1

J USTICE COURT RENO TOWNSHIP WASHOE COUNTY, NEVADA

STATE BAR OF NEVADA
Applicant,

vs.

ZACHARY BARKER COUGHLIN;
Adverse Party
)
)
)
)
)
)
)
)

CASE NO: RCP2012-000607

DEPT. NO: 2


TRANSCRIPT OF 1/4/2013 HEARING IN RCP2012-000607
Proceedings recorded by a digital sound J AVS recording, transcript produced by a certified
transcription service, available here: http://www.youtube.com/watch?v=DhCMlfGhPfc and here:
http://sdrv.ms/143BKSH
APPEARANCES FOR THE APPLICANT..........Patrick O. King, Esq., Assistant Bar Counsel,
State Bar of Nevada 9456 Double R Blvd., Suite B Reno, NV 89502
ADVERSE PARTY WAS NOT PRESENT
BEFORE THE HON. J USTICE OF THE PEACE SCOTT PEARSON, RENO J USTICE COURT
TRANSCRIPTION............ZACHARY BARKER COUGHLIN, ESQ. (ADVERSE PARTY)
INDEX
WITNESSES Direct Cross Redirect Recross
Patrick O. King, Esq.
SBN Clerk of Court/Investigator/Custodian of Records/Paralegal Laura Peters
EXHIBITS Marked Admitted
SBN's Exhibits:
Exhibit 1-
Email from SBN's OBC's Patrick O. King, Esq.,: http://www.scribd.com/doc/164102485/1-4-13-607-
Exhibit-1-12-13-12-0204-62337-SBN-King-s-Email-Fwd-WCPD-Leslie-s-Possible-Veiled-or-
Indirect-Threat-of-Violence-King-Expresses-Concern-for the SBN's staff.
Exhibit 2-
What SBN King's purports to be a printout of the webpage the link in 12/12/12 The Three E's email
King alleges Coughlin sent WCPD Leslie and cc'd the SBN on:
http://www.scribd.com/doc/164102484/1-4-13-0204-62337-Exhibit-2-RCP2012-000607-Workplace-
Harassment-TPO-Extension-Hearing
EXAMINATION RENO, NEVADA, J ANUARY 4TH, 2013
- -oOo- -


2

(Court in session 9:22:19 a.m.)
KING: For the record, I am Patrick King. I am Assistant Bar Counsel for the State Bar of Nevada I
am here representing the State Bar and I will be a witness.
COURT: Okay, you can do it from there. Do you solemnly swear the testimony you are about to give
will be the truth whole truth and nothing but the truth?
KING: I do. Your Honor also in
COURT: J ust a moment let me make the record-
KING: Your Honor also with me in attendance is Laura Peters. She is a paralegal and Official
Court Clerk of the State Bar of Nevada
i
and she will be a witness as well.
(http://www.scribd.com/doc/176518415/8-13-12-61426-Stamped-Coughlins-Petition-Scr-102-4-d-
and-Scr-111-7-in-Re-Coughlin-8-13-12 )
COURT: All right. Ms. Peters go ahead and raise your right hand to you solemnly swear the
testimony you are about to give will be the whole truth and nothing but the truth?
PETERS: I do.
COURT: Okay. Why don't you go ahead and join Mr. King at the counsel table and just for the
record this is RCP2012 000607, State Bar of Nevada versus Zachary Barker Coughlin. This is the
time set for an application on the extended protection order requested by the State Bar of Nevada a
temporary protection order was previously granted in this case and it said in that order that Mr.
Coughlin was served with it set today's day J anuary 4, 2013 at 8:15 a.m. as the time for the hearing
on the extended protection is now by the clock on the wall in the court room 9:26 a.m. by my iPhone
9:25 a.m. Mr. King, if Mr. Coughlin does show up he currently is not here, then my intent whether
he shows up or not is to limit each side to 30 minutes. For their presentation of this case because the
court's docket that we have and the relative simplicity of this case and the number of witnesses.
KING: Thank you, Your Honor, and I am testifying now with the court's permission.
COURT: Very good.
KING: In my capacity as assistant bar counsel I prosecuted Zachary Coughlin for ethical violations
against the Nevada Rules of Professional Conduct. Those were brought to my attention by
independent sources; we call them grievances. I received grievances from (9:24:30 a.m.) a federal
judge, from a municipal judge, from a justice court judge, and from attorneys in the community.
On an ongoing basis, I have received complaints regarding Zachary Coughlin's conduct and I opened
an investigation pursuant to Supreme Court 105.
In pursuing that investigation I contacted Zachary Coughlin and asked him to respond to the
grievances and he failed to do so. What he did instead, was to send an endless stream of e-mails,
basically criticizing me personally as well as our office, other staff at the State Bar and the
judges and attorneys that filed grievances against him. I filed a formal complaint against Zachary
Coughlin and took it to a screening panel that had voted unanimously that his conduct warranted a
formal proceeding. That formal proceeding took place and the panel chair named J ohn Echeverria,
was put in charge of the panel, and the hearing commenced.
People refused to come to the building unless I provided armed security (9:25:55 a.m.), and
they did that explaining that they had been harassed and intimidated by Zachary Coughlin and
were concerned for their safety. I can tell you on a personal, uh, several... from a personal


3

standpoint, several times I was accosted by Zachary Coughlin in the office and by being accosted I
mean he came, he's a big fellow, he's probably around six foot three or so, probably around 240
pounds.
He described to me his height and weight which I wondered why he did that I think he was
trying to demonstrate to me that he was a powerful fellow. He accosted me by coming forward,
causing me to back up (9:26:42 a.m.). I ordered him to leave the building. I turned my back to him
and went towards my office and he followed me I felt that I might be being attacked so I turned
back around to challenge him and forced him from the building. Our building which is at 9456
Double R Blvd. is open to the public and so it's difficult for us to secure the doors. They do have
locks on them but we are supposed to have it open so people can come in and drop off documents
and visit with us.
Also, our accommodations are generally open to attorneys and members of the community for
things like mediations and the like. As a result of Zach Coughlin's conduct, and I will have Laura
Peters testify in a minute
1
....we have three women in the office and myself
ii
. That is the total staff

1
"Subject: (No Subject)? From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Tue
11/06/12 7:44 PM To: laurap@nvbar.org (laurap@nvbar.org); patrickk@nvbar.org
(patrickk@nvbar.org) Dear Bar Counsel King and Clerk of Court/Investigator Peters and
Chairman Echeverria, There is a big problem with respect to when the State Bar of Nevada
actually sent the Respondent, Coughlin the Designation of Witnesses and Summary of Evidence
(DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE. Further,
Coughlin has never received any Notice of Intent to Take Default (NoITD) from the SBN. As
such, the notice and other procedural safeguards attendant to the Hearing set for 11/14/12 are
severely deficient. This is just the 13th chime of the clock, and I have had as many "get right with
J esus" (or any other number of nondenominational Saviors) talks with Bar Counsel King and
Clerk Peters as anyone deserves. Add to that this new thing where first Bar Counsel says, as
required by SCR 105(2)(c)'s: "The notice shall be accompanied by a summary prepared by bar
counsel of the evidence against the attorney, and the names of the witnesses bar counsel intends to
call for other than impeachment, together with a brief statement of the facts to which each will
testify, all of which may be inspected up to 3 days prior to the hearing. " See, it doesn't say, in SCR
105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from
under Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to
allow inspection of others (even where the SCR 105 Complaint specifically invokes such non
copied materials), and then cut short the time up to which Respondent may inspect. Let's say Bar
Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows
Coughlin to go to the SBN and inspect "up to 3 days prior"...so Coughlin may go to the SBN
tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is a violation of SCR
105, right? Please advise in writing. Please see Supreme Court Rule (SCR) 119(2), which holds
that Bar Counsel and the Panel's failure to follow these rules "may result in contempt of the
appropriate disciplinary board or hearing panel having jurisdiction..." Please note there has
already been a Motion for Order to Show Cause filed against Bar Counsel and or the Board or
Panel in 60838 and 61426. Additionally, please be aware that SCR 119(3) holds: 3. Other rules of
procedure. Except as otherwise provided in these rules, the Nevada Rules of Civil Procedure and
the Nevada Rules of Appellate Procedure apply in disciplinary cases. In that regard, the decision
on the motion to bifurcate displayed a clear lack of regard for procedural safeguards in that it was
issued prior to the expiration of five judicial days from the constructive service upon Coughlin,


4

of the office. Each of the three women have explained to me that I need to take precautions to
protect them, that they felt intimidated, they were fearful, that they had made several phone calls
to the police where the police responded.
2

At the time the police responded, I spoke to them on one occasion and they said they
were very familiar with Zach Coughlin and they felt it was important that I contact them

under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used
do to a recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the
SBN outgoing mail box two certified letter to myself that Clerk of Court Peters admitted
would not be picked up that day by the regular postal carrier to the SBN, despite what they
certificates of mailing therein might state. It is particularly troubling to me that the Notice of
Hearing did not have the Designation of Witnesses and Summary of Evidence included with
it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it
from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me
up with less than the required notice (and jam the Panel up to for the matter, though there has been
little indication so far that the Panel cares or has much an intent to do anything more than let Bar
Counsel King lead them down the same primrose path that Clerk Peters can tell you about...). It is
a path that Richard G. Hill, Esq. often takes people down too... I would be very interest to know
who was on the screening Panel...which Bar Counsel King promised to tell me, though, like most
all of Pat's promises, he has broken...could it have been David Hamilton, Esq.? Richard G. Hill's
best friend, David Hamilton? Was it WCDA Mary Kandaras? (NOTE: turns out, it was WCDAs
Offices Bruce Hahn, Duffrin, and Maiss) The one included in the correspondences about my
smartphone and micro sd data card being searched and or seized illegally and or outside any
lawful search incident to arrest given the hand of an booking it into Coughlin's property on
2/27/12, only for the RMC Marshals to return on 2/28/12 (at the soonest) to take it back to J udge
Nash Holmes? What's next, J udges showing up in our bedrooms reading our diaries out of the
blue? It is my understanding that Chief Bar Counsel David Clark gave me permission to
issue subpoenas and granted me indigent status as to witness fees...if this is not within the
power of Bar Counsel or is otherwise against the Orders of the Panel or Board, please let me know
very soon. Please See SCR 110 and in that regard, I am requesting a prehearing conference for the
purpose of gathering admissions from Bar Counsel and narrowing the issues, and in that regard, I
recently sent Bar Counsel and at least Panel Chair Echeverria materials related to what I see as a
frivolous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, J ohn
Gessin. Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons
that I have voiced to President of the State Bar of Nevada Flaherty, in that light: Rule 120. Costs;
bar counsel conflict or disqualification 2. If, for any reason, bar counsel is disqualified or has a
conflict of interest, the board of governors shall appoint an attorney, ad hoc, to act in the place of
bar counsel. Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com Zach has 5 files to share with you on SkyDrive. To view them, click
the links below. 11 6 12 0202 Objection and Notice.pdf supplemental to Coughlin's designation of
witnesses and summary and production of evidence and notice of objection 0204 CORRECTED
CAPTION.pdf 0204 notice of non service of purported notice of intent to take default.pdf 0204
SUBPOENA WITH DISCLAIMER.pdf 0204 subpoena all.pdf Download all"
2
http://youtu.be/zHNwdwwkhOY (from 11/8/12 around 5:00 pm) Laura Peters go to move is
similar to J im Leslie's, it involves threatening to call in the Reno Police Department anytime someone
starts asking her pointed questions that expose what a complete and utter charlatan she is.


5

immediately if he arrived at the offices. (9:28:07 a.m.) The staff had told me that they were not going
to stay after dark, that we needed to leave the office as a group. I have had to institute a policy
which is disruptive to our office by keeping the doors locked during the day, which requires the
receptionist to constantly be looking at the front door to make sure he doesn't approach.
On one particular evening, the police were called because Zach Coughlin was pounding
on a window of, um...uh..., of one of our staff members
3
, it frightened her a great deal. He

3
http://www.scribd.com/doc/154897052/11-7-12-Sbn-King-0204-Regarding-Paula-and-Door-
Closing-Stamping-Ocr SBN King's 11/7/12 letter to Coughlin reads: "Dear Mr. Coughlin:
Yesterday you arrived at the State Bar office after 5:00 p.m. to file several documents. (NOTE:
King is lying here in response to the fact that Paula Campbell told him that Coughlin tricked her
into admitting that King left the SBN's Double R Office several minutes prior to 5 p.m. on 11/6/12,
and also admitted that Laura Peters had left at 3:30 p.m. that day (ie, there was no one to man the
filing office) When you discovered that the front door was locked, and although there is a
mail slot in the door, you elected to walk around the outside of the building ("around the
outside of the building" is quite a stretch considering Paula Campbell's office is the first one
to the right of the SBN's front door, and that is where she was, easily viewable through the
full length glass wall) until you found someone inside. You stood outside an employee's
window, got her attention and asked to be let in. (NOTE: that is a complete an utter lie,
Coughlin asked to have his filing timely file stamped while he waited outside). This employee
unlocked the door and took receipt of your documents after which you continued to ask further
assistance. (NOTE: by "continued to ask for further assistance" King means Coughlin got Paula
Campbell to admit to some things that King wishes she had not, and that Coughlin sought to get
the filing date he deserved for showing up prior to the SBN's posted closing time). Your behavior
is becoming increasingly disturbing and harassing. (NOTE: so, what, as of 11/7/12, could King
possibly point to support this histrionic assertion? Then, consider Coughlin's interaction with
Laura Peters on 11/8/12, also right at 5 p.m. where Peters furthered her previous threat of 10/30/12
Therefore, except for your formal hearing, which will take place on November 14, 2012,
beginning at 8:45 a.m., you are not to arrive at the Reno Office of the State Bar unannounced. If
you have papers or pleadings to present for filing, you are hereby instructed to either mail them or
to call the office (329-4100) prior to your arrival. Please be advised that if you appear at the State
Bar in the future, except for the November 14, 2012, hearing or in the case of your need to file a
document (for which you must call ahead), the police will be summoned immediately. Sincerely,
/s/ Patrick O. King, Esq." Well, King, Peters, and Campbell can now wonder if Coughlin or
anybody else had a recording of the rest of Coughlin's 11/6/12 conversation with Campbell, but
this clip does not really support any of King's melodrama (which inevitably ensues upon King and
Peters being caught in some fraudulent stance (http://www.scribd.com/doc/156153683/10-20-12-
to-11-17-12-0204-599-607-emails-to-SBN) ,such as the one's they adopted over the fax filing
issues, or over the quashing of subpoenas based on not being issued by the Clerk of Court, or on
the gaffe with respect to failing to accord 30 days Notice of the Hearing, or refusal to abide by
SCR 105(2)(c), or failure to timely supplement the SBN's Designation of Witnesses Summary of
Evidence, or fraud with respect to the insufficient service of process of the 8/23/12 Complaint, the
attempts to have Peters serve Coughlin on 9/25/12 where Coughlin showed up for the hearing that
Peters had noticed Coughlin on in writing after such date had been agreed to, and where in Peters
9/11/12 communication with Coughlin she also expressly indicated that any such 8/23/12 certified
mailing of the Complaint of that date would never be asserted as effecting service of process under


6


SCR 109 given the SBN/NNDB/'s express practice.
http://www.youtube.com/watch?v=eB7Fx4Mk0TE (11/6/12 first part of interaction with SBN's
Paula Campbell...if there is a further recording, is it being held for impeachment purposes? Will
Campbell tell the truth, or will she not even be required to testify? Peters initially started her cries
of "this is harassment!" upon Coughlin querying her on 10/31/12 at approximately 4:40 p.m. as to
why she would not allow him to see his file, where he had ventured down to the SBN to do so, and
was having his filings of that date file stamped by Peters, and noticed two letters addressed to him
in the outgoing mail box of the SBN, where the SBN's Vanessa and Peters admitted that the mail
had already gone out that day, and therefore, such mailings would not be "picked up for mailing
that day"

(NOTE: King is unsteady here because he wants to avoid identifying just which "staff member"
he is referring to (surely if something like this had really happened, Coughlin would know whom
King is referring to, so why be so vague, its not like King is shielding any such "staff member"
for safety/anonymity reasons...The real reasons proceeds so evasively is that he knows Coughlin
likely has recordings of all of these events, and he also knows that Coughlin did not bang on Paula
Campbell's office's window during the one time Coughlin ever spoke with Campbell at the SBN
(which King memorialized in 11/7/12 letter he is now stuck with, and which demonstrates what a
compulsive liar he is when contrasted with his "testimony" at the 1/4/13 extension hearing):
http://www.scribd.com/doc/154897052/11-7-12-Sbn-King-0204-Regarding-Paula-and-Door-
Closing-Stamping-Ocr (her office is just to the right of the SBN's Double R Blvd. entrance, and
the entire wall is glass, its a bit hard to miss...Kings 11/7/12 "stay away" letter to Coughlin came
the day after Coughlin's 11/6/12 submission of a filing to the SBN on Election Day 2012 several
minutes prior to 5:00 pm, when Coughlin arrived at the SBN to find the front door locked, and
seemingly no one there (Gosh, sure would avoid lots of these issues if the SBN/Clerk of Court
Peters had not completely and fraudulently attempted to weasel out of the 9/11/12 by Clerk of
Court Peters that Coughlin would be permitted to fax file (King knows Peters told Coughlin this
and they are afraid Coughlin has a recording of it, and so neither of them has come right out and
contradicted Coughlin's assertion (going so far to move for an Emergency Ex Parte Motion to
Quash Coughlins' subpoenas on King and Peters which, of course, Panel Chair Echeverria, the
SBN's neighbor, granted on an ex parte basis asserting the very rationale for so quashing that the
SBN's King and Chief Bar Counsel Clark know very well that King communicated to Coughlin
was not a basis for quashing his subpoenas (Coughlin was funneled to King and the SBN by
NNDB Chairman Susich's 7/27/12 email directing him to direct his questions to King...so, without
any published rules of court or procedure, Coughlin inquired as to whether he could issue his own
subpoenas under SCR 110 or whether he would need to get subpoenas issued by Clerk of Court
Peters, and on 10/15/12 King confirmed to Coughlin Chief Bar Counsel Clark had given King
permission to declare to Coughlin that Coughlin could, indeed, issue his own subpoenas as the
respondent, regardless of the then pendency of the temporary suspension in 60838 (it is a shameful
mark on the Nevada judiciary that Coughlin's temporary suspension has now lasted longer than
the three month (with no temporary suspension) discipline handed out to an attorney whom
admitted to misappropriating $755,000 from clients compared to the $14.00 Coughlin was
convicted of "consuming while shopping" (somehow characterized as petty larceny, which
includes carrying away element) at Wal-Mart worth of cough drops and "a candy bar", where
the conviction in that matter and affirmance on appeal are examples of what a fraudulent joke the


7

motioned towards the front door where he attempted to gain entrance, she refused to let him
enter the building, and ordered him to leave, he would not leave then she again was forced to call
911, (9:29:03 a.m.), he left about 10 minutes later but before the police arrived. J ohn Echeverria, the
attorney who was the Panel Chair, informed me that he had gone to his office and was demanding a
face-to-face meeting with him. (9:29:26 am 1/4/13)
COURT: Mr. Coughlin had gone to Mr. Echeverria's office?
KING: Correct. It's close, its in the same center as our building, and he had demanded to see him.
That concerned J ohn greatly because his daughter works at the front desk. He issued an order after
being advised by us
iii
, (9:29:45 a.m.) that we received a telephone call from the court reporter who
had recorded the proceedings, who said that she had been contacted by Mr. Coughlin at her home,
and so he issued an order that during the pendency of the deliberations by the panel that he was to
haveno contact with the State Bar office, State Bar employees, the court reporter, or any member
of the panel. (9:30:19 a.m.).
Zach Coughlin flagrantly disregarded that, he contacted me on numerous occasions, sent
degrading e-mails, made phone calls. Most recently, just prior to you issuing the protective order that
you issued (Note: TPO issued 12/20/12, Panel's Findings of Fact; Conclusions of Law entered
12/14/12), which we appreciate very much, on the day prior to you issuing the order he made as
many as twenty repetitive phone calls and in some cases hiding his identity and attempting to
disguise his voice and getting through to me
iv
and he uses profanity, he says "I am going to get
you" and the threats are not veiled in my opinion.
4

By personal experience as part of my investigation I examined his website. I was disturbed
to see that his website, which I understand has been taken down, was a long stream of
consciousness in an e-mail and at the end there were pictures of ninja warriors and weapons of
sorts, throwing stars those types of things on an attorney's website very, very bizarre and
disturbing. I do not have a mental health background, I'm not a psychologist or a psychiatrist, but it is
patently clear to me that he has some mental issues.
At the formal hearing when he was asked if he was taking medication or would he avail
himself of treatment he explained to the Panel and in response to my question under oath that he
refused that he felt it was against his principles.
5
At the formal hearing his conduct was consistent

criminal justice system can be in Reno and Washoe County)), and if he is referring to Coughlin's
interaction with Laura Peters on 11/8/12: )
4
(NOTE: interestingly, as to the one actual specific King provided with regard to any alleged
"threats" made by Coughlin, even the person and entity to whom the 12/12/12 email was allegedly
sent, WCPD J im Leslie, Esq., did not feel such was a "direct threat" but rather a "possible veiled
or indirect threat". http://www.scribd.com/doc/156117667/12-13-12-0204-607-3913-Email-From-
SBN-OBC-King-to-Flaherty-Farmer-Clark-607-Was-Attachment-To
http://www.scribd.com/doc/156118859/8-21-12-0204-067980-1048-12420-Grievance-Against-
NCS-to-SBN-Faxed-and-Emailed
http://www.scribd.com/doc/156130481/12-13-12-WCPD-Leslie-Memo-Regardin-His-Conspiring-
With-WCDA-and-SBN-to-Leverage-Criminal-Prosecutions-and-TPOs-to-Mitigate-County-Civil-
Liability-0679 ).
5
The Panel finds few potentially mitigating factors to be present. While the Panel finds that there
is a lack of prior public discipline by the State Bar, the Panel notes that Coughlin has been


8


publicly criticized in the J oshi matter (NOTE: interestingly, the Panel fails to characterize FHE3 as
a sanction here), has been heavily sanctioned with an adverse award of substantial attorney's
fees in the Merliss matter, and has been incarcerated at least twice for criminal contempt of court.
(Echeverria, reaching hard for an SCR 111(5) conviction is conclusive proof of guilt approach,
here, which he also attempts to bootstrap on to his approach to avoiding any analysis or fact
finding vis a vis the various alleged violations of RPC's the SBN/Panel view as having elements
that are exactly the same as a criminal contempt charge/conviction). Although there has been
an absence of prior public discipline by the State Bar, there have been multiple instances of
judicial censure and sanction. (Actually, neither of the alleged sanctions (FHE2, FHE3) are
sanctions. FHE3 was undone by the final Decree of 6/19/09. FHE2 was never a sanction, it
was a prevailing party attorney fee award per NRS 69.050 (and even that is a void order given
such statute applies only to appeals of judgments in plenary civil actions, not appeals of
summary eviction orders, and, regardless, NRS 40.400 makes NRAP 38 the only basis for a fee
award, which neither FHE2 nor the 4/19/12 Motion for Attorney's Fees such was predicated upon
managed to mention, at all. Further, no judge has censured Coughlin nor has Echeverria or the
Panel (much less the OBC) offered any authority to define what is entailed in a censure in the
legally operative sense.)
Although Coughlin suggested at the hearing that he may have personal or emotional
problems or a mental disability, he denied that he needed further help. Furthermore, no medical
evidence was presented regarding the potential impact of a mental disability, no evidence that the
disability was the cause of the misconduct, no evidence of recovery by rehabilitation and no
evidence that a recovery has arrested the misconduct and that a recurrence is unlikely to occur.
The Panel and King wish to continue playing stupid with respect to the events of August
2011, which Coughlin explained in great detail, and the ensuing challenges in becoming local law
enforcement's favorite can to kick around for a couple years (and the concomitant codependent
relationship local law enforcement has with the judiciary)...its not a case an attorney refusing to take
his medication, or refusing to get diagnosed, or refusing treatment. The attorney had his rent stolen
by his ex, could not afford his medications, received the typical complete and utter lack of assistance
from family upon asking for help in such dire circumstances, and was subsequently wrongfully
arrested twice within 17 days less than three weeks after, due to an inability to pay for such forced
Coughlin to abruptly go off both an ADHD medication and an anti-depressant.
But, to be clear, Coughlin did not steal anything. Both of those petty larceny arrests were
wrongful, and the circumstances surrounding such fail to reveal any wrongdoing on Coughlin's part,
and plenty thereof on the part of the officers involved, the prosecutors, bar counsel, and the court
appointed defenders (except in the Wal-Mart petty larceny, as RMC J udge Howard, willfully violated
the 2008 Indigent Defense Order in refusing to per se $10,000 yearly income indigent Coughlin
counsel.
Further, King's approach in essentially running away from Coughlin's providing him
extremely detailed information (Coughlin provided the SBN, King, and the Panel a complete
printout of every single prescription he has filled at any pharmacy since 2008, revealing exactly
what Coughlin testified to, that he abruptly cease taking Adderall and Wellbutrin on or about
August 2
nd
, 2011 (where the first arrest (iPhone abandoned property about to be thrown in the river
ridiculously charged as petty larceny (well, actually charged as ooooh, that's a felony grand
larceny by RPD Officer Nicholas Duralde, where Duralde referred to the certain benefits to charging
it as a felony (such as doing so getting around the prohibition against making a misdemeanor arrest


9


between 7pm and 7am for an alleged misdemeanor occurring outside the officer's presence per NRS
171.136 (where such statute also barred the second arrest 17 days later on 9/9/11, the Wal-Mart petty
larceny of a candy bar and some cough drops (the candy bar's UPC revealed such was an ice
cream bar, indicating Wal-Marts Thomas Frontino was lying where he alleged he personally eye
witnessed Coughlin select and consume such candy bar from the unrefrigerated candy isle
and where the UPC of the same half of one package of Duract Cough Melts recovered from
Coughlins' pocket upon the Reno Sparks Indian Colony tribal police officer violating both NRS
171.136 and NRS 171.1255 recovered from Coughlin's pocket matched exactly the UPC on the
receipt for the $83.82 worth of groceries Wal-Mart admits Coughlin had just purchased (ie, the exact
same Duract Cough Melts were listed amongst the items Wal-Mart admits Coughlin purchased...even
where Wal-Mart's Frontino lied in testifying that Coughlin had not just purchased such a package of
Duract Cough Melts (as Frontino laughably alleged he peered from thirty yards away each and every
item Coughlin purchased and that such did not include a package of the very Duract Cough Melts that
was, in fact, listed amongst those items Coughlin purchased (the UPC thereof and the description) on
the receipt for $83.82 worth of groceries, where such purchase was made immediately prior to the
wrongful arrest.
Coughlin failed to express sorrow and a big mea culpa because he did not do anything wrong,
and he certainly did not commit a theft crime, period.
Coughlin emailed (and provided in hard copy) King and the SBN TWICE, such complete
certified prescription history printout of all medications taken since 2008, and King, in an July 11,
2012 in person meeting with Coughlin fraudulently attempted to get Coughlin to cease providing
him such materials. King wanted to be able to freely allege Coughlin had failed to do this or that
per SCR 117 or otherwise address any problems (not being able to afford medications has now
become NNAMHS finally agreeing to pay for such medications where, in August 2011 it refused to
upon Coughlin twice inquiring as to such possibility):
HEARING - Vol. I, (Pages 308:23 to 309:15) This is a circumstance where in the complaint
we recognized it. We have a policy at the State Bar that if an attorney has a crisis in their life,
whether it be -- heaven forbid, you can have a death of a child or a wife. You could have a disease.
You could have a stroke. You could have even drug or alcohol problems or some sort of an addiction.
And the State Bar wants attorneys to get help and to maintain their law license, and that's that we
wanted for Mr. Coughlin. Instead, he did not accept his condition. And he hasn't today. And when
you are asking those probing questions, leading as they were, did you feel bad when you conducted
yourself this way? There wasn't an immediate yes, and I'll never do it again, and I'm sorry, and I'm
falling on my sword. Now that I've talked to my psychiatrist he's going to try new medications.
None of that has occurred.
(NOTE: As is the essence of Patrick O. King, Esq., its always a tough call as to whether he is
just plain stupid, lazy, or lying or some malevolent combination of all three. Such is that case with
King's inaccurate depiction of the circumstances under which Coughlin's tribulations occurred, where
King refers to he's going to try new medications.... The whole point was that Coughlin could not
afford the medications he was already taking in August of 2011, and that the abrupt cessation thereof
contributed to Coughlin's difficulties, especially in terms of interpersonal interactions, which resulted
in Coughlin being wrongfully arrested in a retaliatory manner incident thereto twice within 17 days
just two weeks after abruptly ceasing to take to powerful pyschoactive medications, Adderall and
Wellbutrin, on August 2, 2011. Its not a case of trying new medications, or for Coughlin to finally
accept his condition, or that one needs to be on some medication(s), and Pat King knows that, or


10


should, and his attempts to weasel around that are despicable, and typical of King's usual modus
operandi.
King tried to leverage an inordinately improbable confluence of cataclysmic life challenges
Coughlin faced in August 2011 resulting in nothing more serious than a conviction for petty theft of
a candy bar and some cough drops from a monopolistic monolithic retailer in the age of the $750
million dollar bailouts of the mega-banks that Patrick O. King, Esq., the foreclosure mediation
program mediator that Geoff Giles, Esq., sued in his capacity as a mediator therein (and where King
harangued Coughlin for two hours one day in J uly 2011 during a sit down at Double R about the
depravity of those with viewpoints opposing those of the mega-banks).
HEARING - Vol. I, (Page 310:5 to 310:24) That's our Nevada Supreme Court saying, if you
are going to behave this way, you don't get to practice. Now come before a disciplinary panel. And
had Mr. Coughlin come before you, which he did not, and said, I have a mental problem or some
other issue, and I'm working on getting it resolved, and I need to throw myself at your mercy, and
give me a chance to go through this designed treatment program that I am working on. And in four
years or three years I want to have an opportunity to come back and prove myself, that would have
been thrilling. And I would have been glad if that was the case. I encouraged Mr. Coughlin to take
that approach. I explained to him, I can't give you legal advice, but this is my opinion. And he said no
way. He suggested I pack my bag and go to Arizona. What was the theft part of? Well, Mr.
Coughlin said what? I went off my meds, and then I got myself arrested, and then I had all these
series of crimes. What date did he give you for when he went off his meds? 2011.
(NOTE: The above represents King's misrepresentations to Coughlin vis a vis King
attempting to shift the Schaeffer clear and convincing evidence burden of proof placed upon he and
the OBC onto Coughlin upon King selling his SCR 117 snake oil (and, believe, King was not touting
any three or four years while Coughlin was kicking tires on the lot, but rather, indicating a very
brief period of time would be involved, and emphasizing (or attempting to apply coercive pressure) to
Coughlin that everything is paused...all the disciplinary matters are paused if you voluntarily sign on
to a SCR 117 Disability Petition with the Bar).
Funny, Stephen R. Harris, Esq., admits to misappropriating $755,000 from clients, and for the
first time in his life admits to the Bar to suffering from an addiction to sex and alcohol, and the SBN
does not even file an SCR 102 Petition for a temporary suspension in Harris' case (thus, Gary
Silverman, Esq.'s 8/14/12 email to Coughlin (how's that for an expert witness), an excerpt of which
begins Coughlin's 11/14/12 Petition for Writ in 61402: Gary Silverman, Esq. email to Coughlin
8/13/12: "You do seem to be a good lawyer, however. At bottom, Steve Harris took hundreds of
thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF."
Further, NVB J udge Beesley voluntarily appears as a character witness as Harris' formal
disciplinary hearing. Additionally, NVB J udge Sleazley, er, J udge Beesley had a salient role in the
Mirching that Coughlin referred to during the formal hearing (HEARING - Vol. I, (Pages 104:20 to
105:3) MR. COUGHLIN: ... But the clock chimed 13 times. And if I don't put into the record what
is it going to say on appeal? They are trying to merge (Mirch) me here. Let's be honest. So if it's a
merging (Mirching) that's going on here, I'm going to preserve everything for the record. MR.
ECHEVERRIA: I'm going to overrule your motion for recusal.)
HEARING - Vol. I, (Page 315:16 to 315:23) MR. KING: Because of that, it is not
appropriate, in my opinion, under these circumstances with Mr. Coughlin's conduct it would be
totally inappropriate to suggest that we're merely going to give him a suspension pending some
sort of nonexistent recovery efforts, some sort of an effort that he could reestablish himself, get


11


on medications, retake the Bar exam and the professional responsibility... (NOTE: Again, King
with the get on medications rather than get back on his medications. King is creepy charlatan
soulless carpet bagging drip from California known chiefly for being lazy and dishonest...just ask
J ames Boles, Esq. (see http://www.scribd.com/doc/154829743/11-16-12-0204-61170-Boles-Reply-
Brief-Detailing-SBN-Failure-to-Investigate ).
(HEARING - Vol. I, (Pages 320:15 to 321:2) MR. ECHEVERRIA: I'm really sorry, Mr.
Coughlin. But I would like you to assist the panel in following our directions. I've asked you to
address, one, whether or not you're competent to continue to practice law. Two, how should we deal
with the supreme court's mandate that we are to consider the nature and intent of punishment as a
result of that theft conviction and other misconduct, and if you believe punishment is warranted,
what the nature of that punishment should be. If we can focus on those issues, it would help this panel
do its job a lot better than trying to understand Mr. Harris' situation or some other lawyer's situation.
Could you focus on that for me, please?). Mega-hypocrites like Echeverria really do not like
confronting the incongruity of their money plays approach to life and law. However, SCR 123(3) and
the Laub decision hold otherwise.
Note, there again Echeverria admits to the fact that he perpetually sought, all throughout this
matter, to misapply SCR 111(8) and the N. S. Ct's 6/7/12 Order in 60838 to eviscerate the
requirement under Schaeffer that King must prove each individual act of misconduct Coughlin was
alleged to have committed by clear and convincing evidence. Every single time Coughlin offered
any evidence or testimony that went to defending against the myriad of vaguely formed and
unsupported by any actual admissible evidence allegations of misconduct made by King, Echeverria
ruled such testimony or evidence offered by Coughlin was inadmissible or irrelevant in light of
his contention that King did not need to prove Coughlin committed any such misconduct (well over
and above limiting such narrowing to SCR 111(5)'s a conviction is conclusive proof that the
Respondent committed the crime...which itself is far from establishing conclusively that either the
petty larceny or criminal trespass convictions at issue in the only two SCR 111 Petitions King filed
involving Coughlin are serious offenses, or that the circumstances attendant to such convictions
and that alleged acts underlying such were conclusively irrelevant, immaterial, or inadmissible).
HEARING - Vol. I, (Pages 315:24 to 316:14) MR. ECHEVERRIA: You're telling us what is
not appropriate. I'd really like to hear what is appropriate. MR. KING: Disbarment. And
disbarment is very serious, because it's permanent. And so the reason I felt to say what isn't
appropriate is I want you to understand that I acknowledge there are going to be great
opportunities for somebody to take a leave, get help, come back. Mr. Coughlin is not that
character. When he is out there, he is hurting people, he is making life difficult for people, he's not
even measuring up to the lowest standard of a lawyer. And so I think under these circumstances the
answer should be, Mr. Coughlin, because of your conduct over these past years, and your refusal to
recognize it or seek help, ...
HEARING - Vol. I, (Pages 203:6 to 204:10) MR. ECHEVERRIA: I'm going to take your
failure to answer my direct question that you're not claiming some form of impairment. Can we
conclude that? THE WITNESS: No, I guess I am. MR. ECHEVERRIA: What's that impairment?
THE WITNESS: There is a shame aspect to it. But I am, I guess, diagnosed with attention deficit
disorder. MR. ECHEVERRIA: Have you sought treatment for that? THE WITNESS: Yeah. MR.
ECHEVERRIA: Have you been prescribed medication for that? THE WITNESS: Uh-huh. MR.
ECHEVERRIA: Do you take it? THE WITNESS: I do. The jail won't let me take it when I'm in
jail. But when I'm outside, I do take it. MR. ECHEVERRIA: Have you taken it today? THE


12


WITNESS: Yeah. But -- MR. ECHEVERRIA: What are you taking? THE WITNESS: Do I have to
answer that? MR. ECHEVERRIA: No. THE WITNESS: There's just a lot of stigma to it. So
much so that when you go to jail they won't let you take it. Then you have to -- MR.
ECHEVERRIA: Do you feel you need additional help in dealing with your problem? THE
WITNESS: Not really. MR. ECHEVERRIA: Okay...
HEARING - Vol. I, (Pages 287:20 to 291:18) MR. ECHEVERRIA: Mr. Coughlin, I'm asking
you specifically. Do you wish to present any evidence with respect to the supreme court's directive
that this panel is to determine the nature and extent of any punishment you should suffer (NOTE: it is
beyond well established the purpose of disciplinary matters is not a punitive one, so the choice of the
word suffer speaks volumes to the bias with which Echeverria approached his role as Panel Chair)
as a member of the State Bar? MR. VELLIS: Or any mitigation. MR. ECHEVERRIA: Or any
mitigation? MR. COUGHLIN: Mitigation. I've been diagnosed and treated with ADD. I hate
admitting this on the record. Also major depressive disorder. My girlfriend of 4 1/2 years, my
domestic partner, in August -- no. She finally graduated in June -- no, May 15
th
(2011). Two
days later she moved out. She hadn't told me for at least, I believe May and June, she took the
rent portion that I normally gave her and she would forward on, and instead she kept it and
started a new life with it when she moved out.
I wasn't aware of that until sometime in August. August 11th the landlord sent me an e-
mail. I was arrested on August 20
th
(2011) for the iPhone thing that there's a trial on the 19th.
17 Days later I was arrested on the Wal-Mart thing. August 2nd (2011) I canceled an
appointment with Dr. Yasar, my psychiatrist, because I couldn't afford it or the medications. I
reached out to my family. There was some ill will incident of the breakup of my domestic
relationship. I didn't receive any help from anybody. I went off my medications because I couldn't
afford them. I did make several calls to NNAMHS (Note: Northern Nevada Adult Mental
Health Services), but given the sensitivity of being on these medications and a lawyer, a
professional, and the prejudice attendant thereto, and the fact that even if I went to NNAMHS
they wouldn't cover the ADD medication, and they would cover the antidepressant, which is
also somewhat of a dual-use medication. But long story short, I was running out of money, and
I decided a lot due to money, some due to desire to take a medication holiday. Just see, when
you take these things long enough, sometimes you want to see what it's like not taking them.
I went off those medications, probably too abruptly, at the start of August. MR.
ECHEVERRIA: What year? MR. COUGHLIN: '11. Within like 20 days all of a sudden the
iPhone arrest that's pending right now, and I maintain my innocence on that. It sounds like a
ridiculous law school effect pattern. But essentially if this is a hypothetical exam in law school, it
would be some guy finds an iPhone on the ground in a skate plaza in downtown Reno at 11:15 at
night on a Saturday, and holds it aloft offering it up to the denizens of the skate plaza. Then he says
something to the effect of, come on, somebody, claim this. I'm going to throw it into the river. And
at that time people will allege that I claimed the phone. And then there's some suggestions -- there's
some ambiguity, some might say, as to whose phone it is at that point. Whether it would be in the
river, is that lost, mislaid property as larceny. Does a police officer have a right to coerce you into
consenting to search. There is a video -- I gave you a video of the arrest -- MR. ECHEVERRIA:
Could you focus for us on -- MR. COUGHLIN: The mitigation.
MR. ECHEVERRIA: -- the factors -- let me ask this question. Do you believe that any of the
issues that you have described impair your ability to practice law and adequately represent clients?
MR. COUGHLIN: I believe when I'm not under such -- getting arrested, spending six days in jail,


13


getting out, finding an eviction notice on my door. An eviction which I would maintain is against
the law, a summary eviction, where nonpayment of rent is not pledged against a commercial
tenant. There's laws against that for a reason, because it can murder your business, and it's huge
fallout personally. So I get arrested. Spend six days in jail. I maintain it's a wrongful arrest. I
might not have done everything perfect, but I do believe if you look at it, look at the criminal law,
you might agree with me the arrest was wrongful. MR. ECHEVERRIA: My question was not
whether that arrest is valid or invalid, but whether or not the conditions that you described you feel
you suffer from impair your ability to practice law and/or represent, adequately represent clients?
MR. COUGHLIN: No. No. And I think if you had been with me through all this you would be
impressed -- MR. ECHEVERRIA: Do you have -- MR. COUGHLIN: -- by my dedication to my
clients and the level of work product I churn out, especially considering the remuneration I've
received from those clients. I have basically worked for minimum wage doing people's custody,
people's foreclosure defense, adversary proceedings in bankruptcy. And there was a noncompete
case I think -- I'm not happy with how my life has gone. I'm not happy with all this drama and
problems with the courts. But --
HEARING - Vol. I, (Pages 296:2 to 300:12) MS. PEARL: You made more sense in the last
15 minutes than you did all day. And I have an enormous amount of respect for you. You're very
intelligent, and I would have you represent me tomorrow in the behavior you had just in the last 30
minutes. I'm very proud of you to do that. May I ask you a question? And when you were going
through all of these trials and tribulations with the judges and the contempt charges, were you on
medication at the time? MR. COUGHLIN: Well, the medication was -- I went off both of them in
August. I got arrested -- August 2nd I went off both of them. I got arrested August 20th. Then I got
arrested on the iPhone thing, I got arrested August 9th on the Wal-Mart thing (NOTE: this
appears to be a typo as the date of the Wal-Mart candy bar arrest was 9/9/11 not August 9th).
The day after the Wal-Mart thing I got back on one of the medications, because I felt I couldn't
afford both. And so I was on that medication while I got the contempt charge with Judge Howard
on November 30th. It wasn't until basically getting -- the February 27th contempt charge with
Judge Nash Holmes, same deal, only on one of the medications. It's somewhat not a controlled
study, because I'm getting evicted, and my life is chaos in the meantime. So Judge Nash Holmes,
that's another contempt. And then it wasn't until -- by the way, I need to say this.
There was -- I want this to be in the record. There was three different competency orders this
year. There's a rule that says proceedings must be stayed for the pendency of those. My
proceedings kept on rolling through the pendency of all three of those. So all three of these
convictions could be thrown out as void given that trial settings were --
MS. PEARL: Let me add a question to what your statement was just now. You're saying that
you went through the competency hearings, and you admit that you have ADD and some
depression issues. Isn't it your responsibility as an attorney to go to the Bar and say, look, I'm
going through some tough times right now that is not -- you're not -- it's not your fault that you
have a disease, that you're needing the medication -- that you could get a suspension of your
license until you can get back into a regimen of pills and back in acting like this court and the
supreme court is asking you to act. Can't you do that? Isn't there a rule of order that says,
look, I need a temporary suspension with no bad marks on my record until I can get my act
back together, and then work on that?
MR. COUGHLIN: I didn't want that. I didn't want that, because that's an out for all of the
misconduct, all the police misconduct, all the prosecutorial misconduct, and some might say all the


14


judicial misconduct that I've come up against this year -- MS. PEARL: Why did you do that? MR.
COUGHLIN: -- it's always Zach's problem, the mental case problem. And it's too much of an out
for misconduct by all these others -- MS. PEARL: I'm done. MR. COUGHLIN: -- I'm a domestic
violence attorney. Mental health care is the first tool the tyrant leverages. Oh, we're going to --
and it comes to this all the time. We're going to get you some mental health. You're not acting
like we want, buddy, we're going to get you some mental health. That's what tyrants and
abusers do.
MS. PEARL: That's not my question. MR. COUGHLIN: I'm not saying it is. MS. PEARL:
I'm not trying to be disrespectful. There is nothing wrong with it. What I'm asking you is why put
yourself in jeopardy of losing your license altogether rather than trying to get it together? MR. KING:
I think he's asked and answered that. MR. COUGHLIN: I think it -- Pat, nobody else has spoken
from this panel the whole day from the chair, and you're going to object. MR. KING: Mr. Coughlin --
MR. ECHEVERRIA: Go ahead, answer the question. We're running out of time. MR. KING: --
explain why he didn't avail himself of Rule 117. We have encouraged him up the ying-yang to
get treatment, taking advantage of that rule -- MR. COUGHLIN: I don't trust Pat King at all.
MR. KING: Would you mind if I asked a follow-up question? MR. ECHEVERRIA: Pardon me?
MR. KING: May I ask a follow-up question? MR. ECHEVERRIA: In a minute. Have you finished
your questions? MS. PEARL: Yes. And I thank you for the answers. MR. COUGHLIN: Thank you.
I appreciate it. MR. KING: Mr. Coughlin, did I on many occasions, including with David Clark,
encourage you to read and take advantage of Rule 117? MR. COUGHLIN: Pat, I just don't trust you
at all. MR. KING: The question is did we encourage you to? MR. COUGHLIN: If you did, Pat, it
came as nothing more than, hey, make my job easy. Sign on this deal. Oh, it pauses everything, it
pauses everything. It will all come out in the wash when you come back. And, Pat, I just don't trust
you, man. I don't. MR. KING: That's okay. But was what was said, that it would pause everything --
MR. COUGHLIN: No, I didn't say that either, Pat. You had your time to prove that, and you didn't
use your case for it, and now you're not going to use my case to prove that.
Coughlin's TWICE provide King with such prescription history information in emails (along
with providing hard copy copies of such emails and the attachments thereto): 7/31/12 Zach Coughlin
resending this FW: Apology and Zach Coughlin prescription medications information; 5/14/12 Zach
Coughlin Apology and Zach Coughlin prescription medications information:
Apology and Zach Coughlin prescription medications information
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 5/14/12 12:37 PM
To: tcoughlinmd@hotmail.com; davidc@nvbar.org; patrickk@nvbar.org;
glennm@nvbar.org; marybarkbark@yahoo.com
1 attachment
Zach Coughlin rx history since February 2008.pdf (1163.3 KB)
Dear Dad, Bar Counsel, Mom and Melissa,
I am sorry for all the hurtful things I have said and done in the last year.
I haven't been on my Wellbutrin/Buproprion antidepressant for quite awhile
(I pulled my pharmacy records recently to try to learn from some things). I
have taken anti-depressants since I was 18 years old. I wasn't on either my
Wellbutrin or Adderall for all of August 2011 until September 14, 2011. I was
arrested on August 20th, 2011 and September 9th, 2011. The Wal-Mart arrest
involved chocolate and cough drops. The cough drops have dextromethorphan


15


in them, which is a dissociative in high enough doses. Chocolate (sugar) is, of
course, an old time palliative. They banned cough drop (the melt or dissolve
very quickly and contain 30 mg in each one...so rather than powering through
a whole bottle of cough syrup to take 300 mg of DM, one could eat 10 cough
drop melts rather easily and quickly). These drops were pulled from shelves for
awhile when they first came out a few years ago, I believe because of the abuse
potential or dangers of being able to ingest that high a quantity of a powerful
dissociative so quickly (the cough syrup version of dextromethorpan is
extremely difficult to just drink a whole bottle of, whereas the sugary cough
melts are pretty much similar to candy).
I went off the Adderall on approximately August 2, 2011. I went off the
Wellbutrin in July 2011, right after the breakup of a four and half year
relationship. Okay, I went and found the records and am attaching them to
this email. I wondered whether the switch from Vyvanse to Adderall coincided
with my getting fired from Washoe Legal Services, but actually, it does not
appear to have. I was suspended on April 20th, 2009 from WLS. Then, my
termination date was May 12th, 2009. I only started taking Adderall instead of
Vyvanse on J une 13th, 2009. I was wondering if I became more irritable upon
starting Adderall instead of Vyvanse and though maybe that cause the problems
with the family court J udge during the March 2009 trial and then with Washoe
Legal Services. I am actually kind of relieved to see their does not appear to be
a causal connection given the chronology. I think I just felt WLS was a bit of a
dead end job for me, was ruining my work ethic and motivation, and was,
perhaps, an environment where white males had to conform to a certain
prototype to fit in, one which I was not entirely at home with.
You can see I filled one prescription for Campral. See this forum for
evidence that tolerance to Adderall is sometimes thought to be counteracted by a
class of medications that includes Campral, Dextormethorphan (DM is also
being used to treat chronic pain patients in some experimental studies), etc.:
http://addforums.com/forums/showthread.php?t=36078
http://www.ncbi.nlm.nih.gov/pubmed/10875724
I recall researching this in an attempt to be ultra cautious in my use of Adderall.
My chronic pain levels seem to be much, much, more manageable
when I am taking Wellbutrin and Adderall. I believe that the chronic upper
back pain I dealt with for years was due, in part, to emotional/mental stress
related to not appropriately addressing my ADHD and the spotty use of
antidepressants I exhibited during those years (if my Dad and I were getting
along, I would get Wellbutrin from him for free, if we weren't, I would rarely
secure my own health insurance or pay out of pocket for that antidepressant,
but would rather "rough it" to save money).
When I went off the Wellbutrin and Adderall, the chronic pain returned, plus,
I was basically in the early stages of a "divorce" from Melissa (whom I dated
and lived with since April-ish 2007 until May 17th, 2011. Melissa and I had
been fighting since we moved into the home/office on River Rock on February
20th, 2010. From probably J une 2010 until she moved out on May 17th, 2011,


16


we fought almost daily, sometimes in a fairly hostile way (I was never
physically violent with her, but she got a bit with me). I was existing on $400 a
week in unemployment benefits, receiving them for 99 weeks. I actually worked
quite hard the entire time. I learned a lot about a lot of different things,
including some things related to the business of law, practice management,
employment law, computers, software, hardware, cars, home improvement, I did
focus on music for about 6 months straight (though I always continued to apply
for jobs and send out resumes during this 99 weeks...Washoe County had 15%
unemployment during those 3 years and jobs were in short supply and starting
my own law practice seemed overly risky), and I was basically Melissa's maid
and helper with proofreading her schoolwork for a couple years (in my mind at
least, of course she may have a vastly different view of things). She worked a
significant amount of hours and was in school full time and was irritable,
extremely emotional, and stretched pretty thin.
I implemented the "I pay for dinner one time, then you pay for dinner one time"
rule for going out to dinner, and, of course, that took a lot of the romance out of
things. I think I became very insecure about money and my career and getting
fired from WLS was very, very discouraging. But, I worked there for 18 months.
Previous to that my longest tenure of employment at any job whatsoever was
literally 4 months at Hale Lane. I am talking ANY job, my whole life. I realize
my father has concerns about someone in recovery taking a controlled
substance like Adderall, but I have exhibited symptoms consistent with a
strong case of ADHD my entire life, and feel the potential for substance abuse
inherent to untreated ADHD presents a great risk than does taking Adderall,
though, admittedly, it is something that one must watch and realize that it
can effect one's behavior and mood, sometimes in good ways, sometimes in
bad ways. But so can drinking or not drinking water. So can taking or not
taking insulin. Same with coffee.
So, in some ways I consider adding the Adderall to the Wellbutrin a success ...
... Melissa also made off with at least one and possibly two months of my rent
contribution that I gave her to give the landlord, plus, she didn't pay the
landlord her contribution for May 2011, June 2011, etc...
SOMETHING PRETTY INTERESTING:
...I am very startled to see that from 5/4/11 to 5/21/11 I would have been out of
Wellbutrin/Buproprion. Melissa and I broke up and she moved out on 5/17/11...
I then went off my Wellbutrin/Buproprion from 7/25/11 until 4/28/12..From
filling the Buproprion at a cost of $20 in J une of 2011 until recently filling the
prescription in late April 2012, the cost has gone up 300%. That medication has
been off patent for some 20 years now, it should not be rising in price, especially
during a period where the economy has struggled so mightily.... I simply could
not afford it though on at least two occasions I called up Northern Nevada Adult
Mental Health and inquired about the possibility of getting the cost paid for by
the state or subsidized...
In that time period I was put in jail 8 times and, essentially evicted 3 times and
fought with and alienated myself from my entire family, lived a very secluded,


17


reclusive life, etc... exhibited poor impulse control, a temper, and symptoms
consistent with untreated Major Depressive Disorder (MDD) and perhaps
some type of hoarding behavior or Obsessive Compulsive Disorder, including
tiling the River Rock home office, collecting car seats, recarpeting the entire
home office with scraps in a patchwork, and tiling the crumbling front steps, and
putting green carpet on the dirt lawn.
I was arrested on:
8/20/11 for petit larceny (the lost mislaid iPhone thing where the finder said he
would "throw it in the river if someone doesn't claim it right away"). 7 days in
jail.
9/9/11 for petit larceny at Wal-Mart of a chocolate bar and two boxes of the
cough medication drops/melts with Dextromethorphan 30 mg per melt. 1 day in
jail.
11/12/11 for criminal trespass at my former home law office (I was issued 3
traffic citations days later when I went to the opposing attorney who signed the
criminal trespass complaints office to retrieve my wallet and driver's license and
was told to leave by the RPD. While driving away the RPD pulled me over and
charged me with a "California Roll"/failure to come to a complete stop and a
couple fix it tickets, that were ultimately fixed). 3 days in jail
11/30/11 for summary contempt during the trial for the Wal-Mart chocolate bar
and cough medication drops Trial before J udge Howard in RMC 11 CR 22176.
1 day in jail.
1/12/12 for jaywalking while filming personal property at my former home law
office being placed in a dump truck for hauling to the dump. 1 day in jail
1/14/12 for "misuse of 911 where no actual or perceived emergency exists), a
gross misdemeanor incident to the domestic violence I was victimized by on E.
9th St. by my housemates. 3 days in jail
2/27/12 for summary contempt during the trial for the 11/15/11 traffic citations
"California Roll"/failure to come to a complete stop at stop sign deal....5 days in
jail
4/19/12 for contempt, I believe, for failing to fully participate (concern for
privacy rights, shame, etc) in the ordered competency evaluation that Judge
Elliott ordered I undergo with the Lake's Crossing doctors. I spent 7 days in
jail.
I am feeling better and better since starting to take my antidepressant,
Wellbutrin again, and now realize I need to be much more diligent in filling
that prescription in a timely manner and making preparations for situations
where I might not be able to afford it. I plan to write many apology letters,
including to judges, bar counsel, opposing counsel, etc. I always fought and
worked hard for my clients though for an extremely competitive price.
Sincerely, Zach Coughlin, Esq.
However, such inconvenient information just did not fit comfortably into the narrative King
wished to push onto these proceedings in the rampant pursuit of his unethical social climbing
(make a bunch of J udges happy, including longtime SBN stalwart/fixture Beesley) and pursuit of a
career utterly devoid of any heavy lifting whatsoever, where he can bring his dog to work every


18

with the other judges compliance which they ultimately help him and criminal contempt. He was
pointing his fingers (9:32 a.m.) derogative territorially and we had two armed guards at that
proceeding so they did not allow it to escalate. I think that another thing he does is he calls and he
tells me and Laura Peters that he will be in the office be at the office in 15 minuntes, and then hangs
up and then that of course puts us makes us all an easy it's a violation of the order it's a violation of
your orders (9:32:45 a.m.) and he has made that call since receiving temporary protective order now
I'm on guard I don't know should I be calling the police what efforts do we need to take I need to go
unlock the back door we need to develop an escape or evacuation plan because we are prohibited
from having weapons to defend ourselves at the State Bar so as a consequence we did not been done
during the day not show up in 15 min. and then he will call again and say I'm going to show up later.
With that said he is intimidating our office, intimidating the staff, intimidating me, and he has
no reason (9:33 a.m.) to be contacting or be coming to the office at all. We have told him you had
if he wants to send something to the State Bar should use the US mail and that would satisfy
any desire or anything he would need to do to file documents with the State Bar if he wanted to
make a complaint against another attorney or judge you can do it through the mail. But what he
has been doing instead is he is coming to the office after hours and with that said I think it is
imperative that we have an extended protective order. I do understand as a branch of the Supreme
Court the State Bar needs to keep open for office and that would even include Zach Coughlin. But
Zach Coughlin only needs to contact us by mail. This matter, after the hearing the panel unanimously
determined that he needed to be permanently disbarred they described his conduct as outrageous and
disruptive and that he was incompetent to practice law. That has gotten him very upset the entire
matter has now been sent to the supreme so we are in essence divested of jurisdiction while the
Supreme Court makes its decisions and Mr. Coughlin has no reason to be coming to the office for
talking to us now as a matter of fact I think it would be improper for me to engage him in any kind of
dialogue while the matter is that the Supreme Court with that said I would like to call Laura Peters
briefly.
COURT: Mr. King before you do that you were also were a person that was addressed with this e-
mail that had the link to the Cape fear
KING: oh yes Exhibit 2 I believe you have identified it as a yes and that was immediately brought to
my attention I looked at the same link (9:35:33 a.m.) it is tremendously disturbing when you realize
that it is depicting someone shooting attorneys and that in this scene to Nero is actually covered with
blood have been shot the attorney so that just adds a great deal of concern to his mental state
COURT: and that was addressed to members of the State Bar as well
KING: for members of the State Bar notches to me if King he has attempted even after your order to
contact us he has contacted the State Bar in Las Vegas messages hostile messages threatening the
individuals with his conduct I added eyes them that I thought it would be inappropriate for them in
light of the fact that the matter is that the Supreme Court in light of the so none of them spoke with
them they just simply hung up but they have expressed concern 930 6:40 AM the matter was brought
to both the president of the bar as well as our Executive Director and they were very very concerned

day, and leave at 3:30 pm regularly, all while engaging in unfathomably unethical ego trips quite
frequently along the way.


19

and asked me to pursue the protective order so it is not just me dealing with temp that's concerned it's
a multitude they came and interviewed the staff see what their opinions were so if there's any other
COURT: no and she can testify from where she is there at the counsel table
KING: so you up in sworn can you state your name and occupation please
PETERS: Laura Peters paralegal with the State Bar of Nevada at the Reno office
KING: and could you describe what occurred last night
PETERS: last night at a little bit after five another employee and I were leaving the building and a
man came walking up to the door just as we were about to lock it he had its some paperwork from
Zach and to Zach's credit he didn't come himself he sent somebody he was waiting at the end of the
driveway but he had some paperwork with and the guys said I want to file this and I said you're not
going to file it and I threw it on the floor because he was try to stuff into the door and then we just
left we just locked it and he left to
KING: Your Honor I consider that to be a direct violation of the order because number one it's that
same intimidating approach of coming after hours when it's dark waiting for the women to be leading
leaving the building or still securing it and he was in the car at the time is that correct?
PETERS: Yes.
v

KING: Zach Coughlin was so it's not like he arranged to have it delivered by third-party which
would still be a violation it says in the order that you are prohibited from either directly or through an
agent from contacting contacting, and I have explained to Mr. Coughlin that he has no reason to
contact us he shall not contact us it's a violation of the order to not come to the office I told them
especially repeatedly to realize what you're doing coming to the office after hours and his comment is
your you are prosecuting me, so it's an attempt on his part I guess to intimidate me from doing my job
so on behalf of the staff and for our protection I would ask that the court asked in the order
COURT: does he have, you touched on this briefly, but does he have any legitimate reason or does
he ever right to file documents with your office
KING: well I would take the same approach that the justice court did they egg knowledge that it's
open to the public and that people have certain rights to file circuit certain documents or the build
themselves of the court system. We are not a court, we are a nonprofit organization, and he does not
have a right to do anything, other than the fact that as a member of the bar he is currently suspended
as the court now knows, attorneys have a duty to file documents with the State Bar a duty to notify us
of his current address things such as that into pay dues and he is not precluded from doing that by us.
I would ask the court to allow Mr. Coughlin to submit any required documents by US mail and no
other method the document that the court saw this morning that he dropped off at the office included
a CD videotape that is approximately 100 pages. That document was e-mailed to me as well and then
he faxes or attempts to fax, the court clerk has ordered him and has written to him indicating not to,
not to fax, not e-mail you're not allowed to nine 4050 8 AM, as well as the panel chair no that's not
true Peters only e-mailed saying don't e-mail you can e-mail documents" if you want her to testify she
can
COURT: no that's fine I just wanted to make sure


20

KING: and so I do not I think it would be appropriate for the order to allow Mr. Coughlin to file or
serve required documents via US mail
COURT: right mind tenant would be then to loan before I formalize my finding, if I grant the order it
will be that he have no contact with any employee or the employer of the State Bar specifically at the
location of 9456 double R Blvd Park for a person at the location other than through US mail
KING: thank you Your Honor and I J oe based on the testimony that I've heard from him and my
contact with him I think he is deeply disturbed I think he does pose a threat and I wish and hope that
there is a mechanism to reign him in and Casey is going to have some sort of an episode because we
read about it in the paper. Yu see it of our life the paranoid but Zach Coughlin's contact in my opinion
as assistant bar counsel is that he is a scary individual and God only knows if he has weapons or is
capable of using them but I would certainly hope not
COURT: are I think you based upon the sworn statements and evidence here today and my
assessment of the credibility of those witnesses and the weight to be given the evidence I do find that
the applicant has presented sufficient proof to support the granting of the extended protection order
and that I am finding that Mr. Coughlin has knowingly threatened or cause substantial harm to the
physical or mental health or safety of members of the State Bar therefore I will grant the extended
protection order precluding Mr. Coughlin from having any contact other than through US mail with
any employee or any person present at the offices of 9456 double R Blvd. and the State Bar at the
State Bar
KING: Your Honor can we look at the Las Vegas office
COURT: well that occurred to me but I'm not sure of jurisdiction for that so let's, I was thinking that
through and I think I have to go with just the location I don't think I have jurisdiction for that.
KING: thank you Your Honor
COURT: the case of that will be the order they can cure pursuant down Las Vegas justice court a
similar order and we will get a copy for you here in a matter it's all right and that concludes this
hearing so if you want to shut that record. 9:44 AM



21

DECLARATION UNDER PENALTY OF PERJURY
I, ZACHARY B. COUGHLIN do hereby certify and declare under penalty of perjury that :
That I was provided an audio of the hearing above-referenced, that the RJ C represented to me that
any recordings provided to me by it are "certified" and that said transcript, which appears
hereinbefore was transcribed verbatim into typewriting as herein appears to the best of my
knowledge, skill, and ability and is a true and correct record thereof, though, obviously, I have a
vested interest in the case in from which this transcript springs and I have interspersed throughout
and within the attached endnotes my own personal editorializing).
DATED this 25th day of J uly, 2013:

/s/ Zachary Barker Coughlin, Esq.
Zachary Barker Coughlin, Esq.

i
Note how thoroughly dishonest it is for the SBNs Clerk of Court
(http://www.scribd.com/doc/176518355/10-5-12-Stamped-60838-SCR-111-King-SBN-Susich-
Motion-Show-Cause-Against-NNDB-and-SBN-12-31434 ) to only identify herself to the RPD
(unless RPD Yturbide has been coached up by the SBN to only characterize Peters as anything but a
Clerk of Court (especially given that the TPO/EPO require Coughlin to have done something
tantamount to interfering with an SBN employee in the performance of (her) dutiesand
Coughlins filing, or having filed documents (whether by courier or facsimile) with the SBNs Clerk
of Court, Peters, is hardly interfering with Clerk Peters in the performance of her duties, which she
shirks of with breathtaking arrogance and an utter lack of professionalism, mixed with heaping
helpings of dishonestywhich is entirely likely, especially given the awkwardly overdoing it that
Detective Yturbide does in writing in his 2/8/13 Declaration Supplement that: While working
at this location Laura Peters was working as a Paralegal/Investigator and did see this occur)
as working as a Paralegal/Investigator and indicating in SBN Peters Online Report of 1/30/13 that:
If Mr. Coughlin has any business with the State Bar, which he shouldn't at this point, he is only
allowed to contact this office through the US mail.. Peters knows full well, or ought to, the there are
a multitude of instances under NRCP and NRAP wherein Coughlin would need to contact or
otherwise conduct business with the SBN and its court and its Clerk of Court, Laura Peters.
Further, items that must be personally served, such as a Complaint for damages against Laura Peters,
the SBN, and Patrick O. King, and subpoenas directed towards each them, obviously would be
obstructed by such RJ C Chief J udge Pearson Order under Peters interpretation of such.

ii
(that would be receptionist Vanessa, Clerk of Court Laura Peters, and the Nevada Lawyer's
Paula Campbell, apparently)
iii
Interestingly, King just brazenly admits to his ex parte substantive communications with Panel
Chair Echeverria here (which, really, considering he was testifying before RJ C J udge Pearson,
was really nothing for King to be concerned about given Pearsons fastidious adherence to only
doing that which make the powers that be pleased with him), while, in the process misleading the


22


tribunal and glossing over the fact that, pursuant to SCR 119(1), King failed to comply with his
duties thereunder to respond in any way whatsoever to Coughlin's requests for a transcript from
the 11/14/12 formal disciplinary hearing and information as to how Coughlin may so obtain (even
for purchase) a copy of such. Echeverria, obviously, assisted King in their bad faith attempts to
obstruct the disciplinary process (Echeverria and King wanted as much of a head start with the
transcript as possible, and actively conspired together to prevent Coughlin from obtaining a copy
of such, buttressed by Echeverria's ruling that only Coughlin would not be permitted to tape
record the proceeding of 11/14/12) via the 11/16/12 Order he entered in response to King's
impermissible ex parte communications (which are inaccurate at best...Coughlin did not contact
court report Hummel at her home, but rather, upon failing to received any response to his
multiple queries directed to SCR 119 and obtaining the transcript of the disciplinary hearing,
Coughlin called Hummel at the number listed for her in an online court reporter
directory/newsletter, widely available via a Google search, and her employer Sunshine Litigation
Services. Finally, over one month after Coughlin began contacting King and the Panel (see
Coughlin's written requests of 11/16/12 etc) seeking to obtain (see Coughlin's written
correspondence with King and the Panel here: http://www.scribd.com/doc/164098585/11-21-11-
to-2-1-13-All-Emails-Between-Coughlin-and-State-Bar-of-Nevada ) King finally emailed
Coughlin back a response on 12/18/12 responsive to Coughlin's request for a transcript.
NNDB Panel Chair J ohn Echeverria's 11/16/12 Order in Case No: NG12-0204, NG12-0434,
and NG12-0435, which reads:
It has come to the attention of the Panel Chair that Zachary B. Coughlin ("Re-
spondent") has been contacting the Reno and Las Vegas Offices of Bar Counsel, the Panel Chair's
law office and the Court Reporter who recorded the disciplinary proceedings at the State Bar office.
Therefore, IT IS HEREBY ORDERED:
That Respondent immediately cease and desist contacting anyone at the
State , Bar offices, the Panel Chair, the panel chair's staff, any of the Panel Members
or their staffs, or the Court Reporter including her employer, Sunshine Reporting
while this matter IS pending decision Respondent is hereby reminded that the Panel
will be deliberating at a future date and may take this conduct into consideration.
DATED this 16
th
day of November, 2012. by J ohn P. Echeverria, Esq., Chair, Formal
Hearing Panel. (The Certificate of Service attached thereto is signed by Laura Peters, an
employee of the State Bar of Nevada

Subject: grievance against Creig Skau, Esq., Reno City Attorney's Office
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/19/12 6:49 AM
To: complaints@nvbar.org (complaints@nvbar.org)
Dear SBN OBC,
...as for the 11/14/12 Hearing, beyond the fact that I was having severe aching in my hands
hands preventing me from taking notes as I would have normally, Chair Echeverria issued
an Order which he did not appear to have jurisdiction to enter refusing to allow me to audio
record the proceeding...and given my ADHD and MDD, I ask that sufficient
accommodations be made under the ADA to ameliorate that discrimination and disparate
impact/disparate treatment I was seemingly maliciously subjected to, given Chair


23


Echeverria's constant haranguing of me regarding my conditions. PLEASE HAVE ALL
RECORDINGS, RECORDS, AND OR DOCUMENTATION (INCLUDING EVEN THE
ROUGHEST DRAFTS OF THE TRANSCRIPT SUNSHINE REPORTING SERVICES'S
CAROL HUMMEL (AND THAT FIRM REALLY WAS CONLICTED OUT OF
PARTICIPATING GIVEN ITS ASSOCIATION WITH THE RMC'S PAM LONGONI
AND MS. LONGONI'S FRAUDULENT CONDUCT IN CONNECTION WITH THE DUE
PROCESS CHALLENGED CONVICTION AND SUBSEQUENT APPEAL (DISMISSED
DUE TO MS. LONGONI, THE RMC'S EXCLUSIVE TRANSCRIPTIONIST THAT THEY
FORCE ON DEFENDANT'S, FRAUDULENT FAILURE TO PREPARE AND TRANSMIT
THE THE TRANSCRIPT IN 11 CR 22176...WHICH PROVIDED A NICE
COUNTERPOINT TO RENO CITY ATTORNEY PAMELA ROBERTS VIOLATING
THE RPD, INCLUDIG RPC 3.9 AND NRS 171.1255 IN PROSECUTING ME INCIDENT
TO A MISDEMEANOR ARREST BY A TRIBAL POLICE OFFICER WHERE WAL-
MART AND THE CITY ATTORNEY ADMIT THAT NO ONE WITH WAL-MART
EFFECTED A CITIZEN'S ARREST (THAT WOULD EXPOSE THE DEEP POCKETS
TO TOO MUCH LIABILITY....WHY DO THAT WHEN THEY KNOW ITS SO HARD TO
FIGHT CITY HALL PARTICULARLY FOR THOSE THAT DON'T OWN THEIR VERY
OWN PIECE OF IT, some might say....).

Please email me those transcripts, recordings, and associate materials right away AND
REALIZE THIS CORRESPONDENCE PLACES THE STATE BAR OF NEVADA
OFFICE OF BAR COUNSEL ON A LITIGATION HOLD NOTICE WITH RESPECT TO
ALL MATERIALS CONNECTED TO THE MATTERS SET FORTH IN THIS
WRITING....

Transcript
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Tue 12/18/12 3:07 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Cc: David Clark (DavidC@nvbar.org)
1 attachment
Transcript receipt_121812.pdf (41.8 KB)
December 18, 2012

Good Afternoon Mr. Coughlin,
I am advised that you called the State Bar to ascertain how you may obtain an official copy of
the transcript of your disciplinary hearing. David Clark asked me to respond to your request. While
I cannot give you legal advice, I can direct you to Supreme Court Rule 119. Pursuant to that rule,
The record of a hearing shall be made available to the attorney at the attorneys expense on request
made to bar counsel. See SCR 119 1. I have asked Sunshine Reporters to provide me with the
amount it will cost to purchase a copy of the transcript. The cost of the transcript is $2,518.20. You
may purchase a copy of the transcript directly from Sunshine Reporting. A copy of the invoice that
Sunshine sent us is attached.
Patrick King, Assistant Bar Counsel



24



NOTE: Coughlin also sent the following correspondence to Sunshine Litigation Services on
(faxed, emailed (11/18/12) , and USPS first class mail) 11/17/12:
Subject: 11/14/12 SBN LITIGATION HOLD NOTICE From: Zach Coughlin
(zachcoughlin@hotmail.Com) Sent: Sun 11/18/12 7:58 AM To: chummel@charter.Net
(chummel@charter.Net); linda@litigationservices.Net (linda@litigationservices.Net)

11/14/12 SBN LITIGATION HOLD NOTICE
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/18/12 7:58 AM
To: chummel@charter.net (chummel@charter.net);
linda@litigationservices.net (linda@litigationservices.net)
Zach Coughlin, J.D.
Patent Agent, USPTO
1471 E. 9th St.
Reno, NV 89512
Tele and Fax: 949-667-7402
ZachCoughlin@hotmail.com
November 17th, 2012,
RE: LITIGATION HOLD NOTICE REGARDING EVERY RECORDING, DOCUMENT, DRAFT
OF ANY SORT, OR PIECE OF DATA COLLECTED WITH RESPECT TO THE ILLEGALLY
HELD DISCIPLINARY HEARING OF 11/14/12 AT THE STATE BAR OF NEVADA, AT WHICH
CAROL HUMMEL WAS THE COURT REPORTER OF RECORD NOTICE OF CONFLICT
BETWEEN ZACH COUGHLIN AND SUNSHINE REPORTING SERVICES GIVEN SUNSHINE'S
ADMISSION THAT PAM LONGONI IS ON ITS STAFF AND MS. LONGONI'S DIRELECTION
OF HER DUTIES IN 11 CR 22176, WHICH RESULTING IN A DISMISSAL OF COUGHLIN'S
APPEAL IN CR11-2064 AND THE CURRENT TEMPORARY SUSPENSION OF COUGHLIN'S
LICENSE TO PRACTICE LAW IN 60838
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

Sunshine Reporting Services
Firm#: 029F
Contact: Ms. Linda Shaw
151 Country Estates Circle
Reno, NV 89511


25


Phone: 775-323-3411
Fax: 775-323-2749
Email: linda@litigationservices.com
Carol Hummel
(775) 827-9120/
1/4
fax (775) 827-9120
chummel@charter.net

Dear CCR Hummel, CCR Longoni, Linda Shaw and Eric Nelson/Sunshine Reporting
Services, \Please provide to me immediately all materials (including the sound recording) of the
11/14/12 Disciplinary Hearing that your employee, CCR Carol Hummel was the CCR on at the State
Bar of Nevada from approximately 8:30 am to approximately 6 pm. As you are aware, I have a
conflict with your employee Pam Longoni that likely will entail substantial litigation, to whatever
extent there is not already litigation ongoing. Please review the attached materials for more
explication in that regard. However, while I am not purporting to give you legal advice, I believe it
was wrong for your firm to work the 11/14/12 Disciplinary Hearing. I am writing to request to be
given immediately, and absent any sort of payment or agreement whatsoever, all materials recording,
transcribed, reported, or otherwise collected in any way by Sunshine Reporting Services and or Carol
Hummel at that 11/14/12 Hearing and any other materials connected thereto, including
correspondence or agreements with the State Bar of Nevada, the Northern Nevada Disciplinary
Board, and the Panel (including Panel Chari J ohn Echeverria, Esq. And the Echeverria Group).
I am indigent, severely so, and the State Bar of Nevada and Chair Echeverria, some might say,
are fraudulently attempting to take away my Fourteenth Amendment property right, my law license,
chiefly through their numerous violations of SCR 105(2)(c) and and any other due process rules, law,
or concepts they can desecrate.
My issues with Ms. Longoni related primarily to her hanging up on me on more than one
occasion in December 2011 when I was attempting to comply with the dictates she and the Reno
Municipal Court put forth to criminal appellant's, including ones like me who were indigent at that
time.
I need the materials I am requesting above immediately, TIME IS OF THE ESSENCE
with respect to a number of actions I must take to preserve my rights, and even the roughest
draft of the transcript and the audio recordings made that day are completely vital to my
protecting my rights. I believe you would be substantially mitigating your potential liability by
emailing these to me immediately, though you should consider getting counsel from your own
attorney in that regard. Further, I believe your firm and or Ms. Longoni may still be required
to prepare and provide to me the transcript for 11 CR 22176 (I am providing you via a cd/dvd
in the mail and a link to a SkyDrive contaning the audio therefor) as well as the transcritp for
11 TR 26800 (a notice of appeal was filed on 3/7/12 and again sometime thereafter, and during
that time the RCM continued its illegal practice of holding Ms. Longoni out as the only court
reporter it would release the audio recordings to (certified or not), and further, as
demonstrated by the attached handout given to all criminal defendant appellants by the RMC,
Ms. Longoni and the RMC maintained a practice that was violative of NRS 189.030: NRS
189.030 Transmission of transcript, other papers, sound recording and copy of docket to
district court. 1. The justice shall, within 10 days after the notice of appeal is filed, transmit to


26


the clerk of the district court the transcript of the case, all other papers relating to the case and
a certified copy of the docket. 2. The justice shall give notice to the appellant or the appellant's
attorney that the transcript and all other papers relating to the case have been filed with the
clerk of the district court. 3. If the district judge so requests, before or after receiving the
record, the justice of the peace shall transmit to the district judge the sound recording of the
case.
If Hummel, Longoni, Shaw, Nelson and Sunshine Reporting Services comply with my
request above AND provide me certified transcripts of the following recordings within 14 days
from the faxed transmission of this correspondence, I will waive any claims I have against the
above name parties, though not any claims against the City of Reno, Reno Muncipal Court,
Second Judicial District Court, etc., Etc. I am providing a partial transcript in the 11 CR 22176
that I attempted to make on my own, and another partial transcript in the summary eviction
case that I had made on a free trial basis. I am prepared to move forward with respect to
pursuing whatever lawful action I may take in connection with this impermissible conflict of
interest (which I believe I can prove you knew full well about) in addition to the misconduct by
Ms. Longoni in connection with RMC 11 CR 22176. And, particularly in RCR2011-063341, I
imagine there ill be an appeal, and agreeing to this settlement might provide an basis for your
firm getting the deal to do the transcript, at least for the 3 days of Trial in that matter...And I
will be pointing out to the RJC that NRS 189.030 Requires the RJC Order the transcript be
prepared within 10 days of the filing of the Notice of Appeal (which must be within 10 days of
"rendition" (ie, oral pronouncement) of judgment under NRS 189.030.
I need the materials at the following link (provided in their FTR or JAVS format as
provided on cd/audio transcripts from the RJC and or RMC, or in the 2009 Judge Linda
Gardner Joshi Divorce Trial, in the WMV or whatever it is that was...Any information you can
provide on what SBN Bar Counsel Pat King feels is "certified" (as is, wait a second, people pay
$35 for the recording from the court and its not "certified", some might say...Or, wait, Pat, you
used those cd's for the Screening Panel and held them out to be the audio transcripts from
Couglin's RMC cases...Then you object on 11/14/12 to Coughlin utilizing either them, or the
one's his mother bought (because the RMC kept stonewalling Coughlin when he tried to get
them himself) or $35 as "not certified" (and that where King tried to enter Judge Linda
Gardner's 2009 Order sanctioning Coughlin, resulting in his firing from WLS by saying it was
"certified" where it was not (and that goes to King's contention that the "clerk of court"
forwarded that Order on to him, three years after the fact...
But Pat doesn't get around to saying he meant the "Clerk of Court" of a Department in
the RMC, even though the Order is from D14 of the Second Judicial District Court (whose
courtroom deputy worked the 11/14/12 Disciplinary Hearing along with one of Pam Longoni's
co-workers...Carol Hummel (no offense Ms. Hummel...I blame Pat King and or Susich here, as
King is now backing out of an agreement to indicate who was on the Screening Panel and the
Panel for the Hearing was obviously hand picked to arrive at the most biased crowd available
or possible. Please find the materials to transcribe here: http://sdrv.Ms/TRtjA3 Please note that
all but the last couple hours of 10/25/11 in rjc rev2011-001708 has been typed out via a free
transcription trial (and that hearing is the continuation...Well, the "Trial" after Coughlin met
the "genuine issue of material fact" burden...Until they realized that meant a "Trial" was
inappropriate...At which point they will argue they switched it back to a "summary eviction
proceeding"...., But 10/13/11 was the first date, and 10/25/11 was the continuation, sort of...And


27


the other dates for that matter are 11/7/11 and 12/20/11, and on appeal in CV11-03628 on
3/23/12 and 3/26/12 in D7...I don't have that recording though...
Also, I need the RMC audio transcript for the February 2012 hearing with Puentes in 11
CR 26405. I fully understand you might laugh at this proposal, but I am offering you a
settlement. If I can show that Ms. Longoni ruined my reputation and career by failing to
prepare my transcript (even where I relented to the demands to pay for it up front, and where I
was told by the RMC and Longoni that she was the "exclusive" RMC transcriptionist and that
I couldn't even get the audio transcript, but would have to pay for it and it would be released to
Longoni...And that handout is bad for your case, so...)
Sincerely, Zach Coughlin
iv
(NOTE: why would a respondent have any trouble "getting through to" the opposing side's
assistant bar counsel? Sure, King does not describe the Northern Bar Office's four employees
(including himself) as a very hearty bunch (they "can't get any work done", according to King, in
light of the enormously disruptive spectre of Couglin, allegedly...though it certainly must help
them cut down on dealing with the public to lock the door during business hours...surely the
Washoe County Public Defender will follow suit)
v
Well, Peters was not so sure Coughlin was in the vehicle when she was asked about such 1/3/13
incident by the RPD. Apparently, Peters was coached up at the time of her 1/4/13 Online
Reportthen lost the will to lie when it came time to move away from the comfort of her keyboard,
incident to her interview with RPD Detective Yturbideonly for Peters to find the strength to lie
again (Pat King has a way of, uh, convicning Peters (see her 10/9/12 Affidavit of Laura Peters,
curiously and anachronistically placed in the formal pleadings file of 11/7/12 and the 12/24/12 and
2/13/13 ROAs in 62337.
RPD Detective Yturbides account of what Peters told him establishes that Peters lied under
oath at the 1/4/13 extension hearing: On 01-03-2013 at about 1700 hours as Laura was closing the
office at the above location an unknown male individual contacted her through the front glass door
which faces to the south of the building. The male asked to file a document with the office and he
was denied due to the hour and the office closing. The male said nothing else, but placed the
document through the mail slot. Laura picked up the document and saw it was a motion by Zachary
Coughlin representing himself in a case that he believes is being handled by this office. Laura knew
this to be a violation of the above listed order as she has had previous contact with Zachary and knew
of the existing order. Later that same night as Laura was leaving the above office she saw the
unknown male get in to a vehicle that she knew was own by Zachary Coughlin. Laura knew this as
she has had previous contacts with Zachary and this vehicle. Laura said she saw the unknown male
get in as a passenger of this vehicle, but did not see the driver. This corroborated that this motion was
being filed on behalf of Zachary by an agent of his. http://www.scribd.com/doc/176510303/2-8-13-
0204-3914-3913-TPO-Arrest-and-Police-Report-by-RPD-Detective-Ytrubide-a9-2

SBN Peters Online Report of 1/4/13 reads: NARRATIVE Online report processed at the
CitiCenter Plaza Substation RIP Laura PETERS submitted the following: The State Bar had a
temporary restraining order in place (Rep 2012-000607) which has since been extended. Yesterday
evening Mr. Coughlin parked his car at the end of the office complex's driveway and sent another
individual to the State Bar office to file a document. I and another female coworker were locking up
the building to leave for the evening when the man approached us and said he would like to file the
document. I told the man that I would not file the document and that it was after hours. He put the


28


document through the mail slot and left. I got into my car and saw Zach parked in the street at the
end of the driveway
Coughlin 1996 Honda Accord, besides having 130K miles on it, also has very dark window
tinting on the front seat, back seat, and rear windows. Its going to be awfully interesting to hear
Peters testify as to just where exactly the enf of the office complexs driveway is.
https://maps.google.com/maps?expflags=enable_star_based_justifications:true&ie=UTF8&cid=1450
156230942019658&q=State+Bar+of+Nevada&iwloc=A&gl=US&hl=en
http://www.scribd.com/doc/176513114/1-4-13-607-Epo-Hearing-3913-3914-SBN-Peters-
Purported-View-of-Coughlin-in-Tinted-Windows-Honda-Accord-at-End-of-Office-Park-s-Drive-Way
http://www.scribd.com/doc/176513113/1-4-13-607-3913-3914-Google-Maps-of-SBN-Clerk-
of-Court-Peters-Lying-About-Seeing-Coughlin-on-1-3-13-at-End-of-Office-Park-s-Driveway-in-
Tinted-Window
Note how thoroughly dishonest it is for the SBNs Clerk of Court
(http://www.scribd.com/doc/176518355/10-5-12-Stamped-60838-SCR-111-King-SBN-Susich-
Motion-Show-Cause-Against-NNDB-and-SBN-12-31434 ) to only identify herself to the RPD
(unless RPD Yturbide has been coached up by the SBN to only characterize Peters as anything but a
Clerk of Court (especially given that the TPO/EPO require Coughlin to have done something
tantamount to interfering with an SBN employee in the performance of (her) dutiesand
Coughlins filing, or having filed documents (whether by courier or facsimile) with the SBNs Clerk
of Court, Peters, is hardly interfering with Clerk Peters in the performance of her duties, which she
shirks of with breathtaking arrogance and an utter lack of professionalism, mixed with heaping
helpings of dishonestywhich is entirely likely, especially given the awkwardly overdoing it that
Detective Yturbide does in writing in his 2/8/13 Declaration Supplement that: While working
at this location Laura Peters was working as a Paralegal/Investigator and did see this occur)
as working as a Paralegal/Investigator and indicating in SBN Peters Online Report of 1/30/13 that:
If Mr. Coughlin has any business with the State Bar, which he shouldn't at this point, he is only
allowed to contact this office through the US mail.. Peters knows full well, or ought to, the there are
a multitude of instances under NRCP and NRAP wherein Coughlin would need to contact or
otherwise conduct business with the SBN and its court and its Clerk of Court, Laura Peters.
Further, items that must be personally served, such as a Complaint for damages against Laura Peters,
the SBN, and Patrick O. King, and subpoenas directed towards each them, obviously would be
obstructed by such RJ C Chief J udge Pearson Order under Peters interpretation of such.
3913 or rpd 13-100306
2/8/13 Arrest Report and Declaration of Probable Cause by RPD Yturbide:
Despite page 1 of the very 12/20/12 RCP2012-000607 Order RPD Detective Yturbide
purports Coughlin to have violated exclaiming that a violation of such is a mere misdemeanor,
crooked RPD Detective Yturbide (husband to vindictive Ecomm 911 dispatcher J odi Yturbide and her
friend and coworker, J essica Duralde, wife of lying, crooked, perjurer RPD Officer Nicholas Duralde
(see Duraldes testimony in RCR2011-063341, now on appeal in CR12-2025) overcharge Coughlin
was a gross misdemeanor for the TPO violation and a felony for the EPO violation. The TPO
violation PC Sheet lists the charge as NRS 200.591.5, with the over-inflated bail of $2,500.
The 12/20/12 Order in 607 makes quite clear on page 1 thereof: WARNING: This is an official
Court Order. If you disobey this Order, you may be arrested and prosecuted for the crime of violating
an Order for Protection Against Harassment in the Workplace and any other crime that you may have
committed in disobeying this Order An intentional violation of a Temporary Order for Protection


29


Against Harassment in the Workplace is a misdemeanor, unless more severe penalty is prescribed by
law for the act that constitutes (he violation of the Order. Under NRS 193.150, A misdemeanor is
punishable by imprisonment in the county jail for not more than 6 months, or by a fine of not more
than $1,000.00, Or by both fine and imprisonment
Detective Yturbides Declaration Supplement reads: On 01-25-2013, I Detective Yturbide
was assigned the original of this case in reference to a Violation of a Temporary Harassment Order.
During my investigation I determined that the arrestee Zachary Coughlin was served the temporary
order on 12-26-2012 at about 1458 hours. On the date of 0 1-0320 13 at about J 700 hours after
having been served the order which states that Zachary is prohibited, either directly or through an
agent from contacting the Nevada State Bar located at 9456 Double R Blvd. #B, did have a male
individual contact that location attempting to file documents on behalf of Zachary Coughlin. While
working at this location Laura Peters was working as a Paralegal/Investigator and did see this
occur. She also saw a vehicle that she knows is Zachary Coughlin's. She knows this is Zachary's
vehicle due to several previous contacts with him. Zachary was contacted at a later date and arrested
tor the violation of the Temporary Order for Protection Against Harassment in the Workplace. This
order is documented under RCP 2012-000607. It was issued on 12-20-2012 and valid until 01-04-
2013. Zachary was also arrested in relation to a violation of this same order that was extended on 01-
04-2013. Reference RPD case #13-2445 . . NFD
SBN Peters Online Report of 1/4/13 reads: NARRATIVE Online report processed at
the CitiCenter Plaza Substation RIP Laura PETERS submitted the following: The State Bar had a
temporary restraining order in place (Rep 2012-000607) which has since been extended. Yesterday
evening Mr. Coughlin parked his car at the end of the office complex's driveway and sent another
individual to the State Bar office to file a document. I and another female coworker were locking up
the building to leave for the evening when the man approached us and said he would like to file the
document. I told the man that I would not file the document and that it was after hours. He put the
document through the mail slot and left. I got into my car and saw Zach parked in the street at the
end of the driveway. This morning the temporary restraining order was extended by J udge Pearson
who confirmed that yesterday's incident was, in fact, a violation of the temporary order. There is no
further information available for this case at this time.
SBN Peters Online Report of 1/18/13 reads: NARRATIVE An extended restraining
order is in place which specifically directs Mr. Coughlin not to contact the State Bar "- _ _ in person,
by telephone, through electronic mail (e-mail) facsimile (fax), or through another person. Adverse
Party may submit documents to the State Bar only through the US mail but those documents must not
contain threats or other intimidating statements." This morning I arrived at work to find our fax
machine printing the first 24 pages of 371. I cancelled the transmission and unplugged the machine
which must be used for other business purposes. This is the second direct violation and the first since
the extended order has been in place. I haven't read the content of the doc--ument, and don't intend to,
but documents we have received in the past from Mr. Coughlin usually include both threatening and
intimidating statements so I have to assume this one does as well. Document available upon request.
SBN Peters Online Report of 1/30/13 reads: NARRATIVE At approximately 1 :30
p.m., The State Bar office was contacted by a person that would not identify himself but wished to
speak with Assistant Bar Counsel Patrick King. The phone call was transferred to Patrick who picked
up the phone and the caller identified himself as Zachary Coughlin. He began to ask Patrick a
question and Pat hung up on him. Mr. Coughlin is again in violation of the Restraining Order put in
place on J an. 4, 2013. If Mr. Coughlin has any business with the State Bar, which he shouldn't at


30


this point, he is only allowed to contact this office through the US mail. This is the third violation of
the Restraining Order - Case No. RCP 2012-000607, Reno J ustice Court.
SBN Peters Online Report of 1/31/13 reads: NARRATIVE Online report processed
at the CitiCenter Plaza Substation RIP Laura PETERS submitted the following: I am informed that
yesterday afternoon at approximately 4 p. M. Zachary Coughlin called the State Bar office and spoke
with a female employee for about 10-15 minutes. Mr. Coughlin then asked to speak to Assistant Bar
Counsel Patrick King who refused to speak with him and instructed the female employee to terminate
the call by hanging up which she did. Mr. Coughlin has repeatedly violated the restraining order - for
which I have reported each individual instance. It is clear that Mr. Coughlin either does not
understand the restrictions for contact outlined in the Restraining Order or has decided he can ignore
the directive of the issuing J udge, Scott Pearson. The extended order limits his contact with the State
Bar to US mail only. There is no further information available for this case at this time.
RPD Detective Yturbides 2/8/13 Police Report provides: NARRATIVE Narrative
RPD FAMILY CRIMES ASSIGNED: Detective Thomas Yturbide, 01-25-2013 CASE #13-100306
and 13-2445 CASE STATUS: , Original supplement ! Involvement PC exists for the arrest of Zachary
COUGHLIN for Violation of a Temporary Order for Protection Against Harassment in the Workplace
and Violation of an Extended Order for Protection Against Harassment in the Workplace. Protection
Orders are documented as follows. Extended Order is valid until 2359 hours on 01-04-2014
FOLLOW-UP DETAILS: On 01-25-2013 I was assigned the original case for 13-100306. During my
investigation I determined the above information about the Protection Order through court records.
After speaking with the witness Laura Peters, who works for the State Bar of Nevada at 9456 Double
R Blvd. #B, I found that Zachary violated the order on two separate occasions. On 01-03-2013 at
about 1700 hours as Laura was closing the office at the above location an unknown male individual
contacted her through the front glass door which faces to the south of the building. The male asked to
file a document with the office and he was denied due to the hour and the office closing. The male
said nothing else, but placed the document through the mail slot. Laura picked up the document and
saw it was a motion by Zachary Coughlin representing himself in a case that he believes is being
handled by this office. Laura knew this to be a violation of the above listed order as she has had
previous contact with Zachary and knew of the existing order. Later that same night as Laura was
leaving the above office she saw the unknown male get in to a vehicle that she knew was own by
Zachary Coughlin. Laura knew this as she has had previous contacts with Zachary and this vehicle.
Laura said she saw the unknown male get in as a passenger of this vehicle, but did not see the driver.
This corroborated that this motion was being filed on behalf of Zachary by an agent of his. In the
temporary order it states that, "It is further ordered that you, the Adverse Party (Zachary Coughlin),
are prohibited, either directly or through an agent, from contacting, intimidating, using, attempting to
use, or threatening the use of physical force, or otherwise interfering in any way with the employer,
an employee of the employer while the employee is performing his duties of employment and any
person while the person is present at the workplace of the employer, including, but not limited to, in
person, by telephone, through the mail, through_ electronic mail (e-mail), facsimile (fax), or through
another person. Zachary violated this by having an agent contact the office located at 9456 Double R
Blvd. While speaking with Laura she told me she had already attended the hearing for the extension
of the protection order and had received the extension on the protection order until 01-04-2014 Laura
went on to tell me that on the morning of 01-17-2013 when she came in to work at about 0700 hours
there was a fax being printed from the fax machine that was supposed to be 371 pages. Laura saw
that the cover page was addressed from "zachcoughlin" and canceled the rest of the fax and


31


unplugged the machine. Laura knew this was a violation to the extended protection because of the
following. In the Extended Order for Protection Against Harassment in the Workplace it states, "the
Adverse Party (Zachary Coughlin), are prohibited, either directly or through an agent, from
contacting, intimidating, using, attempting to use, or threatening the use of physical force, or
otherwise interfering in any way with the employer, an employee_ of the employer while the
employee is performing his duties of employment and any person while the person is present at the
workplace of the employer, including, but not limited to, in person, by telephone, through electronic
mail (e-mail), facsimile (fax), or through another person. Adverse Party may submit documents to the
State Bar only through the U.S. Mail but those documents must not contain threats or other
intimidating statements. While referring to the extended protection order it is a violation for Zachary
to have sent a facsimile (fax) to the State Bar of Nevada located at 9456 Double R. Blvd. Zachary
could have mailed this to the office utilizing the U.S. Mail and it would not have been a violation of
the protection order. After the two above mentioned violations, one for the temporary order and one
for the extended protection order, Laura advised that there was also a phone call from a subject
representing themselves as Zachary Coughlin on 01-30-2013. I have not been able to identify this
subject positively as Zachary Coughlin. Attached with this report are copies of the restraining orders
and the affidavits of service. Copies of these were also booked in to evidence along with the
documents dropped off by the unknown male subject at the State Bar of Nevada on 01-03-2013 and a
copy of the facsimile (fax) sent by "zachcoughlin" to the office on 01-17-2013. Also booked in to
evidence are copies of condensed transcript and findings of fact and conclusion of law for the State
Bar of Nevada Northern Nevada Disciplinary Board cases concerning Zachary Coughlin.
SUMMARY: On 01-03-2013 Zachary Coughlin violated the temporary protection order served
against him as documented above. On 01-17-0213 Zachary Coughlin violated the extended protection
order served against him as documented above. CASE UPDATE: On 02-08-2013 Officers Waddle
and Wilson of the Reno Police Department contacted Zachary at his residence at 1471 E. 9Th St. And
arrested him on the above listed charges. NFD


The following is from the police report of 2/8/13 for the alleged EPO violation at issue in
RMC 13 CR 3914: http://www.scribd.com/doc/176514513/2-8-13-0204-Police-Arrest-Report-EPO-
3914-Shorter-Discovery-From-RCA-Chief-Wong-RPD-13-2445-03914
Again, RPD Detective Yturbides ARDPC overcharges Coughlin with the incorrect statute,
listing NRS 200.591.5 with the Declaration Supplement reading: On 01-25-2013, I (Detective
Yturbide) was assigned this case in reference to an original from case 13- 100306, in which there was
a violation of a Temporary Harassment Protection Order. During my investigation I determined this
separate violation had occurred after the temporary order was extended. The original order (RCP
2012-000607) was issued on 12-20-2012 and served on 12-26-2012 at about 1458 hours on the
arrestee, Zachary Coughlin. The order (RCP 2012-000607) was extended on 01-04-2013 and Zachary
was served on 01-05-2013 at about 1000 hours. The extended order is valid until 01-04-2014. In the
order it states that Zachary directly or through an agent is prohibited from contacting the office of the
State Bar of Nevada located at 9456 Double R Blvd. #B by any means including facsimile (fax).
Zachary is only allowed contact to the office through the U.S. Mail. On 01-17-2013 at about 0509
hours a 371 page fax was sent to the office with a cover page documenting it coming from
"zachcoughlin". The fax was stopped prior to completion. Zachary was contacted at a later date and
booked in to the WCSO J ail. NFD


32