the nonadmittance o/ the tenant to the Eremises C. locFing or
otherDise. +. 3Eon the /iling C. the tenant o/ the a//ida=it Eermitted in suCsection 3, regardless o/ the
in/ormation contained in the a//ida=it, and the /iling C. the landlord o/ the a//ida=it Eermitted C.
suCsection &, the Iustice court or the district court shall hold a hearing, a/ter ser=ice o/ notice o/ the
hearing uEon the Earties, to determine the truth/ulness and su//icienc. o/ an. a//ida=it or notice
Ero=ided/or in this section. 4/ the court determines that there is no legal de/ense as to the alleged
unlaD/ul detainer and the tenant is guilt. o/ an unlaD/ul detainer, the court ma. issue a summar.
order /or remo=al o/ the tenant or an order Ero=iding /or the nonadmittance o/ the tenant. 4/ the court
determines that there is a legal de/ense as to the alleged unlaD/ul detainer, the court shall re/use to
grant either Eart. an. relie/, and, e*ceEt as otherDise Ero=ided in this suCsection, shall require that
an. /urther Eroceedings Ce conducted Eursuant to N$" 4,.!9, to 4,.4!,, inclusi=e. 'he issuance o/ a
summar. order /or remo=al o/ the tenant does not Ereclude an action C. the tenant /or an. damages
or other relie/ to Dhich the tenant ma. Ce entitled. 4/ the alleged unlaD/ul detainer Das Cased uEon
suCsection & o/ N$" 4,.!&4, the re/usal C. the court to grant relie/ does not Ereclude the landlord
therea/ter /rom Eursuing an action /or unlaD/ul detainer in accordance Dith N$" 4,.!&. 7. 'he
tenant ma., uEon Ea.ment o/ the aEEroEriate /ees relating to the /iling and ser=ice o/ a motion, /ile a
motion Dith the court, on a /orm Ero=ided C. the clerF o/ the court, to disEute the amount o/ the
costs, i/ an., claimed C. the landlord Eursuant to N$" %-.4+, or %C.!3, /or the in=entor.,
mo=ing and storage o/ Eersonal EroEert. le/t on the Eremises. 'he motion must Ce /iled Dithin !,
da.s a/ter the summar. order /or remo=al o/ the tenant or the aCandonment o/ the Eremises C. the
tenant, or Dithin !, da.s a/ter: ?a> 'he tenant has =acated or Ceen remo=ed /rom the Eremises; and
?C> - coE. o/ those charges has Ceen requested C. or Ero=ided to the tenant, P Dhiche=er is later. %.
3Eon the /iling o/ a motion Eursuant to suCsection 7, the court shall schedule a hearing on the
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motion. 'he hearing must Ce held Dithin , da.s a/ter the /iling o/ the motion. 'he court shall a//i*
the date o/ the hearing to the motion and order a coE. ser=ed uEon the landlord C. the sheri//,
constaCle or other Erocess ser=er. -t the hearing, the court ma.: ?a> Determine the costs, i/ an.,
claimed C. the landlord Eursuant to N$" %-.4+, or %C.!3, and an. accumulating dail. costs;
and ?C> 5rder the release o/ the tenantOs EroEert. uEon the Ea.ment o/ the charges determined to Ce
due or i/ no charges are determined to Ce due. 9. - landlord shall not re/use to acceEt rent /rom a
tenant that is suCmitted a/ter the landlord or the landlordOs agent has ser=ed or had ser=ed a notice
Eursuant to suCsection i/ the re/usal is Cased on the /act that the tenant has not Eaid collection /ees,
attorne.Os /ees or other costs other than rent, a reasonaCle charge /or late Ea.ments o/ rent or
dishonored checFs, or a securit.. -s used in this suCsection, Jsecurit.K has the meaning ascriCed to it
in N$" %-.!4,. ,. 'his section does not aEEl. to the tenant o/ a moCile home lot in a moCile
home EarF or to the tenant o/ a recreational =ehicle lot in an area o/ a moCile home EarF in this "tate
other than an area designated as a recreational =ehicle lot Eursuant to the Ero=isions o/ suCsection +
o/ N$" 4,.!&. N$" 4,.!%, "er=ice o/ notices to quit; Eroo/ required Ce/ore issuance o/ order to
remo=e. . E*ceEt as otherDise Ero=ided in N$" 4,.!&3, the notices required C. N$" 4,.!& to
4,.!+,, inclusi=e, ma. Ce ser=ed: ?a> B. deli=ering a coE. to the tenant Eersonall., in the Eresence o/
a Ditness; ?C> 4/ the tenant is aCsent /rom the tenantOs Elace o/ residence or /rom the tenantOs usual
Elace o/ Cusiness, C. lea=ing a coE. Dith a Eerson o/ suitaCle age and discretion at either Elace and
mailing a coE. to the tenant at the tenantOs Elace o/ residence or Elace o/ Cusiness; or ?c> 4/ the Elace
o/ residence or Cusiness cannot Ce ascertained, or a Eerson o/ suitaCle age or discretion cannot Ce
/ound there, C. Eosting a coE. in a consEicuous Elace on the leased EroEert., deli=ering a coE. to a
Eerson there residing, i/ the Eerson can Ce /ound, and mailing a coE. to the tenant at the Elace Dhere
the leased EroEert. is situated. !. "er=ice uEon a suCtenant ma. Ce made in the same manner as
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Ero=ided in suCsection . 3. Be/ore an order to remo=e a tenant is issued Eursuant to suCsection & o/
N$" 4,.!&3, a landlord shall /ile Dith the court a Eroo/ o/ ser=ice o/ an. notice required C. that
section. Be/ore a Eerson ma. Ce remo=ed as ErescriCed in N$" 4,.!9, to 4,.4!,, inclusi=e, a
landlord shall /ile Dith the court Eroo/ o/ ser=ice o/ an. notice required Eursuant to N$" 4,.!&&.
E*ceEt as otherDise Ero=ided in suCsection 4, this Eroo/ must consist o/: ?a> - statement, signed C.
the tenant and a Ditness, acFnoDledging that the tenant recei=ed the notice on a sEeci/ied date; ?C> -
certi/icate o/ mailing issued C. the 3nited "tates 0ostal "er=ice; or ?c> 'he endorsement o/ a sheri//,
constaCle or other Erocess ser=er stating the time and manner o/ ser=ice. 4. 4/ ser=ice o/ the notice
Das not deli=ered in Eerson to a tenant Dhose rent is reser=ed C. a Eeriod o/ DeeF or less and the
tenanc. has not continued /or more than 4& da.s, Eroo/ o/ ser=ice must include: ?a> - certi/icate o/
mailing issued C. the 3nited "tates 0ostal "er=ice or C. a Eri=ate Eostal ser=ice to the landlord or the
landlordOs agent; or ?C> 'he endorsement o/ a sheri// or constaCle stating the: ?> 'ime and date the
request /or ser=ice Das made C. the landlord or the landlordOs agent; ?!> 'ime, date and manner o/
the ser=ice; and ?3> )ees Eaid /or the ser=ice. N$" %-.,, J1andlordK de/ined. J1andlordK means
a Eerson Dho Ero=ides a dDelling unit /or occuEanc. C. another Eursuant to a rental agreement. N$"
%-.!, J5DnerK de/ined. J5DnerK means one or more Eersons, Iointl. or se=erall., in Dhom is
=ested: . -ll or Eart o/ the legal title to EroEert., e*ceEt a trustee under a deed o/ trust Dho is not in
Eossession o/ the EroEert.; or !. -ll or Eart o/ the Cene/icial oDnershiE, and a right to Eresent use and
enIo.ment o/ the Eremises. N$" %-.&, J$entK de/ined. J$entK means all Eeriodic Ea.ments to
Ce made to the landlord /or occuEanc. o/ a dDelling unit, including, Dithout limitation, all reasonaCle
and actual late /ees set /orth in the rental agreement. ?-dded to N$" C. 977, 33; - 999, 9%4>.
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'his action is Crought to address )ederal )air 7ousing or Ne=ada laDs ErohiCiting discrimination. 4
am Ceing discriminated against Cased on imEermissilCe characteristics. )urther, m. lease has not
e*Eired or terminated .et. N$" %-.+, J$ental agreementK de/ined. J$ental agreementK means
an. oral or Dritten agreement /or the use and occuEanc. o/ a dDelling unit or Eremises. ?-dded to
N$" C. 977, 33>
N$" %-.&, $etaliator. conduct C. landlord against tenant ErohiCited; remedies; e*ceEtions. .
E*ceEt as otherDise Ero=ided in suCsection 3, the landlord ma. not, in retaliation, terminate a
tenanc., re/use to reneD a tenanc., increase rent or decrease essential items or ser=ices required C.
the rental agreement or this chaEter, or Cring or threaten to Cring an action /or Eossession i/: ?a> 'he
tenant has comElained in good /aith o/ a =iolation o/ a Cuilding, housing or health code aEElicaCle to
the Eremises and a//ecting health or sa/et. to a go=ernmental agenc. charged Dith the resEonsiCilit.
/or the en/orcement o/ that code; ?C> 'he tenant has comElained in good /aith to the landlord or a laD
en/orcement agenc. o/ a =iolation o/ this chaEter or o/ a sEeci/ic statute that imEoses a criminal
Eenalt.; ?c> 'he tenant has organiGed or Cecome a memCer o/ a tenantOs union or similar
organiGation; ?d> - citation has Ceen issued resulting /rom a comElaint descriCed in EaragraEh ?a>; ?e>
'he tenant has instituted or de/ended against a Iudicial or administrati=e Eroceeding or arCitration in
Dhich the tenant raised an issue o/ comEliance Dith the requirements o/ this chaEter resEecting the
haCitaCilit. o/ dDelling units; ?/> 'he tenant has /ailed or re/used to gi=e Dritten consent to a
regulation adoEted C. the landlord, a/ter the tenant enters into the rental agreement, Dhich requires
the landlord to Dait until the aEEroEriate time has elaEsed Ce/ore it is en/orceaCle against the tenant;
or ?g> 'he tenant has comElained in good /aith to the landlord, a go=ernment agenc., an attorne., a
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rights Dhich are guaranteed or Erotected under those laDs. !. 4/ the landlord =iolates an. Ero=ision o/
suCsection , the tenant is entitled to the remedies Ero=ided in N$" %-.39, and has a de/ense in
an. retaliator. action C. the landlord /or Eossession. 3. - landlord Dho acts under the circumstances
descriCed in suCsection does not =iolate that suCsection i/: ?a> 'he =iolation o/ the aEElicaCle
Cuilding, housing or health code o/ Dhich the tenant comElained Das caused Erimaril. C. the lacF o/
reasonaCle care C. the tenant, a memCer o/ his or her household or other Eerson on the Eremises Dith
his or her consent; ?C> 'he tenanc. is terminated Dith cause; ?c> - citation has Ceen issued and
comEliance Dith the aEElicaCle Cuilding, housing or health code requires alteration, remodeling or
demolition and cannot Ce accomElished unless the tenantOs dDelling unit is =acant; or ?d> 'he
increase in rent aEElies in a uni/orm manner to all tenants. P 'he maintenance o/ an action under this
suCsection does not Ere=ent the tenant /rom seeFing damages or inIuncti=e relie/ /or the landlordOs
/ailure to comEl. Dith the rental agreement or maintain the dDelling unit in a haCitaCle condition as
required C. this chaEter. N$" %-.3%, )ailure o/ landlord to suEEl. essential items or ser=ices. .
4/ the landlord is required C. the rental agreement or this chaEter to suEEl. heat, air(conditioning,
running Dater, hot Dater, electricit., gas, a /unctioning door locF or another essential item or ser=ice
and the landlord Dill/ull. or negligentl. /ails to do so, causing the Eremises to Cecome un/it /or
haCitation, the tenant shall gi=e Dritten notice to the landlord sEeci/.ing the Creach. 4/ the landlord
does not adequatel. remed. the Creach, or use his or her Cest e//orts to remed. the Creach Dithin 4%
hours, e*ceEt a "aturda., "unda. or legal holida., a/ter it is recei=ed C. the landlord, the tenant ma.,
in addition to an. other remed.: ?a> 0rocure reasonaCle amounts o/ such essential items or ser=ices
during the landlordOs noncomEliance and deduct their actual and reasonaCle cost /rom the rent; ?C>
$eco=er actual damages, including damages Cased uEon the lacF o/ use o/ the Eremises or the
diminution o/ the /air rental =alue o/ the dDelling unit; ?c> 6ithhold an. rent that Cecomes due
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during the landlordOs noncomEliance Dithout incurring late /ees, charges /or notice or an. other
charge or /ee authoriGed C. this chaEter or the rental agreement, until the landlord has attemEted in
good /aith to restore the essential items or ser=ices; or ?d> 0rocure other housing Dhich is comEaraCle
during the landlordOs noncomEliance, and the rent /or the original Eremises /ull. aCates during this
Eeriod. 'he tenant ma. reco=er the actual and reasonaCle cost o/ that other housing Dhich is in e*cess
o/ the amount o/ rent Dhich is aCated. !. 4/ the tenant Eroceeds under this section, the tenant ma. not
Eroceed under N$" %-.3&, and %-.3+, as to that Creach. 3. 'he rights o/ the tenant under this
section do not arise until the tenant has gi=en Dritten notice as required C. suCsection , e*ceEt that
the tenant ma., Dithout ha=ing gi=en that notice: ?a> $eco=er damages as authoriGed under EaragraEh
?C> o/ suCsection i/ the landlord: ?> -dmits to the court that the landlord had FnoDledge o/ the lacF
o/ such essential items or ser=ices; or ?!> 7as recei=ed Dritten notice o/ the uninhaCitaCle condition
caused C. such a lacF /rom a go=ernmental agenc. authoriGed to insEect /or =iolations o/ Cuilding,
housing or health codes. ?C> 6ithhold rent under EaragraEh ?c> o/ suCsection i/ the landlord: ?>
7as recei=ed Dritten notice o/ the condition constituting the Creach /rom a go=ernmental agenc.
authoriGed to insEect /or =iolations o/ Cuilding, housing or health codes; and ?!> )ails to remed. or
attemEt in good /aith to remed. the Creach Dithin the time ErescriCed in the Dritten notice o/ that
condition /rom the go=ernmental agenc.. 4. 'he rights o/ the tenant under EaragraEh ?c> o/ suCsection
do not arise unless the tenant is current in the Ea.ment o/ rent at the time o/ gi=ing Dritten notice
Eursuant to suCsection . &. 4/ such a condition Das caused C. the deliCerate or negligent act or
omission o/ the tenant, a memCer o/ his or her household or other Eerson on the Eremises Dith his or
her consent, the tenant has no rights under this section. ?-dded to N$" C. 977, 339; - 9%&, 4+;
9%7, 34; 999, !3,; !,,7, !%+; !,, !37> N$" %-.39, 3nlaD/ul remo=al or e*clusion o/
tenant or Dill/ul interruEtion o/ essential items or ser=ices; Erocedure /or e*Eedited relie/. . 4/ the
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landlord unlaD/ull. remo=es the tenant /rom the Eremises or e*cludes the tenant C. ClocFing or
attemEting to ClocF the tenantOs entr. uEon the Eremises, Dill/ull. interruEts or causes or Eermits the
interruEtion o/ an. essential item or ser=ice required C. the rental agreement or this chaEter or
otherDise reco=ers Eossession o/ the dDelling unit in =iolation o/ N$" %-.4%,, the tenant ma.
reco=er immediate Eossession Eursuant to suCsection 4, Eroceed under N$" %-.3%, or terminate
the rental agreement and, in addition to an. other remed., reco=er the tenantOs actual damages,
recei=e an amount not greater than R!,&,, to Ce /i*ed C. the court, or Coth. !. 4n determining the
amount, i/ an., to Ce aDarded under suCsection , the court shall consider: ?a> 6hether the landlord
acted in good /aith; ?C> 'he course o/ conduct CetDeen the landlord and the tenant; and ?c> 'he
degree o/ harm to the tenant caused C. the landlordOs conduct. 3. 4/ the rental agreement is terminated
Eursuant to suCsection , the landlord shall return all EreEaid rent and securit. reco=eraCle under this
chaEter. 4. E*ceEt as otherDise Ero=ided in suCsection &, the tenant ma. reco=er immediate
Eossession o/ the Eremises /rom the landlord C. /iling a =eri/ied comElaint /or e*Eedited relie/ /or the
unlaD/ul remo=al or e*clusion o/ the tenant /rom the Eremises, the Dill/ul interruEtion o/ an.
essential item or ser=ice or the reco=er. o/ Eossession o/ the dDelling unit in =iolation o/ N$"
%-.4%,. &. - =eri/ied comElaint /or e*Eedited relie/: ?a> :ust Ce /iled Dith the court Dithin &
Iudicial da.s a/ter the date o/ the unlaD/ul act C. the landlord, and the =eri/ied comElaint must Ce
dismissed i/ it is not timel. /iled. 4/ the =eri/ied comElaint /or e*Eedited relie/ is dismissed Eursuant
to this EaragraEh, the tenant retains the right to Eursue all other a=ailaCle remedies against the
landlord. ?C> :a. not Ce /iled Dith the court i/ an action /or summar. e=iction or unlaD/ul detainer is
alread. Eending CetDeen the landlord and tenant, Cut the tenant ma. seeF similar relie/ Ce/ore the
Iudge Eresiding o=er the Eending action. +. 'he court shall conduct a hearing on the =eri/ied
comElaint /or e*Eedited relie/ not later than 3 Iudicial da.s a/ter the /iling o/ the =eri/ied comElaint
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/or e*Eedited relie/. Be/ore or at the scheduled hearing, the tenant must Ero=ide Eroo/ that the
landlord has Ceen EroEerl. ser=ed Dith a coE. o/ the =eri/ied comElaint /or e*Eedited relie/. 3Eon the
hearing, i/ it is determined that the landlord has =iolated an. o/ the Ero=isions o/ suCsection , the
court ma.: N$" %-.!9, 7aCitaCilit. o/ dDelling unit. . 'he landlord shall at all times during the
tenanc. maintain the dDelling unit in a haCitaCle condition. - dDelling unit is not haCitaCle i/ it
=iolates Ero=isions o/ housing or health codes concerning the health, sa/et., sanitation or /itness /or
haCitation o/ the dDelling unit or i/ it suCstantiall. lacFs: ?a> E//ecti=e DaterEroo/ing and Deather
Erotection o/ the roo/ and e*terior Dalls, including DindoDs and doors. ?C> 0lumCing /acilities Dhich
con/ormed to aEElicaCle laD Dhen installed and Dhich are maintained in good DorFing order. ?c> -
Dater suEEl. aEEro=ed under aEElicaCle laD, Dhich is: ?> 3nder the control o/ the tenant or landlord
and is caEaCle o/ Eroducing hot and cold running Dater; ?!> )urnished to aEEroEriate /i*tures; and ?3>
Connected to a seDage disEosal s.stem aEEro=ed under aEElicaCle laD and maintained
in good DorFing order to the e*tent that the s.stem can Ce controlled C. the landlord. ?d> -dequate
heating /acilities Dhich con/ormed to aEElicaCle laD Dhen installed and are maintained in good
DorFing order. ?e> Electrical lighting, outlets, Diring and electrical equiEment Dhich con/ormed to
aEElicaCle laD Dhen installed and are maintained in good DorFing order. ?/> -n adequate numCer o/
aEEroEriate receEtacles /or garCage and ruCCish in clean condition and good reEair at the
commencement o/ the tenanc.. 'he landlord shall arrange /or the remo=al o/ garCage and ruCCish
/rom the Eremises unless the Earties C. Dritten agreement Ero=ide otherDise. ?g> Building, grounds,
aEEurtenances and all other areas under the landlordOs control at the time o/ the commencement o/
the tenanc. in e=er. Eart clean, sanitar. and reasonaCl. /ree /rom all accumulations o/ deCris, /ilth,
ruCCish, garCage, rodents, insects and =ermin. ?h> )loors, Dalls, ceilings, stairDa.s and railings
maintained in good reEair. ?i> Ventilating, air(conditioning and other /acilities and aEEliances,
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including ele=ators, maintained in good reEair i/ suEElied or required to Ce suEElied C. the landlord.
!. 'he landlord and tenant ma. agree that the tenant is to Eer/orm sEeci/ied reEairs, maintenance
tasFs and minor remodeling onl. i/: ?a> 'he agreement o/ the Earties is entered into in good /aith; and
?C> 'he agreement does not diminish the oCligations o/ the landlord to other tenants in the Eremises.
3. -n agreement Eursuant to suCsection ! is not entered into in good /aith i/ the landlord has a dut.
under suCsection to Eer/orm the sEeci/ied reEairs, maintenance tasFs or minor remodeling and the
tenant enters into the agreement Cecause the landlord or his or her agent has re/used to Eer/orm them.
?a> 5rder the landlord to restore to the tenant the Eremises or essential items or ser=ices, or Coth; ?C>
-Dard damages Eursuant to suCsection ; and ?c> EnIoin the landlord /rom =iolating the Ero=isions o/
suCsection and, i/ the circumstances so Darrant, hold the landlord in contemEt o/ court. 7. 'he
Ea.ment o/ all costs and o//icial /ees must Ce de/erred /or an. tenant Dho /iles a =eri/ied comElaint
/or e*Eedited relie/. -/ter an. hearing and not later than /inal disEosition o/ the /iling or order, the
court shall assess the costs and /ees against the Eart. that does not Ere=ail, e*ceEt that the court ma.
reduce them or Dai=e them, as Iustice ma. require.
N$" %-.7, J'enantK de/ined. J'enantK means a Eerson entitled under a rental agreement to
occuE. a dDelling unit to the e*clusion o/ others. N$" %-.!,, $ental agreements: "igning;
coEies; required Ero=isions; disEutaCle EresumEtions; use o/ noncon/orming agreement unlaD/ul. .
-n. Dritten agreement /or the use and occuEanc. o/ a dDelling unit or Eremises must Ce signed C.
the landlord or his or her agent and the tenant or his or her agent. !. 'he landlord shall Ero=ide one
coE. o/ an. Dritten agreement descriCed in suCsection to the tenant /ree o/ cost at the time the
agreement is e*ecuted and, uEon request o/ the tenant, Ero=ide additional coEies o/ an. such
agreement to the tenant Dithin a reasonaCle time. 'he landlord ma. charge a reasonaCle /ee /or
Ero=iding the additional coEies. 3. -n. Dritten rental agreement must contain, Cut is not limited to,
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Ero=isions relating to the /olloDing suCIects: ?a> Duration o/ the agreement. ?C> -mount o/ rent and
the manner and time o/ its Ea.ment. ?c> 5ccuEanc. C. children or Eets. ?d> "er=ices included Dith the
dDelling rental. ?e> )ees Dhich are required and the EurEoses /or Dhich the. are required. ?/>
DeEosits Dhich are required and the conditions /or their re/und. ?g> Charges Dhich ma. Ce required
/or late or Eartial Ea.ment o/ rent or /or return o/ an. dishonored checF. ?h> 4nsEection rights o/ the
landlord. ?i> - listing o/ Eersons or numCers o/ Eersons Dho are to occuE. the dDelling. ?I>
$esEecti=e resEonsiCilities o/ the landlord and the tenant as to the Ea.ment o/ utilit. charges. ?F> -
signed record o/ the in=entor. and condition o/ the Eremises under the e*clusi=e custod. and control
o/ the tenant. ?l> - summar. o/ the Ero=isions o/ N$" !,!.47,. ?m> 4n/ormation regarding the
Erocedure Eursuant to Dhich a tenant ma. reEort to the aEEroEriate authorities: ?> - nuisance. ?!> -
=iolation o/ a Cuilding, sa/et. or health code or regulation. ?n> 4n/ormation regarding the right o/ the
tenant to engage in the disEla. o/ the /lag o/ the 3nited "tates, as set /orth in N$" %-.3!&. 4. 'he
aCsence o/ a Dritten agreement raises a disEutaCle EresumEtion that: ?a> 'here are no restrictions on
occuEanc. C. children or Eets. ?C> :aintenance and Daste remo=al ser=ices are Ero=ided Dithout
charge to the tenant. ?c> No charges /or Eartial or late Ea.ments o/ rent or /or dishonored checFs are
Eaid C. the tenant. ?d> 5ther than normal Dear, the Eremises Dill Ce returned in the same condition as
Dhen the tenanc. Cegan. &. 4t is unlaD/ul /or a landlord or an. Eerson authoriGed to enter into a rental
agreement on his or her Cehal/ to use an. Dritten agreement Dhich does not con/orm to the
Ero=isions o/ this section, and an. Ero=ision in an agreement Dhich contra=enes the Ero=isions o/ this
section is =oid. ?-dded to N$" C. 977, 333; - !,,, 3&!; !,,3, !9+%; !,,7, !%!> N$"
%-.!, $ental agreements: 0a.ment o/ rent; term o/ tenanc.. . $ent is Ea.aCle Dithout demand
or notice at the time and Elace agreed uEon C. the Earties. !. 3nless the rental agreement estaClishes a
de/inite term, the tenanc. is /rom DeeF to DeeF in the case o/ a tenant Dho Ea.s DeeFl. rent and in
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all other cases the tenanc. is /rom month to month. 3. 4n the aCsence o/ an agreement, either Dritten
or oral: ?a> $ent is Ea.aCle at the Ceginning o/ the tenanc.; and ?C> $ent /or the use and occuEanc. o/
a dDelling is the /air rental =alue /or the use and occuEanc.. -t .our e=iction hearing, tell the Iudge
.our side o/ the stor.. 8our IoC
is to con=ince the Iudge that .ou ha=e a legal de/ense to the e=iction. 'he Ne=ada "uEreme Court
has determined that Jlegal de/enseK is Dhen .ou ha=e a Jgenuine issue o/ material /act.K -n=ui, 11C
=. <.1. Dragon, 11C, +3 0.3d 4,& ?!,,7> N$" 4,.!& 3nlaD/ul detainer: 0ossession o/
to e*tension o/ Eeriod o/ Eossession uEon request. N$" 4,.!& 3nlaD/ul detainer: 0ossession o/
to e*tension o/ Eeriod o/ Eossession uEon request. . - tenant o/ real EroEert., a recreational =ehicle
or a moCile home /or a term less than li/e is guilt. o/ an unlaD/ul detainer Dhen ha=ing leased: ?a>
$eal EroEert., e*ceEt as otherDise Ero=ided in this section, or a moCile home /or an inde/inite time,
Dith monthl. or other Eeriodic rent reser=ed, the tenant continues in Eossession thereo/, in Eerson or
C. suCtenant, Dithout the landlordOs consent a/ter the e*Eiration o/ a notice o/: ?> )or tenancies /rom
DeeF to DeeF, at least 7 da.s; ?!> E*ceEt as otherDise Ero=ided in suCsection !, /or all other Eeriodic
tenancies, at least 3, da.s; or ?3> )or tenancies at Dill, at least & da.s. ?C> - dDelling unit suCIect to
the Ero=isions o/ chaEter %- o/ N$", the tenant continues in Eossession, in Eerson or C. suCtenant,
Dithout the landlordOs consent a/ter e*Eiration o/: ?> 'he term o/ the rental agreement or its
termination and, e*ceEt as otherDise Ero=ided in suCEaragraEh ?!>, the e*Eiration o/ a notice o/: ?4>
-t least 7 da.s /or tenancies /rom DeeF to DeeF; and ?44> E*ceEt as otherDise Ero=ided in suCsection
!, at least 3, da.s /or all other Eeriodic tenancies; or ?!> - notice o/ at least & da.s Dhere the tenant
has /ailed to Eer/orm the tenantOs Casic or contractual oCligations under chaEter %- o/ N$". ?c> -
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moCile home lot suCIect to the Ero=isions o/ chaEter %B o/ N$", or a lot /or a recreational =ehicle
in an area o/ a moCile home EarF other than an area designated as a recreational =ehicle lot Eursuant
to the Ero=isions o/ suCsection + o/ N$" 4,.!&, the tenant continues in Eossession, in Eerson or C.
suCtenant, Dithout the landlordOs consent: ?> -/ter notice has Ceen gi=en Eursuant to N$" %B.&,
%B.7, or %B.9, and the Eeriod o/ the notice has e*Eired; or ?!> 4/ the Eerson is not a natural
Eerson and has recei=ed three notices /or nonEa.ment o/ rent Dithin a !(month Eeriod, immediatel.
uEon /ailure to Ea. timel. rent. ?d> - recreational =ehicle lot, the tenant continues in Eossession, in
Eerson or C. suCtenant, Dithout the landlordOs consent, a/ter the e*Eiration o/ a notice o/ at least &
da.s. !. E*ceEt as otherDise Ero=ided in this section, i/ a tenant Dith a Eeriodic tenanc. Eursuant to
EaragraEh ?a> or ?C> o/ suCsection , other than a tenanc. /rom DeeF to DeeF, is +, .ears o/ age or
older or has a Eh.sical or mental disaCilit., the tenant ma. request to Ce alloDed to continue in
Eossession /or an additional 3, da.s Ce.ond the time sEeci/ied in suCsection C. suCmitting a
Dritten request /or an e*tended Eeriod and Ero=iding Eroo/ o/ the tenantOs age or disaCilit.. -
landlord ma. not Ce required to alloD a tenant to continue in Eossession i/ a shorter notice is Ero=ided
Eursuant to suCEaragraEh ?!> o/ EaragraEh ?C> o/ suCsection . 3. -n. notice Ero=ided Eursuant to
EaragraEh ?a> or ?C> o/ suCsection must include a statement ad=ising the tenant o/ the Ero=isions o/
suCsection !. 4. 4/ a landlord reIects a request to alloD a tenant to continue in Eossession /or an
additional 3, da.s Eursuant to suCsection !, the tenant ma. Eetition the court /or an order to continue
in Eossession /or the additional 3, da.s. 4/ the tenant suCmits Eroo/ to the court that the tenant is
entitled to request such an e*tension, the court ma. grant the Eetition and enter an order alloDing the
tenant to continue in Eossession /or the additional 3, da.s. 4/ the court denies the Eetition, the tenant
must Ce alloDed to continue in Eossession /or & calendar da.s /olloDing the date o/ entr. o/ the order
den.ing the Eetition. N$" 4,.4,, $ules o/ Eractice. 'he Ero=isions o/ N$", Ne=ada $ules o/ Ci=il
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0rocedure and Ne=ada $ules o/ -EEellate 0rocedure relati=e to ci=il actions, aEEeals and neD trials,
so /ar as the. are not inconsistent Dith the Ero=isions o/ N$" 4,.!!, to 4,.4!,, inclusi=e, aEEl. to
the Eroceedings mentioned in those sections. N$" 4,.34, -dIournments. 'he court or Iustice o/ the
Eeace ma. /or good cause shoDn adIourn the trial o/ an. cause under N$" 4,.!!, to 4,.4!,,
inclusi=e, not e*ceeding & da.s; and Dhen the de/endant, or the de/endantOs agent or attorne., shall
maFe oath that the de/endant cannot sa/el. Eroceed to trial /or Dant o/ some material Ditness, naming
that Ditness, stating the e=idence that the de/endant e*Eects to oCtain, shoDing that the de/endant has
used due diligence to oCtain such Ditness and Celie=es that i/ an adIournment Ce alloDed the
de/endant Dill Ce aCle to Erocure the attendance o/ such Ditness, or the DitnessOs deEosition, in time
to Eroduce the same uEon the trial, in Dhich case, i/ such Eerson or Eersons Dill gi=e Cond, Dith one
or more su//icient sureties, conditioned to Ea. the comElainant /or all rent that ma. accrue during the
Eending o/ such suit, and all costs and damages consequent uEon such adIournment, the court or
Iustice o/ the Eeace shall adIourn the cause /or such reasonaCle time as ma. aEEear necessar., not
e*ceeding 3, da.s. N$" 4,.3&, 'rial not to Ce adIourned Dhen comElainant admits e=idence in
a//ida=it Dould Ce gi=en. 4/ the comElainant admit that the e=idence stated in the a//ida=it mentioned
in N$" 4,.34, Dould Ce gi=en C. such Ditness, and agree that it Ce considered as actuall. gi=en on
the trial, or o//ered and o=erruled as imEroEer, the trial shall not Ce adIourned.
'he landlord is tr.ing to e=ict me /or m. e*ercising m. rights as /olloDs: comElaining o/ haCitaCilit.
issues and =iolations o/ criminal laDs and retaliation.
4 ha=e a lease Dhich has not e*Eired and the landlord has not gi=en me notice that the.Ashe is
terminating m. lease. :. lease alloDs me to use the Eremises /or a h.Crid EurEose o/ a home laD
o//ice, ie a commercial lease, as such the No Cause t.Ee o/ e=iction is not a=ailaCle here, esEeciall.
Dhere, as her, m. lease has not terminated C. its terms as o/ .et.
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4 ha=e not recei=ed a notice /rom the landlord telling me to lea=e the Eremises. the. can talF aCout
Dhat the. told H2ohn DoeH to do, Cut...-itFen requires the. change an. H2ohn DoeH notices to re/lect
m. actual name one the. Dere aEErised o/ it. 'he Dere as earl. as 2anuar. &th, !, according to
"ue 9ing, .et the. /ailed to ser=e aEEroEriate notice.. 4/ 4 ha=e e=er oDed the landlord an. rent, 4
ha=e Eaid it all or ha=e Eaid it Dithin the time required C. laD.
-ssociation@s negligence =is a =is 1aura and Chris@s negligent andintentional torts committed against
me, Dhich ha=e resulted in thousands o/ dollars o/ damages. 0lease coE. me on an. and all
corresEondence =ia /a* or email as the landlords and or their argents ha=e Ceen or areDithholding m.
mail or otherDise inter/erring Dith m. acces to it, and the. ha=e also done Dith resEect to the
essential ser=ice o/ electricit... -ssociation@s negligence =is a =is 1aura and Chris@s negligent
andintentional torts committed against me, Dhich ha=e resulted in thousands o/ dollars o/ damages.
0lease coE. me on an. and all corresEondence =ia /a* or email as the landlords and or their argents
ha=e Ceen or areDithholding m. mail or otherDise inter/erring Dith m. acces to it, and the. ha=e also
d 6ritten comElaint to 0'75-@a emElo.ees or agents, causing 0'75- to retaliate against Coughlin
Das Ero=ide on 2anuar. %, !,! in tDo seEarate Dritings, Dhich alleged: H0ursuant to N$" %- and
N$" 4,, 4 am hereC. comElaining in Driting o/ .ours and 1aura 7arrison@s =iolation o/ the /olloDing
criminal laDs: - /elon. con=iction /or malicious destruction o/ Eri=ate EroEert. under N$" !,+.3,
and 93.&& must Ce C4V41 14-B414'8 )5$ 15"" 5$ D-:-<E '5 0$50E$'8 N$" !,&.9%,
Determination o/ =alue o/ loss /rom crime; notice to =ictim; order o/ restitution deemed Iudgment to
collect damages. C7-0'E$ !,+ ( :-14C453" :4"C74E) N$" !,+.,,& J<ra//itiK de/ined. N$"
!,+.,, Destruction or damage o/ EroEert. C. unlaD/ul assemCl.. N$" !,+.,& Destruction or
damage o/ croEs, gardens, trees or shruCs. N$" !,+.,4, Entering EroEert. Dith intention to damage
or destro. EroEert.. N$" !,+.!& Damage o/ EroEert. used /or EurEose o/ religion, /or Curial or
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memorialiGing o/ dead, /or education, as transEortation /acilit., as EuClic transEortation =ehicle or as
communit. center; damage o/ Eersonal EroEert. contained therein; Eenalties; restitution. N$"
!,+.4, Nuisance in Cuilding; tresEass uEon grounds; disturCing assemCl.. N$" !,+.&, 9illing,
maiming, dis/iguring or Eoisoning animal o/ another Eerson; Filling estra. or li=estocF. N$" !,+.+,
1eading or dri=ing horse aDa. Dithout authorit.. N$" !,+.!,, 0osting o/ Cills, signs or Eosters
unlaD/ul. N$" !,+.!!, $emo=al, alteration or destruction o/ monuments or landmarFs designating
Coundaries. N$" !,+.!+, )raudulent and malicious destruction o/ Dritings. N$" !,+.!7, De/acing
Eroclamations and notices. N$" !,+.!%, 'amEering Dith EaEers. N$" !,+.!9, 5Eening or
EuClishing sealed letter or telegram. N$" !,+.3,, )alse signals endangering cars, =essels or motors.
N$" !,+.3, 4nIur. to other EroEert.. N$" !,+.3!, 3nlaD/ul remo=al o/ Eetri/ied Dood /rom
Eosted or designated sites; duties o/ certain o//icers. N$" !,+.33, 0lacing gra//iti on or otherDise
de/acing EroEert.: )ines and Eenalties; Earent or guardian resEonsiCle /or /ines and Eenalties i/
Eerson =iolating section is under age o/ % .ears; susEension o/ dri=erOs license. N$" !,+.33&
Carr.ing gra//iti imElement at certain locations Dith intent to =andaliGe, Elace gra//iti on or de/ace
EroEert.. N$" !,+.34, <ra//iti $eDard )und created; administrati=e assessment to Ce imEosed /or
certain =iolations; use o/ mone. in )und. N$" !,+.34& 0erson or entit. to Ce Eaid i/ restitution is
ordered /or =iolation o/ N$" !,+.!& or !,+.33,. Zach Coughlin, Esq.H 'he second Driting: H'his is
additional Dritten notice Eursuant to N$" %- and N$" 4, comElaining o/ and requesting reEairs
and reimCursement /or the /olloDing: no cg/i outlet near sinF in uEstairs Cathroom. .ou CroFe the
door to m. room and the locF and /ailed to Ero=ide a Fe. laura harrison slashed tDo o/ m. tires,
necessitating R&, in reEairs. 8ou threD hot co//ee on me and ruined m. htc <! smartEhone, a R4,,
Ehone .ou ha=e Creached are deal Dith resEect to m. Ceing alloDed to Ce neD carEet o=er the =er.
dirt. carEet doDnstairs. 8ou ha=e reEeatedl. used /orce and threat o/ /orce to Ere=ent me /rom
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accessing the Dashing machine doDnstairs /or doing laundr. and Ere=ented m. use o/ the Fitchen
8ou admitted to changing the deadColts on the /ront and CacF door@s on NeD 8ears da. at !:3, am,
locFing me outside on a night Dith /reeGing temEeratures, necessitating an e*Eense o/ R+, /or
alternate lodging that night. )urther, .ou and 1aura 7arrison ha=e unlaD/ull. interruEted an essential
ser=ice, m. electricit., reEeatedl.. N$" %-.39,. 0lease cure these issues or 4 intend to deduct them
/rom an. /uture rent. 4 am comElaining o/ .ours and 1aura 7arrison@s =iolations o/ criminal laD
statutes :. dog had cheDing gum stucF in its hair in se=eral Elaces, in a manner that suggests it Das
EurEose/ull. done. 4 Dill remind .ou that aCuse to animals is included in the 0rotection 5rder
"tatutes. )urther, .ou and :s. 7arrison are in =iolation o/ /ederal laD in Ere=enting m. access to the
mailCo* included in our agreement, as it Das agreed that 4 Dould Ce a//orded the oEEortunit. to
recei=e mail at the 4!! E. 9th "'. #! -ddress and use o/ the mailCo*. "incerel., Zach Coughlin,
Esq.H
0otential counterclaims in a residential e=iction action =ar. /rom Iurisdiction to Iurisdiction. "ee, e.g.,
5hio $e=. Code -nn. Q 9!3.,+. "ome states restrict the counterclaims that a tenant ma. assert in a
summar. e=iction Eroceeding. 4oDa Code -nn. Q +4%.9; :d. Code -nn., $eal 0roE. Q %(4,!.4 ?d>.
4/ a EroEert. oDner used illegal sel/(helE to remo=e a tenant Erior to or during the course o/ an
e=iction action, the tenant ma. ha=e counterclaims /or illegal e=iction, tresEass, or harassment. 'he
tenants Ere=ailed on such a claim in Villeneu=e =. Beane, %! Vt. &7&, !,,7 V' 7&, 933 -.!d 39
?!,,7>, Dhere the tenant /amil. struggled to Ea. their rent and Eurchase heating oil a/ter the /ather@s
serious inIur. in an industrial accident le/t him unaCle to DorF. DesEite the /act that the tenants oDed
CacF rent and the EroEert. oDner had Ceen /orced to Eurchase heating oil to FeeE the /urnace running,
the EroEert. oDner agreed to Eermit the tenants to remain in the residence /or an additional month
a/ter e*Eiration o/ the lease i/ the. Eaid the rent /or that additional month. 'he tenants Eaid the rent
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/or the additional month, Cut Dhile the tenants Dere aDa. at DorF and school one da., the landlord
Cegan remo=ing their Eersonal EroEert. /rom the residence. 6hen one o/ the tenants returned home
/rom DorF une*Eectedl., he had the Eolice remo=e the EroEert. oDner /rom the residence and the
tenants mo=ed their EroEert. CacF into the residence. During the course o/ the e=iction action /iled C.
the EroEert. oDner, the tenants Eaid rent into court until the. =acated the residence. 7oDe=er, the
EroEert. oDner engaged in a camEaign o/ harassment against the tenants Dhile the e=iction action
Das Eending, including ha=ing their utilities shut o// and Eosting signs on the EroEert. oDner@s
neighCoring Eremises stating that the tenants Dould not Ea. rent and Dould not =acate the residence.
Based on these actions, the tenants asserted a counterclaim /or harassment, illegal e=iction, and
tresEass. 'he aEEellate court uEheld the trial court@s aDard o/ R,,,,, in comEensator. damages and
R!,,,, in Euniti=e damages against the EroEert. oDner Cecause the EroEert. oDner@s conduct Das
outrageous and a =iolation o/ the tenants@ right to legal Erocess. Villeneu=e =. Beane, %! Vt. &7&,
!,,7 V' 7&, 933 -.!d 39 ?!,,7>. 5ne common counterclaim is Creach o/ the Darrant. o/
haCitaCilit.. Domen 7olding Co. =. -rano=ich, N.8.3d 7, 7+9 N.8.".!d 7%&, %,! N.E.!d 3&
?!,,3> ?tenant asserted a counterclaim /or Creach o/ the Darrant. o/ haCitaCilit. in the landlord@s
e=iction action>; 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +& ?!,,&> ?tenant asserted a
counterclaim /or Creach o/ the Darrant. o/ haCitaCilit. in the landlord@s e=iction action>. 4n certain
cases, a Creach o/ the Darrant. o/ haCitaCilit. ma. alloD reinstatement o/ the tenanc. e=en i/ the
EroEert. oDner alread. oCtained an e=iction order. )or instance, a :assachusetts Ero=ision Eermits a
tenant to Dithhold rent due to conditions in the residence that materiall. imEair or endanger the
tenant@s sa/et., health, or Dell(Ceing. 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +&
?!,,&> ?interEreting :ass. <en. 1aDs -nn. ch. !39, Q %->. 4/ a :assachusetts court renders Iudgment
in /a=or o/ the EroEert. oDner Cased on the nonEa.ment o/ rent, the tenant ma. reinstate the tenanc.
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C. Ea.ing the amount o/ the Iudgment into court Dithin one DeeF. 2aClonsFi =. Case., +4 :ass. -EE.
Ct. 744, %3& N.E.!d +& ?!,,&> ?interEreting :ass. <en. 1aDs -nn. ch. !39, Q %->. 7oDe=er, such
relie/ is not a=ailaCle unless the tenant Ero=es that the EroEert. oDner had Erior notice o/ the
conditions endangering the tenant@s sa/et., health, or Dell(Ceing. 2aClonsFi =. Case., +4 :ass. -EE.
Ct. 744, %3& N.E.!d +& ?!,,&> ?den.ing a tenant@s motion /or reinstatement o/ her tenanc. Cecause
she /ailed to noti/. the landlord o/ the conditions allegedl. endangering her health, sa/et., or Dell(
Ceing Erior to Dithholding rent>. )ailure to a//ord the EroEert. oDner the requisite notice Erior to
Dithholding rent Erecludes the tenant /rom asserting the Creach o/ Darrant. o/ haCitaCilit. as a
de/ense to an e=iction Eroceeding. 2aClonsFi =. Case., +4 :ass. -EE. Ct. 744, %3& N.E.!d +& ?!,,&>
?a//irming Iudgment in /a=or o/ the landlord /or Eossession and CacF rent>.Because a tenant@s claim o/
retaliator. e=iction is t.Eicall. asserted as an equitaCle de/ense, the usual remed. /or its success/ul
assertion is dismissal o/ the landlord@s action /or Eossession o/ the Eremises.M7!N 7oDe=er, in some
cases the tenant ma. Ce entitled to damages.M 73N 'his ma. include reco=er. o/ a rent aCatement /or a
Eeriod o/ uninhaCitaCilit.,M74N comEensator. damages,M7&N damages /or emotional distress caused C.
the retaliator. e=iction,M 7+N and attorne.@s /ees.M77N :ost courts ha=e held that Euniti=e damages are
not reco=eraCle on a claim o/ retaliator. e=iction,M7%N although a /eD courts ha=e aDarded Euniti=e
damages in some instances.M79N 4t is the tenant@s Curden to Ero=e damages. )or e*amEle, in 0aullin =.
"utton,M%,N a Ne=ada court /ound that the onl. e=idence o/ damages consisted o/ testimon. C. the
tenant that, /olloDing her e=iction, she Eurchased a condominium /or R!&,,,, doDn and R,&&!
mortgage Ea.ment ?Elus R3& association /ee> Eer month. 'he court held that as a matter o/ laD,
damages /or retaliator. e=iction do not include all or Eart o/ the Eurchase Erice o/ a neD home C. the
/ormer tenant. )urther, although the tenant@s ansDers to interrogatories indicated that she did incur
e*Eenses in mo=ing, she did not introduce an. e=idence at trial concerning the amount o/ these
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e*Eenses. Because she /ailed to carr. the Curden to Ero=e her damages, the court =acated a
comEensator. damage aDard o/ R!,,,,. 'he court also re=ersed an R%,,,,, aDard o/ Euniti=e
damages Cecause, said the court, Euniti=e damages are not authoriGed Dithout a =alid aDard o/
comEensator. damages. 'he court /urther determined that Dhile Ne= $e= "tat Q %-.&, clearl.
ErohiCited the non(reneDal o/ a month(to(month tenanc. /or a retaliator. EurEose, the statute Das
silent as to Dhether Euniti=e damages Dere reco=eraCle /or a retaliator. e=iction. 4n <oFe. =.
Bessette,M%N a landlord@s action /or unEaid rent allegedl. due Dhen the tenant =acated the Eremises,
the de/endant tenants counterclaimed /or damages Cased on retaliator. e=iction and the landlord@s
Creach o/ an imElied Darrant. o/ haCitaCilit.. 'he Earties had entered into an oral lease agreement /or
rental o/ a moCile home starting in "eEtemCer 9%& at a monthl. rent o/ R4,,. 'he tenants Eaid /or
electric ser=ice to the moCile home, Cut the landlord Eaid /or the electricit. /or a nearC. Carn, in
Dhich the tenants Dere alloDed to store their /reeGer. 'he trial court /ound that during the tenanc. a
=ariet. o/ EroClems de=eloEed, including Dater leaFage into the home through the roo/ ?Dhich Das
reEaired C. the tenants>, EoDer /ailures due to a /ault. trans/ormer, and a /urnace CreaFdoDn. :ore
serious Das a CreaF in the seDer line, Dhich caused unhealth. /luids to collect underneath the moCile
home and a /oul odor to Eer=ade the Eremises. DesEite numerous comElaints to the landlord to reEair
the seDer line CreaF, the EroClem remained unresol=ed /rom )eCruar. to 2une 9%+, and the tenants
stoEEed Ea.ing rent as o/ 2une , 9%+. 'he court /ound that /inal reEair to the seEtic s.stem came on
2une 7, 9%+, onl. a/ter the tenants EromEted a =isit /rom the toDn health o//icer. 5n 2une +, 9%+,
Erior to the reEair, the landlord ga=e the tenants notice to quit, e//ecti=e -ugust , 9%+. 'he trial
court /ound that a/ter the tenants stoEEed Ea.ing rent, the landlord locFed the Carn Dhere the /reeGer
Das located and shut o// the EoDer, causing the loss o/ R3,, Dorth o/ /ood. 'he tenants =acated the
Eremises on 5ctoCer 3, 9%+, aEEro*imatel. one month a/ter the landlord had sold the moCile home.
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M)N7%N "ee, /or e*amEle, 0ohlman =. :etroEolitan 'railer 0arF, 4nc., !+ N.2. "uEer. 4, 3! -.!d
%%% ?Ch. Di=. 973> ?holding that state statute did not authoriGe reco=er. o/ Euniti=e damages /or
retaliator. e=iction>; 0aullin =. "utton, ,! Ne=. 4!, 7!4 0.!d 749 ?9%+> ?holding that state statute
did not authoriGe reco=er. o/ Euniti=e damages /or retaliator. e=iction>. M)N79N "ee, /or e*amEle,
-DeeFa =. Bonds, !, Cal. -EE. 3d !7%, 97 Cal. $Etr. +&, ?st Dist. 97> ?holding that Euniti=e
damages are reco=eraCle in a retaliator. e=iction action e=en i/ the actual damages are nominal>. "ee
also Del Code -nn tit. !&, Q &&+?d> ?alloDing a success/ul tenant to reco=er three months@ rent or
treCle damages, Dhiche=er is greater, Elus attorne.@s /ees>. M)N%,N 0aullin =. "utton, ,! Ne=. 4!,
7!4 0.!d 749 ?9%+>. M)N%N <oFe. =. Bessette, &4 Vt. &+,, &%, -.!d 4%%, !3 -.1.$.&th %%7
?99,>. M)N%!N 0ursuant to 9 Vt. "tat. -nn. Q 44+&. "ection !3 )ootnotes: M)N%3N )or a general
discussion on the use o/ interrogatories, see Disco=er.S6ritten 4nterrogatories, 4 -m. 2ur. 'rials .
)or interrogatories to disco=er Casic /acts in tort actions, see Danner, 0attern Disco=er.: 'ort -ctions
?!d ed.>. )or checFlists and discussion o/ the use o/ e*Eert Ditnesses, see Danner, E*Eert 6itness
ChecFlists. $egarding deEositions, see 0attern DeEosition ChecFlists ?!d ed.>. 5n state court Eractice
Dith resEect to interrogatories, see Disco=er.S6ritten 4nterrogatories, 4 -m. 2ur. 'rials . 5n
Dritten interrogatories in /ederal district court, see )ederal $ules o/ Ci=il 0rocedure $ules !+, 33; see
also )ederal 0rocedure, 1. Ed. QQ !+:!9, et seq.. 4& -:23$ 05) 3d 37&
'he landlord@s ComElaint /ails to state /acts Dhich Dould alloD himAher to e=ict me, /urther 9ing and
6estern Ne=ada :anagement and "hiela 1ester ha=e admitted the. recei=ed nothing Eursuant to
their arrangement Dith -llaCacF and )oreshee, as such the Ne=ada "uEreme Court holding in <laGier
maFes inaEElicaCle a summar. e=iction Eroceeding. )urther, Dhere, as here, m. lease alloDs me to
use the Eremises /or a home laD o//ice, and the non(Ea.ment o/ rent has not Ceen alleged, N$"
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4,.!&3 maFes inaEElicaCle a summar. e=iction Erocedure under those circumstances, rather, a
Elenar. Erocedure is required. $egardless, a EroEer Iur. trial demand is hereC. made.
'here is EerhaEs another Eerson against Dhom this action should Ce Crought, namel. Erin -llaCacF
and 1aure )orshee.
4 ha=e not Ceen EroEerl. named in the notices. $ather, the Notice EurEortedl. Eosed on 2anuar.
,th, !,! onl. names a H2ohn DoeH desEite m. numerous Dritings to 6estern Ne=ada Dherein m.
name Das madse clear. 'he -itFen case maFes clear that the Erocedural and notice requirements o/
summar. e=iction matters must Ce stricl. adhered to, as such this H2ohn DoeH notice is ine//ecti=e.
4 ha=e other de/enses as /olloDs: retaliation, discrimination, lacF o/ allegation o/ nonEa.ment o/ rent,
75- admitted tenants Dere not oCligated to Ea. rent, as such, under <laGier, summar. e=iction
Erocedures una=ailaCle. 4:05$'-N': 4n some cases, the Court has the EoDer to gi=e .ou time to
/ind a neD Elace to li=e e=en i/ .ou do not ha=e an. o/ the listed de/enses. 4/ .ou Dish the Court to
determine Dhether .ou are entitled to it, Elease checF CeloD:
4 ha=e Ero=ided Dritten request to landlord /or an e*tension o/ 3, da.s in light o/ m. disaCilit..
4 am Driting to request the 3, da.s e*tension Cased uEon disaCilit.. 4 am in=oFing m. 740-- and other Eri=ac. rights
Dith resEect to di=ulging an.thign /urther aCout m. disaCilit..
C53N'E$C1-4:
4/ .ou Celie=e that .ou are entitled to a return o/ Eart o/ .our rent Ea.ment or other damages /rom the
landlord, comElete the statement CeloD: 4 here C. counterclaim in e*cess o/ R,,,,, in damages. 4
/eel that 4 am entitled to this amount /or the /olloDing reasons: damages to m.sel/, m. clients, and
m. Eractice in light o/ landlord@s and landlord@s agents actions. 1aura and Chris Ceing the
-ssociations emElo.ees and there/ore .ou gu.s or them Danted to settle Dith
me on account o/ a resEondeat suEerior theor. o/ liaCilit. maFing .our
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e*Eosure signi/icant enough to Iusti/. doing so. -ssociation@s negligence =is a =is 1aura and Chris@s negligent
andintentional torts committed against me, Dhich ha=e resulted in thousands o/ dollars o/ damages. 0lease coE. me on
an. and all corresEondence =ia /a* or
email as the landlords and or their argents ha=e Ceen or areDithholding m. mail or otherDise inter/erring Dith m. acces
to it, and the. ha=e also done Dith resEect to the essential ser=ice o/ electricit..
,-INTS AND AUT.-RITIES
)-C'"
N$" %-.&, $etaliator. conduct C. landlord against tenant ErohiCited; remedies; e*ceEtions.
. E*ceEt as otherDise Ero=ided in suCsection 3, the landlord ma. not, in retaliation, terminate a
tenanc., re/use to reneD a tenanc., increase rent or decrease essential ser=ices required C. the rental
agreement or this chaEter, or Cring or threaten to Cring an action /or Eossession i/:
?a> 'he tenant has comElained in good /aith o/ a =iolation o/ a Cuilding, housing or health code
aEElicaCle to the Eremises and a//ecting health or sa/et. to a go=ernmental agenc. charged Dith the
resEonsiCilit. /or the en/orcement o/ that code;
?C> 'he tenant has comElained in good /aith to the landlord or a laD en/orcement agenc. o/ a
=iolation o/ this chaEter or o/ a sEeci/ic statute that imEoses a criminal Eenalt.;
?c> 'he tenant has organiGed or Cecome a memCer o/ a tenantOs union or similar organiGation;
?d> - citation has Ceen issued resulting /rom a comElaint descriCed in EaragraEh ?a>;
?e> 'he tenant has instituted or de/ended against a Iudicial or administrati=e Eroceeding or
arCitration in Dhich the tenant raised an issue o/ comEliance Dith the requirements o/ this chaEter
resEecting the haCitaCilit. o/ dDelling units;
?/> 'he tenant has /ailed or re/used to gi=e Dritten consent to a regulation adoEted C. the landlord,
a/ter the tenant enters into the rental agreement, Dhich requires the landlord to Dait until the
aEEroEriate time has elaEsed Ce/ore it is en/orceaCle against the tenant; or
?g> 'he tenant has comElained in good /aith to the landlord, a go=ernment agenc., an attorne., a
rights Dhich are guaranteed or Erotected under those laDs.
!. 4/ the landlord =iolates an. Ero=ision o/ suCsection , the tenant is entitled to the remedies
Ero=ided in N$" %-.39, and has a de/ense in an. retaliator. action C. the landlord /or Eossession.
3. - landlord Dho acts under the circumstances descriCed in suCsection does not =iolate that
suCsection i/:
?a> 'he =iolation o/ the aEElicaCle Cuilding, housing or health code o/ Dhich the tenant
comElained Das caused Erimaril. C. the lacF o/ reasonaCle care C. the tenant, a memCer o/ his or her
household or other Eerson on the Eremises Dith his or her consent;
?C> 'he tenanc. is terminated Dith cause;
?c> - citation has Ceen issued and comEliance Dith the aEElicaCle Cuilding, housing or health
code requires alteration, remodeling or demolition and cannot Ce accomElished unless the tenantOs
dDelling unit is =acant; or
?d> 'he increase in rent aEElies in a uni/orm manner to all tenants.
'he maintenance o/ an action under this suCsection does not Ere=ent the tenant /rom seeFing damages
or inIuncti=e relie/ /or the landlordOs /ailure to comEl. Dith the rental agreement or maintain the
dDelling unit in a haCitaCle condition as required C. this chaEter.
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1ost Ero/its, lost goods, such as /ood, and the Cene/its o/ lost ser=ices, such as ad=ertising, are
e*amEles o/ losses that ma. constitute Hactual damagesH /or illegal e=iction. 4 :.$.".-. Q +,4?!>
?->. Degenhardt =. EDe 1td. 0artnershiE, !, :E !3, 3 -.3d 79, ?:e. !,>. Being an attorne. is
hard enough Dithout dealing Dith all o/ 0arF 'errace@s mal/easance. 0erhaEs i/ E' -1 e=er gathers
uE the gumEtion to hang out his oDn shingle the. Dill more /ull. aEEreciate that.
ANALYSIS
'enant@s reco=er. o/ damages /or emotional distress under 3ni/orm $esidential 1andlord and 'enant
-ct, + -.1.$.4th &!%; $ight o/ landlord legall. entitled to Eossession to disEossess tenant Dithout
legal Erocess, + -.1.$.3d 77; $eco=er. C. tenant o/ damages /or Eh.sical inIur. or mental anguish
occasioned C. Drong/ul e=iction, 7 -.1.$.!d 93+; & -m. 2ur. 0roo/ o/ )acts 3d 37&, 'enant@s $ights
and $emedies -gainst $etaliator. E=iction C. 1andlord. 99 -m. 2ur. 'rials !%9, $etaliator. E=iction
Claims.
E=idence suEEorted /inding that landlord@s e=iction o/ tenant Das retaliator. /or her comElaints
concerning Eersistent ElumCing EroClems and condition o/ common areas. N.$.".
%-.&,. 0aullin =. "utton, 9%+, 7!4 0.!d 749, ,! Ne=. 4!.
B. Da. o/ analog. to Je=iction millsK /or landlords, consider J)or e*amEle, aCuse o/ CanFruEtc.
Eroceedings C. renters Cecame so DidesEread in the Central District o/ Cali/ornia that JMiNn 99, 2.
Cli//ord 6allace, Chie/ 2udge o/ the Ninth Circuit Court o/ -EEeals, estaClished an -d 7oc
Committee on 3nlaD/ul Detainer and BanFruEtc. :ills to looF into EossiCle solutions to the Eractice
o/ aCusi=e /ilings to Ere=ent e=iction.K 2udge <eraldine :und, 3Edated $eEort o/ 3nlaD/ul Detainer
'asF )orce ?99!>. 'he committee /ound that CanFruEtc. JmillsK are a suCstantial cause o/ the
aCuse: 'he. churn out large numCers o/ Eetitions ?Dhich result in an automatic sta., /orestalling
e=iction>, Cut Eursue no /urther action. Estimates suggest that in the Central District alone, some
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!,,,,, to 4,,,,, such Eetitions are /iled e=er. .ear /or the sole EurEose o/ dela.ing the deCtor@s
e=iction. "ee id. at 7. -s those /amiliar Dith CanFruEtc. Eractice are onl. too Eain/ull. aDare, this
t.Ee o/ strategic maniEulation isn@t limited to renters@ Eetitions. "ee generall. :arc. 2.9. 'i//an.,
Crime and BanFruEtc., !4 BanFr.Ct.Dec. ?C$$>, at - ?"eEt. !, 993>.K
Awarding Attorney's Fees to Pro Se Litigants Under Rule 11, 2une, 997, 9& :ich. 1. $e=. !3,%,
2erem. D. "Eector. E' -1 cites no authorit. on this or an. other issue that li=es an.Dhere Ce.ond
/orm motion, temElate time, turn and Curn Eractice o/ laD. 6hile E' -1 did manage to cite the
"eller@s case, the. quotes no language /rom it and seemingl. maFes not attemEt to anal.Ge its ruling.
the. should ha=e. "ellers sEeaFs to aDards o/ attorne.@s /ees to Ere=ailing Earties in ci=il actions. 4t
does not EurEort to sEeaF to attorne.@s /ees aDards stemming /rom $ule =iolation, a situation
Dhere the granting o/ attorne.@s /ees to an attorne. Ero se litigant is /ar more acceEted throughout
-merican IurisErudence. "imEl. Eut, the "eller@s case is inaEElicaCle and E' -1 should stoE citing
cases Dhere the. clearl. has a =er. shalloD grasE o/ Dhat the. sEeaF to.
'o Dit:
Jstates that ha=e considered Dhether an attorne. EroEer Eerson litigant ma. Ce
aDarded attorne. /ees are di=ided, Dith a slight maIorit. Eermitting such /ees.
Decisions aEEro=ing /ee aDards to attorne. EroEer Eerson litigants generall. do so
on the Casis that an attorne. is Eaid /or rendering legal ser=ices, and i/ the. renders
such ser=ices on his oDn Cehal/, it results in as much Eecuniar. loss to him as i/
the. Eaid another attorne. to render the same ser=ices. "o, i/ a losing Eart. must
Ea. attorne. /ees an.Da., it should maFe no di//erence Dhether the /ees are to Ce
Eaid to an attorne. reEresenting himsel/ or another attorne. emElo.ed C. him. 4n
short, Ha laD.er@s time and ad=ice are his stocF in trade.H...6e interEret N$" +9.,3,
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to require that all EroEer Eerson litigants, Dhether attorne. or non(attorne., Ce
oCligated to Ea. attorne. /ees as a Ererequisite /or an aDard o/ Ere=ailing Eart.
attorne. /ees. 'his interEretation gi=es e//ect to the 1egislature@s clear intent that the
Ere=ailing Eart. in Iustice@s court Ce reimCursed C. the losing Eart. /or out(o/(
EocFet costs incurred to Erosecute the suit. 'o interEret the statute otherDise Dould
require us to rede/ine Dhat is meant C. an attorne. /ee, Dhich is commonl.
understood to Ce the sum Eaid or charged /or legal ser=ices. Because :attheDs
reEresented himsel/ and did not Ea. or incur an. oCligation to Ea. attorne. /ees, the
Iustice@s court e*ceeded its Iurisdiction C. aDarding such /ees. 6e there/ore grant,
in Eart, the Eetition /or a Drit o/ certiorari.K "ellers =. )ourth 2udicial Dist. Ct., 9
Ne=. !&+, 7 0 .3d 49& ?!,,3>.
N$" +9.,3, J0re=ailing Eart. alloDed attorne.@s /ee to Ce ta*ed as costs in Iustice court. 'he
Ere=ailing Eart. in an. ci=il action at laD in the Iustice courts o/ this "tate shall recei=e, in addition to
the costs o/ court as noD alloDed C. laD, a reasonaCle attorne. /ee. 'he attorne. /ee shall Ce /i*ed C.
the Iustice and ta*ed as costs against the losing Eart..K "o, E' -1@s Cig contriCution to the legal
research required to rule on this case is to cite "eller@s, Dhich does not sEeaF to Dhether a Ero se
attorne. can recei=e attorne.@s /ees Eursuant to a $ule sanction. 'he statute in=ol=ed does not
aEEl. here, either, Dhere a $ule "anction motion is in Ela.. )urther, e=en i/ it did aEEl., Dhich it
doesn@t, Coughlin did KEa. or incur an. oCligation to Ea. attorne. /eesK as the. has stated in the )act
section that the. Eaid to and incurred such an oCligation to himsel/. 6here :attheDs ma. ha=e not
Ceen e*act enough in his Eleadings, Coughlin has Ceen.
Coughlin has actuall., reasonaCl. and necessaril. incurred R&,,,, in the EreEaration o/ the Eleadings
the. has Eut /orth so /ar in this matter, and in dealing Dith E' -1@s regrettaCle, declasse conduct in
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this matter. E' -1 should Ce sanctioned in that amount, Elus an. /ees incurred in dra/ting a reEl. in
suEEort o/ this motion, and EreEaring /or and attending an. hearing. )urther, Coughlin hereC.
requests a hearing reElete Dith A JURY ?- $4<7' <3-$-N'EE B8 '7E 3N4'ED "'-'E"
"30$E:E C53$' EVEN 4N "3::-$8 EV4C'45N :-''E$", -N '7E$E 4" N5 15N<E$
2C$C0 ,+, "5 4 <E' -N -00E-1 '55T> on this matter to a=oid e=iction. 'here are e=identiar.
issues such as the amount o/ rent deductions agreed to, the amount o/ damages done C. 0arF
'errace@s landscaEing creD, thin sFulled tenant issues, etc.

67E$E)5$E, tenant, Zach Coughlin, Era.s that this Court rule that a summar. e=iction Eroceeding
is una=ailaCle to landlord here and aDard in e*cess o/ R,,,,, damages to 'enantACounterclaimant.
Dec(aratio$ #ade u$der "e$a(t of "er!ur/
I Dec(are* "ursua$t to NRS 03.040 t&at t&e fore)oi$) is true a$d correct a$d #ade u$der
"e$at( of "er!ur
A11IRMATI-N ,ursua$t to NRS 2334.030
'he undersigned does hereC. a//irm that the Ereceding document does not contain
the social securit. numCer o/ an. Eerson.
UAsA Zach Coughlin
Zach Coughlin
'enantACounterclaimant
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,R--1 -1 SER5I+E
4, Zach Coughlin, declare:
5n )eCruar. !7th, !,!, 4, :r. Zach Coughlin ser=ed the /oregoing 'enant@s -nsDer and
-//ida=itADeclaration to 3, Da. No Cause E=iction, 'enant@s Counterclaim C. Elacing a true and
correct coE. hereo/ in the usEs mail, emailing, maFing all reasonaCle attemEts at Eersonall. ser=ing,
and /a*ing true coE. thereo/ to:
0arF 'errace 'oDnhomes 75-
cAo <a.le -gnes 9ern, Esq. and <a.le -. 9ern. 1td.
&4! 9ietGFe 1ane "uite !,,
$eno , NV %9&
'el: 77&(3!4(&93,
)a*: 77&(3!4(+73
ga.leFernVFernltd.com
0arF 'errace 'oDnhomes -ssn
cAo 6estern Ne=ada :anagement, 4nc.
$esidential, Commercial W -ssociation :anagement
"ue 9ing
0residentABroFerA"uEer=ising C:
%,4 :ill "treet, $eno, NV %9&,!
0h: 77&(!%4(4434
)a*: 77&(!%4(44+&
sueVDesternn=.com
DDD.Desternn=.com
in/oVDesternn=.com
$eno 2ustice Court, Ci=il Di=ision
". "ierra "t.
$eno, NV %9&,
Ci=il Di=ision )a*
?77&> 3!&(+7&
(((((((((((((((((((((((((((((
Zach Coughlin, 'enant
( 3! (

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Close Print
City Attorney Skau, updated discovery in iPhone case,
dispatch recordings, don't seem to reveal basis for "a
possible fight" assertions in office testimony and
prosecutors's filings and argument
Sent: Wed 11/14/12 2:09 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com
(skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org
(patrickk@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
(cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com
(consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us);
kadlicj@reno.gov (kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov);
schornsby@nvdetr.org (schornsby@nvdetr.org); jleslie@washoecounty.us
(jleslie@washoecounty.us); jgoodnight@washoecounty.us (jgoodnight@washoecounty.us);
jbosler@washoecounty.us (jbosler@washoecounty.us)
Dear DDA Young and Bar Counsel and Panel Members,
The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what
started all this off (by "all this" I mean the 46 days in jail, the 10 different trips to jail,
the five to six different evictions, all summary, the competency evaluations, and all the
associated grievances. This arrest and prosecution have largely been based on and the
office and prosecutor have cited to, their contention that the information from ECOMM
or dispatch told the RPD Officers (and the arresting Officer Nick Duralde is married to
a dispatcher working that night and perhaps whose voice is on these files, finally given
to me only today, by Reno City Attorney's Office Creighton Skau, after he secured my
attendance at a hearing that I do not believe was noticed in a legal since by sending me
an email saying Judge Sferrazza authorized service of the notice of the hearing by
email...which Judge Sferrazza denies (in fairness to Mr. Skau...its possible the Judge
did say that...Mr. Young could maybe shed some light on that, as apparently their was a
sort of group meeting with he, the Reno City Attorney and the WCPD on or about
November 8th, 2012 in rCR2012-063342, that I was not noticed on and, of course did
not attend).
Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch
reported a "possible fight" and how that somehow justified the rash approach taken by
Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand Larceny (7
days in jail, the eviction notice in the Richard Hills summary eviction from my former
home law office was served during the interim in RJC Rev2011-001708) for a three
year old iphone that the alleged owner, Cory Goble, testified was worth about $80 at
the time....(and the overcharging of a felony enabled Officer Duralde to conduct a
search incident to arrest for a misdemeanor not committed in his presence, after 7
pm...which Nevada law prohibits, particularly where, as here, there was no citizen's
arrest (Coughlin himself called 911 and there is a video of the time prior to arrest
where Coughlin is heard imploring the skater youths to stay peaceful and wait for law
enforcement to arrive so a civil resolution of the dispute could be garnered).
I am writing now and providing this new production of ECOMM/911 dispatch
recordings that would seem to be the State's last hope of proving that the Officers were
told of, by dispatch, "a possible fight" and therein provide some factual basis for that
which Officer Duralde and DDA Young have testified to, and filed pleadings in that
matter arguing that reports of "a possible fight" justified the subsequent terry stop
weapons check pat down, and search incident to arrest (remember, Officer Duralde
announced 20 seconds into arriving on scene that he was going to arrest Coughlin and
do a search of Coughlin's pockets prior to conducting any of the pretexutal
"investigation" that he later testified to...its just that Officer Duralde did not realize he
was being recorded when he said that....no matter how he "remixed" things in his
Supplementary Declaration (filed within 48 hours of arrest) or his Narrative (by all
indications, the Narrative was only filed some three months after the arrest and
apparently after the RPD and City Attorneys Office became aware that the video of the
arrest was publicly available).
I have listened closely to these dispatch recordings and hear nothing about "a possible
fight". Does that make the Officer's Testimony perjury and DDA Young's conduct
misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the SBN's
Office on Double R. Blvd. I ask that you attend and explain these matters as this arrest
is pled in Bar Counsel Kings SCR 105 Complaint.
Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to
subpoena the dispatch recordings until October 3, 2012 (despite the Trial occuring on
May 7th, 2012 (in violation of NRS 178.405, no less), and again on July 16th,
2012....and, again on August 29th, and September 5th, 2012....and then please explain
why you feigned inability to personally serve subpoenas as a basis for failing to get
Nicole Watson (easily found and or served via a certified mailing under NRS 174.345,
at the addresses your investigator refused to turn over to me until November 2012 upon
a court order (you guys are supposed to help defend the accused, not the County or
local law enforcement against their potential civil liability for ego driven foolish
arrests) as a student at McQueen High School along with Lucy Byington, both
percipient witnesses, and where Watson was captured on tape admitting to the "man
with a six-pack" holding the phone aloft and offering it up, and announcing, very
loudly, that he woud "throw it in the river" if it was not immediately claimed (therein
presenting yet another claim of right defense and further vitiating the legitimacy of
DDA Young's retaliatory, deficiently pled, amending of the Complaint on December
5th, 2012 to included "possessing or receiving stolen property from another".
I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City
Attorney's gained an advantage and prejudiced my ability to defend in both NG12-
0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I will
note that at least Joe Goodnight gathered the three 911 calls.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
Download all

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IN THE SUPREME COURT OF THE STATE OF NEVADA
IN RE: REINSTATEMENT OF ROBERT
S. BECKETT, ES ., BAR NO. 3383.
No. 57763
ORDER GRANTING PETITION FOR REINSTATE
This is a petition for reinstatement pursuant to SCR 111(10)
fled by attorney Robert S. Beckett. On December 30, 2010, this court
temporarily suspended Beckett fom the practice of law and referred him
to the disciplinary board based on his plea of no contest to a charge of
obstructing a public ofcer. Our order was premised on the fact that
Beckett's offense constituted a "serious" crime under SCR 111(6), for
which temporary suspension and referral to the appropriate disciplinary
board are mandatory under SCR 111(7) and (8).1
Beckett contends that he should be reinstated to the practice
of law during the pendency of his disciplinary proceedings because the
criminal case underlying our December 30, 2010, order has been dismissed
with prejudice.2 Beckett acknowledges that, even if he is reinstated, our
lAlthough not mentioned in the petition, on January 8, 2010,
we also referred Beckett to the disciplinary board based on his plea of no
contest to one count of misdemeanor wet reckless driving in California.
We declined to impose a temporary suspension at that time.
2Alternatively, Beckett requests that the court set aside his
temporary suspension pursuant to SCR 111(7). We conclude that Beckett
has failed to demonstrate good cause to set aside our order of temporary
suspension under SCR 111(7).
II -C9965
SncvCunt
OF
NEADA
order of reinstatement would not terminate the pending disciplinary
proceedings.3
SCR 111(10) gives us discretion to reinstate an attorney whose
underlying conviction has been reversed. The petition is accompanied by a
certified copy of a February 2, 2011, order from the Pahrump Township
Justice Court dismissing Case No. 10CR01587 with prejudice. In light of
the fact that the charge underlyng our order of temporary suspension has
been dismissed with prejudice, and our previous determination that
Beckett's California misdemeanor conviction did not warrant imposition of
a temporary suspension, we conclude that there is no longer a basis for
Beckett being temporarily suspended pending the outcome of his
disciplinary proceedings. We therefore grant the petition. Attorney
Robert S. Beckett, Bar No. 3383, is hereby reinstated to the practice of law
pending the outcome of his disciplinary proceedings.
It is so ORDERED.
J.
Saitta
J.

J.
Parraguirre
3SCR 111(10) that "reinstatement will not terminate
proceeding pending u,,"U attorney, the of
by hearing on the basis of the
"
2
SurmwCn
NEI ADA
cc: David A. Clark, Bar Counsel
Jeffrey R. Albregts, Chair, Southern Nevada Disciplinary Board
Kimberly K. Farmer, Executive Director, State Bar of Nevada
Michael J. War hola, LLC
Perry Thompson, Admissions Offce, United States Supreme Court
3
file:///R|/1%20a%20NEW%20temp/12%204%2012%20collection%20of%20recent%20emails%20for%20addition%20to%20065630%20Opposition%20originall%20faxed%20for%20filing%20on%2011%2030%2012.htm[12/6/2012 1:22:43 PM]
Close Print
please indicate some response to my subpoena and discovery requests
Sent: Thu 11/22/12 1:18 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
complaints@nvbar.org (complaints@nvbar.org)
3 attachments
exhibit 1 to 61901 10 24 12 filing opposition.pdf (9.4 MB) , 10 24 12 stamped motion for leave to file opposition 61901 0204 12-33724.pdf (228.4 KB) , 11 2 12 file stamped complete w 195
ex and dvd notice of errata and revised supplemental 26405 1708 0204.pdf (979.7 KB)
Dear Mr. Dogan and DDA Young,
Please find attached updated discovery relevant to the RCR2012-065630 matter, especially considering Sargent Paul Sifre's ordering both the 1/12/12 custodial jaywalking arrest and the 1/14/12 "misuse of
911" arrest (though Sargent Kim Bradshaw appears to have a connection to those in addition to the July 3, 2012 "disturbing the peace" arrest in 12 CR 12420.
Mr. Dogan, I am formally requesting that you send the Reno Police Department Custodian of Records (Doreen and Harriet Neumann et al) and the ECOMM (Kelley Odom, Kariann Beechler
a subpoena and supboena duces tecum for all police reports, documentations, recordings of any kind, etc., etc. related to the 10 incarcerations of Zachary B. Coughlin (dob 9/27/76) since 8/19/11,
including the dispatch tapes of communications between the RPD and Ecomm dispatchers.
Please note that the "possible fight" report that the RPD alludes to in its arrest report of 1/12/12 is similar to the now debunked arguments in court and in pleadings on file and questions asked eliciting
testimony thereto by DDA Young and RPD Officer Duralde in RCR2011-063341.
It is my understanding the Richard Hill and or one of his contractors (possibly Phil Stewart of Nevada Building Industries) called RPD Dispatch or 911 (or possibly just called a Sargent or Officer of their
choosing directly) and that what was communicated therein resulted in RPD response appropriate to reports of a "possible fight". Please include in the discovery materials the calls that RPD Officer
Hollingsworth alludes to in the videos from that day that Coughlin can authenticate and verify as he filmed them (which show Hill lying to Officer Hollingsworth where he alleges Coughlin, on 1/12/12,
had already "lost his appeal" in that appeal of the summary eviction from his law office (not true, as the Order denying the appeal was entered 3/30/12)...
This is also a formal complaint/police report of the extortionate threats made by Hill and apparent filing of false police reports where Hill lies to the RPD (like he did in the 11/13/12 custodial arrest that is
now detailed in 61901 and that attached filing in 11 CR 26405) to effect a false arrest of Coughlin.
Please respond in some way, Mr. Dogan as to whether you have complied with my requests that you subpoena Sargent Sifre, Sarget Zach Thew (relevant to a claim of right defense that may arise given
Sargent Thews directions to Coughlin in the days prior to the arrest of 1/14/12) and Sargent Marcia Lopez and Officer Chris Carter...Sargent Lopez's testimony will be particulary important given the
motive she and the RPD had to harass and retaliate against Coughlin arising from Coughlin, on 1/13/12, getting Sargent Lopez to admit on video that she and Carter committed misconduct and fraud
incident to teh 11/13/12 arrest of Coughlin fro criminal trespass in 11 CR 26405.
Further, please subpoena RPD Officer Travis Look (one of the "arresting officers" in 065630 whom utilized excessive force, along with then trainee Wesley Leedy, at the direction of Sargent Paul Sifre,
despite Officer Hollingsworth indicated to Coughlin on video that Coughlin was not violating the law, and therefore, no lawful warning or order having been given to Coughlin). Additionally, please
subpoena Richard Hill, Casey Baker, and Phi Stewart, Christopher Allaback, and Laura Foreshee to testify regarding the arrest.
Further, Mr. Dogan and Mr. Young, the RPD had a multitude of recordings device out and recording that night, yet none have been propounded to me....I am hereby reiterating my request to be provided
that mandatory discovery, regardless of the extent to which the DA's Office does not feel it excuplatory in nature or where, predictably, Mr. Dogan and the WCPD don't see it's utility. Speaking of not
seeing any utility...Mr. Dogan, what is it you have done, in any way, to advocate on my behalf in this matter?
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: zachcoughlin@hotmail.com
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
cvellis@bhfs.com; eifert.nta@att.net; rhrc@laketahoelaw.com; stuttle@washoecounty.us; kadlicj@reno.gov; wongd@reno.gov; schornsby@nvdetr.org
Subject: new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105 Complaint
Date: Wed, 14 Nov 2012 06:46:53 -0800
Dear Panel and Bar Counsel,
Please find the attach additional discovery the Reno City Attorney's Office gave me today related to the custodial jaywalking arrest of 1/12/12, at which
time Richard Hill applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD Officer Look took a special trip to the jail to attempt to
serve the TPO for Hill). Please see attached the video of the arrest and interactions prior thereto, and consider the lack of accuracy in Hill and Baker's
Second Motion to Show Cause, Judge Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause Hearing (which WCSO
Deputy Machen, the same one who filed a false affidavit incident to the summary eviction order posting and lockout on 11/1/11 in the Richard Hill eviction
cases rev2011-001708 served on Coughlin, by way of violating the "courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
case Coughlin did not require personal service anyways...this was hazing by Hill and the RMC Marshals and WCSO Deputies, plain and simple, at the
2/27/12 Trial in 11 TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD Sargent Tarter telling Coughlin to leave Hill's
office upon going there after being released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12 resulting in a wrongful arrest for
criminal trespass of Coughlin by RPD Officer Chris Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer Hollingsworth
in seeking to abuse process and have Coughlin arrested. Then trainee Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for "misuse of 911" which DDA Young nows seeks to amend to a crime
that will leverage the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable cause basis for doing so. Further, both Hill and
Officer Leedy substantially misrepresent what Officer Hollingsworth said. Additionally, should Officer Hollingsworth had indeed told Coughlin that
what he was doing was legal but that the Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve cooperation, that would
violate Soldal v. Cook County, which is essentially what RPD Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which les to
11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes a lot of people to help Board member Richard G. Hill, Esq. and his fled-
to-Kentucky associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-way believing RPD Officer Carter's statement on 11/15/11
that "Richard G. Hill pays me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's merely attributing the statement that RPD
Carter said to Carter is not misconduct. Hill's making up things about a "crack pipe and bag of weed" and "large quantity of pills" (see the video "Zach's
arrest 014 that Hill and Merliss themselves filmed to see that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that mentions
this "large quantity of pills"). If you knew all the Thursday nights I spent since 2003 with Coe, and now deceased Judge Bob, and so many others, you
would realize how infinitely tacky Hill's conduct is.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
FW: please indicate some response to my subpoena and discovery requests
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204 25 page discovery northwind ncs krebs reduced size.pdf
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-000018 0204 Leed.pdf
SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder ptthoa 0204.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
bifurcate atty client severe hearing trialotjl.pdf
bifurcate atty client severe hearing trial.pdf
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf
Download all

Sent: Thu 11/22/12 1:24 PM
To: odomk@reno.gov (odomk@reno.gov); newmanh@reno.gov (newmanh@reno.gov)
3 attachments
exhibit 1 to 61901 10 24 12 filing opposition.pdf (9.4 MB) , 10 24 12 stamped motion for leave to file opposition 61901 0204 12-33724.pdf (228.4 KB) , 11 2 12 file stamped complete w 195
ex and dvd notice of errata and revised supplemental 26405 1708 0204.pdf (979.7 KB)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: bdogan@washoecounty.us; zyoung@da.washoecounty.us; jbosler@washoecounty.us; complaints@nvbar.org
Subject: please indicate some response to my subpoena and discovery requests
Date: Thu, 22 Nov 2012 13:18:10 -0800
Dear Mr. Dogan and DDA Young,
Please find attached updated discovery relevant to the RCR2012-065630 matter, especially considering Sargent Paul Sifre's ordering both the 1/12/12 custodial jaywalking arrest and the 1/14/12 "misuse of
911" arrest (though Sargent Kim Bradshaw appears to have a connection to those in addition to the July 3, 2012 "disturbing the peace" arrest in 12 CR 12420.
Mr. Dogan, I am formally requesting that you send the Reno Police Department Custodian of Records (Doreen and Harriet Neumann et al) and the ECOMM (Kelley Odom, Kariann Beechler
a subpoena and supboena duces tecum for all police reports, documentations, recordings of any kind, etc., etc. related to the 10 incarcerations of Zachary B. Coughlin (dob 9/27/76) since 8/19/11,
including the dispatch tapes of communications between the RPD and Ecomm dispatchers.
Please note that the "possible fight" report that the RPD alludes to in its arrest report of 1/12/12 is similar to the now debunked arguments in court and in pleadings on file and questions asked eliciting
testimony thereto by DDA Young and RPD Officer Duralde in RCR2011-063341.
It is my understanding the Richard Hill and or one of his contractors (possibly Phil Stewart of Nevada Building Industries) called RPD Dispatch or 911 (or possibly just called a Sargent or Officer of their
choosing directly) and that what was communicated therein resulted in RPD response appropriate to reports of a "possible fight". Please include in the discovery materials the calls that RPD Officer
Hollingsworth alludes to in the videos from that day that Coughlin can authenticate and verify as he filmed them (which show Hill lying to Officer Hollingsworth where he alleges Coughlin, on 1/12/12,
had already "lost his appeal" in that appeal of the summary eviction from his law office (not true, as the Order denying the appeal was entered 3/30/12)...
This is also a formal complaint/police report of the extortionate threats made by Hill and apparent filing of false police reports where Hill lies to the RPD (like he did in the 11/13/12 custodial arrest that is
now detailed in 61901 and that attached filing in 11 CR 26405) to effect a false arrest of Coughlin.
Please respond in some way, Mr. Dogan as to whether you have complied with my requests that you subpoena Sargent Sifre, Sarget Zach Thew (relevant to a claim of right defense that may arise given
Sargent Thews directions to Coughlin in the days prior to the arrest of 1/14/12) and Sargent Marcia Lopez and Officer Chris Carter...Sargent Lopez's testimony will be particulary important given the
motive she and the RPD had to harass and retaliate against Coughlin arising from Coughlin, on 1/13/12, getting Sargent Lopez to admit on video that she and Carter committed misconduct and fraud
incident to teh 11/13/12 arrest of Coughlin fro criminal trespass in 11 CR 26405.
Further, please subpoena RPD Officer Travis Look (one of the "arresting officers" in 065630 whom utilized excessive force, along with then trainee Wesley Leedy, at the direction of Sargent Paul Sifre,
despite Officer Hollingsworth indicated to Coughlin on video that Coughlin was not violating the law, and therefore, no lawful warning or order having been given to Coughlin). Additionally, please
subpoena Richard Hill, Casey Baker, and Phi Stewart, Christopher Allaback, and Laura Foreshee to testify regarding the arrest.
Further, Mr. Dogan and Mr. Young, the RPD had a multitude of recordings device out and recording that night, yet none have been propounded to me....I am hereby reiterating my request to be provided
that mandatory discovery, regardless of the extent to which the DA's Office does not feel it excuplatory in nature or where, predictably, Mr. Dogan and the WCPD don't see it's utility. Speaking of not
seeing any utility...Mr. Dogan, what is it you have done, in any way, to advocate on my behalf in this matter?
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
cvellis@bhfs.com; eifert.nta@att.net; rhrc@laketahoelaw.com; stuttle@washoecounty.us; kadlicj@reno.gov; wongd@reno.gov; schornsby@nvdetr.org
Subject: new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105 Complaint
Date: Wed, 14 Nov 2012 06:46:53 -0800
Dear Panel and Bar Counsel,
Please find the attach additional discovery the Reno City Attorney's Office gave me today related to the custodial jaywalking arrest of 1/12/12, at which
time Richard Hill applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD Officer Look took a special trip to the jail to attempt to
serve the TPO for Hill). Please see attached the video of the arrest and interactions prior thereto, and consider the lack of accuracy in Hill and Baker's
Second Motion to Show Cause, Judge Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause Hearing (which WCSO
Deputy Machen, the same one who filed a false affidavit incident to the summary eviction order posting and lockout on 11/1/11 in the Richard Hill eviction
cases rev2011-001708 served on Coughlin, by way of violating the "courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
case Coughlin did not require personal service anyways...this was hazing by Hill and the RMC Marshals and WCSO Deputies, plain and simple, at the
2/27/12 Trial in 11 TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD Sargent Tarter telling Coughlin to leave Hill's
office upon going there after being released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12 resulting in a wrongful arrest for
criminal trespass of Coughlin by RPD Officer Chris Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer Hollingsworth
in seeking to abuse process and have Coughlin arrested. Then trainee Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for "misuse of 911" which DDA Young nows seeks to amend to a crime
that will leverage the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable cause basis for doing so. Further, both Hill and
Officer Leedy substantially misrepresent what Officer Hollingsworth said. Additionally, should Officer Hollingsworth had indeed told Coughlin that
what he was doing was legal but that the Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve cooperation, that would
violate Soldal v. Cook County, which is essentially what RPD Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which les to
11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes a lot of people to help Board member Richard G. Hill, Esq. and his fled-
to-Kentucky associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-way believing RPD Officer Carter's statement on 11/15/11
that "Richard G. Hill pays me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's merely attributing the statement that RPD
Carter said to Carter is not misconduct. Hill's making up things about a "crack pipe and bag of weed" and "large quantity of pills" (see the video "Zach's
arrest 014 that Hill and Merliss themselves filmed to see that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that mentions
this "large quantity of pills"). If you knew all the Thursday nights I spent since 2003 with Coe, and now deceased Judge Bob, and so many others, you
would realize how infinitely tacky Hill's conduct is.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204 25 page discovery northwind ncs krebs reduced size.pdf
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-000018 0204 Leed.pdf
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder ptthoa 0204.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
bifurcate atty client severe hearing trialotjl.pdf
bifurcate atty client severe hearing trial.pdf
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf
Download all
video of RPD Marcia Lopez admitting to misconduct on 1/13/12 supporting inference of retaliation and motive for 1/14/12
065630 arrest and prosecution
Chief Marshal Roper and Marshal Harley on setting the record straight in NG12-0435

Sent: Thu 11/22/12 1:23 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); odomk@reno.gov (odomk@reno.gov); newmanh@reno.gov
(newmanh@reno.gov)
1 attachment
rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv (13.3 MB)
video of RPD Marcia Lopez admitting to misconduct on 1/13/12 supporting inference of retaliation and motive for 1/14/12 065630 arrest and prosecution
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Fri 11/23/12 4:09 PM
To: roperj@reno.gov (roperj@reno.gov); harleyj@reno.gov (harleyj@reno.gov); je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com
(cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); christensend@reno.gov
(christensend@reno.gov); mike@tahoelawyer.com (mike@tahoelawyer.com); davidc@nvbar.org (davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); stuttle@washoecounty.us (stuttle@washoecounty.us); wongd@reno.gov (wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov);
mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); bdogan@washoecounty.us (bdogan@washoecounty.us);
jleslie@washoecounty.us (jleslie@washoecounty.us); holmesd@reno.gov (holmesd@reno.gov)
Dear Panel, Judge Nash Holmes, Chief Roper, Marshal Harley, Bar Counsel, et al,
I apologize for using email to communicate here, but my current indigency and time constraints so require it. Further, I in no way wish to violate any Orders
by any of the RMC Judges respecting emailing or contacting the RMC in connection with specific cases, and submit this limited correspondence in the
hopes that my interpretation of any such Orders is in line with reality and will forgive at least this limited use of email outside of any attempt to file
anything in any of the matters in which I am a party before the RMC. The exigency involved here relates primarily to the enormous deference that will
be given to the Panel's decision in the SBN v. Coughlin disciplinary matter, and my desire to have the Panel afforded every opportunity to have all essential
information necessary to arrive at a just decision at its disposal. What follows is in part a request and in part a recognition of the extent to which Judge
Nash Holmes's action during the 2/27/12 Trial in 11 TR 26800 may likely have been the best thing to have had done, owing to her vast experience in these
and a great deal many other matters, and, hopefully, will have an upbeat result stemming therefrom.
At the Double R Blvd. Northern Office of the State Bar of Nevada, RMC Judge Nash Holmes, on 11/14/12, testified under oath and indicated something
along the lines of the following:
During the 11 TR 26800 "simple traffic citation Trial" on 2/27/12, starting at about 3 pm, Judge Holmes interrogated Coughlin as various points throughout
the Trial as to whether he was recording the proceedings (without permission), and or whether he had a "recording device" (whether every laptop anyone
brings to Court would be considered a "recording device" to Judge Holmes is not exactly clear).
Judge Holmes then testified that after an initial round of interrogation of Coughlin as to whether he was recording the proceedings and or had a "recording
device" that Coughlin got "all sneakity" and said he was not, but then "quote, 'took the Fifth' then immediately asked to be allowed to use the restroom...and
I ordered Marshal Joel Harley to accompany him there...and it was reported to me that while in the restroom Coughlin disassembled a recording device and
hid some part of it in the restroom..." (Coughlin recounts this testimony from memory, and admittedly, it is far from verbatim).
It is categorically false (though not necessarily maliciously so) for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events and when she asked
Coughlin her questions about recording, considering when a restroom break took place and exactly what it is she asked Coughlin and when, and what his responses
were, and when some allegations by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript reads 7 minutes into the audio
record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some extreme form of mental illness. during the trial I asked the
defendant attorney repeatedly if he was recording the proceedings he denied that vehemently a few times and then he quote took the fifth a few other times and
then he requested to be excused to go to the bathroom and the Marshal later reported to me that while the gentleman was in the bathroom he disassembled a
recording device in his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one else had gone into the bathroom and that
was retrieved and it was put into his possession at the Sheriff's office and when they booked him into jail for the contempt charge that was booked into evidence
and I asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme Court Rule 229(2)(B) which was amended by ADKT 440, August 1st,
2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN)
above.
Perhaps NRS 178.405 in the context of NRS 5.073 should have some baring on anything said or done or Ordered by Judge Nash Holmes following her statement at the 7 minute mark that "It
appears to me in this case that the defendant is suffering from some extreme form of mental illness." To the extent any question of Coughlin's competency was communicated to or brought to
Judge Nash Holmes attention prior to the 2/27/12 3:00pm start of the Trial in 11 TR 26800, that proceeding should have been stayed or suspended, especially if the WCPD's Office made such
communnications in close temporal proximity to the 1:31 pm 2/27/12 Order for Competency Evaluation by Judge Clifton in RCR2011-065630. And arguably, given the same office (in a broad
sense) in which DDA Z. Young and DDA Kandaras work, it is arguably a basis for conflicting out the WCDA's Office from any one of the three prosecutions is has maintained against Coughlin
this year (especially considering the issues related to whether the WCSO's timely effected the lockout of 11/1/11 in the eviction from Coughlin's former home law office, which, given the recent
admissions by the locksmith there that day, and the Reno Carson Messenger receipt from the day prior, and Casey Baker, Esq's testimony related to his interactions with the WCSO on October
28th, 2012 during his sworn testimony at the criminal trespass trial before RMC Judge Garder on 6/18/12, and the RJC's failure to even move to Quash Coughlin's subpoenaing records related to
the fax logs and confrimation of transmission or receipt incident to the RJC's "usual custom and practice" of faxing eviction Orders to the WCSO for service (like those in the Richard Hill/Casey
Baker Summary Eviction "Trial" involving Coughlin's former home law office, and the "within 24 hours of receipt" language found within NRS 40.253 (the Order is void or invalid after that
point, in which case, it would mean Hill and or Baker were the trespassers, not Coughlin, regardless, its inappropriate for RMC court appointed defender Loomis to categorically refuse to assert
any claim of right defense that such a criminal trespass defendant may wish to assert for, say, Richard Hill admits to charging the same rent under a "storage of personal property" that was
previously charged for "full use and occupancy". Nonetheless, posting an Eviction Order that does not contain stay away language (much less the fact that is does not have the required
"within 24 hours" language called for by the statute) is not tantamount to posting a no trespassing sign, further, Hazlett-Stevens making arguments in his closing as to matters not in evidence
(allegations of living in the residence) is reversible error, and for Judge Gardner to do as Judge Howard did, an prevent the City Attorney from even having to Oppose Coughlin's Motion for New
Trial, is further indication of the extent to which Coughlin's reactions during the 2/27/12 Trial, however offputting, are not totally unfounded. Further, that which Judge Nash Holmes had
communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her mental
processes" loophole, as he has done. But, actually, a review of the Hardesty/Mirch dynamic may dictate that Coughlin would have been fairly limited in that regard anyways, nonetheless, Judge
Nash Holmes appeared, to her credit, and answered some questions. The answers revealed an opportunity put forward now to clear some things up, though the constraints of the Disciplinary
Hearing format, some disagreements over what the SBN communicated to Coughlin with respect to the rules that would be applied to him vis a vis NRCP 45 subpoenas (whether, he, as a
suspended attorney could issues a subpoena (Coughlin maintains the Bar/Panel/Board did give him such authority) and whether any witness fee or subpoena decus tecum fee must be paid by
Coughlin (Coughlin maintains he was provided indications upon which he reasonably relied that he would not be so required in additions to the rules or practicies attached to the service thereof),
and other factors severely limited the extent to which the opportunity created by Judge Nash Holmes testimony was realized to its full potential. That necessitated this correspondence.
Coughlin recalls the first time he saw opposing counsel allege he was lying in a filing, it was one of the early one's by Richard Hill's former associate Casey Baker, alleging "outright lies". It
was upsetting, especially considering how unfair and baseless the allegations seemed...and Coughlin nows wishes he would have done and said some things differently incident to his testimony
relative to RPD Sargent Tarter and Judge Nash Holmes's own testimony, and intends to address the extent to which objectionable conduct by opposing counsel can often times become a sort of
learned characteristic perpetuating a race to, if not the ethical gutter, at least a preponderance of Rambo litigating. To some extent the incidents with Marshal Harley and RCA Ormaas may be
fallout from that. Important too, however, is to consider whether the "courthouse sanctuary" doctrine has some application, however confusing it may be, where the WCSO may be hired by
private parties to conduct service, and the Marshals are only extending intra-governmental courtesies in assisting in the manner in which Marshal Harley did on 2/27/12. Richard Hill gets the
"oopsies" a lot. Oppsie, I asked for $20K in attorney's fee incident to a summary eviction at the trial court level, despite that not being supportable under NRS 69.020, Hill says. Oopsie, I left
the window unit air conditioner in the exposed to the street by the Lakemill lodge window at your former home law office, which was then robbed, but for which I still managed to charge you full
rental value at full use and occupancy rates, though I had you subject to an arrest for custodial trespass anyways, Hill and Baker say.
(at the 9 minute 48 second mark of the first audio file attached from 2/27/12)
"Judge: Sir, I would like you to raise your hand to be sworn, because its my experience that people who represent themselves tend to testify a whole lot when they are asking other people
questions, so let's just start that way and then we won't have to do it later, so swear him in and then we'll get going
Marshal: Testimony (inaudible)...you are about to (inaudible) understand (inaudible) truth, whole truth, nothing but truth, solemnly?
Coughlin: Yes, Sir?"
However, from there, throughout the Trial Judge Nash Holmes interrupts Coughlin during his questioning of Tarter to indicate to Coughlin that he is asking questions and not testifying, or that he
will have an opportunity to make some point when its his turn to testify, if he chooses to testify, etc., etc, and eventually Judge Nash Holmes asks Coughlin, after the restroom break, if he intends
to testify on his own behalf..."Nor does the trial judge's speculation that Appellant might use his closing argument to present unsworn testimony." Soto, 139 S.W.3d at 857.
The transcript from the 2/27/12 certified audio recording of the traffic citation Trial
at the 1 hour and 6 minute 18 second mark of the running time (yes the certified audio transcript is provided in a FTR format that necessitates installing TheRecord Player, but for the ease of the
receipients of this correspondnece, Coughlin convereted the audio therein exactly as it was into a more workable format, .mp3 files, split into two files for 2/27/12 (before and after the one
restroom break) and one file for the continuation fo the trial on 3/12/12) of file one:
Judge Nash Holmes (Judge): Sir, Mr. Coughln, sit down, I am done with you.
Coughlin: Just to preserve for the record, Your Honor.
Judge: Sit down, sit down, your're done. For the record the defendant is looking in his pockets and behind his back and turning around and clowning around and showing utter disprespect for
this court and if you say another word or do another little antic like that you are going out of this Court in handcuffs. Do you have any other witnesses? Prosecutor?
Prosecutor Ormaas: No, Your Honor, the City rests.
Judge: Sir, do you wish to testify?
Coughlin: Can I call Officer Tarter as my own witness?
Judge: you can call anyone you wish to testify.
Coughlin: I am sorry, Your Honor, but I really need to use the restroom.
Judge: You have two minutes. Marshal (Harley), you will escort him to the restroom, don't take anything with you, Sir...
Coughlin: Can I take my notes with me?
Judge:No, turn them upside down.
Coughlin: Can I take the one page?
Judge: No, turn them upside down.
Coughlin: Really?
Judge: Turn them upside down. Marshal you will go with him to the restroom.
Coughlin: Will I be able to go into the stall alone? Just checking.
Judge: You have two minutes. You have two minutes.
Coughlin: Okay.
(that ends the first audio file attached for 2/27/12, which represents the entirety of the proceeding prior to the ONLY restroom break during that Trial)
(Start of the second audio file of 2/27/12, which represents the entirety of the proceedings of that day following the ONLY restroom break of the day).
Coughlin: (re-enters courtroom): Thank you, Your Honor.
Judge: Okay, we are back on the record in 11 TR 26800. Mr. Coughlin, are you recording these proceedings?
Coughlin: No, Your Honor.
Judge: Do you have any sort of devices in your pocket?
Coughlin: I believe what is in my pocket is private, Your Honor.
Judge: I want to know if you have any sort of recording devices in your pocket!
Coughlin: I believe that is a Fourth Amendment issue, Your Honor.
Judge: I am asking you, are you are recording anything from these proceedings in your pocket without Court permission?
Coughlin: I believe that is a Fourth Amendment issue.
Judge: Sir?
Coughlin: And, no, I'm not.
Judge: Okay, proceed, do you have any questions for this witness (RPD Sargent John Tarter) that are different from the area that we gave gone over already.
Coughlin: Well, I would like to ask a follow up on the rolling stop citation..." (thereafter Judge Nash Holmes does not ask any other questions of Coughlin in any way related to recording or
recording devices, nor did Judge Nash Holmes ask any questions of anyone related to recording or recording devices besides. Judge Nash Holmes did ask, before the restroom break, of
Coughlin, if Coughlin had any evidence or proof to support his contention that he attempted to provide to either Reno City Attorney Wong or Ormaas discovery or information related to the
statement to Coughlin, incident to the November 13th, 2011 custodial criminal trespass arrest of Coughlin at his former law office incident to an impermissible summary eviction of a commercial
tenant not based on the non-payment of rent (ie, a No Cause Eviction Notice was posted and a Landlord's Affidavit alleged a No Cause basis for proceeding).
On the second audio file from 2/27/12, at the 5 minute mark, the follow occurs on the record:
"Coughlin: was I there? Do I remember the name of the other officer who was there with him who went into Richard Hill's law office for twenty minutes with him and hung out?
Judge: If you mention the name Richard Hill again I am going to hold you in contempt because I have told you repeatedly to stick to the relevant issues about the boulevard stop."
(At the 11:17 minute mark of the second audio from 2/27/12 the following occurs on the record):
Judge: Officer (RPD Sargent Tarter), you are excused. Sir, do you intend to testify?
Coughlin: Yes, Your Honor.
Judge: Then testify, you don't need to take the stand, you can testify right there, you don't have to ask yourself questions, just give me a short narrative version of what happened, and don't refer to
yourself in the third person, he was sworn in at the beginning of the case, don't refer to yourself in the third person, just tell me what happened.
Coughlin: Yes, your honor, I reported a bribe to Sargent Tarter, then he retaliated against me.
Judge: Sir! Sir! Keep it relevant!
Reno City Attorney Ormaas: Objection, move to strike!
Judge: Keep it relevant about whether or not the boulevard stop occurred and what happened:
Coughlin: Sargent Tarter perjured his testimony today
Judge: Sir, Sir, answer about the boulevard stop.
Coughlin: Yes, Your Honor, this incident occurred when I went over to Richard Hill's office.
Judge: Sir.
Coughlin: I can't get into that? Okay.
Judge: Sir, boulevard stop.
Coughlin: Sargent Tarter lied today when he...
Judge: All right, Sir!
Coughlin: about the boulevard stop, I am saying...I disagree
Judge: take him into custody, you are in contempt of court, you will spend the next five days in jail, this court is finished, this matter is continued
Coughlin: Your Honor I move for a stay, I have a trial..and I have clients who need me
Judge: that is your problem, Sir. For the record you are in contempt of court because you have been insubordinate, you have disregarded all of my requests, directions, orders, cajoling, my
efforts to get you to follow the instructions of the court, to act like a lawyer, or even to act like a defendant representing himself in this court, you have made faces, belittled, you have argued, you
have played, you have been ridiculous in this courtroom and brought up issues that are irrelevant and immaterial and to disrupt this proceeding, and there are only five or six people here that you
could disrupt, you have done everything you can to divert from the matter at question and to keep us from resolving the issue of whether or not you have committed the traffic violation of the
boulevard stop, and you are in utter contempt of this court and have done nothing to deal with the facts of this case...you are being an obstinate jackass, I am having a hard time believing you are
a lawyer, you obviously missed the class on on evidence, courtroom decorum and on criminal law..."
Coughlin was taken into custody whereupon a search incident to arrest was performed in the holding area/back room of the RMC by Marshal Joel Harley with Marshal Scott Coppa assisting, and
Marshal Coppa was one of two Marshals transporting Coughlin to the Washoe County Detention Facility where he served the 5 days in jail Judge Nash Holmes ordered (and the RMC refused to
return the $100 that Coughlin's mother paid into the RMC when counter clerk "Tom" promised her the Court would issue an Order resulting in Coughlin being released from jail one day
early...however, aside from the WCDC walking Coughlin down in handcuffs from his cell to the booking desk and back, there was no release from custody and Coughlin's mother was not
returned her $100 payment in exchange for an early release by either the RMC or the WCDC.
While conducting the search incident to arrest, RMC Marshal Harley went through Coughlin's pockets and took out a simple flip style cell phone, a smart phone, a micro sd card, and an
electronic shaver. Upon taking possession of the micro sd card Marshal Harley immediately began interrogating Coughlin as to whether it would work with the smartphone, then directed
another Marshal to "go tell the Judge that Coughlin was recording!" without any other support for such an accusation. None of this occurred in the restroom and Chief Marshal Roper has
indicated to Coughlin that Marshal Harley, in carrying out Judge Nash Holmes Order to escort Coughlin to the restroom, did not actually go in the restroom, but rather waited outside its door.
I ask that Chief Marshal Roper, Marshal Harley, and Marshal Coppa correct the misrepresentations made by Judge Nash Holmes (whether or not they were purposeful or where something was lost
in translation and the affidavit requirement of NRS 22.030 for "contempt not in the immediate presence of the Court" was not followed by Judge Nash Holmes incident to her 2/28/12 Order,
wherein Judge Nash Holmes writes, on page 2 of her 2/28/12 Order Finding the Defendnat in Contempt of Court and Imposing Sanctions: "The matter was called at apprxoimately 3:00p.m. and
concluded withoua verdict about 4:30 p.m. after the court held the defendnat in criminal contempt of court for his behavior and activites committed in the direct presence of this court during the
trial. The court finds that defendant's contemptuous conduct conside of his ....deceitful...behavior during trial, all of which appeard to be done to vex an annoy the court, the witness, and the
opposing party, and to disrupt the trial process. The court finds that the following occurred, and constitute contempt...."9) defendant's lying to the court in response to direct questions posed by
the court with regard to his recording the proceedings...(page 3)...The court finds that the defendnat's actions were intentional and done in utter disregard and contempt for the court, an in the
presence of the cour, for purposes of disrupting and delaying the proceedins and dishonoring the rule of law and this court, and constitute the misdemeanor of criminal contempt, a violation of
NRS 22.010. Good cause appearing therefore, the following sanctions are imposed: IT IS ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at the Wahoe County
Regional Detnetion Facility for the term of five (5) days, from the time he was taken into custody on this court's order on February 27, 2012, and that sentence shall not be reduced for any
reason..." The time stamping on that 2/28/12 Order Finding the Defendant in Contempt of Court and Imposing Sanctions indicate "3:47". Washoe County Sheriff's Office personnel Deputy
Hodge, Patricia Beckman, RMC
Somehow, in her 2/28/12 Order (and during the Trial) Judge Nash Holmes found it relevant that, allegedly, the RPD "gave Coughlin a break" over his driver's license being expired (actually,
Coughlin's then valid, current, driver's license was being withheld by Richard G. Hill, Esq., as Coughlin reported to Sargent Tarter...and it was likely an old DL that the RPD is referring to as
"expired" when mentioning the "break", which, again, was somehow relevant enough to find its way into the Order, but the withholding of Coughlin's then current, valid DL by Hill was sustained
as irrelevant during the Trial (and in fact seems to have been one of a myriad of vague basis for issuing a summary criminal contempt Order requiring then licensed attorney with client's
depending upon him, Coughlin, immediately being taken to the WCDC for 5 days in jail...).
Coughlin hereby requests the RMC, WCDA, and WCDC to indicate the extent to which his property was booked into his personal property at the WCDC, only to have the WCDC and or WCDA
release the property to the City of Reno Marshals the following day, well after any timeframe to conduct a search incident to arrest (NNDB Member Mary Kandaras was involved in this matter,
and in fact, despite Judge Nash Holmes ordering the property released on 3/30/12, it took until 4/7/12 and approval by Mary Kandaras before the property was so released. wcso12-1805 c-
47951.
With local attorney Pam Wilmore standing, watching, and or hearing/participating in the conversations, on or about March 21st, 2012 WCSO's P. Beckman handed Coughlin a note that read "Per
Judges Orders, call Marshal Deighton" and provided a phone number for Coughlin to seek further explanation as to the admission that the City of Reno Marshals had returned to the jail on
2/28/12 and retrieved items of Coughlin's personal property, including his "flip" phone, his smart phone, and his micro sd card. Deputy Hodge's admission that, contrary to the indications by
WCSO Cummings and Campbell that the micro sd card was released to Coughlin's agent on 2/29/12, but rather, was not so release, combined with his statement that the smartphone, micro sd
card, etc. were released to the Marshals because it would be easier for Coughlin to get his property back through them, reveal that a search not incident to arrest occurred here by the RMC on
2/28/12 and or the City of Reno Marshals, or, to be fair, at least some sort of "seizure" did (especially considering that upon the smartphone and micro sd card finally being returned to Coughlin
on or about 4/7/12 by WCSO Deputy Iver, Brandi Berriman, and Patricia Beckman (and only after "Maddy" got approval from DDA Kandaras, and after Coughlin was threatened with abuse of
process by Deputy Beatson). The RMC's Marilyn Tognoni also made some indications respecting the smartphone and micro sd card to Coughlin. Perhaps, the allusion to wcso12-1805 c-
47951 in Judge Nash Holmes 3/30/12 Order Releasing Coughlin's property indicates whether a warrant or some other lawful Order allowed for the Marshals to retrieve those items a day after they
were booked into Coughlin's personal property at the jail...but Coughlin has not been provided any such Warrant or Order and hereby requests that he be so provided a copy of it now, and that,
given important data was lost to Coughlin upon his discovery the micro sd card and smartphone had been wiped, that any copies of the data then stored therein be provided to Coughlin (the Diaz
case in the Ninth Circuit seems to provided a great deal of latitude to law enforcement to search digital data within the reach of one whom is subject to a custodial arrest, and perhaps even copy
it...in which case....is would be appreciate if a copy thereof could be provided to Coughlin, and some compensation for the extent to which his 32 GB micro sd card was rendered useless upon its
return, as was his HTC G2 cell phone (which never quite worked the same from then on and was rendered totally inoperative a short time thereafter...the 32 GB micro sd card having an
approximate value of $85 and the HTC G2 smartphone a used value of around $175.00).
I know I write in the third person sometimes (its tough representing yourself, especially when time requires lots of copying and pasting, etc., etc) and that it can appear awkward.
I would appreciate the parties receiving this correspondence who have any knowledge of the events detailed herein (especially with respect to the false accusations related to recordings,
disassembling, and hiding component parts of devices in the RMC restroom as detailed on the record on 3/12/12 in 11 TR 26800 and again in Judge Nash Holmes testimony at the 11/14/12
Disciplinary Hearing for NG12-0434 (and NG12-0204, and NG12-0435) to set the record straight.
For a verbatim or close to it transcription of what Judge Nash Holmes testified to at the Disciplinary Hearing on 11/14/12 (including those matters she purported to repeat details related to what
variosu RMC Marshals told her regarding Coughlin, on would likely need get the transcript or any recordings from the CCR assigned to that Hearing, Carol Hummel, and given Coughlin's current
indigency, any requirement that Coughlin pay up front for the transcript would make review prohibitive, and Coughlin hereby requests of the Panel a fee waiver or deferment of such costs in that
regard):
Linda Shaw, Owner, Sunshine Reporting Services - Reno
1895 Plumas St,
Reno, NV 89509,
(775) 323-3411
Sunshine Reporting Services
Eric Nelson
CCR Longoni
(775) 323-3411
fax (775) 323-2749
151 Country Estates Circle
Reno, Nevada 89511
Carol Hummel
(775) 827-9120/
fax (775) 827-9120
chummel@charter.net
In her 3/12/12 Order in 11 TR 26800, a transmogrification of sorts appears to occur, turning a "simple traffic citation trial" into a Disciplinary Hearing, albeit one of a summary nature, with an
absent Respondent. That Order read, in relevant part:
"Based upon the total circumstances of this case, the in-court performance of the
defendant, as observed by this court, the written documents faxed to the court for filing by
this defendant, the statements and behavior of this defendant and his overall conduct herein,
this court finds, by clear and convincing evidence, that Zachary Barker Coughlin, an attorney
licensed to practice law in the State of Nevada, has committed numerous acts of attorney
misconduct, including, but not limited to, violating the following Rules of Professional
Conduct:
8.4(c}-engaging in dishonesty, fraud, deceit or misrepresentation;
8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
3 .l-defending in a proceeding by asserting or controverting an issue without a basis in
fact and with matters that are known to be frivolous;
3.2-failure to make reasonable efforts to expedite litigation. and, in fact, taking
extreme measures to delay litigation;
3.4(c)-being unfair to opposing counsel by continually alluding to matters the lawyer
does not reasonably believe are relevant or supported by admissible evidence;
1.3-failing to act with reasonable diligence and promptness; and
1. I-lack of competence in his practice and appearances before this court.
In addition, Zachary Barker Coughlin, likely also violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011, by surreptitiously recording
the traffic citation trial of February 27,2012 without the advance permission of this court and
then lying to this court when questioned about it and denying that he had done so.
Whether or not there are medical reasons to explain Mr. Coughlin's actions is not for
this court to decide. He has become nothing less than a vexatious litigant to Reno Municipal
Court due to his unorthodox, disruptive, bizarre and irrational methods and practices that go
beyond the pale of anything that is civil, ethical. professional or competent. Good cause
appearing therefore, the court orders as follows:
IT IS ORDERED that this matter is continued, and all proceedings relating thereto are
tolled, until further order of this court, while the matter of attorney Zachary Barker Coughlin
is referred to the State Bar of Nevada;
IT IS ORDERED that no further action shall be taken by the Reno City Attorney's
Office, or the clerks or staff of Reno Municipal Court, in the above-entitled case, pending
further order of this court;
IT IS ORDERED that Zachary Barker Coughlin is barred and forbidden from faxing,
emailing, delivering. having delivered, serving. presenting for filing. personally or otherwise,
any motion or document to Reno Municipal Court, in the above-entitled case, pending further
order of this court."
One, Coughlin is not emailing this correspondence in that "above titled case (11 TR 26800) but in connection with matters outside that case. Three, it is really not at all clear how Judge Nash
Holmes could make all those rulings, and only after having done that, decide to suspend the proceedings for a Competency Evaluation, given the import of NRS 178.405:
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant; notice of suspension to be provided to other departments.
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial, when upon conviction the defendant is brought up for judgment or when a defendant who
has been placed on probation or whose sentence has been suspended is brought before the court, if doubt arises as to the competence of the defendant, the court shall suspend the proceedings, the trial or
the pronouncing of the judgment, as the case may be, until the question of competence is determined.
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any other departments of the court of the suspension in writing. Upon receiving such notice, the
other departments of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to be competent.
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court.
1. The justice shall, within 10 days after the notice of appeal is filed, transmit to the clerk of the district court the transcript of the case, all other papers relating to the case and a certified copy of the
docket.
2. The justice shall give notice to the appellant or the appellants attorney that the transcript and all other papers relating to the case have been filed with the clerk of the district court.
3. If the district judge so requests, before or after receiving the record, the justice of the peace shall transmit to the district judge the sound recording of the case.
NRS5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the practice and proceedings of justice courts in similar cases. An appeal perfected transfers the
action to the district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS 5.010. The municipal court must be treated and considered as a justice court
whenever the proceedings thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS5.075 Form of docket and records. The Court Administrator shall prescribe the form of the docket and of any other appropriate records to be kept by the municipal court, which form
may vary from court to court according to the number and kind of cases customarily heard and whether the court is designated as a court of record pursuant to NRS 5.010.
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the citation or report in 11 tr 26800 contained any mention of retaliation, given she was
looking right at it and given what she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin reporting to Ormaas what RPD OFficer Carter said to Coughlin in
61901, and Ormaas's responses thereto on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything or whether he possessed a "recording device" until AFTER the one and only
restroom break Judge Nash Holmes mentions on the audio record. Judge Nash Holmes did ask Coughlin if he had any proof that City Attorney's Wong and Ormaas failed, in some way, to received or
follow up on some offer by Coughlin to provide materials related to Coughlin's contentions respecting the statement madAnd that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER
THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A
VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE
QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER
CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and
11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors and public defenders were non too happy with
Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that neither YOung nor Dogan wish to testify about...but which seems to have been held
anyways after a written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group
meetings amongst Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day
too, 2/27/12) Dogan got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a
filing by Coughlin of approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege
theft or possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That, and violating NRs
178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on
2/27/12...never mind Young tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial
seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt Order in 11 tr 26800 until July 2012...but did file a Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order,
Judge Nash Holmes continues to refuse to follow NRS 189.010-050
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a
trial judge of a contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the Oliver case that a person charged with contempt before a
"one-man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S.
257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being known how to comply with, not sufficient
warning, violat Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have
misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again, maybe
not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to issue a
"summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR
105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the
record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather
just some musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar
Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge Gardners
Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was dismissed
under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was
denied based upon a civilpreparation of transcript down payment rule, in that criminalappeal, where the RMC has a thing in place with this Pam Longoni that violates Nevada law in that it refused to
give Coughlin the audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down payment
was made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his communications (there may be an issue of the email
Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his
request to the number the RMC held out for her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN Judge Nash Holmes details some concerns she has with Coughlin's work as a self representing attorney defending a traffic citation (now
NG12-0434, and perhaps, NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn
Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need to send Family Court Judge Linda Gardner's
April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009 Order was not filed by the
RMC Judges?
AS to the application of the "courthouse sanctuary" doctrine to RMC Marshal Harley serving the Order to Show Cause upon Coughlin at approximately 1:25 pm in one of the conference rooms right
outside the interior of Courtroom B at the RMC:
http://caselaw.findlaw.com/ny-district-court/1372465.html
"THE LAW
(COURTHOUSE SANCTUARY)
Despite antagonistic dicta to the contrary; most modern era precedent dealing with the issue of Courthouse Sanctuary from service of process have held that New York State residents
receive no such immunity protections. Baumgartner v. Baumgartner, 273 A.D. 411, 77 N.Y.S.2d 668 (1st Dept.1948); Department of Housing Preservation, City of New York v. Koenigsberg, 133
Misc.2d 893, 509 N.Y.S.2d 270 (N.Y. Civ.Ct.1986); Ford Motor Credit Co. v. Bobo, N.Y.L.J., 1 Misc.3d 901(A), 2003 WL 22928513 (Dec. 17, 2003, J. Miller, Nassau Co. Dist. Ct.) These cases hold
that the Courthouse Sanctuary is only available to foreign state residents who come into New York's Courts to contest jurisdiction. This doctrine has been slightly expanded to include New York
residents who enter the jurisdiction of a New York Court of limited territorial jurisdiction to contest jurisdiction. See Palazzo v. Conforti, 50 N.Y.S.2d 706 (N.Y. Civ.Ct.1944); Singer v. Reising,
154 Misc. 239, 276 N.Y.S. 714 (Queens County 1935).
The Baumgartner Appellate Division panel also acknowledges a limited Courthouse Sanctuary rule for New York residents if such service would constitute a disturbance directly tending
to interrupt the proceedings of the Court or to impair the respect due its authority. This rule by itself would not be applicable to the instant case as service of process was effected in the
Courtroom but outside the Court's presence and in between calendar calls.
STATE RESIDENCY IMMUNITY DISTINCTION?
The English Common Law made no New York State residency distinction. The doctrine of immunity from arrest of a litigant attending a trial of an action to which he is a party found early
recognition and dates back to the book of 13 Henry IV, J.B. Sampson v. Graves, 208 A.D. 522, 203 N.Y.S. 729 (1st Dept.1924). This is for the obvious reason that England had no sovereign states.
The privilege is not a creature of statute, but was created and deemed necessary for the due administration of justice. See Matthews v. Tufts, 87 N.Y. 568 (1882); citing to Van Lien v.
Johnson (N.Y. Ct. Appeals, unreported 1871).
The logical question now arises, exactly when did New York's Appellate Court's recognize a residency distinction for application of the Courthouse Sanctuary? The answer is that the Court
of Appeals never established such a rule. In contra point of fact, the Court of Appeals has opined that:
It is the policy of the law to protect suitors and witnesses from arrests upon civil process while coming to and attending the court and while returning home. Upon principle as well as upon
authority their immunity from the service of process for the commencement of civil actions against them is absolute eundo, morando et redeundo. Person v. Grier, 66 N.Y. 124 (1876).
Emphasis Added.
In this unanimous opinion, the Court of Appeals expressly addressed the New York State resident immunity distinction and established in its dicta that whether any distinction should or does in
fact exist, is at least doubtful. This immunity is one of the necessities of the Administration of Justice, and Court's would often be embarrassed if suitors or witnesses, while attending Court, could
be molested with process. It is noted that Person involved a foreign state resident. In establishing the sanctuary doctrine, the Court stated that this rule is especially applicable in all its
foreign suitors . By direct implication, the Court of Appeals is also applying the protective rule to New York residents.
The basis of the Courthouse Sanctuary rule is that parties should be allowed to contest jurisdiction without submitting to it. Allowing Re-service makes a mockery of the traverse
hearing and essentially allows the plaintiff to use a defective default judgment as a weapon to compel the defendant to submit to the service of process. Ford Motor Credit Co. v. Bobo;
cite supra. The location of an individual's residence does little to legitimize such a mockery. Absent the compulsion of clear controlling precedent; this Court will not condone such a
situation..."
NRS 266.595 Appeals. Appeals to the district court may be taken from any final judgment of the municipal court in accordance with the provisions of NRS 5.073.
NRS5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the practice and proceedings of justice courts in similar cases. An appeal perfected transfers the
action to the district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS 5.010. The municipal court must be treated and considered as a justice court
whenever the proceedings thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS5.075 Form of docket and records. The Court Administrator shall prescribe the form of the docket and of any other appropriate records to be kept by the municipal court, which form
may vary from court to court according to the number and kind of cases customarily heard and whether the court is designated as a court of record pursuant to NRS 5.010.
NRS5.010 General requirements for court; designation as court of record. There must be in each city a municipal court presided over by a municipal judge. The municipal court:
1.Must be held at such place in the city within which it is established as the governing body of that city may by ordinance direct.
2.May by ordinance be designated as a court of record.
The personal service by Marshal Harley of the Order to Show Cause in the appeal of the summary eviction matter from Coughlin's former home law office at 121 River Rock St, with Richard G. Hill,
Esq. as opposing counsel in CV11-03628, occurred while Coughlin was speaking to RCA Ormaas in attempts to resolve the matter (11 TR 26800 a traffic citation matter wherein RPD Sargent Tarter and
other officers responded to Richard G. Hill, Esq.'s office on 11/15/12 (its possible both Hill and Coughlin called the police and or 911...can't remember) when Coughlin appeared there after being
released from 3 days in jail incident to the 11/13/12 criminal trespass arrest (now a conviction and discussed in that attached materials, some of which appear on the Nevada Supreme Court's site
under case 61901, the conviction stemming from 11 CR 26405 before RMC Administrative Judge W. Gardner, the brother of District Court Judge Linda Gardner whose April 2009 Order sanctioning
Coughlin was cited by Washoe Legal Services at the cause for his firing, and led to 60302, now on appeal...
I would really just like to move on from all of this, but this is a time of exigent circumstances, and if the RMC and the City of Reno Marshals do not take affirmative steps to disavow the unsworn
hearsay Judge Nash Holmes attributed in her supposedly sworn testimony at Coughlin's 11/14/12 Disciplinary Hearing, it may be that a negligent hiring, training, or supervision cause of action may
acrue against various Marshals, even personally (and its not so clear Mr. Christensen and the City of Reno would extend any purported representation to such personal liability, for, say, slander or
libel).
NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in judicial duties at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial
proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or in its immediate vicinity, tending to interrupt the due course of the trial or other judicial proceeding.
3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
4. Disobedience of a subpoena duly served, or refusing to be sworn or answer as a witness.
5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge at chambers.
6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the presence of a juror concerning an action in which the juror has been impaneled to determine, or in any manner approaching
or interfering with such juror with the intent to influence the verdict.
7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or process of the court.
[1911 CPA 452; RL 5394; NCL 8941](NRS A 1983, 843)

NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court; affidavit or statement to be filed when contempt committed outside immediate view and presence of court;
disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may be punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection,
the court or judge shall enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
(b) Finds the person guilty of the contempt; and
(c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit must be presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters or
arbitrators.
3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence of the court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the
contempt over the objection of the person. The provisions of this subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was entered in such court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings for the
violation of the judgment or decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been established in the judicial district.
NRS 22.100 Penalty for contempt.
1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall determine whether the person proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be imposed on the person not exceeding $500 or the person may be imprisoned not exceeding 25 days, or both.
3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt pursuant to subsection 3 of NRS 22.010, the court may require the person to pay to the party seeking to enforce the writ, order, rule or process
the reasonable expenses, including, without limitation, attorneys fees, incurred by the party as a result of the contempt.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one of the following kinds shall be guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its immediate view and presence, and directly tending to interrupt its proceedings or to impair the respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or hearing pursuant to an order of court, or in the presence of a jury while actually sitting in the trial of a cause or upon an inquest or other
proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or referee;
4. Willful disobedience to the lawful process or mandate of a court;
5. Resistance, willfully offered, to its lawful process or mandate;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer any legal and proper interrogatory;
7. Publication of a false or grossly inaccurate report of its proceedings; or
8. Assuming to be an attorney or officer of a court or acting as such without authority.
ARTICLE IV - Judicial Department
Sec.4.010Municipal Court. The Municipal Court must include one department and may include additional departments in the discretion of the City Council. If the City Council determines
to create additional departments, it shall do so by resolution and may appoint additional municipal judges to serve until the next election.
(Ch. 662, Stats. 1971 p. 1976; ACh. 553, Stats. 1973 p. 881; Ch. 373, Stats. 1979 p. 645; Ch. 208, Stats. 1985 p. 675; Ch. 9, Stats. 1993 p. 21)
Sec.4.020Municipal Court: Qualifications of Municipal Judge; salary.
1.A Municipal Judge must be:
(a)An attorney licensed to practice law in the State of Nevada.
(b)A qualified elector within the City.
2.A Municipal Judge shall not engage in the private practice of law.
3.The salary of a Municipal Judge must be:
(a)Fixed by resolution of the City Council.
(b)Uniform for all judges in the Municipal Court.
(Ch. 662, Stats. 1971 p. 1976; ACh. 343, Stats. 1973 p. 422; Ch. 553, Stats. 1973 p. 881; Ch. 98, Stats. 1977 p. 211; Ch. 561, Stats. 1977 p. 1395; Ch. 208, Stats. 1985 p. 675; Ch. 599, Stats. 1993 p.
2501; Ch. 327, Stats. 1999 p. 1369)
Sec.4.030Disposition of fines. All fines and forfeitures for the violation of ordinances shall be paid to the City Clerk in the manner to be prescribed by ordinance.
(Ch. 662, Stats. 1971 p. 1977)
Sec.4.040Procedure, additional judges. The practice and proceedings in the Court must conform as nearly as practicable to that of justices courts in similar cases. Upon the written
request of the City Manager an additional temporary Municipal Judge may be provided for so long as the City Council authorizes additional compensation for such a Judge. Whenever a person is
sentenced to pay a fine, the Court may adjudge and enter upon the docket a supplemental order that the offender may, if he or she desires, work on the streets or public works of the City at the rate of $25
for each day. The money so earned must be applied against the fine until it is satisfied.
CONTEMPT
Acts or omissions constituting, generally, 22.010
Affidavit of facts constituting, 22.030
Affidavits presented in bad faith, NRCP 56(g), JCRCP 56(g)
Appearance, failure of defendant to make, 22.130
Arrest
Bond, 22.070
Excuses for not bringing arrested person before court, 22.140
Illness of defendant, effect, 22.140
Attorneys at law
Bar examination, early release of results, SCR 68
Discharged, failure to deliver certain materials to client, 7.055
Bail
Violation of conditions deemed contempt, 178.484
Commercial premises, violations of writ of restitution, 118C.210
Commission in presence of court or judge, 22.030
Compelling performance, imprisonment, 22.110
Court order, violation, 1.250, 22.010
Court reporters, 656.240
Criminal, 193.110, 193.300, 199.340
Custodial parent, failure to comply with visitation orders, 125C.030, 125C.040
Discharge from arrest, 22.070
Disqualification of judge or justice, making of charge not punished as contempt, 1.225, 1.230
Documents, refusal to permit inspection, NRCP 37(b)(2), JCRCP 37(b)(2)
Failure to perform specific acts directed by judgment, 22.010, NRCP 70, JCRCP 70
Imprisonment, 22.100, 22.110
Indictment for contemptuous conduct, 22.120
Justice courts, civil proceedings, 74.040
Material witness granted immunity, failure to testify, 178.576
Misconduct by defendant during criminal trial, 175.387
Municipal court may punish for, 266.570
Punishment, 22.030, 22.100, 22.120
Reentry on real property after ejectment, 22.020
Refusal to answer or be sworn, 22.010, 50.195, NRCP 37(b)(1), JCRCP 37(b)(1)
Sheriffs duties, 22.060, 50.205
Subpoenas, failure to obey
Deemed contempt, 22.010, 174.385
Witnesses, forfeitures and damages, 50.195
Summary punishment, 22.030
Trials for contempt
By court or jury, 22.100
Disqualification of judge, 22.030
Investigating charge, 22.090
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-Mart are in a long term business partnership where the 2nd St. Wal-
Mart is on tribal land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely making misdemeanor petty theft/shoplifting
custodial arrest (Officer Kameron Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me all the information necessary to
issue a citation" explanations (including Crawfords lying under oath that Coughlin didn't provide his driver's license to him on September 9th, 2011,
especially where Wal-Mart's Frontino admits he did not make a citizen's arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by
tribal officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a chance to explain how she prosecutes cases based upon arrests by
tribal officers for misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12 Disciplinary Hearing, and the SBN and Panel's violations of SCR 105
contributed greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr. Garin/Ms. Nordstrom should be provided transcripts from
the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person employed as a police officer by an Indian tribe may make an arrest in obedience to a
warrant delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public offense, and the officer or agent has reasonable cause to believe that the person arrested is
the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery upon that persons spouse and the peace officer finds evidence of bodily harm to the
spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a person who is reasonably believed by the officer or agent to have committed a felony
within the boundaries of the reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
Please see the photograph in the attached materials of the RSIC Officer taking Coughlin's driver's license from him, thereby vitiating his assertion that an arrest was an available option due to Couglin not
providing his driver's license to the Officers.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 1 of 2.pdf
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 2 of 2.pdf
11TR26800 031412 RMC continuation of trial Nash Ormaas Hill traffic citation 031412_20120312-1033_01cd003b8f0851d0.mp3
11 23 12 AMENDED SUPPLEMENTAL TO RESPONDENT'S EMERGENCY MOTION TO SET ASIDE, ALTER OR
AMEND ALL ORDERS SO FAR BY NNDB, SBN, PANEL, OR BOARD, AND NOTICE OF IRREGULARITIES OF
PROCEEDINGS THUS FAR and SUPPLEMENT TO VERIFIED ANSWER OR RESPONSE TO WHATEVER EX
wcda conflicts making prosecutions of Coughlin impermissible
11TR26800 RMC 022712 part 2 of 2 from 2 27 12 031412_20120227-1621_01ccf56bce224540.mp3
11TR26800 RMC 022712 part 1 of 2 from 2 27 12 031412_20120227-1507_01ccf5618f76c460 (2).mp3
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204.pdf
CR12-1262 appeal.pdf
11 2 12 file stamped complete notice of errata and revised supplemental 26405 1708 0204.pdf
11 15 11 rpd tarter redacted 0204 0434 26800 police report ormaas retaliation.pdf
Download all

Sent: Fri 11/23/12 5:32 PM
To: (je@eloreno.com) (e@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (davidc@nvbar.org) (davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
(eifert.nta@att.net); (mike@tahoelawyer.com) (mike@tahoelawyer.com); (patrickk@nvbar.org) (patrickk@nvbar.org); (skent@skentlaw.com) (skent@skentlaw.com); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org)
Please find attached and let me know if you want yours faxed as well
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 23 12 0204 RESPONDENT'S AMENDED SUPPLEMENTAL WITH EX 1 ATTACHED ALL 2025 BATE STAMPED PAGES OF IT.pdf

Sent: Sun 11/25/12 1:37 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
Dear DDA Young, Kandaras, and Watts-Vial,
Mr. Watts-Vial, please indicate any relation you have to any Judicial Assistant or other personnel in the Second Judicial District Court, including to Laura
Watts-Vial of Judge Walker's Department (wherein I had a case this last year, in which the various conflicts and issues I have set forth to DDA's Young
and Kandaras arose as well). Please note, Mr. Watts-Vial, that NRCP 45 was altered by representations made by those with the authority to make
them concerning the subpoenas and subpoena duces tecums for the SBN matter NG12-0204 etc...as such, a response is hereby requested...see SCR
105(4). Further, Judge Sferrazza clearly waived witness fees and those for subpoena duces tecums at the 48 minutes mark of the second file from the
October 22nd, 2012 Hearing in rcr2011-063341.
Please find attached the correspondence from your coworkers at the WCDA further making you aware of the basis for recusing yourself from this
prosecution (maybe recusal is a term for judges only, but at least a conflict analysis is indicated...).
Also, I just refaxed to the RJC something I believe was faxed to you and the RJC (I resent it do to some concerns about the tranmission being successful...).
When I resent it to the RJC I included this excerpt with one new line about Judicial Secretary Townsend on the cover sheet, and am copying you on that
now to avoid any ex parte appearance:
"then there is the fact that the RJC purports to have fax Coughlin two different Orders on 11/16/12 speaking to the various motions to quash subpoenas, but
that, however, the RJC seems to have, uh, accidentally faxed the same order twice, therefore prejudicing coughlins case with respect to his not having been
served the second order a single time, but rather his having been served the 12/16/11 filed rcr2011-06334 "Order Denying Motions for Mistrial and
Continuance" (with a file stamp of 11:41 AM) TWICE, while the "Order" baring a file stamp of 11:42 am on 12/16/11 in rcr2011-063341 was never faxed
to Coughlin, despite the Certificate of Service of RJC Lori Townsend indicating it was..."
Then I added a line about how, while Judge Sferrazza denied a State Bar request to testify at the 11/14/12 Disciplinary Hearing brought against me (itself suggesting a basis for recusal) that did not
prevent his Judicial Secretary (and maybe all of the Judge's) from emailing the SBN about me as far back as April 2012 (I can't find the exact sentence, but that is nearly verbatim it, so...also, I
added a sentence or so about the RJC also having a conflict where it failed to provide me a hearing on the Complaint/Motion for Illegal Lockout I filed on or about November 2, 2011 considering the
invalid/void nature of a lockout by the WCSO incident to an Order that had expire or where the wcso otherwise did not comply with NRS 40.253's "within 24 hours of receipt" dictate. I would have
copied you exactly on what was written on the fax cover sheet, but it got erased from my clipboard (I copied something else to paste before pasting that into this correspondence....the joys of
voxox....)
I am reattaching that filing.
As for the indication at Trial that there was no cd/dvds attached to my various motions prior to Trial, I am writing to see if you will stipulate (provided the Court would allow it) something with
respect to the cd/dvds missing be placed into the record somehow (whether incorporating the Skydrive link materials that I could reduce further to a cd/dvd or some other means)...
Please note, beyond all the impermissible conflicts attendant to DDA Kandaras being on the NNDB, her involvement in the confiscation of my smartphone and micro sd card for 37 days, the release to
the City of Reno Marshals a day after those materials were booked into my personal property at the jail, the cover-up related thereto, to wiping of the data on those items prior to their being
returned to me...the failure of the WDCA to have witnesses show up at the 11/14/12 bar hearing based upon contentiosn by your offices David Watts-Vial that do not account for the unique
alterations to NRCP 45 provided by SCR 105(4), etc., etc.
Sincerely,
Supplemental to 11 23 12 correspondence regarding discovery in Joshi 54844, April 2009 Order sanctioning Coughlin
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 21 12 notice of non service 063341 with attached exhibit 1.pdf
11 13 12 fax at 441pm from watts-vial wcda 0204 063341 quash subpoenas.pdf
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 final b redued sizef.pdf bf.pdf
4 16 12 email to kandaras 26800 0434 063341 065630 067980.pdf
11 14 12 063341 Kandaras Emergency ex parte 0204 quash Coughlin Motion to Quash Subpoenas (1).pdf
11 2 12 WCSO SBN 0204 KANDARAS RECEIVED SUBPOENA.pdf
wls gardner emails siragusa and non profit property tax email collection 0204 60302.pdf
nvbar david and laura watts-vial 0204 063341.pdf
11 21 12 notice irregs plus attached ex 1.pdf
Download all

Sent: Sun 11/25/12 1:41 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (je@eloreno.com) (je@eloreno.com); (patrickk@nvbar.org) (patrickk@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com)
(cvellis@bhfs.com); (jgarin@lipsonneilson.com) (jgarin@lipsonneilson.com); (pelcano@washoelegalservices.org) (pelcano@washoelegalservices.org); (linda.gardner@washoecounty.us)
(linda.gardner@washoecounty.us)
1 attachment
03018 to 03041 Judge Linda Gardner listed by SBN King as greivant in ng12-0435 fyi prosecutorial misconduct blog smaller size.pdf (10.5 MB)
I believe I informed WLS of this previously, but I did try to have discovery send out in Joshi, but Deborah Pringle and then WLS Office Manager Robin Kunce indicated it would
take something on the order of six weeks to get a check cut for anything, such as for witness fees or those associated with a subpoena duces tecum, and the Trial of March 12th,
2009 in Joshi was not far out enough to account for such an unanticipated indication from WLS as to what would be required to conduct what Judge Gardner indicated in her April
2009 Order as the sort of discovery she felt would be necessary to rebut an inference of vexatiousness for not immediately caving to Mr. Springgate's Siragusa argument. Further,
it was never my understanding that either Ms. Santiago or myself "agreed" to then Master Gardner entering an Order "resolving" the dispute as to the car title in the Temporary
Protection Order hearing in Santiago v. Vaxevanis.

What is interesting is that, on one hand, Mr. Elcano is being told to fire me or else by CAAW and Tahoe Women's Services for allegedly not being zealous enough in advocating
their agendas, er, for the victims of domestic violence in the Carnine and Haubl matters, , Further, in early January 2009, WLS's Rhonda Harrison is saying "eat me" to Coughlin
when he attempts to use the upstairs restroom at WLS. Couglin sens a written complaint about that to Mr. Elcano, and he holds a meeting with Coughlin which results in, as Mr.
Elcano testified at the Disciplinary Hearing, his "standing by my employee". It would seem true that Mr. Elcano did jut that, at that time (ie, stand by his employee, Coughlin).
In fact, it was during a face to face meeting with Coughlin in February 2009 or so that Elcano told Coughlin about the appraisals of Coughlin's work by Judge Gardner and Master
Edmondson, with both, essentially, giving Coughlin a "thumb's up" review (ie, good enough work not to be fired, etc.). It was at that point that Mr. Elcano casually mentioned
that he had done something in the past for Judge Gardner (it didn't sound as ominous coming from Paul as it does when I write it....) and that, essentially, that was some indicia of
reliability as to Judge Gardner's candor to Elcano in assessing Coughlin's work at that time, and therefore, Mr. Elcano was reinforced in his belief in his position that it would be
inappropriate to let CAAW and Tahoe Women's Services, essentially, tell him who to fire or not.

But the irony is that I was fired, according to Mr. Elcano's letters to me of May 1, 2009 and May 7, 2009 because of the April 13th, 2009 Order by Judge Linda Gardner finding my
conduct at trial to be vexatious. It is inaccurate and overly convenient to now attempt to remix that assessment, as Mr. Elcano did in his testimony on 11/14/12 to indicate my
advocacy was merely 'incompetent'. Further, testimonial evidence is evidence, as such, Judge Gardner's Order is inaccurate to the extent is suggests no evidence was put on as to,
say a Tonopah formula approach is determing the alimony question. Whereas Judge Gardner found I advocated too zealously on behalf of a battered woman (to the point of
vexatiousness, no less), Tahow Women's Services and CAAW had, in close proximity and previous to Judge L. Gardner's April 2009 Order, complained that I did not advocate
strenously enough, apparently (Mr. Elcano has refused to release those writings to me).

Tahoe Women's Services (which apparently changed its name to something less gender polarizing upon Coughlin's critique thereof, as it is now known as
Crisis Intervention Services) provided a written complaint about Coughlin's performanc eot Elcano in FV08-02254 - PAOLA C. PEREZ HAUBL VS. ANDREW A.
CRAIG. Coughlin hereby requests, again, a copy thereof.
Likewise, the Committee to Aid Abused Women (CAAW) (no name change as of yet) complaint in writing to Elcano about Coughlin with respect to his
representation of Michelle Carnine in a TPO and or divorce matter. Coughlin hereby requests a copy of any written complaints submitted by anyone with respect
to either of those Carnine matters:

CASE NO. FV08-02021 MICHELLE CARNINE OBO STORMY VS. BRADLEY
CARNINE CASE NO. DV08-01532 MICHELLE CARNINE VS. BRADLEY CARNINE

The funny thing is, for prosecutors (and see J udge Gardner's apparent "FYI" correspondence to the State Bar of Nevada's Pat King in NG12-0435, bate stamping
indicating J udge Linda Gardner as the grievant, and the blog entry related to prosecutorial misconduct being taken note of place directly after the fate stamped
folder name listing J udge L. Gardner as the grievant in that 0435 case...with both J udge L. Gardner and her brother, RMC J udge W. Gardner being lifelong
prosecutors before taking the bench, like most judges in Washoe County, though they are two of the rare exceptions who did not go to McGeorge).

Some might say the District Attorney and Reno City Attorney Offices influence as prosecutors extends to the District,J ustice, and Municipal Courts to an
impermissible extent...and now, with the firing of Coughlin from Washoe Legal Services, and the entering into the Early Case Resolution (ECR) contract between
the WCDA's Office and WLS to deliver some sort of approach that some say violates the Sixth Amendment, local legal aid is impermissibly influence by local
prosecutors, so much so that, regardless of what the legislature may enact (often in response to the tireless advocacy by those such as WLS's J on Sasser,
especially regarding AB226 in the landlord tenant context along with Coughlin's Boyd School of Law early, unaccredited days, classmates, Assemblymen William
Horne and J ason Frierson, in conjunction with Tik Segerblom). A quick look at a retaliatory arrest and eviction of Coughlin this year reveals a disturbing pattern
of the local judiciary being overly influenced by the prosecutor's office, and taking a markedly laissez faire approach to prosecutorial misconduct, in marked contrast
to the seemingly overly aggressive approach by lifelong prosecutor's turned judges RMC J udge Nash Holmes, RMC J udge Kenneth Howard, RMC J udge William
Gardner, and Second J udicial District Court J udge Linda Gardner in "protecting the public" from the work of one Zachary Barker Coughlin, Esq. (whom has held
himself out as an attorney who takes on cases of prosecutorial and police misconduct...a type of attorney whom the SBN's Patrick O. King seems to have carved
out a specialty in prosecuting, right, J ames Andre Boles, Esq, the attorney whom has most consistently sued local law enforcement for wrongful arrest and other
police misconduct, just now being harrassed by the SBN in In Re the Discipline of J ames Andre Boles, Esq.? Is SBN Bar Counsel Patrick O. King, Esq. puttin'
in work for prosecutors and police alike?):
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29336

Further, during the numerous retaliatory prosecutions this year of Coughlin, a multitude of prosecutorial misconduct has been apparent, inlcuding DDA Zach Young
(McGeorge '04) making argument in filings with the Reno J ustice Court in RCR2011-063341 that alleged communitcations between ECOMM/911 dispatch and the
RPD in relation to the arrest of 8/20/11 (the one that started the entire 16 month ordeal off) that contained communications from dispatch to the RPD of "a possible
fight", which DDA Young and RPD Officer Nick Duralde (whose wife, J essica Duralde was working that night at a 911 dispatcher and whose voice may be on the
tapes only released by Reno City Attorney Skau on 11/13/12 incident to an Emergency Hearing on Motions to Quash Coughlin's subpoenas (and, really, J udge
Sferrazza admitted later that the hearing was also based on Motion to Quash that were not even filed, but rather just a sua sponte overall intention by J udge
RE: Supplemental to 11 23 12 correspondence regarding discovery in Joshi 54844, April 2009 Order sanctioning Coughlin
Sferrazza, the longest tenured Mayor in Reno's history, a former Chairman, Vice-Chairman and Washoe County Commissioner from 1998-2007, to Quash pretty
much every subpoena Coughlin drafted in any way related to anyone in goverment).

The prosecutorial misconduct has been detailed at length in Couglin's filing with the Nevada Supreme Court this year, save, perhaps the new instances where DDA
Young's assertions of dispatch alerting RPD Officers of "a possible fight" prior to their arriving to respond on 8/20/11 (and the utility thereof incident to the Hearing
on Coughlin's Motion to Suppress) has been thoroughly disproved by City Attorney Skau's only finally releasing those tapes on 11/13/12, after he secured
Coughlin's attendane at a Hearing on his Motion to Quash Subpoenas by alleging the court had granted him the power to effect service thereof by emailing
Coughlin (and Coughlin SBN form Disciplinary Hearing was held the next day 11/14/12, where J udge Linda Gardner's bailiff was assigned to the affair, the same
bailiff present at the April 12th, and 17th, 2009 Trial dates in the J oshi matter that became 60302 and 54844. J udge Gardner's brother also refused to recuse
himself from the criminal trespass prosecution of Coughlin incident to an arrest at his former home law office. Coughlin has detailed the prosecutorial misconduct
of City Attorney's Roberts (in 60838) and Hazlett-Stevens (in 61901) in addition to that of DDA Zach Young (three different prosecutions, each one more
retaliatory than the last) and the multitude of violations of the stay required by NRS 178.405 (in consideration of NRS 5.071, especially).

Sincerely,

Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Mon 11/26/12 1:59 PM
To: (skent@skentlaw.com) (skent@skentlaw.com); (je@eloreno.com) (je@eloreno.com); (patrickk@nvbar.org) (patrickk@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com)
(cvellis@bhfs.com); (jgarin@lipsonneilson.com) (jgarin@lipsonneilson.com); (pelcano@washoelegalservices.org) (pelcano@washoelegalservices.org); (linda.gardner@washoecounty.us)
(linda.gardner@washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

To: skent@skentlaw.com; je@eloreno.com; patrickk@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; jgarin@lipsonneilson.com; pelcano@washoelegalservices.org; linda.gardner@washoecounty.us
Subject: Supplemental to 11 23 12 correspondence regarding discovery in Joshi 54844, April 2009 Order sanctioning Coughlin
Date: Sun, 25 Nov 2012 01:41:47 -0800
I believe I informed WLS of this previously, but I did try to have discovery send out in Joshi, but Deborah Pringle and then WLS Office Manager Robin Kunce indicated it would
take something on the order of six weeks to get a check cut for anything, such as for witness fees or those associated with a subpoena duces tecum, and the Trial of March 12th,
2009 in Joshi was not far out enough to account for such an unanticipated indication from WLS as to what would be required to conduct what Judge Gardner indicated in her April
2009 Order as the sort of discovery she felt would be necessary to rebut an inference of vexatiousness for not immediately caving to Mr. Springgate's Siragusa argument. Further,
it was never my understanding that either Ms. Santiago or myself "agreed" to then Master Gardner entering an Order "resolving" the dispute as to the car title in the Temporary
Protection Order hearing in Santiago v. Vaxevanis.

What is interesting is that, on one hand, Mr. Elcano is being told to fire me or else by CAAW and Tahoe Women's Services for allegedly not being zealous enough in advocating
their agendas, er, for the victims of domestic violence in the Carnine and Haubl matters, , Further, in early January 2009, WLS's Rhonda Harrison is saying "eat me" to Coughlin
when he attempts to use the upstairs restroom at WLS. Couglin sens a written complaint about that to Mr. Elcano, and he holds a meeting with Coughlin which results in, as Mr.
Elcano testified at the Disciplinary Hearing, his "standing by my employee". It would seem true that Mr. Elcano did jut that, at that time (ie, stand by his employee, Coughlin).
In fact, it was during a face to face meeting with Coughlin in February 2009 or so that Elcano told Coughlin about the appraisals of Coughlin's work by Judge Gardner and Master
Edmondson, with both, essentially, giving Coughlin a "thumb's up" review (ie, good enough work not to be fired, etc.). It was at that point that Mr. Elcano casually mentioned
that he had done something in the past for Judge Gardner (it didn't sound as ominous coming from Paul as it does when I write it....) and that, essentially, that was some indicia of
reliability as to Judge Gardner's candor to Elcano in assessing Coughlin's work at that time, and therefore, Mr. Elcano was reinforced in his belief in his position that it would be
inappropriate to let CAAW and Tahoe Women's Services, essentially, tell him who to fire or not.

But the irony is that I was fired, according to Mr. Elcano's letters to me of May 1, 2009 and May 7, 2009 because of the April 13th, 2009 Order by Judge Linda Gardner finding my
conduct at trial to be vexatious. It is inaccurate and overly convenient to now attempt to remix that assessment, as Mr. Elcano did in his testimony on 11/14/12 to indicate my
advocacy was merely 'incompetent'. Further, testimonial evidence is evidence, as such, Judge Gardner's Order is inaccurate to the extent is suggests no evidence was put on as to,
say a Tonopah formula approach is determing the alimony question. Whereas Judge Gardner found I advocated too zealously on behalf of a battered woman (to the point of
vexatiousness, no less), Tahow Women's Services and CAAW had, in close proximity and previous to Judge L. Gardner's April 2009 Order, complained that I did not advocate
strenously enough, apparently (Mr. Elcano has refused to release those writings to me).

Tahoe Women's Services (which apparently changed its name to something less gender polarizing upon Coughlin's critique thereof, as it is now known as
Crisis Intervention Services) provided a written complaint about Coughlin's performanc eot Elcano in FV08-02254 - PAOLA C. PEREZ HAUBL VS. ANDREW A.
CRAIG. Coughlin hereby requests, again, a copy thereof.
Likewise, the Committee to Aid Abused Women (CAAW) (no name change as of yet) complaint in writing to Elcano about Coughlin with respect to his
representation of Michelle Carnine in a TPO and or divorce matter. Coughlin hereby requests a copy of any written complaints submitted by anyone with respect
to either of those Carnine matters:

CASE NO. FV08-02021 MICHELLE CARNINE OBO STORMY VS. BRADLEY
CARNINE CASE NO. DV08-01532 MICHELLE CARNINE VS. BRADLEY CARNINE

The funny thing is, for prosecutors (and see J udge Gardner's apparent "FYI" correspondence to the State Bar of Nevada's Pat King in NG12-0435, bate stamping
indicating J udge Linda Gardner as the grievant, and the blog entry related to prosecutorial misconduct being taken note of place directly after the fate stamped
folder name listing J udge L. Gardner as the grievant in that 0435 case...with both J udge L. Gardner and her brother, RMC J udge W. Gardner being lifelong
prosecutors before taking the bench, like most judges in Washoe County, though they are two of the rare exceptions who did not go to McGeorge).

Some might say the District Attorney and Reno City Attorney Offices influence as prosecutors extends to the District,J ustice, and Municipal Courts to an
impermissible extent...and now, with the firing of Coughlin from Washoe Legal Services, and the entering into the Early Case Resolution (ECR) contract between
the WCDA's Office and WLS to deliver some sort of approach that some say violates the Sixth Amendment, local legal aid is impermissibly influence by local
prosecutors, so much so that, regardless of what the legislature may enact (often in response to the tireless advocacy by those such as WLS's J on Sasser,
especially regarding AB226 in the landlord tenant context along with Coughlin's Boyd School of Law early, unaccredited days, classmates, Assemblymen William
Horne and J ason Frierson, in conjunction with Tik Segerblom). A quick look at a retaliatory arrest and eviction of Coughlin this year reveals a disturbing pattern
of the local judiciary being overly influenced by the prosecutor's office, and taking a markedly laissez faire approach to prosecutorial misconduct, in marked contrast
to the seemingly overly aggressive approach by lifelong prosecutor's turned judges RMC J udge Nash Holmes, RMC J udge Kenneth Howard, RMC J udge William
Gardner, and Second J udicial District Court J udge Linda Gardner in "protecting the public" from the work of one Zachary Barker Coughlin, Esq. (whom has held
himself out as an attorney who takes on cases of prosecutorial and police misconduct...a type of attorney whom the SBN's Patrick O. King seems to have carved
please attached filing of 11 26 12 Notice of Hill and Baker's Malfeasance
out a specialty in prosecuting, right, J ames Andre Boles, Esq, the attorney whom has most consistently sued local law enforcement for wrongful arrest and other
police misconduct, just now being harrassed by the SBN in In Re the Discipline of J ames Andre Boles, Esq.? Is SBN Bar Counsel Patrick O. King, Esq. puttin'
in work for prosecutors and police alike?):
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29336

Further, during the numerous retaliatory prosecutions this year of Coughlin, a multitude of prosecutorial misconduct has been apparent, inlcuding DDA Zach Young
(McGeorge '04) making argument in filings with the Reno J ustice Court in RCR2011-063341 that alleged communitcations between ECOMM/911 dispatch and the
RPD in relation to the arrest of 8/20/11 (the one that started the entire 16 month ordeal off) that contained communications from dispatch to the RPD of "a possible
fight", which DDA Young and RPD Officer Nick Duralde (whose wife, J essica Duralde was working that night at a 911 dispatcher and whose voice may be on the
tapes only released by Reno City Attorney Skau on 11/13/12 incident to an Emergency Hearing on Motions to Quash Coughlin's subpoenas (and, really, J udge
Sferrazza admitted later that the hearing was also based on Motion to Quash that were not even filed, but rather just a sua sponte overall intention by J udge
Sferrazza, the longest tenured Mayor in Reno's history, a former Chairman, Vice-Chairman and Washoe County Commissioner from 1998-2007, to Quash pretty
much every subpoena Coughlin drafted in any way related to anyone in goverment).

The prosecutorial misconduct has been detailed at length in Couglin's filing with the Nevada Supreme Court this year, save, perhaps the new instances where DDA
Young's assertions of dispatch alerting RPD Officers of "a possible fight" prior to their arriving to respond on 8/20/11 (and the utility thereof incident to the Hearing
on Coughlin's Motion to Suppress) has been thoroughly disproved by City Attorney Skau's only finally releasing those tapes on 11/13/12, after he secured
Coughlin's attendane at a Hearing on his Motion to Quash Subpoenas by alleging the court had granted him the power to effect service thereof by emailing
Coughlin (and Coughlin SBN form Disciplinary Hearing was held the next day 11/14/12, where J udge Linda Gardner's bailiff was assigned to the affair, the same
bailiff present at the April 12th, and 17th, 2009 Trial dates in the J oshi matter that became 60302 and 54844. J udge Gardner's brother also refused to recuse
himself from the criminal trespass prosecution of Coughlin incident to an arrest at his former home law office. Coughlin has detailed the prosecutorial misconduct
of City Attorney's Roberts (in 60838) and Hazlett-Stevens (in 61901) in addition to that of DDA Zach Young (three different prosecutions, each one more
retaliatory than the last) and the multitude of violations of the stay required by NRS 178.405 (in consideration of NRS 5.071, especially).

Sincerely,

Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Mon 11/26/12 2:04 PM
To: skent@skentlaw.com (skent@skentlaw.com); je@eloreno.com (je@eloreno.com); patrickk@nvbar.org (patrickk@nvbar.org); eifert.nta@att.net (eifert.nta@att.net); cvellis@bhfs.com
(cvellis@bhfs.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); davidc@nvbar.org (davidc@nvbar.org); info@bhfs.com (info@bhfs.com); rosec@nvbar.org (rosec@nvbar.org);
mike@tahoelawyer.com (mike@tahoelawyer.com); info@tahoelawyer.com (info@tahoelawyer.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org)
1 attachment
11 26 12 0204 Notice of Hill and Baker Malfeasance for Motion for New Disciplinary Hearing or Trial 063341 1708 60331 61383 reduced size.pdf (17.8 MB)
FW: Disposal of Personal Property at River Rock
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Tue 11/27/12 5:03 AM
To: stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); complaints@nvbar.org (complaints@nvbar.org); patrickk@nvbar.org
(patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net)
23 attachments
LT Coughlin (disp of pers ppty - with encl)(12-2-11).pdf (86.4 KB) , Casey Baker email of 12 14 11 reporting burglary and stolen items to zachcoughlin@hotmail.com from
cdbaker@richardhillaw.com.pdf (47.4 KB) , 12 26 11 Notice of Appeal RJC rev2011-001708 needs stamped 03628 3 30 12 flanagan order.pdf (375.0 KB) , 12 21 11 Order Resolving Motion
to Contest Property Lien 0204 1708.pdf (2.4 MB) , 12 17 11 Stancil sand Jonas statements Contest Lien Hearing setting 11 22 11 from a month prior 1708 063341 0204.pdf (1407.5 KB) , 12
16 11 fax to rjc regarding Lien on items Baker's negligence resulted in being stolen already rev20110-001708.pdf (257.3 KB) , 10 31 11 receipt 1708 lockout wcso 26405 03628 60331 within
24 hours hill tried to get at 5 01pm versus baker oct 28th testimony from Memo of Costs - EX 1 (4-3-12).pdf (19.7 KB) , 11 1 11 lockout wcos coverup 4 3 12 Pages from Memo of Costs -
EX 1 (4-3-12)-4.pdf (27.6 KB) , 11 1 11 locksmith receipt wcso lockout from Memo of Costs - EX 1 (4-3-12)-2 compare 6 18 testimony when the locksmith finally got there.pdf (79.3 KB) ,
11 1 11 rjc page on lockouts within 24 hours.htm (34.5 KB) , 11 2 11 Complaint for illegal lockout rjc failed to give hearing 0204 1708 24 hours wcso 063341.pdf (527.5 KB) , 142 rjc lockout
order with fax headers rev2012-001048 ncs.jpg (734.4 KB) , LT Coughlin (disp of pers ppty - with encl)(12-2-11) (3).pdf (432.4 KB) , 1 14 12 bf additional discovery 12 cr 00696 jaywalking
arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-000018 0204 Leed.pdf (685.4 KB) , 2 14 12 OCR and bold reduced size letter from SBN patrickk@nvbar.org King containing 1
14 12 grievance by Richard G. Hill Esq cropped out page numbers.pdf (411.4 KB) , 4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf (905.5 KB) ,
11 26 12 5 big recent emails 60302 60317 Garin WLS Gardner 0204 60331 61383 063341 etc.pdf (645.8 KB) , 10 25 11 Affidavit in Support of and Motion for Summary Judgment Denying
Summary Eviction Trial Statement MTN for Sanctions 1708 0204 063341.pdf (1703.8 KB) , 1 11 11 0204 CR12-1262-3059269 baker on wcso receipt transcript from criminal trespass trial
testimony of richard hill and his associate before RMC Judge William Gardner reduced size.pdf (1537.9 KB) , 2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED
RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf (473.9 KB) , 2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal
harley.pdf (463.3 KB) , 3 19 12 fas to rmc marshals regarding property wcso - Copy.pdf (40.0 KB) , 6 26 12 email to various rjc wcso rpd on soldal.pdf (28.3 KB)
Dear RJC Court Administrator Tuttle and the RJC, et al,
I appreciate an opportunity to revisit some past scheduling issues.
The thing that really stands out that Hill alleges he can control the RJC, indicating it won't give Coughlin a hearing until 12/20/11, depsite Coughlin having
appeared for the 11/22/11 9:30 am hearing (Bailiff Plamondon and the RJC, Chief Clerk Stancil, etc. did not need Coughlin's permission, nor was
"courthouse sanctuary" doctrined follow on 11/3/11 to whip up a Notice of Hearing an Proof of Service thereof and have Bailiff Plamondon sign it for the
11/7/11 Hearing in rev2011-001708...So, how could it be the RJC/Hill need Coughlin's permission to set a 11/22/11 Hearing? Coughlin showed up, Hill
didn't. Then Hill asserts an ability to make the RJC put it on hold until 12/20/11...which, given Baker's letter of 12/2/11, seems to be patently strategic and
coercive (ie, your last day for Coughlin to get his property, according to Baker's 12/2/11 letter, conveniently, is the day before the 12/20/11 date the RJC
finally was "able" to set a Hearing on incident to Coughlin's 11/17/11 filing of a Motion to Contest Personal Property Lien (but wait, on 12/20/11, Ms.
Stancil and Ms. Jonas are called to testify by Judge Sferazza at the Contest Personal Property Lien Hearing as to what they then remember about 11/16 and
11/17? Funny, nothing on the docket or case summary about 11/17...also, the ROA reveals an 11/23 filing by Coughlin of a Notice of Hearing that the
RJC did not have filled...Kind of gives the RMC a run for its money where the RMC continued the trespass Trial where Hill signed the complaint, because
Hill needed a six week vacation, only for the RMC to deny Coughlin a single continuance, then get Coughlin's law license suspended in 60838 where Hill
was applying an unlawful rent distraint on exculpatory materials baring on Coughlin's innocence.
Casey Baker's attached letter of December 2, 2011, reads:
"Zachary Coughlin c/o Silver Dollar Motor Lodge 817 North Virginia Street, Ste. 2 Reno, Nevada 89501
Re: Disposal of personal property left at 121 River Rock, Reno, Nevada
Dear Mr. Coughlin:
This letter is sent to you for all purposes contemplated by NRS n8A.460. A copy of that statute is enclosed for your reference.
More than 30 days have now elapsed since you were evicted from the real property at 121 River Rock, Reno, Nevada. You have failed to redeem your
personal property left on the premises by paying the reasonable costs of inventory, moving and storage, as provided in the referenced statute, despite the Dr.
Merliss' offers to allow you to do so. You have failed to bring the matter on for a hearing as provided in that statute, despite your opportunity to do
so.
Because you refused to communicate or cooperate the court, the time for a hearing pursuant to NRS 118A.460(2) has now expired, and your
Motion to Contest Personal Property Lien, filed on November 16,2011, is stale. As such, Dr. Merliss is not under any obligation to allow you to redeem
your personal property, on any conditions. ORIGINAL BY U.S. MAIL COpy BY EMAIL
Letter to Zachary Coughlin Re: Re: Disposal of personal property left at 121 River Rock, Reno, Nevada December 2, 2011 Page 20f 3
Nevertheless, Dr. Merliss is still willing to work with you so that you can redeem your property. The terms and conditions for you to enter the River Rock
property and remove your belongings are the same as those terms contained in Mr. Hill's email to you dated November 25, 2011, a copy of which is
enclosed herewith, with the following changes:
1.
The final day on which you will be allowed to enter onto the River Rock property pursuant to this offer is Monday, December 19, 2011. Subject to your full
compliance with all terms of the offer, as modified herein, your right to enter the property will begin at 9:00 a.m. on the day of your choosing, and expire at
4:45 p.m. that same day. Your access will be restricted to weekdays, only (Le. Monday through Friday, no weekends). This is to accommodate the advance
notice required of you, as set forth below.
2.
Because you have demonstrated your inability to proceed truthfully and in good faith, the payment contemplated in paragraph 1 of Mr. Hill's email must be
delivered to our office by no later than 24 hours in advance of the date you wish to begin to move your belongings. That payment must include payment for
the day on which you propose to move your things. The daily rate set forth in Mr. Hill's email still applies. In addition, your payment must include the $1,
060 already incurred to secure the property after your repeated break-ins, plus any other sums that may be incurred in that regard in the interim. When you
let me know when you wish to remove your property, I will provide you with a total.
3.
You must also provide, also at least 24 hours in advance, proof that you have adequate manpower and vehicular means to move your goods. That means a
verifiable reservation or receipt for a Uhaul or similar vehicle. Given the sheer volume of your belongings, a pickup truck will not be considered adequate.
4.
All other terms of Mr. Hill's email, enclosed herewith, remain the same. That includes the signatures of you and your agents, as described in that email.
Those signatures must also be delivered at the same time as your payment and proof of vehicle arrangements.
If you have not made appropriate arrangements with our office, and removed your things by Monday, December 19, 2011, Dr. Merliss win dispose of all
personal property left on the premises sometime after that date. We anticipate that those items with sufficient value to justify processing will be sold at a
"yard sale" type proceeding. Those items without sufficient value will simply be discarded. Dr. Merliss will likely credit bid on some items.
any
Letter to Zachary Coughlin Re: Re: Disposal of personal property left at 12 1 River Rock, Reno, Nevada December 2,
20 11 Page 2 of3
In the meantime, you do not have permission to go on the River Rock property, for reason.
It is up to you how you wish to proceed. May we please hear from you?
Sincerely,
Casey Baker, Esq.
Encl. -NRS 118A.460 -Email dated November 25, 20 11
Cc: Dr. Merliss" ou have failed to bring the matter on for a hearing as provided in that statute, despite your opportunity to do so.
Because you refused to communicate or cooperate the court, the time for a hearing pursuant to NRS 118A.460(2) has now expired, and your
Motion to Contest Personal Property Lien, filed on November 16,2011, is stale.
Such a good point by Casey Baker about stale Orders, like those stale lockout orders of 10/25/11 and 10/27/11 given NRS 40.253's "within 24 hours of
receipt" requirement...by the way, when can I expect a response from the RJC about the fax logs and order confirmation of delivery,transmission,receipt
respecting the lockout orders being faxed to the WCSO in rev2011-001708? Because, as you can see in the attached transcript of his sworn testimony on
6/18/12...Baker indicates the he and Hill's office relied on the RJC to transmit the Lockout Order to the WCSO's Office....and the attach eviction order
example from that lovely Northwinds fiasco arrest of Coughlin, no in the RJC RCR2012-067980 (despite the 6/26/11 "heads up" email from Coughlin to the
RJC (somehow RJC REV2012-001048 still saw Judge Schroeder sign the eviction Order (though the 6/28/12 fax from the Sparks Justice Court in the RJC
file is interesting, as is Gayle Kern's proof of service in RJC rev2012-000374 and the fact that Judge Schroeder's Orders in that matter never seem to get sent
to Coughlin by anyone but Kern, and, as she did with the 5/15/2012 Order, she sends them to address she knows are old for Coughlin....

I feel (though I doubt its true) that Hill is presenting as though he has an ability to improprly influence a tribunal (wherein there Hill purports to be the final
arbiter of how long it will take Coughlin to get a Contest Personal Property Lien incident to Coguhlin 11/17/11 filing in rev2011-001708.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: stuttle@washoecounty.us; kstancil@washoecounty.us; cdbaker@richardhillaw.com
Subject: FW: Disposal of Personal Property at River Rock
Date: Sun, 4 Dec 2011 01:40:15 -0800
I know what was said during the telephone conversation, believe me, I know verbatim what was said...there was a condition placed on getting my hearing for
a motion to return personal property. I showed up to the first hearing, saw Mr. Sexton there...Hill didn't, I want my recent emailed pdf motion to vacate to
be filed in as an opposition to Hill's Motion to show cause, Now I get this idiotic letter from Baker. The whole order should be vacate due to it being a
commercial lease and a no cause eviction notice (those are not allowed, ie no summary eviction for no cause in commercial leases, period, see NRS 40.253
adn the nv supreme court landlord tenant handbook..I want my hearing whenver wherever, why hasn't it been sheduled or set?
tZach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 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 for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of
this information is strictly prohibited. This message is 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.
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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.
From: cdbaker@richardhillaw.com
To: zachcoughlin@hotmail.com
Subject: Disposal of Personal Property at River Rock
Date: Fri, 2 Dec 2011 15:42:39 -0800
Mr. Coughlin:

Attached please find a copy of my letter to you that was mailed today.

Sincerely,

Casey D. Baker, Esq.
Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: cdbaker@richardhillaw.com

CONFIDENTIAL: ATTORNEY WORK PRODUCT; ATTORNEY-CLIENT PRIVILEGE
This e-mail may contain legally privileged or confidential information. If you are not the intended recipient, please do not read, copy, use, or disclose this communication to anyone other than the intended recipient. If you have received this message in error, please notify the sender and delete the email message from
your system. Thank you.
Circular 230 Notice.
To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii)
promoting, marketing or recommending to another party any transaction or matter addressed herein.

RE: getting my property
From: Richard Hill (rhill@richardhillaw.com) You moved this message to its current location.
Sent: Mon 11/21/11 2:07 PM
Cc: cdbaker@richardhillaw.com
the court is trying to get ahold of you to hear your motion on the landlord's lien tomorrow.

if you don't contact them, you won't get a hearing & your stuff will just stay where it is until late december, because our schedule is blocked until then.

please contact the court
325-6501

rgh
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, November 21, 2011 1:03 PM
To: rhill@richardhillaw.com; cdbaker@richardhillaw.com
Subject: getting my property
Dear Mr. Hill and Mr. Baker,
I am writing to check in with you and see if you will allow me to get anything from the 121 River Rock property today. I cannot stress enough how much you are damaging my business, and my client's affairs
minute by minute. Your "suggestions" that I address the back porch first show a completely callous disregard for my clients rights. Further, I believe you are committing a crime by withholding my wallet and
state issued identification. Let's just resolve this. I believe the wallet is in the basement, perhaps on the hanging table by the mattress. The phone is likely nearby that. There are a couple of phones.
Further, I need all three scanner/printer type devices, both laptops, various power cords, the desktop, all my monitors (both upstairs and in the basement), I also need to get my families mementoes and
heirlooms and anything connected to my law practice, right away. It is not that I am abandoning anything else, its that I have exigent client needs that must be addressed. You try running your life without
your ID card and bank card, it is not easy. I checked the phone number I gave you, and received no messages from either of you, nor did I receive any emails. I feel it would be more prudent for me to go to the
property and avoid you or your agents handling any of my fragile property or confidential client files. If you want someone to supervise, that is fine, but I dont' have a photographic memory and cannot just write
to you with exact information related to everythign I need to get on an exigent basis and include exact location information. I don't see my stuff as "junk" as you have characterized it, however, I believe NRS
40.460 addresses how you may protect your clients interests, and it speaks to what you may do after 30 days have passes, not all the busybody, nosy, hall monitor "conditions" and "hoops" you would love to make
me jump through pursuant to your fantastical interpretation of the statute, assuming you ever even read it, which, considering Mr. Baker's asking the court for some $20K in attorneys fees in a summary eviction
proceeding where no allegations of controlled substances manufacture where ever made, despite Baker's citing to NRS 40.253(3), and where NRS 69.030 only allows for prevailing party fees in "civil actions", which,
under JCRCP 3 are distinct from eviction matters., is not that likely.

SincereZach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 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 for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is 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 recipient(s), 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 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.
River rock
Sent: Mon 11/21/11 4:28 PM
Cc: 'Casey Baker' (cdbaker@richardhillaw.com)
Mr coughl i n - t he cour t advi ses t he hear i ng i s of f - because of your l ack of
cooper at i on.
See you i n december , I ' m busy
Rgh
CONFI DENTI AL: ATTORNEY WORK PRODUCT; ATTORNEY- CLI ENT PRI VI LEGE
Thi s e- mai l may cont ai n l egal l y pr i vi l eged or conf i dent i al i nf or mat i on. I f
you ar e not t he i nt ended r eci pi ent , pl ease do not r ead, copy, use, or
di scl ose t hi s communi cat i on t o anyone ot her t han t he i nt ended r eci pi ent . I f
you have r ecei ved t hi s message i n er r or , pl ease not i f y t he sender and del et e
t he emai l message f r om your syst em. Thank you.
Ci r cul ar 230 Not i ce.
To ensur e compl i ance wi t h r equi r ement s i mposed by t he I RS, we i nf or m you
t hat any U. S. f eder al t ax advi ce cont ai ned i n t hi s communi cat i on ( i ncl udi ng
any at t achment s) i s not i nt ended or wr i t t en t o be used, and cannot be used,
f or t he pur pose of ( i ) avoi di ng penal t i es under t he I nt er nal Revenue Code or
( i i ) pr omot i ng, mar ket i ng or r ecommendi ng t o anot her par t y any t r ansact i on
or mat t er addr essed her ei n.
RE: getting my property
Sent: Mon 11/21/11 2:07 PM
Cc: cdbaker@richardhillaw.com
the court is trying to get ahold of you to hear your motion on the landlord's lien tomorrow.

if you don't contact them, you won't get a hearing & your stuff will just stay where it is until late december, because our schedule is blocked until then.

please contact the court
325-6501

rgh
Sent: Monday, November 21, 2011 1:03 PM
To: rhill@richardhillaw.com; cdbaker@richardhillaw.com
Subject: getting my property
Dear Mr. Hill and Mr. Baker,
I am writing to check in with you and see if you will allow me to get anything from the 121 River Rock property today. I cannot stress enough how much you are damaging my business, and my client's affairs
minute by minute. Your "suggestions" that I address the back porch first show a completely callous disregard for my clients rights. Further, I believe you are committing a crime by withholding my wallet and
state issued identification. Let's just resolve this. I believe the wallet is in the basement, perhaps on the hanging table by the mattress. The phone is likely nearby that. There are a couple of phones.
Further, I need all three scanner/printer type devices, both laptops, various power cords, the desktop, all my monitors (both upstairs and in the basement), I also need to get my families mementoes and
heirlooms and anything connected to my law practice, right away. It is not that I am abandoning anything else, its that I have exigent client needs that must be addressed. You try running your life without
your ID card and bank card, it is not easy. I checked the phone number I gave you, and received no messages from either of you, nor did I receive any emails. I feel it would be more prudent for me to go to the
property and avoid you or your agents handling any of my fragile property or confidential client files. If you want someone to supervise, that is fine, but I dont' have a photographic memory and cannot just write
to you with exact information related to everythign I need to get on an exigent basis and include exact location information. I don't see my stuff as "junk" as you have characterized it, however, I believe NRS
40.460 addresses how you may protect your clients interests, and it speaks to what you may do after 30 days have passes, not all the busybody, nosy, hall monitor "conditions" and "hoops" you would love to make
me jump through pursuant to your fantastical interpretation of the statute, assuming you ever even read it, which, considering Mr. Baker's asking the court for some $20K in attorneys fees in a summary eviction
proceeding where no allegations of controlled substances manufacture where ever made, despite Baker's citing to NRS 40.253(3), and where NRS 69.030 only allows for prevailing party fees in "civil actions", which,
under JCRCP 3 are distinct from eviction matters., is not that likely.

SincereZach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 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 for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is 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 recipient(s), 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 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.
River rock
Sent: Mon 11/21/11 4:28 PM
Cc: 'Casey Baker' (cdbaker@richardhillaw.com)
Mr coughl i n - t he cour t advi ses t he hear i ng i s of f - because of your l ack of
cooper at i on.
See you i n december , I ' m busy
Rgh
CONFI DENTI AL: ATTORNEY WORK PRODUCT; ATTORNEY- CLI ENT PRI VI LEGE
Thi s e- mai l may cont ai n l egal l y pr i vi l eged or conf i dent i al i nf or mat i on. I f
you ar e not t he i nt ended r eci pi ent , pl ease do not r ead, copy, use, or
di scl ose t hi s communi cat i on t o anyone ot her t han t he i nt ended r eci pi ent . I f
you have r ecei ved t hi s message i n er r or , pl ease not i f y t he sender and del et e
t he emai l message f r om your syst em. Thank you.
Ci r cul ar 230 Not i ce.
To ensur e compl i ance wi t h r equi r ement s i mposed by t he I RS, we i nf or m you
t hat any U. S. f eder al t ax advi ce cont ai ned i n t hi s communi cat i on ( i ncl udi ng
any at t achment s) i s not i nt ended or wr i t t en t o be used, and cannot be used,
f or t he pur pose of ( i ) avoi di ng penal t i es under t he I nt er nal Revenue Code or
( i i ) pr omot i ng, mar ket i ng or r ecommendi ng t o anot her par t y any t r ansact i on
or mat t er addr essed her ei n.
--Forwarded Message Attachment--
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County Home => Reno Justice Court => Divisions => Civil Division => Evictions => Nuisance, Waste, and Unlawful Business => Tenant - How to Answer
Tenants - How to Answer
After you have been served with the 3 day notice for nuisance, waste and unlawful business - you cannot file an affidavit of tenant to contest the notice because the 3 day notice for nuisance, waste and
unlawful business was NOT issued by the Court.
If you are still at the residence after 3 days, the landlord may then serve you with an unlawful detainer notice. You have the option at that time to either file an affidavit of tenant OR appear on the court
date and contest the matter at that time.
in compliance with Judge Sferrazza Order of 9/5/12 FW: Zach Coughlin has shared a folder with you
The filing fee for the affidavit of tenant is $33.00.
Preparation for Hearing
When you appear for the hearing, check in with the clerk and you will be directed to the courtroom in which the eviction matters are being heard. You will need to be prepared to defend the allegations
made in the notice at this hearing so bring any appropriate documentation.
Disposition of the Hearing
* A lockout order is required to be served immediately but in no case later than 24 HOURS after the Sheriff receives it.
* If the judge grants the lockout order, you will be locked out of the unit upon service of the order.
* If the judge gives you time to pay or move and you don't comply, you will be locked out upon service of the order.
THIS MEANS THAT YOU MAY BE LOCKED OUT ON THE SAME DAY THAT THE LOCKOUT ORDER IS GRANTED.
Sent: Tue 11/27/12 8:26 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
re:rcr2011-063341
Dear Judge Sferrazza and DDA Young,
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance of counsel claim and or the coerced waiver of my
Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent faxing of
numerous filings to the wrong fax number by myself.
https://skydrive.live.com/redir?resid=43084638F32F5F28!5141&authkey=!APibWiVXTMSWkw0
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
in compliance with
Judge Sferrazza
View photos Download all
You are invited to view Zach's album. This album has 43 files.
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf
4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
11 21 12 Notice of Irregularities 063341 with ex 1 started revised.pdf
11 30 11 063341 Coughlin_Discovery Received_11.30.11 rotated.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdf
11 13 12 063341 submission of materials and motion for order dmv and cell records or subpoena.pdf
11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text of motion no exhibits.pdf
2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed pdffactpro more nuance.pdf
final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341 - Copy.pdf
pre trial brief state of nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd and tagged jbig2 lossy.pdf
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf
pre trial brief state of nevada v coughlin rcr2011-063341.pdf
rcr11-063341 notice of appearance coughin file 3 3 2012.pdf
rcr11-063341 affidavit in support of motion to file pre-trail motions late bw - Copy.pdf
11 27 12 complete with ex 1 063341 notice of developments.pdf
11 26 12 0204 Notice of Hill and Baker Malfeasance for Motion for New Disciplinary Hearing or Trial 063341 1708 60331 61383.pdf
6 25 12 Order for Sanctiosn 03628 0204 Flanagan $40K in attorneys fees summary eviction appeal.pdf
Order of 9/5/12

10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order to Baker 1708 0204.pdf
From: stuttle@washoecounty.us
CC: CWood@washoecounty.us; RBaker@washoecounty.us
Subject: RE: Zach Coughlin has shared a folder with you
Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:

Reno Justice Court has no record of your attempted filing on 10/18/12. If you choose to pursue this filing action, you will need to bring the documents in because we do not accept filings via email. Any documents
filed with the court will be retained by the court and we will not make copies for you, the DA or PD. Providing the appropriate parties copies of your filing is your responsibility, not the court. You may also bring in
your confirmation of transmission from the 10/18/12 filing attempt and we will retain that receipt as part of the court record. Steve

Steve Tuttle

Court Administrator
Reno Justice Court

Sent: Saturday, November 03, 2012 9:39 PM
To: Tuttle, Steve
Subject: Zach Coughlin has shared a folder with you

Dear Mr. Tuttle,
I perused the file in RCR2011-063341 and noticed that the document I submitted for filing on or about 10 18 12 was not file stamped or even in the file, though I have confirmation of receipt of transmission. Can you please
indicate why it is not appearing in the file and find attached another copy of the exhibit 1 thereto.
https://skydrive.live.com/redir?resid=43084638F32F5F28!3600
102611coughlin2 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy Spencer.wmv
101211coughlin CRC 11-063341 Competency Evaluation Hearing that got continued.wmv
090512coughlin2 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
071612coughlin rcr2011-063341 rjc .wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony - Copy.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin1 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde - Copy.wmv
090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
Please get this to these City of Reno employees

Share your files with

Sent: Wed 11/28/12 12:35 AM
To: renodirect@reno.gov (renodirect@reno.gov)
somet i mes t hey don' t cl ean out t hei r i nbox, but I seem t o not have my emai l set up t o r ecei ve bounceback messages per f ect l y al l t he t i me, so i n an abundance of
caut i on, I ask t hat Reno Di r ect hel p make sur e t hese good f ol ks get t he message bel ow:
kbeechl er @r eno. gov
odomk@r eno. gov
bonyr @r eno. gov
chr i st ensend@r eno. gov

Subject: RE: RCR12-065630
Date: Thu, 8 Nov 2012 05:02:29 -0800
Dear Mr. Dogan,
I understand it is my inviolable right as a criminal defendant to subpoena witnesses. Please subpoena RPD Sargent Zach Thew and inteview him
regarding any claim of right defense Coughlin may have respecting any alleged issuance by Thew to Coughlin of an invitation to Call him at a certain RPD
number and or 911 in connection with various discussion Thew and Couglin had prior to the 1/14/12 arrest. Please also (in conjunction with the
investigator on this case, and I have yet to be informed of whom that is...and Mr. Novak, I appreciate the work and notations you made to the file that I have
only just been made privy to by Mr. Leslie...I submit you are done a disservice where there is not more transparency given to the results of your work to
your criminal indigent defendants, as the circumstances dictate they assume the worst when supporting documentation to cursory contentions is not show.

So, whom is the investigator here, and will you please provide me the documentation detailing the results of the investgiation undertaken? If no, please
indicate so in writing and detail the basis for such a refusal.
Mr. Dogan and or Mr. Leslie, please also subpoena Sargent Paul Sifre and Officer Schaur. Please propound to DDA Young the videos I am attaching
once again, on of the moments just prior to arrest with Sifre, where Sargent Sifre violates fundamental tenants of domestic violence victim advocacy
wherein he engages in "blame the victim" behavior (Coughlin was adjudge a victim of domestic violence on or about 1/23/12 by Master Edmonson, in two
separate cases FV12-00188 and 187..
Further, view the "Sargent Lopez I have a question for you video and attached Motion for New Trial filing in the criminal trespass conviction matter (see
also, 61901 on the N. S. Ct. site) 11 cr 26405, wherein, on 1/13/12, one day prior to the arrest in the case you are attorney of record on rcr2012-065630, on
1/14/12) RPD Sargent Marcia Lopes is caught on taping admitting to fraud on her part, that of Officer Chris Carter, Jr., landlord Merliss, and opposing
counsel Hill incident to the criminal trespass arrest. Please develop a defense and investigation based upon witness bias an motive, seeking to draw a
connection between the actions a day later by Sifre, Schaur, et al, vis a vis the interaction with Sargent Lopez here. Please also interview and subpoena
Officer Travis Warren, whom Coughlin has recently learned approached and met with his parents at Coughlin's father's medical practice (and Coughlin's
father is both John Kadlic, Reno City Attorney, and perhaps Robert Bony, Esq., Deputy City Attorney's patients) and purportedly sought to "have Coughlin
committed" or somethign along those lines. Please develop a defense and collect and provide investigation relative to the idea that doing so by the RPD
and or Reno City Attorney is violative of Palmer v. Pioneer, and has prejudiced Coughlin's case (what if your family deserted you Biray, in part, due to
fraudulent misrepresentations by local law enforcement with an agenda that includes covering up a number of wrongful arrests potentially exposing them to
both criminal and civil penalties? What would you think of a public defender and his assistant who had not done jack to advocate on your behalf? Who
had not sent out a single subpoena? Why haven't you collected the dispatch tapes, not just the 911 calls. The communications between dispatch and the
RPD are likely way more revelatory than the calls themselves. You are aware, are you not, that RPD Officer Duralde an 5 other officers pulled Coughlin
over shortly after midnight on 1/13/12, just after Coughlin had bailed out on the jaywalking arrest, right? You are aware Coughlin filed a written
complaint against Duralde (arresting Officer in the case Goodnight, then Leslie was one in rcr2011-063341, right) on 9/7/12 and 1/8/12, right? You were
aware of that, right Biray? Right, Leslie? So, please subpoena the dispatch communications between the RPD and Ecomm, not just the logs, which is
what Ecomm tried to pass off as responsive recently. The audio tapes...Kariann Beechler. She fees it appropriate to act as a filter to complaints of
police misconduct, even though engendering legitimate and perceived fear of substantial immediate harm at the hands of local law enforcement. Further,
please subpoena Deputy Medina and Sargent Bradshaw. Also, review the results of a subpoena duces tecum to the RPD regarding anything related to
Coughlin, especially the 11/15/11 incident with Sargent Tarter...
Can you indicate whether the "misuse of 911" statue appears in any published decisions? Why did you indicate, on the record, in court on 11/6/12 that
you are "unaware of any basis for an opposition" the DDA Young's Motion to Amend? Are you indicating you have failed to receive the voluminous
correspondence and media submission from Coughlin wherein the prejudice to Coughlin and his defense was detailed, especially vis a vis the denial of a
speedy trial (60 days), the spoliation of evidence angle, and the prosecutorial misconduct line of argument (DDA Young attempted to hold a trial on 5/7/12
in violation of the mandatory stay in NRS 178.405 in view of the then still pending Order for Competency Evaluation you, Dogan, procurred at a Status
Conference with Young on 2/27/12, wherein Judge Schroeder is listed as the Hearing Judge. Neither of you have ever denied that in any way. Then
Young violated NRs 178.405 again by filing, at 2:55pm on that day, a document in the associate case rcr2011-063341, despite the file stamping of 1:31 pm
2/27/12 on Judge Clifton's Order For Competency Evaluation. Neither you, Dogan, nor Young have ever denied the veracity of that statement, despite it
being assert directly to you on numerous occasions.
As to the amended charge, please see the attached Beckett treatment of it (former Nye County DA, SCR 111(10), etc.
Further, please subpoena and interview Officer Alan Weaver, Sargent Brian Dye, and Sargent Oliver Miller to develop more clearly a basis for moving for
a mistrial for prosecutorial and or law enforcement misconduct here (by only against DDA Young should you obtain some reasonable sufficient basis for
viewing his complicity in this mesdeeds, or assent to them in and way,.
Zach Coughlin
1471 E. 9th St.
"The Fall Guy" played by Steve Tuttle
Reno, NV 89512
Tel and Fax: 949 667 7402
rpd sargent lopez i have a question for you 11 cr 26405 00696 26800.wmv
10 31 12 marked as received by Clerk of Court Orduna and proof of service by Rick Reasoner 0204.pdf
2 27 12 065630 Young and Dogan Clandestine Status Conference leads to SBN SCR 105 Complaint against Coughlin 0434 Nash.pdf
2 27 12 Judge Schroeder status conference clifton order rcr2012-065630 26800.pdf
2 28 and 3 12 and 3 12 and 3 14 nash orders and grievances 26800 0204 0434.pdf
5 4 12 mch goondnight email trespas rmc 26405 loomis young 063341 065630.htm
5 4 12 email goodnight mhc hazlett young trespass loomis.htm
rmc longoni handout demanding payment on transcripts on appeals in violation of nevada law 26405 cr11-2064 cr12-1262 26406 11 tr26800 ocr.pdf
12 21 11 email to rmc regarding no response from Longoni.pdf
10 5 12 stamped 60838 SCR 111 King SBN Susich Motion Show Cause against NNDB and SBN 12-31434.pdf
2 28 12 Contempt Order Nash 26800 26405 065630 00696 063341 bf size reduced.pdf
SAM_0204 RPD SIFRE MISUSE OF 911 ARREST 1 14 12 JACKSON MISSING DOG_00009.mp4
Download all
From: BDogan@washoecounty.us
Subject: RCR12-065630
Date: Fri, 28 Sep 2012 17:33:45 +0000
Your case with me has been continued to October 30th, at 10:00 A.M.

Biray Dogan, Deputy PD
(775) 337-4868
Fax: (775) 337-4856

Sent: Thu 11/29/12 2:05 PM
To: stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us)
Remember that TV show. I loved that one.
Cheers,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 29 12 fax to RJC Steve Tuttle 063441 LITIGATION HOLD NOTICE.pdf
Zach Coughlin (law license in Nevada temporarily suspended)
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949.667.7402
October 26th, 2012,
TO:
Reno Justice Court
Criminal Division
P.O. Box 30083
Reno, Nevada 89520-3083
FAX: 775 325 6510
EMAIL: STUTTLE@WASHOECOUNTY.US
SENT via all three, fax email and usps mail first class
re:LITIGATION HOLD NOTICE requesting RJC immediately fax Coughlin and or email a digital version of everything filed or entered in the file of RCR2011-063341 AND PLACING RJC AND
WASHOE COUNTY EMPLOYED RJC BAILIFFS SUPERVISED BY STEVE TUTTLE ON A LITIGATION HOLD NOTICE RESPECTING ANYTHING CONNECTED TO COUGHLIN'S
SUBMISSION OF CD/DVDS AS EXHIBITS, INCLUDING, BUT NOT LIMITED TO THE INCIDENT WITH BAILIFF PLAMONDON ON NOVEMBER 15TH, 2012, UPON WHICH CD/DVDS
EXHIBITS LEFT IN THE CUSTODY OF RJC CHIEF CRIMINAL CLERK ROBBIN BAKER FOR FILING BY COUGHLIN HAVE NOW, ACCORDING TO JUDGE SFERRAZZA AND JUDGE
CLIFTON, TURNED UP MISSING, DESPITE THE ADMISSION BY ROBBIN BAKER TO COUGHLIN THAT SHE PERSONALLY EYEWITNESSES COUGHLIN SUBMITTING THEM TO HER
FOR FILING (BAKER ADMITTED THIS TO COUGHLIN ON TUESDAY, NOVEMBER 27TH, 2012...THEN SHORTLY THEREAFTER TRIED TO RECANT HER ADMISSION UPON A STERN
MESSAGE TO HER FROM CATHY WOOD (WHOM CLAIMED TO PERSONALLY KNOW COUGHLIN DID NOT SUBMIT SUCH CD/DVDS AS ATTACHED EXHIBITS FOR FILING
DESPITE ADMITTING SHE WAS NOT PRESENT WHEN COUGHLIN SO SUBMITTED THEM ON THE 15TH OF NOVEMBER. ROBBIN BAKER THEN GREW VERY LOUD AND
AGITATED, AND ON THE VERGE OF TEARS, WHILE CATHY WOOD GLARED AT HER MENACINGLY AND TOLD COUGHLIN IN A LOUD VOICE, WITNESSED BY "ALLISON" THAT
SHE WOULDNT' SPEAK WITH HIM ANYMORE AND TURNED HER HEAD AWAY IN SHAME AND DISGUST OVER HER ACTIONS. PLEASE RETAIN THE VIDEO OF MY
ATTEMPTING TO FILE DOCUMENTS UPON BEATING THE DOOR TIMERS TO GAIN ENTRY TO THE COURT PRIOR TO 5 PM ON NOVEMBER 28TH, 2012. ALSO, I BELIEVE IT WAS
THE SAME CLERK 'TAMI' WHOM REFUSED TO IDENTIFY HERSELF BY NAME AT THE CONCLUSION OF THE 11/20/12 TRIAL IN 063341 AND THEN PROCEEDED TO ATTEMPT TO
MANUFACTURE SOME "THAT'S IT, I'M DONE" NONSENSE UPON BEING ASKED A SIMPLE QUESTION THAT SAID "OOOOH, BURN!" WHEN I ATTEMPTED TO ACCESS THE RJC
RECENTLY ON AN OCCASION WHEN THE DOOR HAD JUST RECENTLY LOCKED. I AM NOT 100 PERCENT SURE IT WAS "TAMI" (SHE WAS THE CLERK FOR THE ENTIRE TRIAL
IN 063341, AND THE RJC BAILIFFS MADE SURE TO PUT BAILIFF REYES ON THE CASE DESPITE MY HAVING FILED A PROTECTION ORDER AGAINST HIM IN THE LAST YEAR).
IT IS WAS NOT "TAMI" WHO MADE THE "OOOOH, BURN!" COMMENT, I WELCOME BEING TOLD WHICH OF THE RJC EMPLOYEES HURRIEDLY EXITING THE BUILDING PRIOR
TO 5 PM (VERY INTERESTING WHAT A STUDY OF THE MINUTES PRIOR TO 5 PM DAILY OF THE DOORS, TIMERS, AND EMPLOYEE EXODUS AT THE COURTHOUSE REVEAL...)
SAID "OOOOH, BURN!". ALSO, I AM STILL WAITING ON YOUR RESPONSE RESPECTING WHAT CHRISTINE ERICKSON HAS TOLD YOU UPON YOUR INVESTIGATING MY
ALLEGATIONS THAT SHE REPEATEDLY TOLD ME FOR MONTHS, INCIDENT TO THE START OF MY WORK BEFORE THE RJC, THAT FAX FILING IS NOT ALLOWED, AS DID
ROBBIN BAKER. TO THE EXTENT JUDGE CLIFTON WISHES TO DISTANCE HIS 1983 MCGEORGE PEDIGREE FROM THE 1982 PEDIGREE OF DISTRICT ATTORNEY GAMMICK AND
THE RMC DEFENDER KEITH LOOMIS WHO QUIT ON TWO OF MY CASES, OR THE 1981 DEGREE OF RMC JUDGE HOWARD, WHOSE ORDER RESULTED IN MY CURRENT
SUSPENSION DESPITE THAT CASE BEING BASED UPON AN ARREST BY TRIBAL OFFICES BARRED UNDER NRS 171.1255, AND WHERE THE RMC, IN CONSPIRACY WITH PAM
LONGONI, COURT REPORTER, CONTINUES TO DISTRUBTE A FLYER REQUIRING INDIGENT CRIMINAL DEFENDANTS TO PAY UP FRONT THE COST OF TRANSCRIPTS, A DOWN
PAYMENT, AND REFUSES TO FORWARD THEM AT ALL UNTIL FULL PAYMENT, IN VIOLATION OF NRS 189.030 (NRS 4.14(A) IS FOR CIVIL CASES...WHICH BRINGS UP THE FACT
THAT THE RJC FALED TO ORDER THE PREPARATION FO COUGHLIN'S TRANSCRITP IN REV2011-001708 DESPITE HOLDING, IN VIOLATION OF NEVADA LAW, AS ADMITTED BY
JUDGE SFERRAZZA A RENT ESCROW DEPOSITI OF $2,275 WHERE JUDGE SFERRAZZA ADMITTED THAT WAS "CONVERSION" AND THAT THE RJC JUDGES HAD A MEETING
AND ADMITTED THEY VIOLATED NEVADA LAW UNDER JCRCP 83 IN ENFORCING A RENT ESCROW DEPOSIT REQUIREMENT WHERE NO LOCAL RULE HAD BEEN PUBLISHED
AND APPROVED BY THE NEVADA SUPREME COURT, AS SEEN IN JCRLV 44. ALSO, BAILIFF PLAMONDON VIOLATED COURTHOUSE SANCTUARY ON 11/3/11 PURPORTING
SERVE AN ORDER BY STEVE TUTTLE ON COUGHLIN WHILE COUGHLIN ATTEMPTING TO FILE DOCUMENTS IN THE FILING OFFICE...THEN RJC CLAIMS COUGHLIN REFUSED
TO "ALLOW" SETTING OF HEARING REQUIRED BY NRS 40.253(8) ON 11/17/12 (VIA UNSWORN "STATEMENTS" OF JONAS AND STANCIL" INCIDENT TO COUGHLIN'S 11/116/12
FILING A MOTION TO CONSTEST PERSONAL PROPERTY LIEN.. CAKE AND EAT IT TOO? GOES BOTH WAYS. NEVER NEEDED COUGHLIN'S PERMISSION TO SET A HEARING
BEFORE, DIDN'T EVEN NEED SERVICE, JUST A VOICEMAIL BY A CLERK WAS ALWAYS ENOUGH FOR THE RJC....COUGHLIN HAD TO WAIT 6 WEEKS TO GET A HEARING THE
LAW REQUIRES BE HELD IN TEN, AND COUGHLIN CHECKED IN WITH BAILIFF SEXTON FOR THE 11/22/11 HEARING THAT THE RJC AND HILL NOW CLAIM COULDNT' BE "SET"
BECAUSE COUGHLIN, ALLEGEDLY, REFUSED TO ALLOW IT TO BE SET...SHOW ME ANYTHING PROVING ANY REFUSAL ON MY PART. I SHOWED UP, THEY DIDN'T...COMPARE
THAT TO THE AUDIO OF THE REV2012-00374 EVICTION WHERE THE CLERK SUGGESTS TO JUDGE SCHROEDER TO TAKE THE CASES OUT OF HIS INTENDED ORDER TO
HURRY THROUGH A DEFAULT ON COUGHLIN, AND THE FACT THAT THE FAXED ORDER INDICATES A TIME OF 8:24 FOR A HEARING SET FOR 8:30 AM. MAYBE YOU ARE THE
FALL GUY HERE, MR. TUTTLE, BECAUSE THE BUCK STOPS SOMEWHERE, WOULDN'T YOU THINK. LOTS OF INTERPERSONAL GRUDGERY BEING PERMITTED UNDER YOUR
WATCH.
COUGHLIN APPEARED AT THE RJC FILING OFFICE ON NUMEROUS OCCASION SINCE THE 11/20/12 CONVICTION FOR TWO CHARGES THAT THE LAW FORBIDS A COURT FROM
CONVICTING ONE ON BASED UPON THE SAME SET OF FACTS (IE, ONE CANNOT BOTH COMMIT LARCENY OF A PHONE, THEN POSSESS OR RECEIVE SUCH ALLEGEDLY
STOLEN PROPERTY FROM HIMSELF...JUDGE SFERRAZZA AND DDA YOUNG PRETEND TO BE CONFUSED BY THAT...THEY ARE NOT).
THE RJC HAS DENIED COUGHLIN ACCESS TO THE FILE IN RCR2011-063342 REPEATEDLY SINCE THE CONVICTION OF 11/20/12 AND ACCESS TO THE FILE IS ESSENTIAL,
PARTICULAR DUE TO THE APPARENT FRAUD BY THE RJC AND OR ITS BAILIFFS RESPECTIVE THE CD/DVD EXHIBITS TURNIN' UP MISSIN', ROBBIN BAKER'S NEAR CRYIN',
CATHY WOOD'S GLARIN' AT HER, BAILIFF PLAMONDON GETTING UPSET ABOUT COULD POINTING OUT THAT WHEN HE WAS A WAITER PEOPLE WOULD SHOW UP AT ONE
MINUTE TO CLOSE AND ORDER DINNER AND DRINK 3 BOTTLES OF WINE....AND BAILIFF PLAMONDON EXITING THE RJC FILING OFFICE WITH THE FILINGS COUGHLIN LEFT
IN THE POSSESSION OF ROBIN BAKER FOR FILING AND ACCOSTING COUGHLIN MORE THAN HALWAY DOWN THE HALL TOWARDS THE RENO MUNICIPAL COURT SOME
FIVE MINUTES LATER. YOU HAVE BIG PROBLEMS IN THE LITTLE CITY, MR. TUTTLE.
PLEASE FAX AND EMAIL ME DIGITAL COPIES OF THE ENTIRE FILE, WITH EVERYTHING IT INCLUDES IMMEDIATELY. I WAS DENIED ACCESS TO THE FILING OFFICE
YESTERDAY, NOVEMBER 29TH, 2012 DESPITE MAKING INTO THE DOORS THAT WE DISCUSSED BEING ON A TIMER INCIDENT TO OUR CORRESPONDENCES OF FEBRUARY
2012. PLEASE REVIEW FOR YOUR EDIFICATION MATTERS RELATED TO THE RJC FAILING TO FILE MULTIPLE NOTICES OF APPEAL BY ZACH COUGHLIN, INCLUDING THE ONE
SUBMITTED ON 12/26/11 IN REV2011-001708, ON MARCH 16TH, 2012 IN REV2012-00374
JUDGES MAY HAVE IMMUNITY, BUT COURT ADMINISTRATORS AND FILING OFFICE CLERKS AND BAILIFFS DO NOT. NEITHER DO COURTS. TAKE A LOOK AT GLAZIER AND
LIPPIS V JUSTICE COURT.
IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND IN CASE
ANYTHING GOES MISSING AGAIN
PLEASE COPY THE CONTENTS OF ANY OF THE CD/DVD'S THAT DO "TURN UP" IMMEDIATELY TO A SKYDRIVE AND SEND ME THE LINK. FURTHER, THE RJC WILL BE
REQUIRED TO PAY AN ENORMOUS BILL FRO THE TRANSCRIPTS OF THE OVER 15 HOURS OF TRIAL IN RCR2011-063341 UPON MY FILING THE NOTICE OF APPEAL IN RCR2011-
063341, AND ARRANGEMENTS HAVE BEEN MADE TO ASSURE THAT IT WILL BE FILED, AND THAT I WILL BE ABLE TO PROVE IT WAS FILED, IN A TIMELY MANNER INCIDENT
TO NRS 189.030. FURTHER, BAILIFF REYES ADMITTED TO THREATENIN TO PUT "MY FOOT UP YOUR ASS" ON NOVEMBER 27TH, 2012 (REFERRING TO HIS CONDUCT IN
OCTOBER 2011, HE EXCUSED IT AS AN ACCEPTABLE "SUBTERFUGE" AND THEN PROCEEDED TO INDICATED THAT "ITS NOT A FOURTH AMENDMENT VIOLATION IF THE
PERSON IS GUILTY OF THE CRIME FOR WHICH THEY WERE SUSPECTED UPON SEARCHING THEM"...
Sincerely,
Zach Coughlin
Sent: Thu 11/29/12 4:57 PM
To: stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us (psferrazza@washoecounty.us);
rjcweb@washoecounty.us (rjcweb@washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 29 12 063341 MOTION FOR NEW TRIAL FINAL WITH 217 MENTION.pdf
EX1 063341 FINAL.pdf
data-2012-11-24-17-43-52 063341 11 19 12 lichty admits phone did not vibrate.wav
data-2012-11-24-17-44-12.wav
data-2012-11-24-18-40-33.wav
data-2012-11-24-18-40-47.wav
data-2012-11-24-18-43-05.wav
data-2012-11-24-18-45-14.wav
data-2012-11-24-18-49-41.wav
data-2012-11-24-18-49-41(1).wav
PLEASE DIGITALLY TRANSMIT MY ENTIRE FILE TO ME IMMEDIATELY
data-2012-11-24-18-53-39.wav
data-2012-11-24-18-53-39(1).wav
data-2012-11-24-19-00-18.wav
data-2012-11-24-19-00-18(1).wav
data-2012-11-24-19-21-24.wav
data-2012-11-24-19-21-24(1).wav
data-2012-11-24-19-26-17.wav
data-2012-11-24-19-31-25.wav
data-2012-11-24-19-37-26.wav
data-2012-11-24-19-40-46.wav
Download all

Sent: Fri 11/30/12 3:12 AM
To: jbosler@washoecounty.us (jbosler@washoecounty.us); bdogan@washoecounty.us (bdogan@washoecounty.us); complaints@nvbar.org (complaints@nvbar.org)
just an hour and a half before Dogan's retaliatory "clandestine status conference" with DDA Young on 2/27/12 wherein he obtained an Order for
Competency Evaluation from Judge Clifton. Please indicate whom Judge Nash Holmes is referring to from your office in her March 14th, 2012 letter to
the SBN. Please email me my entire file and or fax it to me immediately, I have the trial in less than 14 days.
Dear SBN, please file this as a formal grievance against Mr. Dogan including his utter failure to communicate with me as his client, beyond just generally
doing absolutely nothing to defend the case, appearing in court, lying about whether he served or had served his Motion to Quash of 11/7/12 on me in
rcr2011-063341, then smirking at me, and failing to display candor to the tribunal despite having any opportunity to afterwards, in addition to cackling from
the peanut gallery with Jim Leslie during my Trial.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: bdogan@washoecounty.us
Subject: RE: arraignment
courtesy copies in case any issues with the filing office
Date: Mon, 27 Feb 2012 12:04:46 -0800
Dear Mr. Dogan,
Was it abnormal for my case to be assigned to you on January 17th, 2012, prior to any arraignment? You and I discussed Chris Fortier calling and
writing me ahead of the February 14th, 2012 arraignment as well. Is there some reason you were docketed as attorney of record well in advance of the
arraignment, which, apparently, is contrary to the established practice in the RJC vis a vis WCPD's being assigned to cases?
It is my understanding, from your email late last Friday, that the status conference that was set for today at 1:30 pm has been cancelled, though it has yet to
be rescheduled.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: RE: arraignment
Date: Fri, 24 Feb 2012 16:29:04 -0800
From: BDogan@washoecounty.us
Your case has been continued. I will send the new court date by mail.
Sent: Wednesday, February 22, 2012 6:36 AM
To: Dogan, Biray
Subject: arraignment
'Sup Biray,
I went and got the arraignment done today....Judge Pearson informed me we have a mandatory 2/27 1:30 STATUS Conference RJC with in rcr12-065630
However, I already had a "Trial" set in bench trial 11 tr 26800 RMC (ticket number 544281) 1pm feb 27th Judge Holmes (talk to cashiers) right of way stop sign, can you get a continuanc brokered on the
status conference. Judge Pearson said you are my attorney of record in this matter, though you haven't been communicating with me much far as I can tell and you guys hung up on me last we spoke.
Hope to hear from you, amigo,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar No: 9473
Sent: Fri 11/30/12 11:32 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); stuttle@washoecounty.us (stuttle@washoecounty.us); rjcweb@washoecounty.us (rjcweb@washoecounty.us)
notice of appeal filed in rcr2011-063341 on 11/30/12 courtesy copies and safety transmission in case any filing office issues
911 calls missing from what was produced by City Attorney Skau
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 39 12 LAST THING.pdf
11 30 1 ex 1 063341 2 pages per sheetfinal.pdf
11 30 12 063341 ifp coughlin.pdf
ADDENDUM OR SUPPLEMENTAL OR AMENDED MOTION FOR NEW TRIAL AND MOTION FOR ARRET OF JUDGMENT AND NOTICE OF NONSERVICE OF DOGAN'S.pdf
Download all

Sent: Fri 11/30/12 11:33 AM
To: stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 30 12 063341 SIGNED NOTICE OF APPEAL.pdf
11 30 12 063341 ifp coughlin.pdf
Download all

Sent: Mon 12/03/12 2:53 AM
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr.
Leslie's representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received 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 instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
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 Leslie's failure to utilize any of the
work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of 11:27:11 pm
reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the
Dispatch recordings (and those provided 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 arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which required production of
those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main justification 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 recieved 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.
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 filming/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 the arrest recording
contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further, where Zarate does not allege
to have seen the phone light up to Duralde or in his Witness Statement, come Trial 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 all the way across the skate park...but wait...come November 19th, 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 somewhere out there that does a timeline of all
these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc. And
one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the pat-down
search of the Defendant was proper under the totality of the circumstances. Prior to arriving, Officer Duralde learned that the scene involved a loud
disturbance with possible fight, thereby immediately raising the concern of weapons and the safety of all those present." And, of course, Officer Duralde
responded splendidly to Coach Young's, er, DDA Young's training regime and sang the "possible fight...report from dispatch 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 did change his Suppression Motion Ruling at the
Trial somewhat...altering it to make less obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the Suppression
Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson admitting to hearing the "man with a six pack threaten to throw the
iPhone into the river" capture on video and audio recordings into the record...despite Duralde testifying to a multitude of double hearsay (and not even
capture on a recording so close in time to the arrest and at the very same location, involving the majority of the players in the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed on"
date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in
support of the objectives he has, which here, were motivate by a retaliatory intent and the "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 receive the 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 moments(file 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
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
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 the phone with him when he first 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 111(6) and 37 CFR 11.25(3).
I 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 rcr2011-063341 (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
NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the SBN Coughlin's
2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally released them o October
30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his formal
disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on 11/14/12
after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point is,
if the RJC and both of you 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 plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure 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 turn over any relevant dispatch recordings pertinent to the arrest and events surround it of
8/20/11 leading to rcr2011-063341, 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 night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of the "man with
the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to steal his bike
and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in the attached still
frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two 911 calls that evening,
the first (if the file name time stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the ECOMM text logs
reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls for Service Inquiry Response"
Coughlin was provided recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number (belonging to Austin Lichty, but
passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law license away from me for at least 5 years, if not forever....and
DDA Young...over some alleged "skater sets his iPhone down on the concrete in the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in
Reno, "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 it
immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's Narrative of unknown origin date") told Goble he saw
Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in his Narrative)
contain the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde
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 filmed of the arrest, title:

Then, Officer 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, 2011 11-26-30 PM Source_ID = 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
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of printing"
variations...).
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc of phone susps os left on post lighting up in sups pock RP screaming at susp
2. 082011 112620pm 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
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the Ecomm
recordings and dispatch logs...
1. VID_20110820_232413 your all on tape now goble and friends.3gp 8 seconds long
2. VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID_20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records for the iPhone reveal only four calls occurred in or out during the relevant time frame:
Goble's AT&T records:
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 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 prosecution 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 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later by a 3 Justice Panel
(including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look at the circumstances
of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 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...I just had some issues printing it out and bringing it with me (my legal assistant
couldn't figure that out...WLS 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 exclusively hearsay testimony (often unattributed 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 complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail 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
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.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation of NRS 205.275, a misdemeanor, in the manner following, to wit:
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 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.
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. Ct. 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.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the robbery
proceeds in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(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 State failed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show (1)
that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one 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 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN.
407 Ill. 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 ]
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327 (1946)), and must contain the nature and elements of the offense in order that the
defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this omission,
creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from himself, the fact that
the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v.
Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the
offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does not
create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances that would
reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question (in any manner
whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it is not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the offense of
theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property soon after a theft
is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d 860, 275
N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the necessary elements of the
offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the 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 defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find 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 "theft" cases. He erroneously urges that the state failed to meet that
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the time
and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4 Cal.App.2d 214, 40
P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States,
418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and later 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 the error effectively cured it. The error was not cured by
the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant guilty of burglary, Count 2, or receiving, Count 3.
Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element of the crime of receiving stolen goods..17. Criminal Law. In prosecution for
receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again possessing
property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession thereof. Comp.
Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for possession of
stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish probable cause that she
had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does 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 from mere possession.
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 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 robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property. Point v. State, 102
Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. 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 charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests with
the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see Gilman
275 V. Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem
929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE
2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following 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 the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theft of a purse, and Lelise prefers to spend his time 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 Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of
avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a
"rent escrow" of $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 are 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, 2011 trial they 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 detainer trial and the ability to bring counterclaims were matters Coughlin was
precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in
violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings Coughlin
submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing
office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
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 while Coughlin 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 being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file stamp
discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST 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. 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 video and audio recordings, including those preserved on pocket recording devices, 9-1-1 emergency calls, and
any dispatch logs, 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
Jim 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 sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim 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.
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 they 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) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young
on February 27, 2012 in RMC case 11 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 RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno employees of and admission to taking bribes
from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November
13, 2011. That criminal 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 filing December 26, 2011 was not file stamped by the civil 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 to 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 numerically in
the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State 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 11 TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC
judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office
upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately
had to admit on videotape to Coughlin that neither she nor Hill meritless 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 identified 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 from the Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law
considering judge Sferrazza's admission that the Reno justice 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 forced 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 Sheriff's 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 D.
Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the 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 O. 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 of 911 charge to do a
charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 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 RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein
implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary
protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012
will jaywalking (Hill lied to RPD officer Hollingsworth 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
before judge 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 Sferrazza and
1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's office 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 from Walmart in 11 CR
22176 (the sole basis for Coughlin's current temporary suspension of his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of
Nevada law where tribal police officers affected a custodial arrest for a misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS
171.1255 should especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. 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 footage supportive of its allegations even where its interior is absolutely dotted 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 some of Walmarts 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 for over a decade routinely claim do not remember the return policy or restated in a
manner that depart 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 of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on
September 9th, 2011 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 a justice 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 after 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 court 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 enforcement 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 Office. That Walmart petty larceny conviction stemmed from a trial before Reno
Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school 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 express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then
appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on
in that November 30 trial on it in 2011 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 which judge
Howard down such a matter 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 Municipal
Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week
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 his own witness at the December 20, 2012 hearing that was finally 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 2011.... It
incident to that same hearing on Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements
purporting to prove that Coughlin somehow failed to allow the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was
able to apparently without Coughlin's permission serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when
Coughlin was seeking axis justice court filing office 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 Dist.
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 that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 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 filed on November 26, 2012
seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge Clifton's
request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote representation
of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he and
his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org)
(former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD 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 fact 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 I his last-minute supplementing judge 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 along 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 anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge
Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on
behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $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 procured order for summary eviction in the Reno justice court RJC Rev2011-000374 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 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12,
without announcing 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 Management's Sue King switched 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 HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to Coughlin). in the third grievance against Coughlin forming
SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.
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 11/14/12
formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart 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, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL, ROBERT
KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of Opposition# (2)
Exhibit Exhibit 1 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 rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF
APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order Coughlin's
property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "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 micro 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 2/29/12 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 confiscating without a warrant/5
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 after Coughlin presented upon being released from 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 in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files 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 querying him as he too was on Richard Hill's payroll that RPD Officer
Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent 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 of the 121 River rock property for the month of November
that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any diligence by both officer Carter and Sargent
Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10, 2012 trial date in that criminal trespass
matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed 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
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's smart
phone and micro sd card, and regular cell phone on 2/28/12, when, outside 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 2/27/12 (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" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In 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 smart phone or recording device and hiding some component part thereof in the restroom
that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 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 office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly 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 RJC2011-001708, 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 FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the Order he entered on 12/21/12 following
a very contentious six hour hearing on Coughlin's November 17th, 2011 filed 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 that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza may enter or render incident to that
Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton 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 occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so
close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. Dr. Merliss owns the property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was
leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately
August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding
rent. All 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 1, 2011.
On that date, the Washoe County Sheriffs Department performed 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 days, it became apparent that "somebody" was breaking into the home on a regular basis. On Sunday,
November 13, 2011, Dr. Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true for Hill to write "The lease expired in February 2011." 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 contribution to the $900 for each of the months of May 2011 and June 2011
and only sent the landlord Merliss $550 for May 2011 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 of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's secretly absconding with
Coughlin's rental contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss). Merliss admitted to assenting to the
repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in violation of NRCP 11)
admitted, under oath, that he had expressly, in writing, 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 weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned
next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the
10/25/12 eviction "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 office substantial losses lost profits time away from work and expenses associated with immediately
mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to
landlord Merliss, who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing
with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior to their tearing it up and leaving industry when
they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Hill's grievance of 1/14/12 to the SBN goes on to allege:
"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. The Reno Police
Department was summoned. They tried to coax whoever was in the basement out, without success. After Dr. Merliss had to kick the door down, it "was discovered that Mr. Coughlin had
broken in and was in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is also facing a contempt
motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012, but was
continued at the request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process, a lien was asserted against
the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the Reno Justice Court. The court tried to
promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then reinitiated that process and a hearing was held in
December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing. You may also want to contact Reno Justice Court staff, and in
particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time
window to remove his personal property. The first day was Thursday, December 22, 20 11. 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 23, 2011, 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.
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, 2011, 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 from the house. Coughlin called the police, who
arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5
minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead with
that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell phone susp os also loud verb disturb.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-16-41 AM Source_ID = 13 Duralde indicated he will be en route to main station to drop off Coughlin's smartphone for copying data prior to
State Bar of Nevada refusing to file stamp Respondent's pleadings
depart.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-41 AM Source_ID = 6 Duralde's wife Jessica c151 reno, Alaksa can you switch to share some information call please.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead with that.wav
11 30 12 063341 updated motion for new trial with ex 1 attached in 2 pages per format.pdf
Download all

Sent: Mon 12/03/12 10:48 AM
To: Patrick King ( (patrickk@nvbar.org); (davidc@nvbar.org) (davidc@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (mike@tahoelawyer.com)
(mike@tahoelawyer.com); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com); (skent@skentlaw.com)
(skent@skentlaw.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); schornsby@nvdetr.org (schornsby@nvdetr.org)
Please incorporate by reference all my filings with the Nevada Supreme Court into any answer or responsive pleadings you find I have filed.
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
12 1 12 ex 1 to notice to that laura peters is 0204 screen print bz.pdf
12 1 12 ex 1 to notice that laura peters affidavit is whopper chocked 0204 bate stamped.pdf
12 1 30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs attachment.pdf
6 7 12 email to gammick and @nvbar.org four hours before 60838 suspension order 0204.htm
6 9 12 Petty theft conviction leads to Reno lawyer's suspension - News - ReviewJournal.com.pdf
6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
10 22 12 60203 garin's respondent's brief back from tiff.pdf
Download all
To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; mike@tahoelawyer.com; complaints@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; skent@skentlaw.com
Subject: RE: Mr Coughlin
Date: Wed, 21 Nov 2012 21:22:16 -0800
Dear SBN and Panel
The Disciplinary Hearing File that Pat King purported to have copied and provided to me contains numerous instances of my filings (as ruled on by Panel
Chair Echeverria, not being filestamped...). Echeverria's very ruling on filing he was not mailed (to the extent that was the case, and perhaps it was a
test) concedes at least the approval of filign by fax (express indication of the permissibility thereof in accordance with SCR 105(4) was provided by SBN
Clerk of Court Peters on 9/11/12.
Please confirm that my filings, all of them, including the Motion to Show Cause of 10/2/12, starting on bate stamp 02849 have been provided to all
Panel members as the SBN has repeatedly indicated they would be (included the copying of all attachments, including cd/dvds). Further, the Motion
to Dismiss of 9/17/12 lacks a file stamp (and it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs indicates...which means the SBN failed
to Oppose the Motion to Dismiss, and the Complaint was dismissed prior to any other purported proof of service being effected (or spurious assertions
of Coughlin dodging service given his numerous written correspondences and calls offering to meet Reno Carson or the SBN...until Coughlin finally just
gave the SBN his physical address on 10/23/12, despite safety concerns....)
Who gave you this order that you attached in the email of your's included below (the 8/28/12 Order by Judge Flanagan in the Carpentier foreclosure
defense case in SBN King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning Coughlin, which Washoe Legal Service's ED
Elcano cited as the sole reason for firing Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way through NERC and
Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and 2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
of these grievances? Did Mr. Susich disclose that conflict incident to the problems Maureen Cole had in carrying out the duties of her job as an attorney
for the NV DETR and NERC?
Please copy me on anything proving Chairman Susich so disclosed that conflict.
Additionally, more and more frequently, when I question Laura Peters on some misstatement or attempt to mislead that she makes, she starts talking about
getting a "protection order" or otherwise seeking to abuse process. Speaking of abusing process, due process namely, Peters was caught signing
Certificates of Mailing for 10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes system that Peters knew would not be picked up
by the SBN's mail carrier the day the certificate of mailing indicated the would be, or at least were placed...Please explain how your office's certified
mailing procedures work and comply with federal law.
Additionally, I have review the materials you had Sierra Legal Duplicating provide and there is no indication of where materials such as the 8 28 12 Order
sanctioning Coughlin generated from or whom transmitted them to the SBN. I had a discussion with Bar Counsel Clark over a year ago about whether
there was some centralized method of keeping track of Orders sanctioning attorneys. He indicated there was not. Please indicate then, who provided
you the various different Orders sanctioning Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of Court" provided the April
2009 Order Sanctioning Coughlin by Second Judicial Family Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of Court for
Department 3" (ie, of the Municipal Court's Department 3, which you fail to specify in your 3/23/12 email reporting such an identified "Clerk of Court"
wrote you that day about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even talkin' 'bout? Pajamas? Seriously, not even wearing
pajamas in court, but just out and about.) Pat, you are going to look like such an unbelievably compromised, crooked, and inept Bar Counsel when it is
displayed what a tenuous thread each and every aspect of all these half baked grievances hang from.
Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me, that I transcribe makes the appearance of impropriety disclosed herein look worse and
worse for the RMC, the SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this Panel is now in possession of the certified audio of the following transcripts:
April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming
the third grievance in SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close attention to the statements on the record by Hon. W. Garder
between the 4:45 minute mark to the 9:30 mark and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in light of his sister being Family Court
Judge L. Gardner (see Mandamus Petition Coughlin filed against W. Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance based upon his
sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from 1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30 minute mark wherein the following exchange took place:
Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's April 2009 grievance onto the State Bar in the last two weeks
Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he will continue to be your attorney today."
At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was
holding out the 121 River Rock Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction where the nonpayment of rent is not plead or alleged in the Hill
eviction case prior to the service of any eviction notice or even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a case wherein Coughlin was representing a single
father in a custody dispute based upon a judicial canon (see atached).

formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing from what was produced by City
Attorney Skau
King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin
(ng12-0204, ng12-0434, and ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in failing to have a proceeding (singular) addressing the "sole
issue" of determining the punishment of Coughlin for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough drops" where Wal-mart alleges
Coughlin consumed those items while shopping for and paying for $83.82 worth of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see 60838 and
61426:
60838 Walmart case with Court's June 7th, 2012 Order suspending Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
S
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
0204 Coughlin Disciplinary Hearing File.pdf
10 31 12 Order by Echeverria 0204.pdf
12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
12 15 11 22176 2064 Order by Howard on transcript costs.pdf
031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
Download all
> From: PatrickK@nvbar.org
> To: zachcoughlin@hotmail.com
> Subject: FW: Mr Coughlin
> Date: Thu, 30 Aug 2012 20:48:18 +0000
>
> Good Afternoon Mr. Coughlin,
>
> Attached is an Order that pertains to you.
>
> I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you expect to file an Answer?
>
> Thank you.
>
> Patrick King
Sent: Tue 12/04/12 2:07 PM
To: HomerJ@reno.gov (homerj@reno.gov); skauc@reno.gov (skauc@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); complaints@nvbar.org (complaints@nvbar.org);
patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); rosec@nvbar.org
(rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); philp@nvbar.org (philp@nvbar.org); glennm@nvbar.org (glennm@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org); bdogan@washoecounty.us
(bdogan@washoecounty.us); jleslie@washoecounty.us (jleslie@washoecounty.us)
12 attachments
CR11-2064-2676094 (Opposition to Motion to Dismiss CR11-2064-2676094.pdf).pdf (167.7 KB) , 11 7 12 subpoenas 063341 gricela alvarez and hassett proof of service or waivers.pdf (10.4
MB) , CR11-2064 MOTION FOR EXTENSION OF TIME (Mtn for Extension of Time).pdf (132.1 KB) , CR11-2064-2655401 (Mtn to Dismiss ...).pdf (117.4 KB) , CR11-2064-2676094
(Exhibit 2).pdf (133.6 KB) , CR11-2064-2676094 (Exhibit 3).pdf (48.0 KB) , 111912coughlin4.wmv (298.2 KB) , 111912coughlin6.wmv (3.6 MB) , 11 27 12 11 29 12 and 12 3 12 emails to
psferrazza@washoecounty.us and zyoung@da.washoecountys.us in response to Order to submit materials regarding Leslie's ineffective assistance 063341 0204.htm (245.1 KB) , 11 8 12
Homer email and 11 9 12 Skau email 063341 0204.htm (121.3 KB) , 6 7 12 60838 Order temporarily suspended Coughlin's law license scr 111 0204 12-17976.pdf (198.3 KB) , 12 1 30 notice
that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs attachment.pdf (327.9 KB)
Dear Office of Bar Counsel,
This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
Cc: Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you purportedly served, so
you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set
forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th
St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently
not there. Today, Reno Carson Messanger Service again attempted to serve you there at around 11:00 a.m. They called my
office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me
with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that
address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick
up at our Office, third floor of City Hall.
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted mostly
of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to
serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a photograph of
the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau fraudulently procurred Couglin's attendance at
the 11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only
Coughlin's formal disciplinary hearing but also the petty larceny trial of 11/19 and 11/20 and is a straight scum bag move by Creig Skau.
Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the JAVS audio transwcript of the 10/22/12
Hearing in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he fails to inform the court of
the waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez (whom, somehow, Judge Sferrazza was apparently aware of and had opinions on....curiously).
Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341 (really, everything Jim Leslie did in this case or
any other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is dragging his feet, your honor...He's wasting county assets."...Really, Jim, this is a
grievance against you for seeking to coerce a waiver of Coughlin's fifth amendment rights incident to your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression
Hearing or the Trial..and a greivance against DDA Young for similarly coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the first for 11/20
to get an idea of the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep Coughlin's laptops over night...but there is some really bad
audio on there with Judge Sferrazza and DDA Young getting completely coercive with respect to a waiver of Coughlin's Fifth Amendment rights and "you can't put on anything else or any evidence, YOU
NEED TO TESTIFY!" and Young "you Honor, it was my understanding that you let mr. Coughlin out of custody on the condition that he testify! If he won't do it TAKE HIM BACK INTO
CUSTODY!"
add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive any reports from dispatch of "a possible
fight" where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and therefore, such allegations of a report from dispatch of "a possible fight" did not bare
on Duralde's probable cause/reasonable suspicion analysis. further young put on perured testimony by Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when Young
was provide a video wherein Zarate admits he only inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant Tibbals or
anyone with the WCPD.
And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon arriving...yet, every bit of video evidence and or
testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to hearing "the man with the six pack" threaten to throw the iPhone "in the river if someone doesn't claim it
right now" was continually excluded as "hearsay"....
A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):
these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc. And one
problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the pat-down
date of 11/28/11
Austin Lichty (who is captured on the video of the moments(file 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
phone
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure 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.
the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to steal his bike and
or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in the attached still

the other end"
variations...).
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 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...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
407 Ill. 596 (1950). 96 N.E.2d 446.
[ 21 Ill. App.3d 980 ]
Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the offense
of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
legally.
Laws, sec. 10335."
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests with the
275 V. Comm 474, 657 SE 2d 474.
929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Sheely 102 p.2d 96
Woods 19 NYS 2d 683
prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the theft
of a purse, and Lelise prefers to spend his time 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 Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of avenging the
criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a "rent escrow" of
$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 are 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, 2011 trial they 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 detainer trial and the ability to bring counterclaims were matters Coughlin was precluded from accessing
by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in violation the courthouse sanctuary
doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out
of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to
those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
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 being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file stamp
whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim 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.
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) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on
February 27, 2012 in RMC case 11 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
from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November 13,
2011. That criminal 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 filing December 26, 2011 was not file stamped by the civil 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 to 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 numerically in the caption of the
SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State 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 11
TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including
then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin
being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on
videotape to Coughlin that neither she nor Hill meritless 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 identified 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 from the Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law
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 of 911 charge to do a charge
more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 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 RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating
the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection
order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will
jaywalking (Hill lied to RPD officer Hollingsworth 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
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 footage supportive of its allegations even where its interior is absolutely dotted 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 some of Walmarts 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 for over a decade routinely claim do not remember the return policy or restated in a manner that
depart 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 of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September
9th, 2011 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 a justice 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 after 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 court 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 enforcement 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 Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge
Kenneth Howard (a 1981 graduate McGeorge school 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 express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then appoint Coughlin court
appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30
trial on it in 2011 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 which judge Howard down such a
matter 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 Municipal Court freely granted Richard
G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week 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 his own witness at the December 20, 2012 hearing that was finally 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 2011.... It incident to that same
hearing on Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove
that Coughlin somehow failed to allow the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently
without Coughlin's permission serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking
axis justice court filing office for something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he and his
wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org)
of law in 1977 along 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 anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's
department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of
recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $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
procured order for summary eviction in the Reno justice court RJC Rev2011-000374 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 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without
announcing 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
Management's Sue King switched 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
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 after Coughlin presented upon being released from 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 in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files 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 querying him as he too was on Richard Hill's payroll that RPD Officer Chris
Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia Lopez refused to
criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, 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 FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the Order he entered on 12/21/12 following a very
contentious six hour hearing on Coughlin's November 17th, 2011 filed 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 that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza may enter or render incident to that Hearing...which
was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton 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 occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close
to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately August
2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding rent. All 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 1, 2011. On that date,
the Washoe County Sheriffs Department performed 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 days, it became apparent that "somebody" was breaking into the home on a regular basis. On Sunday, November 13, 2011, Dr.
Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
admitted, under oath, that he had expressly, in writing, 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 weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned next door and
his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction
"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 office substantial losses lost profits time away from work and expenses associated with immediately mitigating the criminal
conduct of green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to landlord Merliss, who
apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green action
lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds at the
property Merliss owns next-door at 252 Mill St.
particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time window
to remove his personal property. The first day was Thursday, December 22, 20 11. 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 23, 2011, 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.
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.
Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the house. Coughlin called the police, who arrived
at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
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Close
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Print
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/27/12 8:26 AM
re:rcr2011-063341
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance of counsel claim and or the coerced waiver of
my Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent faxing of
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
in compliance with
Judge Sferrazza
Order of 9/5/12

Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:

Reno Justice Court has no record of your attempted filing on 10/18/12. If you choose to pursue this filing action, you will need to bring the documents in because we do not accept filings via email. Any
documents filed with the court will be retained by the court and we will not make copies for you, the DA or PD. Providing the appropriate parties copies of your filing is your responsibility, not the court. You
may also bring in your confirmation of transmission from the 10/18/12 filing attempt and we will retain that receipt as part of the court record. Steve

Steve Tuttle

Court Administrator
Reno Justice Court

To: Tuttle, Steve

Dear Mr. Tuttle,
I perused the file in RCR2011-063341 and noticed that the document I submitted for filing on or about 10 18 12 was not file stamped or even in the file, though I have confirmation of receipt of transmission. Can you
please indicate why it is not appearing in the file and find attached another copy of the exhibit 1 thereto.


IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND IN
CASE ANYTHING GOES MISSING AGAIN
Sent: Thu 11/29/12 4:57 PM
To:
stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us (psferrazza@washoecounty.us);
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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Sent: Mon 12/03/12 2:53 AM
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received 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 instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Dispatch recordings (and those provided 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 arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which required
production of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main justification 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 recieved 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.
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 filming/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 the arrest
recording contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further, where Zarate
does not allege to have seen the phone light up to Duralde or in his Witness Statement, come Trial 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 all the way across the skate park...but wait...come November 19th,
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 somewhere out there
that does a timeline of all these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by
these witnesses...etc. And one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes:
"In the instant case, the pat-down search of the Defendant was proper under the totality of the circumstances. Prior to arriving, Officer Duralde
learned that the scene involved a loud disturbance with possible fight, thereby immediately raising the concern of weapons and the safety of all those
present." And, of course, Officer Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and sang the "possible
fight...report from dispatch 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 did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less obvious the extent to which Young was repeatedly
allowed to enter hearsay into the record, both in the Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson
admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on video and audio recordings into the record...despite
Duralde testifying to a multitude of double hearsay (and not even capture on a recording so close in time to the arrest and at the very same location,
involving the majority of the players in the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed
on" date of 11/28/11
Austin Lichty (who is captured on the video of the moments(file 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
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 the phone with him when he first 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 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
2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally released them o
October 30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his
formal disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on
11/14/12 after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But
the point is, if the RJC and both of you 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 plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure 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.
8/20/11 leading to rcr2011-063341, 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 night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of
the "man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to
steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in
the attached still frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two
911 calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though
the ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls for
Service Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number
(belonging to Austin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law license away from me for at
least 5 years, if not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in the middle of the ice rink plaza
downtown on 8/20/11 at 11:20 pm ish in Reno, "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 it immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's Narrative of unknown
origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in his Narrative)

Then, Officer 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, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles
396 on the other end"
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of
printing" variations...).
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 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 prosecution 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 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later
by a 3 Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you
look at the circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 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...I just had some issues printing it out and bringing it
with me (my legal assistant couldn't figure that out...WLS 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 exclusively hearsay testimony (often unattributed 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 complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail 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
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 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.
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 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.
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show
(1) that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one 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 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186."
PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96 N.E.2d 446.
[ 21 Ill. App.3d 980 ]
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this
omission, creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from himself,
the fact that the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449
(1929); People v. Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment
failed to charge the offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does
not create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances that
would reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question (in any
manner whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it is
not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the
offense of theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property
soon after a theft is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1
Ill.App.3d 860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the
necessary elements of the offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of these words would only be grammatically redundant and mere
surplusage legally.
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the defendant guilty beyond a reasonable doubt. For this reason I, too, would
reverse the defendant's conviction."
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the
time and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received 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 instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4
Cal.App.2d 214, 40 P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961);
Thomas v. United States, 418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and later
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 the error effectively
cured it. The error was not cured by the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant guilty of
burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again
possessing property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession
thereof. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for possession
of stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish probable cause
that she had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does 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 from mere
possession.
"Under Nevada law, Lane could not be convicted of both robbery and receiving 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 robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property. Point v.
State, 102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests
with the
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see
Gilman 275 V. Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378.
triem 929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb,
838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427
Appeala
Sheely 102 p.2d 96
Woods 19 NYS 2d 683
prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theft of a purse, and Lelise prefers to spend his time 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 Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal
of avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did,
deposit a "rent escrow" of $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 are 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, 2011 trial they 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 detainer trial and the ability to bring
counterclaims were matters Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which
service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff
Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her
position well prior to the 5 PM closing of that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
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 while Coughlin 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 being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19,
2011 file stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST 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. 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 video and audio recordings, including those preserved on pocket
recording devices, 9-1-1 emergency calls, and any dispatch logs, 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 Jim 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 sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or
indication that Jim 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.
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 they 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) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status
conference between Dogan young on February 27, 2012 in RMC case 11 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 RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno
employees of and admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint
for trespass find by Richard Hill on November 13, 2011. That criminal 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 filing December 26, 2011 was not file
stamped by the civil 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 to 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 numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State 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 11 TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash
Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter
incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal
trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless 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 identified 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 from the Reno
justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's admission that the Reno justice 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 forced 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 Sheriff's 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 D. Baker, Esq. lied about his testimony at the criminal trespass Trial of
Coughlin from which Judge William Gardner refused to recuse himself despite the 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 O. 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 of 911 charge to do a charge more deleterious to Coughlin's
professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 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 RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating the three,
count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order
to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will
before judge 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 Sferrazza
and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's office 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 from
Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that
was violative of Nevada law where tribal police officers affected a custodial arrest for a misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against
doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. 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 footage supportive of its allegations even where its interior is absolutely dotted
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 some
of Walmarts 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 for over a decade routinely claim do not remember
the return policy or restated in a manner that depart 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 of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted
neiher he nor anyone with Wal-Mart on September 9th, 2011 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 a justice 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 after 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 court 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 enforcement 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 Office. That Walmart petty
larceny conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school 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 express failure to rule that jail time was not a possibility in his pretrial
order and where mandatory authority exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with
that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 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 which judge Howard down such a matter 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 Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take
a six-week vacation beginning early November 2011 and it was that same six-week 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 his own witness at the December 20, 2012 hearing that was finally 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 2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge Sferrazza
ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow the justice court to setting hearing on
his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a violation of the courthouse
century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for something unrelated to bailiff
Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
away the ability to file by fax from Coughlin a privilege that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 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 filed on November
26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge
Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote
representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he
and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at
www.nvbar.org) (former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD 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 fact 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 I his last-minute supplementing judge 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 along 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 anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge
Beesley's case filings in judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by
both Coughlin formal disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $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 procured order for summary eviction in the Reno justice court RJC Rev2011-000374 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 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke
into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without announcing 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 Management's Sue King switched 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 HOA had expressly approved the arrangement with two
individuals whom were arguably sublessors to Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash
Homes in NG12-0402.
formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart 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, 2011 Coughlin filed the following:
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL,
ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of
Opposition# (2) Exhibit Exhibit 1 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 rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR
26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "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 micro 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 2/29/12 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 confiscating without a
warrant/5 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 after Coughlin presented upon being released from 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 in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files 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 querying him as he too was on Richard Hill's
payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and
Sargent 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 of the 121 River rock
property for the month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any
diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an
April 10, 2012 trial date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time
he had filed 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
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's
smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside 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 2/27/12 (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" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In 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 smart phone or recording device and hiding some
component part thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 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 office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly 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 RJC2011-001708, 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 FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to
characterize the Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed 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 that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any
Order Judge Sferrazza may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in
chief bailiff Sexton 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 occasions the week of Thanksgiving 2011 that
Coughlin indicated that the filing office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately
August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his
withholding rent. All 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 1, 2011. On that date, the Washoe County Sheriffs Department performed 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 days, it became apparent that "somebody" was breaking into the home on a regular
basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true for Hill to write "The lease expired in February 2011." 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 contribution to the $900 for each of the months of May 2011 and
June 2011 and only sent the landlord Merliss $550 for May 2011 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 of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's secretly
absconding with Coughlin's rental contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss). Merliss
admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction
notices, in violation of NRCP 11) admitted, under oath, that he had expressly, in writing, 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 weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's
landscaper for the other property Merliss owned next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000"
that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction "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 office substantial losses lost profits
time away from work and expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf installation even though
they knew it was there prior to submitting their bid for services to landlord Merliss, who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin
on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law
office the week prior to their tearing it up and leaving industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Department was summoned. They tried to coax whoever was in the basement out, without success. After Dr. Merliss had to kick the door down, it "was discovered that Mr. Coughlin
had broken in and was in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is also facing a
contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012,
but was continued at the request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process, a lien was asserted
against the personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the Reno Justice Court. The court
tried to promptly set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then reinitiated that process and a hearing was held
in December, at which time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing. You may also want to contact Reno Justice Court staff,
and in particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day
time window to remove his personal property. The first day was Thursday, December 22, 20 11. 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 23, 2011, 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.
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, 2011, 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 from the house. Coughlin called the police,
who arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
minutes.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead
with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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Print
Case No. RCR2011-063341
From:Jeannie Homer (HomerJ@reno.gov)
Sent: Thu 11/08/12 2:48 PM
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order toQuash Subpoenas and for
Protective Order Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte Emergency Order PendingHearing.pdf (81.0 KB)
Please see attached documents from Creig Skau, Deputy City Attorney:

1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1 & 2)

2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9:00a.m.)

Thank you.

Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov

ATTORNEY-CLIENT PRIVILEGE

This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a
person responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY
PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message and its attachments.

Fwd: FW: Case No. RCR2011-063341
From:Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
1 attachment
Dear Mr. Coughlin,
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted
mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to
serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a
photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:

IN THE JUSTICE COURT OF RENO TOWNSHIP

COUNTYOF WASHOE, STATE OF NEVADA

STATE OF NEVADA,
Plaintiffs,

vs.

COUGHLIN, ZACHARY BARKER

Defendant.

CASE
NO.:
RCR2011-
063341

DEPT.
NO.: 2

EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (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 for an order shortening time 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, 2012, Deputy City Attorney Creig Skau appeared on behalf of the RCAO and the City employees requesting protective relief.
Zack Young was present in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defenders office represented Mr. Coughlin, that the Public
Defender was served believing this was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himself this morning and attempted to call and left a voice mail message with a phone
number believed to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and filed
requests for relief similar to the RCAOs requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr. Coughlin, no argument was received on the merits of the motion.
However, the Court finds that the RCAOs motion and supporting materials present a sufficient evidentiary basis to issue this Order.

The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 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 in accordance with NRS 174.305 is hereby quashed. Any subpoena not personally served by a
non-party or otherwise properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds such as relevancy or undue burden until the hearing
on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this matter on November 13, 2012, to the effect that upon service of this Order
on Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter issue or cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena duces tecum in
this case unless he has first presented the proposed subpoena or subpoena duces tecum to the Court for the Courts review regarding adequacy, relevancy and necessity of the subpoena or subpoena
duces tecum, and sufficiency of the proposed method of service.
4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order and the RCAOs motion and any supplements by personal
service upon Zachary Barker Coughlin at the address in the Courts file, 1471 E. 9
th
Street, Reno, NV 89512, with a copy mailed to said address. Service shall also be attempted by email at
zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.

/s/

JUSTICE OF THE PEACE

The City of Reno's Motion states:

JOHN J. KADLIC
RenoCityAttorney
CREIGTON SKAU
Deputy City Attorney
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys for City of Reno


STATE OF NEVADA, Case No. RCR2011-063341
Plaintiffs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
__________________________________/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER REGARDING ISSUANCE OF SUBPOENAS

COMES NOW, City of Reno (City), as the employer and on behalf of Reno Police Department Officers Ron Rosa and Thomas Alaksa, and Court Marshall Joel
Harley and Reno Emergency Communication Center employees Savannah Montgomery and Scott Weese (and any other City employees (collectively City employees) whose names were
unreadable in subpoenas), by and through their counsel of record, John J. Kadlic, Reno City Attorney, and Creig Skau, Deputy City Attorney, and hereby moves this Court for an order to quash the
subpoenas claimed to have been served on for these City employees in violation of Justice Court Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
///

JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and any additional or further evidence the Court deems just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. 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 incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among other things, the City of Reno Police Report and City of Reno ECOMM materials
regarding Case Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno for $108. A copy of the letter is attached as Exhibit 2 and
incorporated herein by reference. On November 5, 2012, this same letter was sent again to Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah
Montgomery and Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated because service of the subpoenas for these four (4)
individuals was ineffective, these individuals would not be appearing on November 19, 2012. (Exhibit 2).
4. On November 1, 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 office of the Reno Police Department at approximately 4:50 p.m. after being told the office was closed. Three (3) subpoenas 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 Odom and Suzy Rogers. A copy of this packet is
attached as Exhibit 3 and incorporated herein by reference.
5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in
earlier subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials unrelated to Case RMC RCR2011-063341. A copy of these documents is attached as
Exhibit 4 and incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin regarding the letter this office mailed on November 2, 2012. Among other things, Mr.
Coughlin did not indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese. Mr. Coughlin did state to have these witnesses
ready for trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing seventeen (17) pages of blended documents regarding matters pending before Reno
Justice Court on November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department. 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.
1. 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 RCR2011-063341. This document also appears to contain names of other individuals but the handwriting is unreadable. It is not known 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. Coughlin, personal appearance may not be required. A copy
of the packet is attached as Exhibit 6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(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 person 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 officer 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 5(b).

The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on October 26, 2012 and November 3, 2012 and re-delivered to the Reno Police
Department on November 2, 2012 and November 6, 2012 commanding the appearance of the many different City employees above are deficient and ineffective as they fail to comply with personal
service requirement of JCRCP 45(b). Accordingly, service was ineffective and all of the subpoenas should be quashed.

In addition to the failure of personal service, all of Mr. Coughlins subpoenas referenced in Exhibits 1, 3, 4 and 5, also:
1. Violate JCRCP 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP 45.
2. Violate JCRCP 45(b)(1) which states that a subpoena may be served by any person who is not a party to the proceeding. All of the subpoenas were e-mailed to City ECOMM
employees Kelley Odom, Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2, 2012 and November 6, 2012 by Mr. Coughlin, a party in this matter.
1. Violate JCRCP 45(b)(1) which states that service of a subpoena commanding attendance requires that payment for one days attendance and the mileage allowed by law. No witness fee or
mileage fee has been submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a
person subject to the subpoena. Mr. Coughlin is serving a litany of subpoenas on many City departments and City employees regarding this case. However, he is also serving subpoenas on
City departments and City employees on a multitude of other cases and proceedings that are unrelated to the instant action. These subpoenas are unduly burdensome, duplicative, irrelevant,
unintelligible, oppressive, harassing, seek information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for all City employees to appear on November 19, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or 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 dropping off the same subpoenas (some of which relate to this matter and many which relate to a State Bar proceeding or
other criminal matters) at multiple City departments. This is creating confusion and leading to a waste of time and resources of public safety employees. As an attorney, Mr. Coughlin should be
aware of the subpoena process. This is not the first matter in which Mr. Coughlin has abused a court procedural matter. For this Courts information, Reno Municipal Court Judge Holmes
issued a Sua Sponte Order Denying Relief Sought in Improper Document on March 13, 2012 finding, among other things, that Mr. Coughlin failed to follow proper legal procedure in preparing and
filing motions in a matter pending before that Court and that Mr. Coughlin blatantly abused that Courts fax filing process. As such, that Court ordered that Mr. Coughlin be prohibited from faxing
any documents to that Court. A copy of this Order is attached as Exhibit 7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this
matter to this Court for review prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a specific case and is following the appropriate legal process.

III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. 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 Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department 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 requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior to issuance and service
to ensure Mr. Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney

By:

CREIGTON SKAU


P.O. Box 1900

Reno, NV 89505


As to the other matters addressed by you below, I work in the Civil Division and I have no knowledge or authority to address them. I suggest that you take up those matters with the
attorney(s) assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorney

-----Original Message-----
From: Jeannie Homer <homerj@reno.gov>
To: "'bonyr@reno.gov'" <bonyr@reno.gov>, "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri, 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI

Sent: Thursday, November 08, 2012 8:36 PM
To: HomerJ @reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341

couldn't open them, and I don't accept service of anything form you... See Allison Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your
offices violation of the RMC Rules to the extent there is not difference technologically anymore between an email and a fax:

Rul e 5: Mot i ons/Pl eadi ngs by Fac si mi l e
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet and exhibits. A document shall not be split into multiple transmissions to avoid the page
limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the
receiving party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J . Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the follo wing court day.
Rul e 6: Cont i nuanc es
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must state the reason therefore and whether or not any continuance has previously been sought or granted.

Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin
was suing in CV11-03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in
response to Coughlin's request for one in 11 CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance an blaming it on the Court.

Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional snail mail, usps, or personal service. And I am not
currently included amongst those who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the 'governmental agency" and "attorney
exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served where he has been. Take, for instance

Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from representation:
Rul e 3: Aut hor i zat i on t o Repr esent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw froma case shall file a motion with the court and serve the City Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a
confirmation of delivery of his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination of both asserting, in one way or another, that the Notice
of Appeal was not received in a timely manner. The delivery confirmations say otherwise.

Please remit $250,000 in the formof a certified check to the address below within 10 days in settlement of these torts. SBN, please provide to me the grievance number associate with this new grievance that is created upon the successful
transmission of this email.

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
Voxox noreply@voxox.com Jun 27
Hi zachcoughlin,
You r Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 08:54:28 PM on 2012-06-27.
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive fromVoxox? Get Voxox: http://download.voxox.com and adjust your Notifications in the
Settings/Preferences window. Voxox by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Hi zachcoughlin,
to me
to me
to me
Your Fax was delivered @ 08:13:34 AM on 2012-06-28.
Hi zachcoughlin,
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341



Thank you.

Jeannie Homer
Legal Secretary
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a
person responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is
to me
to me
more of the formal grievance against Skau, Young, Leslie, and Dogan RE: formal written grievance against Skau, Young, Leslie,
Dogan, etc. FW: 911 calls missing from what was produced by City Attorney Skau
STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message and its attachments.

Sent: Tue 12/04/12 3:08 PM
To: complaints@nvbar.org (complaints@nvbar.org); patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); skent@skentlaw.com
(skent@skentlaw.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); rosec@nvbar.org (rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); philp@nvbar.org (philp@nvbar.org); glennm@nvbar.org (glennm@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org
(schornsby@nvdetr.org)
Dear Office of Bar Counsel, NNDB, Panel, and President Flaherty,
Please forward this email on to John Echeverria, Patrick King and David Clark and the NNDB Chairman Susich, SBN President Flaherty, and NNDB Chairman Susich in case they don't get the transmission
sent here.
The video and audio and other materials supporting this greivance are available here:
http://sdrv.ms/YwYabQ
Please add City Attorney John Kadlic to the grievance as at some point he needs to take responsibility for all the dirty deeds done not so cheap by his cadre of malevolent, corrupt, deputy city attorneys.
Clerk of Court Peters has been refusing to allow me to have a file stamp copy of my filings, save an introductory few instances...please Order her to do so.

While I was never sent the 10/9/12 Affidavit of Laura Peters that the SBN and Peters slipped into the Formal Disciplinary File, incongruously, inserted, bate stamped, after the 10/30/12 Order by Chairman
Susich (strange...how could it be file stamped October 10th, 2012, yet be filed after Chairman Susich's 10/30/12 Order? Eventually that Affidavit was provided to me on 11/8/12 (6 days before the
formal disciplinary hearing, buried within 3,000 or more pages of documents (so instead of the 27 days to review them called for by SCR 105(2)(c), I was affored only, roughly 3 (depending on how you
count the "within 3 days prior" in consdiering SCR 105(4) and NRCP 6(a),(e)...
It is definately not my understanding that any Cease and Desist Order by Chair Echeverria or "stay away" letter by Patrick King means I can no longer file documents in this matter, or that any failure by
Clerk of Court Peters to provide me a file stamped copy of my filings means they are not filed or that the SBN is failing to abide by its express declaration and agreements and pronouncements of the
procedural policies and rules applicable to this matter wherein King, Peters, the SBN/Panel/Board have failed to provide me any written adopted procedural rules, have made numerous declarations and
express indications of specific policies and rules attendant to my utilizing subpoenas (which King fraudulently mislead the Panel as to in his Motions to Quash and in his argument during the 11/14/12
Hearing...noticeably absent is an Affidavit from King regarding what he communicated to Coughlin respecting David Clark's ruling on Coughlin's use of subpoenas and the procedural mechanics attendant
thereto, or, even more noticeable, is an mention by Laura Peters in her 10/9/12 Affidavit respecting the permission to fax file granted to Coughlin in this matter.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
110812coughlin 063341 Reno City Attorney Skaur at 25 minute mark violates duty of candor to tribunal and fairness to opposing counsel considering 11 9 12 email by Skau.wmv
To: homerj@reno.gov; skauc@reno.gov; zyoung@da.washoecounty.us; complaints@nvbar.org; patrickk@nvbar.org; davidc@nvbar.org; je@eloreno.com; skent@skentlaw.com; cvellis@bhfs.com;
mike@tahoelawyer.com; eifert.nta@att.net; nevtelassn@sbcglobal.net; rosec@nvbar.org; laurap@nvbar.org; philp@nvbar.org; glennm@nvbar.org; fflaherty@dlpfd.com; fflaherty@dyerlawrence.com;
tsusich@nvdetr.org; schornsby@nvdetr.org; bdogan@washoecounty.us; jleslie@washoecounty.us
Subject: formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing from what was produced by City Attorney Skau
Date: Tue, 4 Dec 2012 14:07:52 -0800
Dear Office of Bar Counsel,
This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
1 attachment
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you purportedly served, so
you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set
forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th
St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently
not there. Today, Reno Carson Messanger Service again attempted to serve you there at around 11:00 a.m. They called my
office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me
with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that
address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick
up at our Office, third floor of City Hall.
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a photograph of the
packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau fraudulently procurred Couglin's attendance at the
11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only Coughlin's
formal disciplinary hearing but also the petty larceny trial of 11/19 and 11/20 and is a straight scum bag move by Creig Skau.
Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the JAVS audio transwcript of the 10/22/12 Hearing
in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he fails to inform the court of the
waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez (whom, somehow, Judge Sferrazza was apparently aware of and had opinions on....curiously).
Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341 (really, everything Jim Leslie did in this case or any
other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is dragging his feet, your honor...He's wasting county assets."...Really, Jim, this is a grievance
against you for seeking to coerce a waiver of Coughlin's fifth amendment rights incident to your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression Hearing or the
Trial..and a greivance against DDA Young for similarly coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the first for 11/20 to get an idea of the
hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep Coughlin's laptops over night...but there is some really bad audio on there with Judge
Sferrazza and DDA Young getting completely coercive with respect to a waiver of Coughlin's Fifth Amendment rights and "you can't put on anything else or any evidence, YOU NEED TO TESTIFY!" and
Young "you Honor, it was my understanding that you let mr. Coughlin out of custody on the condition that he testify! If he won't do it TAKE HIM BACK INTO CUSTODY!"
add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive any reports from dispatch of "a possible fight"
where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and therefore, such allegations of a report from dispatch of "a possible fight" did not bare on
Duralde's probable cause/reasonable suspicion analysis. further young put on perured testimony by Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when Young was
provide a video wherein Zarate admits he only inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant Tibbals or anyone
with the WCPD.
And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon arriving...yet, every bit of video evidence and or
testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to hearing "the man with the six pack" threaten to throw the iPhone "in the river if someone doesn't claim it right
now" was continually excluded as "hearsay"....
A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):
This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr. Leslie's
representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on this just
because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received 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 instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
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 Leslie's failure to utilize any of the work I
did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of 11:27:11 pm reporting Goble's
since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the Dispatch recordings (and
those provided 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 arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which required production of those "dispatch logs or
recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main justification 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 recieved 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.
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 filming/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 the arrest recording contradict what Officer
Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further, where Zarate does not allege to have seen the phone
light up to Duralde or in his Witness Statement, come Trial 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 all the way across the skate park...but wait...come November 19th, 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 somewhere out there that does a timeline of all these calls, all these videos,
superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc. And one problem for DDA Young and
Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the pat-down search of the Defendant was proper
under the totality of the circumstances. Prior to arriving, Officer Duralde learned that the scene involved a loud disturbance with possible fight, thereby
immediately raising the concern of weapons and the safety of all those present." And, of course, Officer Duralde responded splendidly to Coach Young's, er,
DDA Young's training regime and sang the "possible fight...report from dispatch 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 did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less obvious
the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the Suppression Motion Hearing and at Trial, whereas Coughin
never could get that darn Nicole Watson admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on video and audio
recordings into the record...despite Duralde testifying to a multitude of double hearsay (and not even capture on a recording so close in time to the arrest and at
the very same location, involving the majority of the players in the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed on" date
of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in support of
the objectives he has, which here, were motivate by a retaliatory intent and the "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 receive the
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 moments(file 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
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 the phone with him when he first 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 111(6) and 37 CFR 11.25(3).
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 rcr2011-063341 (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 NG12-0204 SCR 105
Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori Townsend from sending into
the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the SBN Coughlin's 2/15/12 filing in 063341). Add to
that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally released them o October 30th, 2012...and it really is not accurate
to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his formal disciplinary hearing before the SBN despite the SBN
gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on 11/14/12 after service of the Complaint and Designation of
Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point is, if the RJC and both of you 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 plenty of opportunities to put this thing aside,
because there are a multitude.
explanation.
8/20/11 leading to rcr2011-063341, 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 night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of the "man with the gauged
ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to steal his bike and or dog, reach
into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in the attached still frame, it is quite
clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two 911 calls that evening, the first (if the file
name time stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the ECOMM text logs reveal an E911 entry of
11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls for Service Inquiry Response" Coughlin was provided
recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number (belonging to Austin Lichty, but passed to Goble by "Peanut"
with the gauged ears...yeah, these are the guys taking my law license away from me for at least 5 years, if not forever....and DDA Young...over some alleged
"skater sets his iPhone down on the concrete in the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in Reno, "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 it immediately" whereupon Goble's friend Nate Zarate
apparently (according to RPD Duralde's Narrative of unknown origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing
from Goble in his Narrative)
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde 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 filmed of the arrest, title:

Then, Officer 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, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the
other end"
variations...).
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the Ecomm recordings
and dispatch logs...
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 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 prosecution 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 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later by a 3 Justice Panel (including Justice Hardesty,
whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look at the circumstances of my firing therein (I was
hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 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...I just had some issues printing it out and bringing it with me (my legal assistant couldn't figure that out...WLS 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 exclusively hearsay testimony (often unattributed 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 complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail 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
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 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.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the robbery proceeds
in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(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 State failed to prove beyond all
reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show (1) that the property
has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one 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 Ill. 465.) Proof of
these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96 N.E.2d 446.
[ 21 Ill. App.3d 980 ]
defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the indictment,
drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this omission, creates the
presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from himself, the fact that the property
received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v. Harris, 394 Ill. 325,
329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the offense of receiving stolen
property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does not create
the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances that would reasonably
induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question (in any manner whatsoever), the
property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the offense of theft
under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property soon after a theft is
evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d 860, 275 N.E.2d
236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the necessary elements of the offense, i.e., that
the property was already stolen by another when the defendant received it.
legally.
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find 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 "theft" cases. He erroneously urges that the state failed to meet that standard
under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the time and place it
was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received 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 instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870
(Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States, 418 F.2d 567 (5
Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and later 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 the error effectively cured it. The error was not cured by the setting aside of the
receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant guilty of burglary, Count 2, or receiving, Count 3. Milanovich v. United States,
supra. Both convictions should have been set aside and a new trial ordered"
property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession thereof. Comp. Laws,
sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for possession of stolen
property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish probable cause that she had
committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
"Under Nevada law, Lane could not be convicted of both robbery and receiving 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 robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property. Point v. State, 102 Nev.
143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see Gilman 275 V.
Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem 929
P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d 1197 In
RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Sheely 102 p.2d 96
Woods 19 NYS 2d 683
Between the following 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
the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the theft of a purse,
and Lelise prefers to spend his time 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 Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of avenging the criticisms Coughlin
levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a "rent escrow" of $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 are 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, 2011 trial they 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 detainer trial and the ability to bring counterclaims were matters Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting
approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno
justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the Reno
justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury
that Ms. Baker admitted this to him
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 while Coughlin 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 being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file stamp discovery requests served upon
the stay and district attorney Zach young reads at page 1 therein: "REQUEST 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. 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 video and audio recordings, including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, 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 Jim 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 sort of concern for
his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim 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.
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 they 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) of Coughlin
smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on February 27, 2012 in RMC
case 11 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 RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno employees of and admission to taking bribes from Richard Hill by RPD officer Chris
Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal 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 filing December 26, 2011 was not file stamped by the civil 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 to 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 numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by
the State 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 11 TR 26800 held in violation of NRS 178.405 by way of NRS 5.071
(RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself
from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011,
resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless 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 identified 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 from the Reno justice
court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's admission that the Reno justice 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 forced 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 Sheriff's 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 D. Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse
himself despite the 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 O. 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 of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 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 RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand
located at 1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing
quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of
Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth 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 before judge 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 Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's office 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 from
Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was
violative of Nevada law where tribal police officers affected a custodial arrest for a misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in
NRS 171.1255 should especially where Walmarts sole witness testifying at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a
drops while doing so... Despite the fact that that Walmart alleges to have had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted 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 some of Walmarts 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 for over a decade routinely claim do not remember the return policy or restated in a manner that depart 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 of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 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 a justice 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 after 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 court 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 enforcement 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 Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school 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 express failure to rule that
jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge
Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 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 which judge Howard down such a matter 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 Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-
week vacation beginning early November 2011 and it was that same six-week 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 his own witness
at the December 20, 2012 hearing that was finally 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 2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing
office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow the justice court to setting hearing on his motion to contest personal property lien however that
doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that
same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office 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 Dist. 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 that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 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 filed on November 26, 2012 seeking such an
order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge Clifton's request that he provide
judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote representation of Coughlin" in 065630).
wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org) (former
law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD 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 fact 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 I his last-minute supplementing judge 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 along 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
anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's department in the NVB.) in
early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of recently as of November 8, 2012
reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $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 procured order for summary eviction in the Reno justice
court RJC Rev2011-000374 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 3/15/12, and where the Washoe
County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without announcing 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 Management's Sue King switched 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 HOA had expressly approved the
arrangement with two individuals whom were arguably sublessors to Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge
Dorothy Nash Homes in NG12-0402.
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 11/14/12 formal
disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart 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, 2011 Coughlin filed the following:
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order Coughlin's property
released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "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 micro 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 2/29/12 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 confiscating without a warrant/5 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 after Coughlin presented upon being released from 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 in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files 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 querying him as he too was on Richard Hill's payroll that RPD Officer Chris Carter, Jr
admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent 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 of the 121 River rock property for the month of November that was commiserate with the
same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno
Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10, 2012 trial date in that criminal trespass matter wherein Reno Municipal Court
judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed 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
phone and micro sd card, and regular cell phone on 2/28/12, when, outside 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 2/27/12 (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" of 3/12/12 in
comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In 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 smart phone or recording device and hiding some component part thereof in the restroom that Judge Nash Holmes
murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 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 office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly 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 RJC2011-001708, 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 FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the Order he entered on 12/21/12 following a very contentious six hour hearing
on Coughlin's November 17th, 2011 filed 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 that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza may enter or render incident to that Hearing...which was conducted in an is coercive
atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton 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 occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close to the 5 PM closing time of the filing office.
(see attached in Exhibit 1).
"4. We represent Dr. Matthew MerIiss, a physician from Chico, California. Dr. Merliss owns the property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was leased to
Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately August 2011 to assist
in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding rent. All 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 1, 2011. On that date, the Washoe County
Sheriffs Department performed 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 days, it became apparent that "somebody" was breaking into the home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met
him at the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true for Hill to write "The lease expired in February 2011." 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 contribution to the $900 for each of the months of May 2011 and June 2011 and only sent
the landlord Merliss $550 for May 2011 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 of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's secretly absconding with Coughlin's rental
contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss). Merliss admitted to assenting to the repayment plan with Ms.
Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in violation of NRCP 11) admitted, under oath, that he had
expressly, in writing, 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 weeds" (see the
attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned next door and his quasi real estate broker property
manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction "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 office substantial losses lost profits time away from work and expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not
only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to landlord Merliss, who apparently did not realize or remember that he had also assented
to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put
into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That was scheduled for January 10, 2012, but was continued
at the request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628, pending in Department 7. As part of the eviction process, a lien was asserted against the
personal property that Coughlin left behind at the home. On November 16, 2011, Coughlin filed a motion to contest the landlord's lien in the Reno Justice Court. The court tried to promptly
set a hearing, but Coughlin refused to cooperate in setting the matter, and the court took it off calendar. Coughlin then reinitiated that process and a hearing was held in December, at which
time the court heard evidence of Coughlin's lack of cooperation in setting the November hearing. You may also want to contact Reno Justice Court staff, and in particular, chief clerk
Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time window to remove his personal
property. The first day was Thursday, December 22, 20 11. 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
23, 2011, 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.
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.
Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the house. Coughlin called the police, who arrived at
the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
minutes.wav
that.wav
Zach Coughlin
Close
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402

Print
Sent: Tue 11/27/12 8:26 AM
re:rcr2011-063341
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance of counsel claim and or the coerced waiver of my
Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent faxing of
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
in compliance with
Judge Sferrazza
Order of 9/5/12

Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:

Reno Justice Court has no record of your attempted filing on 10/18/12. If you choose to pursue this filing action, you will need to bring the documents in because we do not accept filings via email. Any documents
filed with the court will be retained by the court and we will not make copies for you, the DA or PD. Providing the appropriate parties copies of your filing is your responsibility, not the court. You may also bring in
your confirmation of transmission from the 10/18/12 filing attempt and we will retain that receipt as part of the court record. Steve

Steve Tuttle

Court Administrator
Reno Justice Court

To: Tuttle, Steve

Dear Mr. Tuttle,
I perused the file in RCR2011-063341 and noticed that the document I submitted for filing on or about 10 18 12 was not file stamped or even in the file, though I have confirmation of receipt of transmission. Can you please
indicate why it is not appearing in the file and find attached another copy of the exhibit 1 thereto.


IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND IN
CASE ANYTHING GOES MISSING AGAIN
Sent: Thu 11/29/12 4:57 PM
To:
stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us (psferrazza@washoecounty.us);
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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data-2012-11-24-18-45-14.wav
data-2012-11-24-18-49-41.wav
data-2012-11-24-18-49-41(1).wav
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Sent: Mon 12/03/12 2:53 AM
these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc. And one
problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the pat-down
date of 11/28/11
Austin Lichty (who is captured on the video of the moments(file 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
phone
explanation.
the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to steal his bike and
or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in the attached still

the other end"
variations...).
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 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...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
407 Ill. 596 (1950). 96 N.E.2d 446.
[ 21 Ill. App.3d 980 ]
Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the offense
of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
legally.
Laws, sec. 10335."
275 V. Comm 474, 657 SE 2d 474.
929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Sheely 102 p.2d 96
Woods 19 NYS 2d 683
prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the theft
of a purse, and Lelise prefers to spend his time 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 Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of avenging the
criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a "rent escrow" of
$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 are 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, 2011 trial they 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 detainer trial and the ability to bring counterclaims were matters Coughlin was precluded from accessing
by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in violation the courthouse sanctuary
doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out
of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to
those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
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 being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file stamp
whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim 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.
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) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young on
February 27, 2012 in RMC case 11 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
from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on November 13,
2011. That criminal 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 filing December 26, 2011 was not file stamped by the civil 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 to 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 numerically in the caption of the
SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State 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 11
TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including
then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin
being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on
videotape to Coughlin that neither she nor Hill meritless 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 identified 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 from the Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law
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 of 911 charge to do a charge
more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 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 RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating
the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection
order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will
drops while doing so... Despite the fact that that Walmart alleges to have had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted 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 some of Walmarts 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 for over a decade routinely claim do not remember the return policy or restated in a manner that
depart 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 of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September
9th, 2011 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 a justice 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 after 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 court 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 enforcement 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 Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge
Kenneth Howard (a 1981 graduate McGeorge school 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 express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then appoint Coughlin court
appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30
trial on it in 2011 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 which judge Howard down such a
matter 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 Municipal Court freely granted Richard
G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week 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 his own witness at the December 20, 2012 hearing that was finally 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 2011.... It incident to that same
hearing on Coughlin's motion to contest personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove
that Coughlin somehow failed to allow the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently
without Coughlin's permission serve Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking
axis justice court filing office for something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org)
of law in 1977 along 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 anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's
department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of
recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $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
procured order for summary eviction in the Reno justice court RJC Rev2011-000374 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 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without
announcing 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
Management's Sue King switched 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
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 after Coughlin presented upon being released from 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 in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files 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 querying him as he too was on Richard Hill's payroll that RPD Officer Chris
Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia Lopez refused to
criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, 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 FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the Order he entered on 12/21/12 following a very
contentious six hour hearing on Coughlin's November 17th, 2011 filed 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 that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza may enter or render incident to that Hearing...which
was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton 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 occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close
to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
leased to Mr. Coughlin and his then-girlfriend. The lease expired in February 2011. The girlfriend left the community in approximately May 2011. Dr. Merliss contacted us in approximately August
2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding rent. All 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 1, 2011. On that date,
the Washoe County Sheriffs Department performed 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 days, it became apparent that "somebody" was breaking into the home on a regular basis. On Sunday, November 13, 2011, Dr.
Merliss came to town, and I met him at the home on River Rock Street. As we walked through the home, it was obvious that"
admitted, under oath, that he had expressly, in writing, 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 weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned
next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the
10/25/12 eviction "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 office substantial losses lost profits time away from work and expenses associated with immediately
mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to
landlord Merliss, who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing
with the weeds. Green action lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior to their tearing it up and leaving industry when
they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
particular, chief clerk Karen Stancil, about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court issued an Order granting Coughlin a two-day time window
to remove his personal property. The first day was Thursday, December 22, 20 11. 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 23, 2011, 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.
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.
Coughlin flagged the contractor down in traffic when he (the contractor) was on his way to the dump with the abandoned property from the house. Coughlin called the police, who arrived
at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
minutes.wav
that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
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Case No. RCR2011-063341
From:Jeannie Homer (HomerJ@reno.gov)
Sent: Thu 11/08/12 2:48 PM
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order toQuash Subpoenas and for
Protective Order Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte Emergency Order PendingHearing.pdf (81.0 KB)



Thank you.

Jeannie Homer
Legal Secretary
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person
responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY

Fwd: FW: Case No. RCR2011-063341
From:Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
1 attachment
Dear Mr. Coughlin,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a photograph of the
packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:



STATE OF NEVADA,
Plaintiffs,

vs.

COUGHLIN, ZACHARY BARKER

Defendant.

CASE
NO.:
RCR2011-
063341

DEPT.
NO.: 2

EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (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 for an order shortening time 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, 2012, Deputy City Attorney Creig Skau appeared on behalf of the RCAO and the City employees requesting protective relief. Zack
Young was present in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defenders office represented Mr. Coughlin, that the Public Defender
was served believing this was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himself this morning and attempted to call and left a voice mail message with a phone number believed
to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and filed
requests for relief similar to the RCAOs requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr. Coughlin, no argument was received on the merits of the motion.
However, the Court finds that the RCAOs motion and supporting materials present a sufficient evidentiary basis to issue this Order.

The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 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 in accordance with NRS 174.305 is hereby quashed. Any subpoena not personally served by a non-
party or otherwise properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds such as relevancy or undue burden until the hearing on the
merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this matter on November 13, 2012, to the effect that upon service of this Order on
Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter issue or cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena duces tecum in this
case unless he has first presented the proposed subpoena or subpoena duces tecum to the Court for the Courts review regarding adequacy, relevancy and necessity of the subpoena or subpoena duces
tecum, and sufficiency of the proposed method of service.
4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order and the RCAOs motion and any supplements by personal service
upon Zachary Barker Coughlin at the address in the Courts file, 1471 E. 9
th
Street, Reno, NV 89512, with a copy mailed to said address. Service shall also be attempted by email at
zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.

/s/

JUSTICE OF THE PEACE

The City of Reno's Motion states:

JOHN J. KADLIC
RenoCityAttorney
CREIGTON SKAU
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax


STATE OF NEVADA, Case No. RCR2011-063341
Plaintiffs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
__________________________________/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER REGARDING ISSUANCE OF SUBPOENAS

COMES NOW, City of Reno (City), as the employer and on behalf of Reno Police Department Officers Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley
and Reno Emergency Communication Center employees Savannah Montgomery and Scott Weese (and any other City employees (collectively City employees) whose names were unreadable in
subpoenas), by and through their counsel of record, John J. Kadlic, Reno City Attorney, and Creig Skau, Deputy City Attorney, and hereby moves this Court for an order to quash the subpoenas claimed to
have been served on for these City employees in violation of Justice Court Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
///

JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and any additional or further evidence the Court deems just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. 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 incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among other things, the City of Reno Police Report and City of Reno ECOMM materials
regarding Case Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno for $108. A copy of the letter is attached as Exhibit 2 and
incorporated herein by reference. On November 5, 2012, this same letter was sent again to Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah
Montgomery and Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated because service of the subpoenas for these four (4)
individuals was ineffective, these individuals would not be appearing on November 19, 2012. (Exhibit 2).
4. On November 1, 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 office of the Reno Police Department at approximately 4:50 p.m. after being told the office was closed. Three (3) subpoenas 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 Odom and Suzy Rogers. A copy of this packet is attached
as Exhibit 3 and incorporated herein by reference.
5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in
earlier subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials unrelated to Case RMC RCR2011-063341. A copy of these documents is attached as
Exhibit 4 and incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin regarding the letter this office mailed on November 2, 2012. Among other things, Mr.
Coughlin did not indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese. Mr. Coughlin did state to have these witnesses ready for
trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing seventeen (17) pages of blended documents regarding matters pending before Reno
Justice Court on November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department. 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.
1. 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 RCR2011-063341. This document also appears to contain names of other individuals but the handwriting is unreadable. It is not known 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. Coughlin, personal appearance may not be required. A copy of the packet is
attached as Exhibit 6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(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 person 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 officer 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 5(b).

The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on October 26, 2012 and November 3, 2012 and re-delivered to the Reno Police
Department on November 2, 2012 and November 6, 2012 commanding the appearance of the many different City employees above are deficient and ineffective as they fail to comply with personal service
requirement of JCRCP 45(b). Accordingly, service was ineffective and all of the subpoenas should be quashed.

In addition to the failure of personal service, all of Mr. Coughlins subpoenas referenced in Exhibits 1, 3, 4 and 5, also:
1. Violate JCRCP 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP 45.
2. Violate JCRCP 45(b)(1) which states that a subpoena may be served by any person who is not a party to the proceeding. All of the subpoenas were e-mailed to City ECOMM employees
Kelley Odom, Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2, 2012 and November 6, 2012 by Mr. Coughlin, a party in this matter.
1. Violate JCRCP 45(b)(1) which states that service of a subpoena commanding attendance requires that payment for one days attendance and the mileage allowed by law. No witness fee or
mileage fee has been submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person
subject to the subpoena. Mr. Coughlin is serving a litany of subpoenas on many City departments and City employees regarding this case. However, he is also serving subpoenas on City
departments and City employees on a multitude of other cases and proceedings that are unrelated to the instant action. These subpoenas are unduly burdensome, duplicative, irrelevant,
unintelligible, oppressive, harassing, seek information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for all City employees to appear on November 19, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or 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 dropping off the same subpoenas (some of which relate to this matter and many which relate to a State Bar proceeding or other criminal
matters) at multiple City departments. This is creating confusion and leading to a waste of time and resources of public safety employees. As an attorney, Mr. Coughlin should be aware of the
subpoena process. This is not the first matter in which Mr. Coughlin has abused a court procedural matter. For this Courts information, Reno Municipal Court Judge Holmes issued a Sua Sponte
Order Denying Relief Sought in Improper Document on March 13, 2012 finding, among other things, that Mr. Coughlin failed to follow proper legal procedure in preparing and filing motions in a matter
pending before that Court and that Mr. Coughlin blatantly abused that Courts fax filing process. As such, that Court ordered that Mr. Coughlin be prohibited from faxing any documents to that
Court. A copy of this Order is attached as Exhibit 7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to
this Court for review prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a specific case and is following the appropriate legal process.


III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. 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 Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department 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 requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior to issuance and service to
ensure Mr. Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney

By:

CREIGTON SKAU


P.O. Box 1900

Reno, NV 89505


As to the other matters addressed by you below, I work in the Civil Division and I have no knowledge or authority to address them. I suggest that you take up those matters with the
attorney(s) assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorney

-----Original Message-----
From: Jeannie Homer <homerj@reno.gov>
To: "'bonyr@reno.gov'" <bonyr@reno.gov>, "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri, 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI

Sent: Thursday, November 08, 2012 8:36 PM
To: HomerJ @reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341

couldn't open them, and I don't accept service of anything form you... See Allison Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your
offices violation of the RMC Rules to the extent there is not difference technologically anymore between an email and a fax:

Rul e 5: Mot i ons/Pl eadi ngs by Fac si mi l e
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet and exhibits. A document shall not be split into multiple transmissions to avoid the page
limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar number must be conspicuously displayed
on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the
receiving party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J . Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the follo wing court day.
Rul e 6: Cont i nuanc es
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must state the reason therefore and whether or not any continuance has previously been sought or granted.

Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was
suing in CV11-03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response
to Coughlin's request for one in 11 CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance an blaming it on the Court.

Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional snail mail, usps, or personal service. And I am not currently
included amongst those who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the 'governmental agency" and "attorney exceptions"...someone needs to
tell Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served where he has been. Take, for instance

Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from representation:
Rul e 3: Aut hor i zat i on t o Repr esent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw froma case shall file a motion with the court and serve the City Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of
delivery of his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination of both asserting, in one way or another, that the Notice of Appeal was not
received in a timely manner. The delivery confirmations say otherwise.

Please remit $250,000 in the formof a certified check to the address below within 10 days in settlement of these torts. SBN, please provide to me the grievance number associate with this new grievance that is created upon the successful
transmission of this email.

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
Hi zachcoughlin,
You r Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
xoxo,
The Voxox Team
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Hi zachcoughlin,
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341



Thank you.

Jeannie Homer
Legal Secretary
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person
responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY

to me

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